ML23118A176
| ML23118A176 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/04/2023 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Coffey B Point Beach |
| Wall, S P | |
| References | |
| EPID L-2022-LLA-0106 | |
| Download: ML23118A176 (1) | |
Text
May 4, 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 REGARDING RISK-INFORMED APPROACH FOR CLOSURE OF GENERIC SAFETY ISSUE-191 (EPID L-2022-LLA-0106)
Dear Mr. Coffey:
By letter dated July 29, 2022 (Agencywide Documents Access and Management System Accession No. ML22210A086), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted license amendment request and exemption request for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach). The proposed amendments would revise the licensing basis described in the Point Beach Updated Final Safety Analysis Report to include a risk-informed method of evaluating the effects of loss-of-cooling accident (LOCA) generated debris on long-term core cooling (LTCC). The requested exemption would allow the use of risk-informed methods to evaluate the LTCC effects of debris generation resulting from a postulated LOCA in order to address the safety issues described in Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors. The proposed license amendments and exemption requests are part of NextEras final resolution to Generic Safety Issue (GSI-191), Assessment of Debris Accumulation on Pressurized-Water Reactor Sump and Performance, and for responding to GL 2004-02.
To support its review, by letter dated September 30, 2022 (ML22264A305), the U.S. Nuclear Regulatory Commission (NRC) staff notified the licensee that they would conduct a regulatory audit from October 10, 2022, to February 24, 2023, 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 April 28, 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 RISK-INFORMED APPROACH FOR CLOSURE OF GENERIC SAFETY ISSUE-191 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 July 29, 2022 (Agencywide Documents Access and Management System Accession No. ML22210A086), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted license amendment request (LAR) and exemption request for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach). The proposed amendments would revise the licensing basis described in the Point Beach Updated Final Safety Analysis Report to include a risk-informed method of evaluating the effects of loss-of-cooling accident (LOCA) generated debris on long-term core cooling (LTCC). The requested exemption would allow the use of risk-informed methods to evaluate the LTCC effects of debris generation resulting from a postulated LOCA in order to address the safety issues described in Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (ML042360586). The proposed license amendments and exemption requests are part of NextEras final resolution to addressing the concerns of Generic Safety Issue (GSI-191), Assessment of Debris Accumulation on Pressurized-Water Reactor Sump and Performance, and for responding to GL 2004-02.
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 September 30, 2022 (ML22264A305), 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), sections 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 September 30, 2022 (ML22264A305), the NRC staff issued an audit plan. The original audit duration was from October 10, 2022, to February 24, 2023. Due to the volume of documents and the necessity to have clarification discussions, the virtual audit was extended to April 28, 2023. To support discussions, the NRC staff provided 49 audit questions with items for NextEra to clarify. NextEra posted answers to these questions in the ePortal. The NRC staff held clarification discussions with the NextEra staff by teleconference on December 19, 2022, February 14, 2023, and April 18, 2023. All audit questions were discussed. Technical discussions were focused on the following major areas:
General Information and Licensing Bases Debris Generation/Zone of Influence (Excluding Coatings)
Transport Head Loss and Vortexing Net Positive Suction Head (NPSH)
Coatings In-Vessel Evaluation Chemical Effects Risk-Informed Basis Defense in Depth and Safety Margin Performance Monitoring Program 3.0 AUDIT TEAM The NRC audit team included the following:
Scott Wall, Plant Licensing Branch III (LPL3)
Dan Brockman, LPL3 Andrea Russell, Technical Specifications Branch (STSB)
Steve Smith, STSB Charles Moulton, PRA Licensing Branch B (APLB)
Daniel Ju, APLB Bryce Lehman, Structural, Civil, Geotech Engineering Branch (ESEB)
Shaohua Lai, ESEB Eric Reichelt, Piping and Head Penetrations Branch (NPHP)
John Tsao, Vessels and Internals Branch (NVIB)
Matthew Yoder, Corrosion and Steam Generator Branch (NCSG)
Robert Hoffman, Environmental Review Materials Branch (ELRB)
Paul Klein, NCSG Osvaldo Pensado, Southwest Research Institute (SwRI)
Stuart Stothoff, SwRI 4.0 DOCUMENT AND FILES REVIEWED To assist in understanding the licensees overall methodology and verify the accuracy of the licensees calculations the NRC staff reviewed the items listed below. This review contributed to the development of some of the questions referred to in section 2.0 above.
Item #
Audit Item 1
Files to verify the computer-aided design (CAD) model debris generation and NARWHAL software results. Specifically, the NRC staff requests:
(a) Excel files with debris generated and transported, itemized by weld location, break size, and orientation.
(b) Excel files with the list of breaks that result in failure, the failure cause, the break size causing failure, and the considered pump configuration.
(c) The list of all weld locations, with coordinates and weld diameters.
(d) Examples of time-varying head loss to compute strainer failure due to physical limits (e.g., flashing, void fraction, structural load), including independent variables (e.g., temperatures, flow rates, debris generated and transported to strainers) to compute the head loss and the physical limits, or confirmation that the only relevant type of strainer failure was exceedance of strainer test limits for the purpose of estimating increases in core damage frequency.
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 NextEras final resolution to addressing the concerns of GSI-191.
Several RAIs were issued to the licensee on May 1, 2023 (ML23122A013). The licensee is scheduled to provide a response to the RAIs by June 16, 2023.
ML23118A176 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DRA/APLB/BC(A) NRR/DSS/STSB/BC NAME SWall SRohrer SMehta VCusumano DATE 04/28/2023 05/02/2023 05/03/2023 05/03/2023 OFFICE NRR/DSS/SFNB/BC NRR/DEX/ESEB/BC NRR/DNRL/NPHP/BC NRR/DNRL/NCSG/BC NAME SKrepel ITseng MMitchell SBloom DATE 05/02/2023 05/04/2023 05/02/2023 05/02/2023 OFFICE NRR/DNRL/NVIB/BC NRR/DORL/LPL3/BC(A) NRR/DORL/LPL3/PM NAME ABuford VSreenivas SWall DATE 05/03/2023 05/04/2023 05/04/2023