ML24102A277
| ML24102A277 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/11/2024 |
| From: | Michael Mahoney NRC/NRR/DORL/LPL2-2 |
| To: | Mack J Florida Power & Light Co |
| References | |
| L-2032-LLA-0142 | |
| Download: ML24102A277 (7) | |
Text
From:
Michael Mahoney Sent:
Thursday, April 11, 2024 10:45 AM To:
Mack, Jarrett
Subject:
Audit Plan - Turkey Point - SFP Criticality LAR (L-2023-LLA-0142)
Attachments:
Audit Plan_Turkey Point SFP LAR - PUBLIC - REDACTED.pdf Jarrett, By letter L-2023-071, dated October 11, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Package No. ML23285A035), Florida Power and Light Company (FPL, the licensee) submitted a license amendment request (LAR) to for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point).
The LAR proposes to revise the Turkey Point Technical Specifications (TS) by incorporating changes to TS 3. 7.13 "Fuel Storage Pool Boron Concentration," TS 3.7.14 "Spent Fuel Storage," and TS 4.3 "Fuel Storage," to allow for an updated spent fuel pool criticality safety analysis which accounts for the impact on the spent fuel from a proposed transition to 24-month fuel cycles.
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 limited, read-only access to the information identified in Section 5.0 of the attached audit plan. The NRC staff plans to conduct a desk audit to review the documentation provided on the portal. The online reference portal would allow the NRC staff 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. 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. The audit may also include interactions (e.g., teleconferences or webinars) on a mutually agreeable schedule sufficient to understand or resolve issues associated with the information made available on the online reference portal.
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 5.0 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 (public), and I will provide you with the accession number.
Please note that that attached audit plan is a redacted (public) version as the audit plan
contains proprietary information. The version of the audit plan with proprietary (non-public) information was transmitted to you via BOX.
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:
2471 Mail Envelope Properties (SA1PR09MB9486E8F998F634DA5E17C1D7E5052)
Subject:
Audit Plan - Turkey Point - SFP Criticality LAR (L-2023-LLA-0142)
Sent Date:
4/11/2024 10:44:42 AM Received Date:
4/11/2024 10:44:47 AM From:
Michael Mahoney Created By:
Michael.Mahoney@nrc.gov Recipients:
"Mack, Jarrett" <Jarrett.Mack@fpl.com>
Tracking Status: None Post Office:
SA1PR09MB9486.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3334 4/11/2024 10:44:47 AM Audit Plan_Turkey Point SFP LAR - PUBLIC - REDACTED.pdf 368307 Options Priority:
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OFFICIAL USE ONLY PROPRIETARY INFORMATION Enclosure OFFICIAL USE ONLY - PROPRIETARY INFORMATION AUDIT PLAN REGARDING LICENSE AMENDMENT REQUEST TO UPDATE THE SPENT FUEL POOL CRITICALITY ANALYSIS FLORIDA POWER AND LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING STATION, UNITS 3 AND 4 DOCKET NOS. 50-250 AND 50-251 EPID NO. L-2023-LLA-0161
1.0 BACKGROUND
By letter L-2023-071, dated October 11, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Package No. ML23285A035), Florida Power and Light Company (FPL, the licensee) submitted a license amendment request (LAR) to for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point).
The LAR proposes to revise the Turkey Point Technical Specifications (TS) by incorporating changes to TS 3. 7.13 "Fuel Storage Pool Boron Concentration," TS 3.7.14 "Spent Fuel Storage," and TS 4.3 "Fuel Storage," to allow for an updated spent fuel pool criticality safety analysis which accounts for the impact on the spent fuel from a proposed transition to 24-month fuel cycles.
The NRC staffs review of the LAR has commenced in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, License Amendment Review Procedures. The NRC staff has determined that a regulatory audit should be conducted in accordance with the NRR Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ML19226A274), for the NRC staff to gain a more detailed understanding of the licensees proposed license amendment.
A regulatory audit is a planned, license-related or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. A 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 the 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, there may be supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and record-keeping 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.
OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION 2.0 REGULATORY AUDIT BASIS 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 further rounds of requests 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 responses to items in Section 5.0 of this audit plan, to be reviewed by the staff using an online reference portal. Upon completion of this audit, the NRC staff is expected to achieve the following.
- 1. Confirm licensee information which supports statements made in the LAR.
- 2. Determine whether the information included in any examined documents is necessary to be submitted to support a safety conclusion.
The 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 submitted on the docket.
3.0 REGULATORY AUDIT SCOPE OR METHOD The purpose of the remote audit is to gain a more detailed understanding of licensees proposed LAR. The areas of focus for the regulatory audit are the information contained in the licensees October 11, 2023, submittal, and the proposed audit questions and discussion topics in section 5.0 of this audit plan.
4.0 AUDIT TEAM The audit will be conducted by NRC staff from the NRR Division of Safety Systems (DSS),
Containment and Plant Systems Branch (SCPB), Nuclear Methods and Fuels Analysis Branch (SFNB), and Technical Specification Branch (STSB). The audit will be led by staff from the NRR Division of Operating Reactor Licensing (DORL). NRC staff from other organizations may be assigned to the team as appropriate and others may participate as observers. Observers at the audit may include other NRR Project Managers and various regional staff.
The following are members of the NRC audit team:
Team Member Title Organization Mike Mahoney Michael.Mahoney@nrc.com Project Manager NRR/DORL/LPLII-2 Kevin Heller Kevin.Heller@nrc.gov Nuclear Engineer NRR/DSS/SFNB Jack Vande Polder Jack.VandePolder@nrc.gov Reactor Systems Engineer NRR/DSS/SFNB Josh Wilson Joshua.Wilson@nrc.gov Safety And Plant Systems Engineer NRR/DSS/STSB
OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION 6.0 LOGISTICS The audit will be started once an electronic reference portal is set up and the initial responses to items in Section 5.0 are made available to the NRC staff to review. The initial desk audit will be conducted over several weeks. The licensee will be kept informed on a regular basis during periodic discussions with the project manager regarding the progress. The audit may include interactions (e.g., teleconferences or webinars) on a mutually agreeable schedule sufficient to understand or resolve issues associated with the information made available.
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.