ML23137A094
| ML23137A094 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/17/2023 |
| From: | Michael Mahoney NRC/NRR/DORL/LPL2-2 |
| To: | Phillabaum J Florida Power & Light Co |
| References | |
| L-2022-LLA-0182 | |
| Download: ML23137A094 (7) | |
Text
From: Michael Mahoney Sent: Wednesday, May 17, 2023 8:36 AM To: Phillabaum, Jerry Cc: Mack, Jarrett; Mack, Kenneth; Falkiewicz, Timothy; Vincent, Keith; Keith, Karl; Natreon Jordan
Subject:
Audit Plan - St Lucie Plant, Units 1 and 2 - 10 CFR 50.69 LAR (EPID L-2022-LLA-0182)
Attachments: Audit Plan - St. Lucie - 50.69 LAR (L-2022-LLA-0182).docx
Mr. Phillabaum,
By letter dated December 2, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22336A071), Florida Power & Light Company (FPL, the licensee) submitted a license amendment request for the St. Lucie Plant, Unit Nos. 1 and 2, respectively.
The proposed amendment would modify the licensing basis by the addition of a license condition to allow implementation of provisions of Title 10 of the Code of Federal Regulations, Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.
To improve the efficiency of the NRC staffs review, FPLs representatives and the NRC staff have discussed the performance of an NRC staff audit using an online reference portal that would allow the NRC staff (and NRC contractors) limited, read -only access to the information identified in Section 4.0 of the attached audit plan. The online reference portal would allow the NRC staff (and NRC contractors) to audit internal licensee information to confirm that the information support statements were made in the LAR and to determine whether the information included in the documents is necessary to reach a safety conclusion on the application. The NRC staff plans to conduct a desk audit to review the documentation provided on the portal, which is expected to last several weeks. The audit will include interactions (e.g.,
teleconferences or webinars) on a mutually agreeable schedule (currently planned for July 20 and 21, 2023), sufficient to understand or resolve issues associated with the information made available on the online reference portal. Any audit information that the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be formally submitted on the docket via requests for additional information (RAIs).
Use of the online reference portal is acceptable, as long as the following conditions are met:
- The online reference portal will be password -protected, and passwords will be assigned to those directly involved in the review on a need-to-know basis.
- The online reference portal will be sufficiently secure to prevent NRC staff from printing, saving, or downloading any documents; and
- Conditions of the use of the online reference portal will be displayed on the login screen and with concurrence by each user.
These conditions associated with the online reference portal must be maintained throughout the duration of the audit process.
The NRC staff would like to request that the portal be populated with the information identified in section 4.0 of attached audit plan. The NRC staff may request additional documents during the review, which will be transmitted to you via email.
This email will be added to ADAMS and I will provide the accession number to you.
If you have any questions, please contact me.
Thanks
Mike Mahoney Project Manager, LPL2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Desk: (301)-415-3867 Mobile: (301)-250-0450 Email: Michael.Mahoney@nrc.gov
Hearing Identifier: NRR_DRMA Email Number: 2099
Mail Envelope Properties (SA1PR09MB9486C8CCCFA892D781E8F146E57E9)
Subject:
Audit Plan - St Lucie Plant, Units 1 and 2 - 10 CFR 50.69 LAR (EPID L-2022-LLA-0182)
Sent Date: 5/17/2023 8:36:24 AM Received Date: 5/17/2023 8:36:26 AM From: Michael Mahoney
Created By: Michael.Mahoney@nrc.gov
Recipients:
"Mack, Jarrett" <Jarrett.Mack@fpl.com>
Tracking Status: None "Mack, Kenneth" <Kenneth.Mack2@fpl.com>
Tracking Status: None "Falkiewicz, Timothy" <Timothy.Falkiewicz@fpl.com>
Tracking Status: None "Vincent, Keith" <Keith.Vincent@fpl.com>
Tracking Status: None "Keith, Karl" <Karl.Keith@fpl.com>
Tracking Status: None "Natreon Jordan" <Natreon.Jordan@nrc.gov>
Tracking Status: None "Phillabaum, Jerry" <Jerry.Phillabaum@fpl.com>
Tracking Status: None
Post Office: SA1PR09MB9486.namprd09.prod.outlook.com
Files Size Date & Time MESSAGE 3183 5/17/2023 8:36:26 AM Audit Plan - St. Lucie - 50.69 LAR (L-2022-LLA-0182).docx 55609
Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
REGULATORY AUDIT PLAN REGARDING LICENSE AMENDMENT REQUEST TO ADOPT THE REQUIREMENTS OF 10 CFR 50.69 FLORIDA POWER & LIGHT COMPANY ST. LUCIE PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389 EPID L-2022-LLA-0182
1.0 BACKGROUND
By letter L-2022-175 dated December 2, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22336A071), Florida Power & Light Company (FPL) (the licensee) requested a license amendment to the Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Unit Nos. 1 and 2, respectively. The licensee requested to adopt Title 10 of the Code of Federal Regulations, Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, into its licensing basis.
The U.S. Nuclear Regulatory commission (NRC) staff has reviewed the licensees submittal and determined that a regulatory audit of the information identified in the Information Request section below would assist in the timely completion of the subject LAR review process. The NRC staff is continuing to review other aspects of the licensees submittal and may identify the need for additional audit subjects by separate correspondence.
2.0. REGULATORY AUDIT BASES
An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this LAR review, because the NRC staff will have an opportunity to minimize the potential for request for additional information (RAIs) and ensure no unnecessary burden will be imposed by requiring the licensee to address issues that are no longer necessary to make a safety determination. The NRC staff is requesting an initial set of internal licensee information to be audited by the staff using an online reference portal. Upon completion of this audit, the NRC staff is expected to achieve the following.
- 1. Confirm internal licensee information that supports statements made in the LAR.
- 2. Determine whether the information included in the documents is necessary to be submitted to support a safety conclusion.
The audit information the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY
The purpose of the remote audit is to gain a more detailed understanding of the licensees process to implement risk-informed categorization and treatment of structures, systems and components as proposed in the LAR. The NRC staff will audit internal events and fire probabilistic risk assessment (PRA) and the risk informed approach implementing 10 CFR 50.69.
The areas of focus for the regulatory audit are the information contained in the licensees submittal, the enclosed audit information needs, and all associated and relevant supporting documentation (e.g., methodology, process information, calculations, etc.) identified below.
The audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274).
4.0 INFORMATION REQUESTS
Please provide the following information for the NRC staff to audit:
- 1. Applicable peer review reports and closure reports for internal events, internal flooding and fire PRAs.
- 2. Available 10 CFR 50.69 structures, systems, and components categorization program procedures (i.e., Categorization review and adjustment process, decision criteria for Independent Decision-Making Panel (IDP), etc.).
- 3. Uncertainty notebooks for internal events, internal flooding, and fire PRAs related to PRA model assumptions and sources of uncertainty.
- 4. Documentation of review of PRA model assumptions and sources of uncertainty and identification of key assumptions and sources of uncertainty for the application identified in the LAR.
- 5. PRA notebooks for the modeling of FLEX equipment and FLEX human error probabilities, if credited in the PRA.
- 6. Circuit analysis report (with the resolution to Facts and Observation (F&O) CS-A3-
- 01) to perform a comparison of the components identified on the multiple spurious operation (MSO) list against the Fire PRA components not already evaluated for Appendix R.
- 7. Circuit analysis report (with the resolution to F&O CS-B1-01) to perform overcurrent coordination analysis for circuits not already evaluated for Appendix R.
- 8. Seismic Fire Interaction report (with resolution to F&O SF-A1) on the impact of a seismic event on fire suppression, procedures, and fire brigade training.
5.0 AUDIT TEAM
Key licensee personnel involved in the development of the LAR should be made available for interactions on a mutually agreeable schedule to respond to any questions from the NRC staff.
Team Member Division Area of Responsibility Michael Mahoney NRR/DORL/LPLII-2 Project Management Michael.Mahoney@nrc.gov Alexander Schwab NRR/DRA/APLA Technical Review Alexander.Schwab@nrc.gov Mihaela Biro NRR/DRA/APLA Technical Review Mihaela.Biro@nrc.gov Daniel Ju NRR/DRA/APLC Technical Review Daniel.Ju@nrc.gov Sunwoo Park NRR/DRA/APLC Technical Review Sunwoo.Park@nrc.gov Mark Wilk Pacific Northwest Technical Review Mark.Wilk@pnnl.gov National Laboratory Garill Coles Pacific Northwest Technical Review Garill.Coles@pnnl.gov National Laboratory
6.0 LOGISTICS
The virtual audit will be conducted from 7/20/2023 to 7/21/2023, after an electronic reference portal is set up and the draft documentation addressing the items in section 4.0 of this audit report is made available to the NRC staff. The initial NRC staff desk audit will be conducted over several weeks. The NRC project manager will coordinate with the NRC staff and licensee for any teleconferences needed after the NRC staff has reviewed the documentation. The audit will include interactions (e.g., teleconferences) on a mutually agreeable schedule sufficient to understand or resolve issues associated with the information made available. The audit teams access to the online portal may be terminated after completion of the virtual audit at a time established by the project manager.
7.0 SPECIAL REQUESTS
The NRC staff would like access to the documents listed above in Section 4.0 through an online portal that allows the NRC staff and contractors to access documents via the internet.
The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff and contractors have access to the online portal:
- The online portal will be password-protected, and separate passwords will be assigned to the NRC staff and contractors who are participating in the audit.
- The online portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information on the online portal.
- Conditions of use of the online portal will be displayed on the login screen and
will require acknowledgement by each user.
Username and password information should be provided directly to the NRC staff and contractors. The NRC project manager will provide FPL the names and contact information of the NRC staff and contractors who will be participating in the audit. All other communications should be coordinated through the NRC project manager.
7.0 DELIVERABLES
An audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee.