Text

Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of Huma Factors Results
	ML23017A226
Person / Time
Site:	Turkey Point
Issue date:	01/17/2023
From:	Strand D; Florida Power & Light Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23017A225	List: L-2023-004, Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of Huma Factors Results;
References
	L-2023-004
	Download: ML23017A226 (1)
	v • d • e

L-2023-004 10 CFR 50.90 Framatome Inc. Proprietary (Not proprietary when separated from Attachments 1 through 5)

January 17, 2023 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE: Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating Licenses DPR-31 and DPR-41 Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of Human Factors Results Summary Reports and System Level Failure Modes and Effects (FMEA) Analysis

References:

1. Florida Power & Light Company letter L-2022-120, Turkey Point Nuclear Plant, Units 3 & 4, License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project, July 30, 2022 (ADAMS Accession No. ML22213A045)

2. Florida Power & Light Company letter L-2022-166, Turkey Point Nuclear Plant, Units 3 & 4, Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project, October 5, 2022 (ADAMS Accession No. ML22278A076)

Per Reference 1, and pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) submitted a request to amend Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively. The proposed license amendments replace the Reactor Protection System (RPS), Engineered Safety Features Actuation System (ESFAS), and Nuclear Instrumentation System (NIS) with digital systems that are based on the Framatome Tricon Programmable Logic Controller (PLC) Version 10 digital based platform.

In Reference 2, FPL provided supplemental information in support of the license amendment request and agreed to submit by January 16, 2023, additional documents the NRC determined was necessary to complete its acceptance review. This letter provides the following attachments:

1. Treatment of Important Human Actions - RPS/ESFAS/NIS and DCS Results Summary Report

2. System Level Failure Modes and Effects Analysis In addition, the following documents are available for NRC viewing on the NextEra Online Reference Portal.

As discussed on January 17, 2023, with NRC Project Manager, Michael L. Marshall Jr., versions of these documents will be submitted on the docket within 30 days of this letter.

1. Functional Requirements Analysis, Functional Allocation and Task Analysis - RPS / ESFAS / NIS and Distributed Control System (DCS) Results Summary Report

2. Functional Requirements Analysis, Functional Allocation and Task Analysis Diverse Actuation System (DAS) and Distributed Control System (DCS) Results Summary Report

3. Operating Experience Review Results Summary Report Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035

Turkey Point Nuclear Plant L-2022-004 Docket Nos 50-250 and 50-251 Page 2 of 2 Attachments 1 and 2 contain information that Framatome, Incorporated, considers to be proprietary in nature. Pursuant to 10 CFR 2.390(a)(4), FPL requests that the proprietary information be withheld from public disclosure. The request is supported by two affidavits signed by Framatome, Incorporated, the owner of the information, in Attachment 3. The affidavits set forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Correspondence with respect to the proprietary aspects of this information or the supporting Framatome affidavits should be addressed to Mr. Phillip Opsal, Manager, Product Licensing for Framatome, 3315 Old Forest Road, Lynchburg, Virginia 24501.

Attachments 4 and 5 contain the redacted versions of Attachments 1 and 2.

This supplement does not alter the conclusions provided in Reference 1 that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and that there are no significant environmental impacts associated with the proposed change.

This letter contains no new or revised regulatory commitments.

Should you have any questions regarding this submission, please contact Mr. Kenneth Mack, Fleet Licensing Manager, at 561-904-3635.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 17th day of January 2023.

Sincerely, Dianne Strand Dianne Strand General Manager, Regulatory Affairs Attachments (5) cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health

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AFFI DAVIT

1. My name is Philip A. Opsal. I am Manager, Product Licensing for Framatome Inc. (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.

3. I am familiar with the Framatome information contained in Framatome Document No. 51-9355272-002, Treatment of Important Human Actions - RPS/ESFAS/NIS and DCS). Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.

6. The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:

(a) The information reveals details of Framatomes research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.

(e) The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c), 6(d), and 6(e) above.

7. In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 9, 2023.

Philip A. Opsal Manager, Product Licensing Framatome Inc.

AFFI DAVIT

1. My name is Philip A. Opsal. I am Manager, Product Licensing for Framatome Inc. (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.

3. I am familiar with the Framatome information contained in Framatome Document No. 51-9330940-001, FPL Digital Modernization Project (F.505454)

FMEA - RPS/ESFAS/NIS. Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.