ML22311A533
| ML22311A533 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/10/2022 |
| From: | Nextera Energy |
| To: | Natreon Jordan Plant Licensing Branch II |
| References | |
| EPID L-2022-LRM-0088 | |
| Download: ML22311A533 (14) | |
Text
Pre-Submittal Meeting to Discuss Upcoming NextEra Energy License Amendment Request to Adopt 10 CFR 50.69 November 10, 2022
2 Participants Keith Vincent, Manager - Acting Fleet Reliability and Risk Manager, NextEra Luke Karten, Principal Engineer - Fleet Reliability and Risk, NextEra Loren Heistand, Project Manager - Fleet Center of Work Excellence Jerry Phillabaum, Principal Engineer - Fleet Licensing, NextEra Justin Wheat, Principal Engineer - ENERCON FP&L - Florida Power and Light
3 Agenda Purpose Regulatory Guidance PRA Model Technical Adequacy 10 CFR 50.69 LAR Overview Current Schedule Closing Remarks LAR - License Amendment Request PRA - Probabilistic Risk Assessment
4 Purpose Purpose of adopting 10 CFR 50.69 at St. Lucie (PSL):
Continues the strategy of adopting risk-informed decision-making processes across the fleet Utilize existing infrastructure (e.g., PRA models) to:
Improve focus on risk significant components, which improves safety Apply alternate treatments to low-risk components, which improves operational flexibility and safety RISC-1 Safety Related Safety Significant RISC-2 Non-Safety Related Safety Significant RISC-3 Safety Related Low Safety Significant RISC-4 Non-Safety Related Low Safety Significant RISC - Risk Informed Safety Class
5 Regulatory Requirements and Guidance 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.
10 CFR 50.90, Application for amendment of license, construction permit, or early site permit.
NEI 00-04, Revision 0, 10 CFR 50.69 SSC Categorization Guideline EPRI 3002017583, Alternative Approaches for Addressing Seismic Risk in 10 CFR 50.69 Risk-Informed Categorization EPRI - Electric Power Research Institute NEI - Nuclear Industry Institute
6 PRA Model Technical Adequacy Internal Events and Internal Flooding PRA Model o Full-scope peer review in July 2002 o Several self-assessments and focused-scope peer reviews followed (details in the LAR) o Finding closure review conducted in September 2017 o Reviewed as part of NFPA 805, RMTS, and SFCP o No open finding-level facts and observations (F&Os)
Fire PRA Model o Full-scope peer review in June 2010 o Focused-scope peer reviews in 2013 o Finding closure review conducted in September 2017 o Reviewed as part of NFPA 805, RMTS, and SFCP o Three open finding-level F&Os will be addressed in the LAR NFPA - National Fire Protection Association SFCP - Surveillance Frequency Control Program RMTS - Risk Managed Technical Specifications
7 10 CFR 50.69 LAR Overview Follows NEI 00-04 PRA evaluations utilizing internal events, internal flooding, and fire PRAs Non-PRA evaluations such as external events screening and shutdown assessment Alternative approach for seismic risk categorization (Tier 1) using EPRI 30020175083 Seven qualitative criteria in Section 9.2 of NEI 00-04 Defense-in-depth assessments Passive categorization uses ANO-2 methodology Does not credit FLEX strategies Includes criteria for when categorization results need reevaluation due to issues that significantly impact the PRA models Models were reviewed for key assumptions and sources of uncertainty; each source was evaluated for impacts to 10 CFR 50.69 ANO - Arkansas Nuclear One FLEX - Diverse and Flexible Coping Strategies
8 10 CFR 50.69 LAR Overview - External Hazards Screened in accordance with Generic Letter 88-20, NUREG/CR-2300, and NUREG-1407
- Updated to use criteria in ASME/ANS PRA Standard RA-Sa-2009
- All external hazards screened from applicability except internal flooding, internal fire, and seismic activity
- Future identification of unscreened hazards will follow NEI 00-04, Figure 5-6 ASME - American Society of Mechanical Engineers ANS - American Nuclear Society
9 10 CFR 50.69 LAR Overview - Seismic Risk Approach for seismic categorization will follow EPRI 3002017583 PSL meets the criteria for Tier 1 methodology EPRI 3002017583 uses the methodology for Tier 1 that was reviewed and approved by the NRC for (Calvert Cliffs Amendment 332/ML19330D909)
10 Precedents - Seismic Tier 1 Ginna Calvert Cliffs Farley St. Lucie USGS - United States Geological Survey
11 10 CFR 50.69 LAR Overview - Shutdown Risk & Integral Assessment
- Shutdown risk follows the process illustrated in NEI 00-04, Figure 5-7
- Will use the shutdown safety management plan in NUMARC 91-06
- Integral assessment performed manually using NEI 00-04, Section 5.6 NUMARC - Nuclear Management and Resources Council
12 Current Schedule Plan to submit 10 CFR 50.69 LAR by December 6, 2022 Approval requested within 13 months o One month acceptance review o 12-month LAR review Plan to implement the amendment within 90 days
13 Closing Remarks PRA models are technically adequate and have been reviewed by the NRC in other applications SSC categorization follows NEI 00-04 EPRI Tier 1 methodology for seismic is consistent with other precedents LAR includes learnings from many other submittals Not crediting FLEX equipment or operator actions
Questions