ML23039A002
| ML23039A002 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/21/2023 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Coffey B Point Beach |
| Wall, S P | |
| References | |
| EPID L-2022-LLA-0074 | |
| Download: ML23039A002 (1) | |
Text
February 21, 2023 Mr. Bob Coffey Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd Juno Beach, FL 33408
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - AUDIT
SUMMARY
FOR LICENSE AMENDMENT REQUEST TO ADOPT RISK-INFORMED EXTENDED COMPLETION TIMES - RISK INFORMED TECHNICAL SPECIFICATIONS TASK FORCE INITIATIVE 4B (EPID L-2022-LLA-0074)
Dear Mr. Coffey:
By letter dated May 20, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22140A131), as supplemented by letters dated July 11, 2022, and January 11, 2023 (ML22192A152 and ML23011A280, respectively), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted a license amendment request (LAR) for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach). The proposed LAR would modify the plants technical specifications to permit the use of risk-informed completion times in accordance with Technical Specification Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk-informed Extended Completion Times - RITSTF [Risk-Informed Technical Specification Task Force] Initiative 4b.
To support its review, by letter dated August 11, 2022 (ML22216A203), the U.S. Nuclear Regulatory Commission (NRC) staff notified the licensee that they would conduct a regulatory audit from August 22, 2022, to December 16, 2022, through an online portal (also known as electronic portal, ePortal, electronic reading room) established by NextEra. Due to the volume of documents and the necessity to have clarification discussions, the virtual audit was extended to February 3, 2023. The regulatory audit summary is enclosed with this letter.
If you have any questions, please contact me at (301) 415-2855, or by e-mail at Scott.Wall@nrc.gov.
Sincerely,
/RA/
Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301
Enclosure:
Regulatory Audit Summary cc: Listserv
Enclosure REGULATORY AUDIT
SUMMARY
REGARDING LICENSE AMENDMENT REQUEST TO TO ADOPT TSTF-505, RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF 4B NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301
1.0 BACKGROUND
By letter dated May 20, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22140A131), as supplemented by letters dated July 11, 2022, and January 11, 2023 (ML22192A152 and ML23011A280, respectively), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted a license amendment request (LAR) for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach). The proposed LAR would modify the plants technical specifications to permit the use of risk-informed completion times in accordance with Technical Specification Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk-informed Extended Completion Times - RITSTF [Risk-Informed Technical Specification Task Force] Initiative 4b.
The U. S. Nuclear Regulatory Commission (NRC) staff performed a preliminary review of the LAR and determined that a regulatory audit would assist in the timely completion of the review.
An audit plan was provided to the licensee on August 11, 2022 (ML22216A203), which provided the list of requested documents and other details pertaining to the audit. The purpose of the audit was to gain an understanding of the information needed to support the NRC staffs licensing decision regarding the LAR and to develop requests for additional information (RAIs),
if necessary. The information submitted in support of the LAR is under final review, and any additional information needed to support the LAR review will be formally requested by the NRC staff using the RAI process in accordance with Office of Nuclear Reactor Regulation (NRR)
Office Instruction LIC-101, Revision 6, License Amendment Review Procedures (ML19248C539).
The regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information, that will require docketing to support the basis of a licensing or regulatory decision.
Performing a regulatory audit of the licensees information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensees processes or procedures.
Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, the NRC staff may review supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) section 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which, although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information.
2.0 SCOPE By letter dated August 11, 2022 (ML22216A203), the NRC staff issued an audit plan. The original audit duration was from August 22, 2022, to December 16, 2022. Due to the volume of documents and the necessity to have clarification discussions, the virtual audit was extended to February 3, 2023. To support discussions, the NRC staff provided 37 audit questions with items for NextEra to clarify. NextEra posted answers to these questions to the online portal. The NRC staff held clarification discussions with the NextEra staff via Microsoft Teams on November 16, 2022, November 17, 2022, and November 22, 2022. All audit questions were discussed. Technical discussions were focused on the following major areas: probabilistic risk assessment (PRA), external hazards, fire protection, technical specifications, electrical engineering, and instrumentation and controls.
3.0 AUDIT TEAM The NRC audit team included the following:
Scott Wall, Plant Licensing Branch III (LPL3)
Jonathan Evans, PRA, Licensing Branch A (APLA)
Kristy Bucholtz, APLA Jigar Patel, APLA De Wu, PRA Licensing Branch C (APLC)
Sunwoo Park, APLC Andrea Russell, Technical Specifications Branch (STSB)
Nageswara Karipineni, Containment and Plant Systems Branch (SCPB)
David Nold, SCPB Calvin Cheung, Instrumentation and Controls Branch B (EICB)
Norbert Carte, EICB Edmund Kleeh, Electrical Engineering Branch (EEEB)
Steve Wyman, EEEB Charley Peabody, Nuclear Systems Performance Branch (SNSB)
Santosh Bhatt, SNSB Steve Short, Pacific Northwest National Laboratory (PNNL)
Mark Wilk, PNNL 4.0 DOCUMENT AND FILES REVIEWED Item #
Audit Item 1
Reports of full-scope and focused-scope peer reviews, facts and observations (F&Os) closure reviews, and any self-assessments referred to in the license amendment request (LAR) for the internal events, internal flooding, fire, and seismic probabilistic risk assessments (PRAs) cited in the LAR.
2 For the internal events, internal flooding, fire, and seismic PRAs, plant-specific documentation (e.g., uncertainty notebooks) related to:
- a. The review of the PRA model assumptions and sources of uncertainty (generic and plant-specific assumptions/uncertainties)
- b. Identification of key assumptions and sources of uncertainty for this LAR
- c. Parametric uncertainty and state-of-knowledge correlation evaluation 3
PRA notebooks for the modeling of FLEX equipment and FLEX human error probabilities credited in the PRAs.
4 PRA notebook(s) on the modeling of digital control systems, including basis for the representative failure probabilities.
5 Documentation of how shared or cross-tied systems are modeled in the PRA.
6 Fire PRA notebooks containing the results of the fire PRA.
7 Primary fire PRA notebooks (for example, Fire Modeling Notebook, Main Control Board Analysis Notebook, Circuit Failure Mode Likelihood Analysis Notebook) that address the major elements of the fire PRA and the methods used in those elements.
8 Additional documentation that supports the seismic PRA and external events screening, including:
Calculations of seismic core damage frequency (SCDF) and seismic large early release frequency (SLERF) for RICT program, including all input parameters and their justification of use.
Evaluation of seismic-induced loss of offsite power (LOOP) and its impact on RICT program.
Reports related to external flooding impact on Point Beach site, and evaluation of its impact on RICT program Reports related to high winds and tornado impact on Point Beach site, tornado/wind generated missile vulnerability evaluation, tornado missile protection structural barriers, and evaluation of tornado missile barriers for RICT program.
9 If modeled, the PRA notebooks associated with the modeling of Open Phase Condition (OPC) in electrical switchyards and the Open Phase Isolation System (OPIS).
Item #
Audit Item 10 Documentation supporting the development of the real-time risk tool and benchmarking it against the PRA.
11 Documentation supporting the example risk-informed completion times (RICT) calculations presented in LAR Enclosure 1, Table E1-2.
12 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).
13 Final RICT program procedures (e.g., for risk management actions, PRA functionality determination, and recording limiting conditions for operation). [The licensee may choose (optional) to provide draft RICT program procedures if final procedures are not available.]
14 Relevant design documentation (e.g., piping and instrumentation diagrams):
Documentation to support LAR Enclosure 1, Table E1-3(1) and Table E1-3(2) showing each primary transient/accident and the specific diverse actuation functions which support it.
15 Other documentation that the licensee determines to be responsive to the staff's information requests.
16 Design documentation of major electrical SSCs to facilitate better audit discussions:
Simplified one-line diagrams for AC and DC power distribution systems including 120 Vac system for uninterruptible power for plant protection systems (Please ensure the diagrams are clear and readable).
Information on diesel generators (DGs)- total loads and shared supporting systems and also minimum DGs required for each unit and for station for shutdown).
Load list(s) only for Class 1E buses for AC and DC systems for response to LOCA and LOOP.
Identify any buses, loads, and other equipment shared in the AC and DC distribution systems for DBAs.
For offsite power system - normal lineup for startup and shutdown and any alternate lineups.
Procedures for loss of one Class 1E AC bus, and also for one Class 1E DC bus.
5.0 RESULTS OF THE AUDIT As a result of the audit, the NRC staff gained a better understanding of the licensees analyses and calculations supporting the adoption of TSTF-505. Several RAIs were issued to the licensee on December 20, 2022, and January 31, 2023 (ML22354A161 and ML23033A029, respectfully).
On January 11, 2023 (ML23011A280), the licensee provided the response to the December 20, 2022, RAIs and is scheduled to provide a response to the January 31, 2023, RAIs by March 3, 2023.
ML23039A002 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DRA/APLA/BC NRR/DRA/APLC/BC NAME SWall SRohrer RPascarelli SVasavada DATE 02/07/2023 02/08/2023 02/10/2023 02/10/2023 OFFICE NRR/DSS/STSB/BC NRR/DEX/EICB/BC NRR/DEX/EEEB/BC NRR/DSS/SNSB/BC(A)
NAME VCusumano MWaters WMorton DWoodyatt DATE 02/12/2023 02/10/2023 02/10/2023 02/16/2023 OFFICE NRR/DSS/SCPB/BC NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME BWittick NSalgado SWall DATE 02/15/2023 02/21/2023 02/21/2023