ML25057A434
| ML25057A434 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  (NPF-086) |
| Issue date: | 03/28/2025 |
| From: | V Sreenivas NRC/NRR/DORL/LPL1 |
| To: | Coffey B Florida Power & Light Co |
| Lantigua R, NRR/DORL/LPL1 | |
| References | |
| EPID L-2025-LLA-0025 | |
| Download: ML25057A434 (1) | |
Text
March 28, 2025 Robert 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:
SEABROOK STATION, UNIT 1 - REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B (EPID L-2025-LLA-0025)
Dear Robert Coffey:
By letter dated February 3, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25034A143), NextEra Energy Seabrook, LLC (the licensee) submitted a license amendment request (LAR) to amend the licenses for Seabrook Station, Unit 1, Renewed Facility Operating License No. NPF-86. The proposed LAR would adopt Technical Specifications Task Force Traveler 505 (TSTF-505), Revision 2, Provide Risk-informed Extended Completion Times, RITSTF Initiative 4b.
The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit virtually via Microsoft Teams using a licensee-established electronic portal available to NRC staff from approximately May 1, 2025, through October 31, 2025, with formal audit meetings to be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.
R. Coffey If you have any questions, please contact me by telephone at 301-415-2597 or by email to v.sreenivas@nrc.gov.
Sincerely,
/RA/
V. Sreenivas, Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443
Enclosures:
- 1. Audit Plan
- 2. Audit Requests cc: Listserv REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST TO ADOPT RISK INFORMED COMPLETION TIMES - TSTF-505 NEXTERA ENERGY SEABROOK, LLC SEABROOK STATION, UNIT 1 DOCKET NO. 50-443
1.0 BACKGROUND
By letter dated February 3, 2025 [1], NextEra Energy Seabrook, LLC (the licensee) submitted a license amendment request (LAR) for Seabrook Station, Unit 1 (Seabrook). Reference Error!
Reference source not found. would modify the Seabrook Technical Specifications (TSs) to permit the use of Risk-Informed Completion Times (RICTs) in accordance with Technical Specifications Task Force Traveler 505 (TSTF)-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b [2].
The staff from the U.S. Nuclear Regulatory Commissions(NRC) Office of Nuclear Reactor Regulation(NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures [3].
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of the licensees non-docketed information that provides the technical basis for the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR LIC-111, Regulatory Audits [4], with exceptions noted within this audit plan.
The NRC staff will perform the audit to support its evaluation of whether the licensees request can be approved per Title 10 of the Code of Federal Regulations 50.90, Application for amendment of license, construction permit, or early site permit. The staffs review will be informed by Standard Review Plan Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis [5]. The audit will assist the NRC staff with understanding the licensees proposed program for implementing RICTs for certain TSs.
3.0 SCOPE The audit team will view the documentation and calculations that provide the technical support for the LAR. The scope of the NRC staffs audit will focus on the following subjects:
Understand how the licensees proposed program conforms to NRC-endorsed guidance in the Nuclear Energy Institute (NEI) report NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification Guidelines [6].
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for this application.
Identify any information needed to enable the staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information [7].
The NRC staff will audit the PRA methods that the licensee would use to determine the risk impact from which the revised completion times for TSTF-505 would be obtained. This will include the licensees assessment of internal events (including internal flooding) and fire as well as the treatment of uncertainties and evaluation of defense in depth. The NRC will also audit the licensees quantification of risk from significant external events, whether the licensee uses PRA or bounding methods. In addition, the audit team will discuss these topics with the licensees subject matter experts.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff will request information and interviews throughout the audit period. The NRC staff will use an audit items list to identify the information to be audited (e.g., methodology, process information, and calculations) and the subjects of requested interviews and meetings.
The NRC staff requests the licensee to have the information referenced in the attachment of this audit plan available and accessible for the NRC staffs review via a web-based electronic portal within two weeks of the date of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within one week of the date of the NRCs notification to the licensee of the new requests. The NRC staff requests the licensee to notify the review team when an audit item is added to its electronic portal by sending an email to the NRC licensing project manager.
The NRC staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff.
5.0 AUDIT TEAM The following table identifies the NRC audit team members, including contractors, and their respective focus areas:
Name Email Review Area (Organization)
V Sreenivas (1)
V.Sreenivas@nrc.gov Plant Licensing Branch LPL 1 (LPL1)
Ricardo Lantigua Ricardo.Lantigua@nrc.gov Plant Licensing Branch LPL 1 (LPL1)
Alexander Schwab (2)
(3)
Alexander.Schwab@nrc.go v
PRA Licensing Branch A (APLA)
Mihaela Biro Mihaela.Biro@nrc.gov Jay Robinson Jay.Robinson@nrc.gov PRA Licensing Branch B (APLB)
Charles Moulton Charles.Moulton@nrc.gov Sunwoo Park Sunwoo.Park@nrc.gov PRA Licensing Branch C (APLC)
Steven Alferink Steven.Alferink@nrc.gov Ellery Coffman Ellery.Coffman@nrc.gov Edmund Kleeh Edmund.Kleeh@nrc.gov Electrical Engineering Branch (EEEB)
Khoi Nguyen Khoi.Nguyen@nrc.gov Jason English Jason.English@nrc.gov Instrumentation and Controls Branch (EICB)
Ming Li Ming.Li@nrc.gov Robert Torres Davis Roberto.TorresDavis@nrc.g ov Mechanical Engineering and Inservice Testing Branch (EMIB)
Hanry Wagage Hanry.Wagage@nrc.gov Containment and Plant Systems Branch (SCPB)
Derek Scully Derek.Scully@nrc.gov Containment and Plant Systems Branch (SCPB)
Jo Ambrosini Josephine.Ambrosini@nrc.
gov Nuclear Systems Performance Branch (SNSB)
Khadijah West Khadijah.West@nrc.gov Technical Specifications Branch (STSB)
To Be Determined (TBD) (4)
TBD Pacific Northwest National Laboratory (PNNL)
TBD (4)
TBD Notes:
(1) NRR Division of Operating Reactor Licensing Project Manager (2) Technical Lead (3) Contracting Officer Representative (4) NRC Contractor 6.0 LOGISTICS The audit will be conducted using a secure, online electronic portal established by the licensee to present supporting documentation and calculations and by interviews with the licensees subject matter experts virtually. The audit will begin approximately within two weeks of the date of this audit plan.
A desktop audit will take place between approximately May 1, 2025, and October 31, 2025, The NRC licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC project manager will coordinate with the licensee to set dates and times to discuss information needs and questions arising from the NRCs review of the audited items. The NRC staff may change and/or add audit dates and times when deemed necessary. Audit meeting agenda and questions will be sent in advance of the audit meeting.
7.0 SPECIAL REQUESTS The following conditions associated with the online web-based electronic portal should be maintained while the NRC staff and contractors on the audit team have access to the online portal:
The online electronic portal will be password-protected, and separate passwords will be assigned to each member of the audit team.
The online web-based electronic portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information from the web portal.
Conditions of use of the online electronic portal will be displayed on the login screen and will require acknowledgment by each user.
The licensee should provide username and password information directly to the NRC staff and contractors on the audit team, listed above. The NRC project manager will provide the licensee the names and contact information of the NRC staff and contractors who are added to the audit team. All other communications should be coordinated with the NRC project manager. The NRC project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the electronic portal.
No data accessed by the audit team members will be retained by the NRC following the conclusion of the audit.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, in accordance with NRR LIC-115 [7] and issue such RAIs separate from audit-related correspondence. The NRC staff will issue an audit summary report within approximately 90 days after the end of the audit and prior to completing its safety evaluation of the LAR.
9.0 REFERENCES
[1] Mack, Kenneth A., NextEra Energy Seabrook, LLC, Seabrook Station, Unit 1, letter to U.S.
Nuclear Regulatory Commission, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF-Initiative 4b, February 3, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25034A143).
[2] Technical Specifications Task Force (TSTF) - A Joint Owners Group Activity, TSTF Comments on Draft Safety Evaluation for Traveler TSTF 505, Provide Risk-Informed Extended Completion Times, and Submittal of TSTF-505, Revision2, July 2, 2018 (ML18183A493).
[3] U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-101, Revision 6, License Amendment Review Procedures, July 31, 2020 (ML19248C539).
[4] U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-111, Revision 2, Regulatory Audits, December 19, 2024 (ML24309A281).
[5] U.S. Nuclear Regulatory Commission, NUREG-0800 - Standard Review Plan: Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, June 19, 2007 (ML071700658).
[6] Nuclear Energy Institute (NEI), NEI 06-09, Revision 0-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines -
Industry Guidance Document, October 12, 2012 (ML122860402).
[7] U.S. Nuclear Regulatory Commmission, Office of Nuclear Reactor Regulation, LIC-115, Revision 1, Licensing Processes, August 5, 2021 (ML21141A238).
ITEM AUDIT REQUEST 1
Reports cited in Enclosure 2 of the license amendment request (LAR) to adopt Technical Specifications Task Force Traveler 505 (TSTF-505) from full-scope and focused-scope peer reviews, self-and gap assessments (including findings, observations (F&Os), and dispositions), and closure reviews of facts and observations.
2 For the probabilistic risk assessments (PRA) identified under Item #1 above, plant-specific documentation (e.g., uncertainty notebooks) related to:
- a. The review of the PRA model assumptions and sources of uncertainty (generic and plant-specific assumptions/uncertainties) for the TSTF-505 LAR.
3 PRA notebooks for the modeling of FLEX equipment and FLEX human error probabilities credited in the PRAs.
4 PRA notebooks for the modeling of digital control systems, including basis for the representative failure probabilities.
5 If modeled, PRA notebooks associated with the modeling of open phase condition in electrical switchyards and the open phase isolation system.
6 Documentation of how shared or cross-tied systems are modeled in the PRA.
7 Fire PRA notebooks containing the results of the fire PRA, including risk importance measures.
8 The following information from Enclosure 4:
- a. Reference 11 - External Hazards Assessment Report
- b. Reference 16 - NextEra AR 02054161
- c. Reference 43 - Engineering Evaluation EE-17-005 (EC288388)
- d. Reference 44 - SBK PRAE-14-002, "SBK PRA Evaluation"
- e. Documentation to support the calculation of the seismic LERF penalty
- f.
Conservative bounding assessment of the CDF due to meteorite impact
- g. Documentations justifying the screening of other external hazards including high winds and external flooding 9
Documentation supporting the example risk-informed completion times (RICT) calculations presented in LAR Enclosure 1, Table E1-2.
10 Documentation supporting the development of the real-time risk tool and benchmarking it against the PRA.
11 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).
12 If available, final RICT program procedures (e.g., for risk management actions, PRA functionality determination, and recording limiting conditions for operation). [The licensee may choose (optional) to provide draft RICT program procedures if final procedures are not available.]
ITEM AUDIT REQUEST 13
-Containment Isolation Valve (CIV) Operability and Maintenance Records (Historical failure data, including actuator performance, seat leakage trends, and corrective actions, Recent Inservice testing (IST) results to confirm compliance with ASME OM Code requirements)
-Engineering Evaluations Supporting RICT Application to CIVs (Justification demonstrating that containment isolation function remains intact under extended RICTs, Structural integrity assessments for CIVs under extended inoperability conditions)
-Code Compliance and Relief Requests (if applicable) (Documentation confirming that extended RICTs do not conflict with ASME Section XI and IST requirements, any relief requests or justifications if ASME Code surveillance/testing intervals are impacted)
-PRA Inputs Related to CIV Failures and Mitigation Measures (Any probabilistic risk assessment (PRA) evaluations that consider degradation mechanisms specific to CIVs, sensitivity analyses evaluating cumulative risk when multiple CIVs are inoperable).
14 Single line diagrams of electrical power distribution systems, load lists for safety related loads per division/train, latest TS Basis, design document for electrical system, list of electrical shared SSCs between divisions, if any, and any associated cross-tie(s), and a description of how such shared SSCs and cross-tie(s), if any, are modeled in the Salem PRA.
15 Other documentation that the licensee determines to be responsive to the U.S.
Nuclear Regulatory Commission staffs information requests.
ML25057A434 NRR-106 OFFICE NRR/DORL/LPL1/PMiT NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NAME RLantigua VSreenivas KEntz DATE 2/25/2025 2/26/2025 2/27/2025 OFFICE NRR/DRA/APLA/BC NRR/DRA/APLB/BC NRR/DRA/APLC/BC Acting NAME BPascarelli EDavidson SAlferink (for ANeuhausen)
DATE 3/10/2025 3/11/2025 3/10/2025 OFFICE NRR/DEX/EMIB/BC NRR/DEX/EICB/BC NRR/DEX/EEEB/BC Acting NAME SBailey FSacko AFoli (for WMorton)
DATE 3/27/2025 3/13/2025 3/25/2025 OFFICE NRR/DSS/STSB/BC NRR/DSS/SNSB/BC NRR/DSS/SCPB/BC NAME SMehta DMurdock MValentin DATE 3/25/2025 3/13/2025 3/10/2025 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME HGonzález VSreenivas DATE 3/26/2025 3/28/2025