ML23270B888
| ML23270B888 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/23/2023 |
| From: | Michael Mahoney Plant Licensing Branch II |
| To: | Coffey B Florida Power & Light Co |
| Jordan N | |
| References | |
| EPID L-2022-LLA-0182 | |
| Download: ML23270B888 (1) | |
Text
October 23, 2023 Mr. Bob Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company 700 Universe Blvd.
Mail Stop: EX/JB Juno Beach, FL 33408
SUBJECT:
ST. LUCIE PLANT, UNITS 1 AND 2 - REGULATORY AUDIT
SUMMARY
REGARDING LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF SRUCTURES, SYSTEMS, AND COMPONENTS FOR NUCLEAR POWER REACTORS (EPID L-2022-LLA-0182)
Dear Mr. Coffey:
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 Nuclear Regulatory Commission (NRC) staff reviewed FPLs LAR and determined that a regulatory audit would assist in the timely completion of the LAR review. The NRC staff conducted a regulatory audit that consisted of a remote audit from July 20 21, 2023. The audit plan was provided to Mr. Jerry Phillabaum of your staff by email dated May 17, 2023. The audit plan included a list of items to be provided on an electronic portal. The staff reviewed these documents and held discussions with members of FPL on the LAR relevant to the NRC staffs
review. The results of the regulatory audit were used by the NRC staff to finalize requests for additional information, which were issued by email dated August 14, 2023. The audit summary for the audit is enclosed.
Sincerely,
/RA/
Michael Mahoney, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335, and 50-389
Enclosure:
Audit Summary cc: Listserv
Enclosure REGULATORY AUDIT
SUMMARY
RELATED TO 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
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 a 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 U.S. Nuclear Regulatory Commission (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) 50.71, Maintenance of records, and/or 10 CFR 54.37, which, although not required to be submitted as part of the licensing action, would help the staff better understand the licensees submitted information.
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.
An audit team consisting of NRC staff and a contractor from the Pacific Northwest National Laboratory (PNNL) conducted a remote regulatory audit to support the review of the LAR from July 20 21, 2023. 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).
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 the Office of Nuclear Reactor Regulation Office Instruction LIC-101, Revision 6, License Amendment Review Procedures (ML19248C539).
2.0 AUDIT ACTIVITIES AND OBSERVATIONS The NRC audit team consisted of NRC staff and an NRC contractor from Pacific Northwest National Laboratory (PNNL). The list of attendees from the NRC, PNNL, FPL, and FPLs contractors is provided in section 4.0.
During the remote regulatory audit, the NRC audit team held an entrance meeting with FPL on July 20, 2023. During the remainder of the remote audit, the NRC audit team participated in technical discussions with FPL according to the audit plan dated May 17, 2023 (ML23137A094).
These technical discussions were focused on previously submitted NRC staff audit questions (ML23248A129). A formal, virtual audit meeting with the licensee was held from July 19 - 20, 2023 to facilitate technical discussions of audit questions and disciplines according to the audit plan.
Technical discussions were focused on the following major areas: probabilistic risk assessment (PRA), external hazards, and fire protection. On July 20, 2023, the NRC staff provided a brief conclusion of the formal, virtual audit meeting including audit objectives that were met and details on the path forward. There were several open items from audit discussions, but no deviations from the audit plan. Non-docketed information provided by the licensee in response to audit questions and the formal meeting is listed in Attachment 2 of this audit summary. The formal audit meeting ended on July 20, 2023, and the licensee and NRC staff agreed that the NRC would issue RAIs to address the open audit items.
Section 5.0 contains a list of the documents audited by the NRC audit team.
3.0 RESULTS OF THE AUDIT As a result of the remote regulatory audit, RAIs were issued to FPL on August 18, 2023 (ML23226A076). FPL provided a response to the RAIs in a supplement dated September 11, 2023 (ML23255A041).
4.0 AUDIT PARTICIPANTS NRC FPL Michael Mahoney Jerry Phillabaum Alexander Schwab Timothy Falkiewicz Mihaela Biro Keith Vincent Sunwoo Park Luke Karten Daniel Ju Joseph Stringfellow Mark Wilk (NRC Contractor - PNNL)
David Passehl (Jensen Hughes)
Garill Coles (NRC Contractor - PNNL)
Robert Kirchner (Jensen Hughes)
Zachary Mcmackin (Jensen Hughes)
Usama Farradj (Jensen Hughes)
Gregory Hubers (Jensen Hughes)
Leo Shanley (Jensen Hughes) 5.0 LIST OF DOCUMENTS PROVIDED ON THE ELECTRONIC PORTAL FPL provided the following supporting documents (e.g., analyses, calculations, reports, drawings, and procedures) on the NextEra Online Reference Portal during the audit.
10 CFR 50.59 Structures, Systems, and Components Categorization Program Procedures EN-AA-112-1004, RIEP [Risk-Informed Engineering Programs] SSC Categorization Integrated Decision-Making Panel, Revision 0.
LI-AA-1003, Integrated Decision-Making Panel for Risk-Informed Programs, Revision
- 0.
EN-AA-112-1005, REIP Requirements for Immediate Review, Periodic Reviews, and Performance Monitoring, Revision 0.
EN-AA-112-1003, RIEP Alternative Treatment Requirements, Revision 0.
EN-AA-112-1002, RIEP Categorization for Systems, Structures, and Components, Revision 0.
EN-AA-112, Risk-Informed Engineering Programs (RIEP) 10CFR50, Revision 0.
EN-AA-112-1001, Risk-Informed Engineering Programs (10 CFR 50.69) Passive Component Categorization, Revision 0.
Circuit Analysis Report with Resolution of Finding and Observation (F&O) CS-A3-01 AR [Analysis Report] for Non-Safety Related Motor Control Center (MCC) 1A3 and 1B3 Breaker Coordination.
PSL-BFJR-16-039, St. Lucie NFPA [National Fire Protection Association] 805 - Task 2 Component and Cable Selection, Revision 4.
AR 02318093, Enhance Non-Safety MCC Brks [Breakers] Coord[ination] for Fire PRA Modeling, dated April 8, 2021.
AR 02318092, NRC 2019 NFPA Audit Preparation - Apparent Calc PSL-1FSE-09-001 Safety Related Motor Control Center Circuit Coordination Concerns, dated June 14, 2019.
AR 02318092, NRC TFPI [Triennial Fire Protection Inspection]: U1 [Unit 1] SR [safety-related] MCCS Potential Lack of Coordination, dated April 8, 2021.
, MCC TCC Plots (Existing and Proposed), from calculation PSL-1FSE-09-001, Revision 02.
Documents Regarding Comparison of MSO List Against Fire PRA Components PSL-BFJR-16-039, St. Lucie NFPA 805 - Task 2 Component and Cable Selection, Revision 4.
FPLSL120-PR-001, PSL Cable Analysis, Revision 001.
Peer Review Reports and Closure Reports PSL-BFJR-18-020, PSL Internal Events & Fire PRA Peer Review Closure, Revision 0.
PSL-BFR-23-013, St. Lucie Nuclear Power Plants Focused Scope PRA Peer Review:
Interfacing Systems LOCA [Loss of Coolant Accident], Revision 0.
PSL-BFJR-23-012, An Independent Review of the Port St. Lucie PRA Against the Requirements of the ASME [American Society of Mechanical Engineers] PRA Standard, Revision 0.
PSL-BFJR-23-011, Focused Peer Review of St. Lucie PSA [Probabilistic Safety Assessment] Common Cause Failure (CCF) Methodology, Revision 0.
PSL-BFJR-19-005, St. Lucie IE [Internal Events], IF, Fire Finding Closure Report -
Enercon, Revision 0.
PSL-BFJR-19-024, Independent Assessment of Facts & Observations Closure of the Plant St. Lucie Probabilistic Risk Assessment, Revision 0.
PSL-BFJR-17-025, Fire PRA Peer Review, Revision 0.
LTR-RAM-II-11-054, RG [NRC Regulatory Guide] 1.200 PRA Focused Peer Review Against the ASME PRA Standard Requirements for Plant St. Lucie (PSL) Probabilistic Risk Assessment, Revision 1.
LTR-RAM-II-09-051, Status Assessment of St. Lucie Unit 1 PRA Peer Reviews in Support of the EPU [Extended Power Uprate], Revision B.
LTR-RAM-II-09-038, Focused Scope Peer Review of the St. Lucie Units 1 and 2 Large Early Release Frequency PRA Against the ASME PRA Standard Requirements, dated July 2009.
PSL-BFJR-17-034, Closure of F&Os for St Lucie Units 1 & 2, Revision 0.
PSL-BFJR-17-034, Closure of F&Os for St Lucie Units 1 & 2, Revision 1.
PSL-BFJR-17-034, Closure of F&Os for St Lucie Units 1 & 2, Revision 2.
PSL-BFJR-17-034, Closure of F&Os for St Lucie Units 1 & 2, Revision 3.
PRA model assumptions and sources of uncertainty and identification of key assumptions and sources of uncertainty for the application identified in the LAR PSL-BFJE-17-056, PSL PRA Input to the 50.69 LAR, Revision 1.
Seismic Fire Interaction Report Report No. 0493060006.105, St. Lucie Nuclear Plant PRA Summary Report, Revision
- 15.
Uncertainty Documents PSL-BFJR-16-050, St. Lucie NFPA 805 - Uncertainty and Sensitivity Report, Revision
- 1.
PSL-SNBK-UNC, Uncertainty Notebook for St. Lucie Units 1 & 2, Revision 1.
PSL-BFJR-18-001, Quantification of Internal Flood Analysis for St. Lucie Units 1 & 2, Revision 3.
ML23270B888 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DRA/APLA/BC NAME MMahoney RButler BPascarelli DATE 09/18/2023 10/5/2023 09/19/2023 OFFICE NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME DWrona MMahoney DATE 10/20/2023 10/23/2023