ML23068A071

Summary of Audit Meeting with Florida Power and Light Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Turkey Point, Units Nos. 3 and 4 (EPID L-2022-LLA-0105) - Nonproprietary

ML23068A071
Person / Time
Site:	Turkey Point
Issue date:	04/28/2023
From:	Geoffrey Miller NRC/NRR/DORL/LPL2-1
To:	Florida Power & Light Co
References
EPID L-2022-LLA-0105
Download: ML23068A071 (1)

Text

OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY PROPRIETARY INFORMATION April 28, 2023 LICENSEE:

Florida Power & Light Company FACILITY:

Turkey Point Nuclear Generating, Unit Nos. 3 and 4

SUMMARY

OF AUDIT MEETING WITH FLORIDA POWER AND LIGHT CONCERNING A DIGITAL INSTRUMENTATION AND CONTROL UPGRADE LICENSE AMENDMENT REQUEST FOR TURKEY POINT, UNITS NOS. 3 AND 4 (EPID L-2022-LLA-0105)

On February 6 and 7, 2023, a portion of a regulatory audit was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Florida Power & Light Company (the licensee, FPL) via video conference. The purpose of the meeting was to discuss the digital instrumentation and control (I&C) license amendment request (LAR) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). The audit was established as documented in Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML22213A117 and ML22322A181.

This 2-day meeting was focused on human factors engineering (HFE) activities associated with the project. During this meeting, the licensee discussed aspects of their submittal and results from HFE activities so far. The licensee also provided a virtual demonstration of their glass-top simulator, including a discussion of the verification and validation activities that they plan to complete on this simulator in the coming months.

Throughout the discussion, the NRC staff shared preliminary observations and provided feedback associated with their ongoing technical review. This feedback included the items listed below.

The NRC staff clarified that observations and information provided was for awareness only, to support the NRCs ongoing review. No new regulatory decisions were made or shared during this meeting, and the NRC staff did not provide any official requests for additional information. If the NRC staff determine, at a later date, that additional information is needed to support their technical review, the NRC staff will communicate information needs in an official request for additional information (RAI) issued to the licensee.

The NRC staff addressed the fact that the HFE Validation & Verification (V&V)

Implementation Plan (IP) discusses ((

)) The staff noted that the fidelity of the glass-top testbed would likely constitute a deviation from the fidelity expectations outlined in Criterion of 11.4.3.3(2). The staff noted that such a deviation may be acceptable; however, further justification would be needed to ensure that simulator fidelity deviations will not impact or bias operator performance in a manner that would invalidate testing results. (For example, the licensee could conduct testing of

OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY PROPRIETARY INFORMATION operator performance on an unmodified version of the glass-top simulator, comparing results from testing conducted on the full-fidelity plant reference simulator, to demonstrate that the two can be considered as like-for-like in nature.

The NRC staff noted that the V&V IP ((

))

The NRC staff also noted that robust training of the operators participating in validation testing activities will be important for ensuring that validation testing does not fail due to reasonably preventable operator performance deficiencies. (Additional information can be found in Section 11.4.3.6.4 of NUREG-0711.)

The NRC staff noted that the V&V IP ((

)) However, if issues identified during PV2 are significant, the NRC may need to review documentation of how identified issues are resolved, in order to support approval of the LAR.

The NRC staff also noted thatfor significant performance issues identified during PV2the resolution of issues may be reliant on results from ISV testing. In such a scenario, the NRC staff would likely need to request that relevant information from the ISV test be docketed prior to NRC issuance or licensee implementation of a license amendment. The staff noted that such performance issues identified during PV2 could have the potential to challenge to the project schedule.

The NRC staff noted that, ((

))

The NRC inspectors also noted that, ((

)) The Licensee did note that ((

))

The NRC will consider any potential impacts associated with risk considerations related to the plants probabilistic risk analysis (PRA) and/or human reliability analysis

OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY PROPRIETARY INFORMATION (HRA) ((

))

The NRC noted that ((

))

The NRC staff will consider such potential impacts in their assessment of the licensees Task Analysis, and this change will also be considered in relation to Technical Specifications requirements considerations.

The NRC staff noted that ((

)) The NRC staff noted that they would focus on this consideration in their review of the licensees assessment.

The NRC staff noted the importance of controlling information related to validation test scenario, ((

)) The NRC staff noted thatto avoid biasing results from one test phase to anotherthe licensee will likely either need to control test parameters either by running different scenarios in the different phases ((

)), having different crews participate in testing during the different phases ((

)), or both.

The NRC staff noted that, ((

)) The NRC staff noted that NUREG-0700 contains guidance information density in digital displays, which should be considered throughout the design process.

No regulatory decisions were made during the meeting.

Please direct any inquiries regarding this meeting to Ed Miller at 301-415-2481 or Ed.Miller@nrc.gov.

Sincerely,

/RA/

G. Edward Miller, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251 cc w/Redacted Summary: Listserv

Package: ML23068A066 Proprietary Summary: ML23068A101 Nonproprietary Summary: ML23068A071 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL2-2/LA NRR/DRO/IOLB/BC NRR/DORL/LPL2-2/BC NAME GEMiller RButler LNist DWrona DATE 3/28/2023 3/13/2023 3/28/2023 4/07/2023 OFFICE NRR/DORL/LPL1/PM NAME GEMiller DATE 4/28/2023