ML25092A069
| ML25092A069 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/08/2025 |
| From: | Nextera Energy |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML25092A069 (1) | |
Text
License Amendment Request to Adopt 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors Turkey Point Nuclear Plant Pre-Submittal Meeting April 2025
2 Agenda
- Introductions
- Background
- License Amendment Request (LAR) Scope
- LAR Overview
- Approach for Addressing Seismic Risks
- Schedule
- Summary, Closing Remarks, Questions, & Discussion
3 Participants Cynthia Cashwell - Regulatory Affairs Manager, Turkey Point Jerry Phillabaum - Fleet Principal Licensing Engineer, NextEra Joseph Stringfellow - PRA Engineer, NextEra Maribel Valdez - Fleet Licensing Manager, NextEra Keith Vincent - Fleet Reliability and Risk Manager, NextEra Justin Wheat - Consultant
4 Background
- Florida Power & Light (FPL) submitted a LAR to adopt 10 CFR 50.69 at Turkey Point, on December 22, 2017 (ML17363A216).
- On January 19, 2018, FPL requested to withdraw the LAR due to issues with the proposed approach, which screened seismic risk from the categorization process (ML18024A444).
- The NRC staff acknowledged the request to withdraw the LARs in ML18018A921 (Turkey Point and St. Lucie applications). Although the acceptance review for the Turkey Point LAR was not completed, the staff noted two deficiencies - (1) the evaluation of seismic risks, and (2) the disposition of open findings associated with the PRA models.
5 Background
- FPL addressed the NRCs feedback and resubmitted a LAR to adopt 10 CFR 50.69 at St. Lucie, on December 2, 2022 (ML22336A071). The LAR proposed use of the alternative seismic approach for Tier 1 plants, as specified in EPRI Technical Report 3002017583.
- The NRC approved FPLs request to adopt 10 CFR 50.69 at St. Lucie on March 12, 2024 (ML24017A209).
- Lessons learned from licensing St. Lucie (RAIs), as well as the lessons learned from developing similar requests within the NextEra fleet (Point Beach & Seabrook 50.69 LARs), will be utilized in developing the LAR for Turkey Point.
6 10 CFR 50.69 LAR Scope
- The proposed amendment would add a condition to the Turkey Point license to document the NRCs approval for the use of 10 CFR 50.69
- The license condition identifies the processes to be used for categorization of structures, systems and components (SSCs) o Internal events, internal flooding, internal fire risk - PRA model o Shutdown risk - Shutdown safety assessment process o Passive component risk - Arkansas Nuclear One, Unit 2 (ANO-2) method o External hazards - IPEEE screening updated using the screening process in the ASME/ANS PRA Standard, except for seismic risk o Seismic risk - EPRI alternative approach as described in the LAR
7 10 CFR 50.69 LAR Overview
- Follows NEI 00-04 (except for the evaluation of seismic risk) o PRA evaluations utilizing internal events, internal flooding, and fire PRA models o Non-PRA evaluations such as external events screening and shutdown safety assessment o Seven qualitative criteria in Section 9.2 of NEI 00-04 o Defense-in-depth assessment o Passive categorization using ANO-2 methodology
- External Hazards o Screened in accordance with GL 88-20 and updated to use the criteria in ASME PRA Standard RA-Sa-2009 o Currently evaluating/updating the external hazards screening information that was submitted in the previous 50.69 LAR (Att. 4 of ML17363A216)
8 10 CFR 50.69 LAR Overview
- PRA Model Technical Adequacy o Models were assessed as part of adopting the Risk-Informed Completion Time (RICT) program (ML15029A297) o The NRC concluded that the internal events (including internal flooding) and fire PRA models satisfied RG 1.200 and were adequate for the RICT program (ML18270A429) o Currently evaluating/updating the impact of sources of uncertainty and the impact of open F&Os on risk-informed categorization (Att. 3/6 of ML17363A216)
- Assessment of shutdown risk follows the process described in NEI 00-04, Section 5.5, and FPL will use the shutdown safety management plan described in NUMARC 91-06
- Integral assessment performed using NEI 00-04, Section 5.6
9 Approach for Addressing Seismic Risks The approach for assessing seismic follows the same approach licensed for St. Lucie (Tier 1).
The LAR will incorporate by reference the case studies from EPRI 300217583.
The Turkey Point GMRS peak acceleration is less than 0.2g and less than the SSE between 1.0 and 10 Hz.
Turkey Point meets the criteria for Tier 1 and has a low seismic risk contribution.
Comparison of the Turkey Point GMRS & SSE (ML16013A472)
10 Current Schedule
- Plan is to submit LAR on the docket in Q2 2025
- FPL will be prepared to support an audit, if needed, later in 2025
- Approval requested within one year after acceptance
- Plan to implement the amendment within 60 days
11 Summary
- The Turkey Point LAR to adopt 10 CFR 50.69 is scheduled to be docketed in late Q2 2025.
- The PRA models are adequate for risk-informed applications; the NRC reviewed PRA technical adequacy when licensing the RICT program.
- The proposed categorization approach follows NEI 00-04, except for the evaluation of seismic risks, which uses the EPRI alternative approach for Tier 1 sites.
- FPL will address the NRCs feedback from the previous submittal and will implement other lessons learned from the fleet.