ML24353A154
| ML24353A154 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Point Beach, Seabrook, Turkey Point  |
| Issue date: | 12/20/2024 |
| From: | Justin Poole Plant Licensing Branch 1 |
| To: | Coffey B NextEra Energy |
| Marshall, Michael | |
| References | |
| EPID L-2022-LLA-0146 | |
| Download: ML24353A154 (1) | |
Text
I December 20, 2024 Bob Coffey Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company NextEra Energy Point Beach, LLC NextEra Energy Seabrook, LLC Mail Stop: EX/JB 700 Universe Blvd.
Juno Beach, FL 33408
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2; SEABROOK STATION, UNIT NO. 1; ST. LUCIE PLANT, UNITS 1 AND 2; AND TURKEY POINT NUCLEAR GENERATING, UNITS 1 AND 2 - FINAL AUDIT
SUMMARY
REPORT IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUESTS REGARDING FLEET EMERGENCY PLAN AMENDMENT (EPID L-2022-LLA-0146)
Dear Bob Coffey:
By application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024 (Agencywide Documents Access and Management System Accession Nos. ML22278A031, ML22343A254, ML23219A102, ML23332A005, ML24127A063, ML24206A140, ML24260A246, ML24269A203, and ML24289A016, respectively), Florida Power & Light Company, NextEra Energy Seabrook, LLC and NextEra Energy Point Beach, LLC (collectively referred to as NextEra or the licensee), submitted changes to the emergency plans for Point Beach Nuclear Plant, Units 1 and 2, St. Lucie Plant, Units 1 and 2, Seabrook Station, Unit No. 1, and Turkey Point Nuclear Generating Plant, Units 3 and 4 to the U.S. Nuclear Regulatory Commission (NRC) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, the proposed license amendment request (LAR) would create a new fleet common emergency plan with site-specific annexes developed utilizing NUREG 0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support Nuclear Power Plants, Revision 2 dated December 2019 (ML19347D139) and establishes an updated licensing basis for NextEra nuclear sites.
By \
letter dated August 3, 2023 (ML23201A087), the NRC staff stated that during the review of the LAR, it had identified several items that require further clarification and detailed explanations. The NRC staff further stated that it would conduct a regulatory audit to support its review of the LAR in accordance with an audit plan. The audit was conducted in two parts with NRC conducting a technical review audit in accordance with the audit plan on September 27
B. Coffey 2
and 28, 2023 at a third-party office in Rockville, Maryland; followed by NRC staff observing the demonstration drill performed at the Point Beach Nuclear Plant on June 11, 2024.
The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the proposed licensing action. Based on the audit, NextEra provided the necessary information for the NRC staff to determine a reasonable assurance finding as part of a review of the LAR.
If you have any questions, please contact me at 301-415-2048, or by email to Justin.Poole@nrc.gov.
Sincerely,
/RA/
Justin Poole, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-250, 50-251, 50-266, 50-301,50-335, 50-389, and 50-443
Enclosure:
Audit Report cc: Listserv
Enclosure REGULATORY AUDIT REPORT NEXTERA ENERGY POINT BEACH LLC, NEXTERA ENERGY SEABROOK LLC, AND FLORIDA POWER & LIGHT COMPANY LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, SEABROOK STATION, UNIT NO. 1, ST. LUCIE PLANT UNITS 1 AND 2, AND TURKEY POINT NUCLEAR GENERATING PLANT UNITS 3 AND 4 AUDIT TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST FLEET EMERGENCY PLAN AMENDMENT DOCKET NOS.: 50-266, 50-301, 50-443, 50-335, 50-389, 50-250 AND 50-251
1.0 BACKGROUND
By application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024 (Agencywide Documents Access and Management System Accession Nos. ML22278A031, ML22343A254, ML23219A102, ML23332A005, ML24127A063, ML24206A140, ML24260A246, ML24269A203, and ML24289A016, respectively), Florida Power & Light Company, NextEra Energy Seabrook, LLC and NextEra Energy Point Beach, LLC (collectively referred to as NextEra or the licensee), submitted changes to the emergency plans for Point Beach Nuclear Plant, Units 1 and 2, St. Lucie Plant, Units 1 and 2, Seabrook Station, Unit No. 1, and Turkey Point Nuclear Generating Plant, Units 3 and 4 to the U.S. Nuclear Regulatory Commission (NRC) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, the proposed license amendment request (LAR) would create a new fleet common emergency plan with site-specific annexes developed utilizing NUREG 0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support Nuclear Power Plants, Revision 2 dated December 2019 (ML19347D139) and establishes an updated licensing basis for NextEra nuclear sites.
By \
letter dated August 3, 2023 (ML23201A087), the NRC staff stated that during the review of the LAR, it had identified several items that require further clarification and detailed explanations. The NRC staff stated that it would conduct a regulatory audit to support its review of the LAR in accordance with an audit plan. The audit would be conducted remotely using video and teleconferencing and a secure, online portal, established by the licensee, as well as a possible site visit by the NRC staff.
The purpose of the audit was to gain understanding, to verify information, and to identify information that will require docketing to support the proposed licensing action.
2 The NRC staff conducted the regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Revision 1, Regulatory Audits (ML19226A274).
2.0 SCOPE AND PURPOSE The initial part of the audit was held on September 27 and 28, 2023. The purpose of the audit was to help the NRC staff better understand the information provided by NextEra supporting the LAR. The NRC staff further observed a demonstration drill at Point Beach on June 11, 2024.
3.0 AUDIT TEAM The following NRC staff members participated in the audit:
Jessie Quichocho - Branch Chief Michael Norris, - Technical Reviewer Ray Hoffman - Technical Reviewer Jeffrey Herrera - Technical Reviewer Keith Miller - Technical Reviewer Jure Kutlesa - Region III Senior Emergency Preparedness Inspector Justin Poole - Project Manager 4.0 AUDIT REPORT The purpose of this regulatory audit was to enhance the NRC staffs technical understanding of the LAR, interact with the licensee technical staff supporting the LAR, and identify what information would need to be docketed to support completion of the review.
The NRC staff conducted an audit in accordance with the audit plan on September 27 and 28, 2023, at a third-party office in Rockville Maryland. During both days, the discussions focused on licensee capabilities to perform functions in the areas of Command and Control, Communications, Dose Assessment, Radiation Protection, and Maintenance. At the conclusion of this meeting, NextEra indicated that it would provide additional technical justification.
By \
letter dated November 28, 2023 (ML23332A005), NextEra provided additional technical justification in a supplement to its LAR. In a public meeting conducted on March 19, 2024 (ML24066A167), the NRC staff provided a presentation (ML24078A023) that described the NextEra application and supplemental request for additional information (RAI) responses that needed additional justification or validation for the NRC staff to find acceptable. The NRC staff stated that NextEra should provide sufficient technical justification for the discussed issues to allow the NRC staff to continue its review of the application.
In the meeting, NextEra agreed to provide a supplement to its application addressing the remaining RAIs. Additionally, NextEra proposed that it could conduct an emergency preparedness drill to demonstrate certain attributes of the proposed changes to the common fleet emergency preparedness plan that were the subject of previous RAIs and discussed at the public meeting as challenges to the NRC staffs review.
3 By email dated May 1, 2024 (ML24122C692), the NRC staff provided NextEra a list of attributes that the drill should sufficiently demonstrate to meet the objectives that were provided by NextEra in their responses to specific RAIs. By \
letter dated May 6, 2024 (ML24127A063),
NextEra provided a supplement to its LAR. The NRC staff subsequently observed the demonstration drill at the Point Beach Nuclear Plant on June 11, 2024, as part of the audit.
By \
letter dated July 12, 2024 (ML24193A243), the NRC staff provided an interim audit summary that provided the observations of the NRC staff from the June 11, 2024, demonstration drill and provide an updated status of the remaining RAIs. While a demonstration drill by a licensee itself is not considered technical justification for NRC staff to determine a reasonable assurance finding as part of a review of LAR, based on the observations from the demonstration drill, the NRC staff was not able to further their understanding of previous RAI responses submitted by NextEra.
By \
letter dated July 24, 2024 (ML24206A140), NextEra stated its intent to supplement the LAR with additional information including a revised common emergency plan and revised site-specific annexes to bring to closure the outstanding RAls. By letters dated September 16, 2024 (ML24260A246), September 25, 2024 (ML24269A203), and October 15, 2024 (ML24289A016), NextEra provided the necessary information for the NRC staff to determine a reasonable assurance finding as part of a review of the LAR which closed the audit.
5.0 DOCUMENTS REVIEWED The following documents were reviewed during the audit:
Point Beach FSG-0_003, FLEX Information and Reference Guide Point Beach FSG-1 UNIT 1_003, Long Term RCS Inventory Control Point Beach FSG-1 UNIT 2_003, Long Term RCS Inventory Control Point Beach FSG-2_003, Alternate AFW Suction Source Point Beach FSG-3 UNIT 1_002, Alternate Low Pressure Feedwater Point Beach FSG-3 UNIT 2_002, Alternate Low Pressure Feedwater Point Beach FSG-4_005, ELAP DC Bus Load Shed_Management Point Beach FSG-5.1_002, FLEX Post Event Damage Assessment Point Beach FSG-5.2_003, FLEX Equipment Staging Point Beach FSG-5.3_003, FLEX Electrical Operations Point Beach FSG-5.4_003, FLEX Pump Operations Point Beach FSG-5.5_001, FLEX Equipment Refueling Point Beach FSG-5.6_001, FLEX Miscellaneous Equipment and Monitoring Point Beach FSG-5.7_002, FLEX NSRC Equipment Operation Point Beach FSG-5_008, Initial Assessment and FLEX Equipment Staging Point Beach FSG-6_001, Alternate CST Makeup Point Beach FSG-7 UNIT 1_004, Loss of Vital Instrumentation or Control Power Point Beach FSG-7 UNIT 2_004, Loss of Vital Instrumentation or Control Power Point Beach FSG-8 UNIT 1_004, Alternate RCS Boration Point Beach FSG-8 UNIT 2_005, Alternate RCS Boration Seabrook FSG-0.0_005, Extended Loss of All AC Power with SEPS Seabrook FSG-0.1_003, Extended Loss of All AC Power Without SEPS Seabrook FSG-1_000, Long Term RCS Inventory Control Seabrook FSG-3.1.1_002, FLEX Low Pressure Pump (FLPP) Operation
4 Seabrook FSG-3.1.2_002, Diesel Fire Pump Operation Seabrook FSG-3.1_001, Alternate Low Pressure Feedwater Equipment Deployment Seabrook FSG-3_000, Alternate Low Pressure Feedwater Seabrook FSG-4.1.1_002, FLEX 405 KW Diesel Generator Operation Seabrook FSG-4.1.2_001, FLEX 30 KW Diesel Generator Operation Seabrook FSG-4.1_006, ELSP Power Management Equipment Deployment Seabrook FSG-4_013, ELAP Power Management Seabrook FSG-5.1.1_003, Fuel Transfer Trailer Operation Seabrook FSG-5.1.2_001, Portable Light Tower Operation Seabrook FSG-5.1_004, FLEX Equipment Deployment Seabrook FSG-5_010, Initial Assessment and FLEX Equipment Staging Seabrook FSG-6.1.1_001, CT Makeup Pump Operation Seabrook FSG-6.1_001, Alternate CST Makeup Equipment Deployment Seabrook FSG-6_001, Alternate CST Makeup Seabrook FSG-7.1.1_001, Control Room Instrumentation Alternate Indication Readout Seabrook FSG-7_004, Loss of Vital Instrumentation or Control Power St. Lucie Common Unit, 0-FSG-11_006, Alternate Spent Fuel Pool Makeup and Cooling St. Lucie Unit 1, 1-FSG-01_002, Long Term Inventory Control St. Lucie Unit 1, 1-FSG-02_004, Alternate AFW Suction Source St. Lucie Unit 1, 1-FSG-03_008, Alternate Low Pressure Feedwater St. Lucie Unit 1, 1-FSG-04_004, ELAP DC Bus Load Shed and Management St. Lucie Unit 1, 1-FSG-05_010, FLEX Implementation St. Lucie Unit 1, 1-FSG-06_007, Alternate CST Makeup St. Lucie Unit 1, 1-FSG-07_006, Loss of DC Power St. Lucie Unit 1, 1-FSG-08_002, Alternate RCS Boration St. Lucie Unit 1, 1-FSG-09_002, Low Decay Heat Temperature Control St. Lucie Unit 1, 1-FSG-10_002, Safety Injection Tank Isolation St. Lucie Unit 1, 1-FSG-12_002, Containment Temperature and Pressure Control St. Lucie Unit 1, 1-FSG-13_002, Transition from FLEX Equipment St. Lucie Unit 1, 1-FSG-14_006, Shutdown RCS Makeup St. Lucie Unit 1, 1-FSG-99_015, Appendices_Figures_Tables_Data Sheets St. Lucie Unit 2, 2-FSG-01_000, Long Term Inventory Control St. Lucie Unit 2, 2-FSG-02_003, Alternate AFW Suction Source St. Lucie Unit 1, 1-FSG-03_008, Alternate Low Pressure Feedwater St. Lucie Unit 2, 2-FSG-04_006, ELAP DC Bus Load Shed and Management St. Lucie Unit 2, 2-FSG-05_008, FLEX Implementation Turkey Point 0-FSG-03_000, Alternate Low Pressure Feedwater Turkey Point 0-FSG-04_002_A, ELAP DC Load Shed_Management Turkey Point 0-FSG-05_000_D, Initial Assessment and Equipment Staging Turkey Point 0-FSG-06_000, Alternate CST Makeup Turkey Point 0-FSG-07_000, Loss of Vital Instrumentation or Control Power Turkey Point 0-FSG-11_000, Alternate SFP Makeup and Cooling Turkey Point 0-FSG-13_000, Transition from FLEX Equipment Turkey Point 0-FSG-99_004, FSG Supplemental Guidance Turkey Point 3-FSG-01_001, Long Term RCS Inventory Control Turkey Point 3-FSG-08_004, Alternate RCS Boration Turkey Point 3-FSG-09_000, Low Decay Heat Temperature Control Turkey Point 3-FSG-10_001, Passive RCS Injection Isolation
5 Turkey Point 3-FSG-14_000, RCS Makeup While Shutdown Turkey Point 4-FSG-01_002, Long Term RCS Inventory Control Turkey Point 4-FSG-08_005, Alternate RCS Boration Turkey Point 4-FSG-09_000, Low Decay Heat Temperature Control Turkey Point 4-FSG-10_001, Passive RCS Injection Isolation Turkey Point 4-FSG-14_000, RCS Makeup While Shutdown Supplemental Information Response EP-AA-OPSCK-SDA, Shift Dose Assessor Checklist EP-AA-OSCCK-FIN, FIN Supervisor Checklist EP-AA-OPSCK-RPT, Shift RPT Checklist EP-AA-OSCCK-RPS, Seabrook OSC Radiation Protection Supervisor Checklist EP-AA-TSCCK-CRPC, Combined TSC_OSC Radiation Protection Coordinator Checklist EP-AA-EROFM-007, Command and Control Turnover Checklist EP-AA-TSCCK-SED, Site Emergency Director Checklist EP-AA-OPSCK-ECA, Shift Emergency Classification Advisor Checklist MA-AA-100-1011, Revision 12, Equipment Troubleshooting PI-AA-100, Revision 21, Condition Assessment and Response MA-AA-100-1011-F01 Revision 7, Troubleshooting Form NRC Observation Drill Narrative Summary NRC Observation Drill NRC Observation Drill Comments NRC Observation Drill Post Clarification Call PB ERO Response - Dose Assessment Channel PB ERO Response - Leadership Channel Supplemental Information Response (09-03-2024)
Supplemental Information Response (09-05-2024)
6.0 CONCLUSION
The purpose of the audit was to gain understanding, verify information, and identify required information for docketing to support the proposed licensing action. As a result of the NRC staffs review of documents and observations from the audit, NextEra provided the necessary information for the NRC staff to determine a reasonable assurance finding when reviewing the LAR.
Date: December 20, 2024
ML24353A154 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NSIR/DPR/RLC/BC NAME JPoole KEntz JQuichocho DATE 12/17/2024 12/19/2024 11/15/2024 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME HGonzález JPoole DATE 12/20/2024 12/20/2024