ML25262A105
| ML25262A105 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/23/2025 |
| From: | Blake Purnell Plant Licensing Branch II |
| To: | Coffey R Florida Power & Light Co |
| Buckberg, P. NRR/DORL 415-1383 | |
| References | |
| EPID L 2025 LLA 0101 | |
| Download: ML25262A105 (1) | |
Text
September 23, 2025 Robert Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd.
Juno Beach, FL 33408
SUBJECT:
TURKEY POINT NUCLEAR GENERATING, UNIT NOS. 3 AND 4 REGULATORY AUDIT PLAN REGARDING LICENSE AMENDMENT TO IMPLEMENT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS (EPID L-2025-LLA-0101)
Dear Mr. Coffey:
By letter dated June 30, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25182A034), Florida Power & Light Company (FPL, the licensee) submitted a license amendment request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4 (Turkey Point). The proposed amendments would allow the licensee to implement Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, at Turkey Point.
The U.S. Nuclear Regulatory Commission (NRC) staff has found the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, verify information, and identify information that requires docketing to support the licensing decision. The detailed audit plan is enclosed with this letter.
The NRC staff will conduct the audit virtually. The NRC staff requests that the licensee establish a web-based electronic portal within 2 weeks of the date of this letter for the staff to review licensee documents. The audit plan provides more detail regarding the needs for the electronic portal and a list of staff that will require access. The NRC staff will schedule virtual audit meetings with the licensee, as needed, throughout the audit period. The NRC staff will begin the audit after the online portal is established, and the audit will continue through November 2025.
If you have any questions, please contact me at (301) 415-1380 or by email at Blake.Purnell@nrc.gov.
Sincerely, Blake Purnell, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Audit Plan cc: Listserv BLAKE PURNELL Digitally signed by BLAKE PURNELL Date: 2025.09.23 09:37:57 -04'00'
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE LICENSE AMENDMENT REQUEST TO IMPLEMENT 10 CFR 50.69 FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING, UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251
1.0 BACKGROUND
By letter dated June 30, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25182A034), Florida Power & Light Company (FPL, the licensee) submitted a license amendment request (LAR) for Turkey Point Nuclear Generating, Unit Nos. 3 and 4 (Turkey Point). The proposed amendments would allow the licensee to implement Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, at Turkey Point.
The U.S. Nuclear Regulatory Commission (NRC) staff has found the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, verify information, and identify information that requires docketing to support the licensing decision.
2.0 REGULATORY AUDIT BASIS The regulatory audit will be conducted in accordance with the Office of Nuclear Reactor Regulations (NRR) Office Instruction LIC-111, Regulatory Audits, Revision 2, dated December 2024 (ML24309A281), with exceptions noted within this audit plan. A regulatory audit is a process by which the NRC staff examines and evaluates non-docketed information provided by the licensees with the intent to gain understanding, verify information, and/or identify information that will require docketing to support the basis of a licensing or regulatory decision. This audit will assist the NRC staff in efficiently conducting its review of the LAR and gaining insight into the licensees processes and procedures. Specifically, the audit will assist the NRC staff with understanding the licensees proposed programs for categorizing structures systems and components (SSCs) based on their risk significance. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY By letter dated December 3, 2018 (ML18270A429), the NRC issued amendments to the Turkey Point technical specifications to allow the licensee to use risk-informed completion times (RICT) for certain remedial actions. As described in the safety evaluation for these amendments, the NRC staff evaluated the acceptability of the Turkey Point probabilistic risk assessment (PRA) models for internal events, internal flooding, and internal fire as they are used to support the RICT program. The NRC staff has adjusted its review scope to leverage this previous evaluation. 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 00-04, Revision 0, SSC Categorization Guideline (ML052910035), as endorsed by Regulatory Guide 1.201, Revision 1, Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to their Safety Significance (ML061090627).
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 PRA used for these applications.
Identify any information needed to enable the NRC 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).
The NRC staff will audit the PRA methods that the licensee would use to categorize SSCs based on their risk significance. This will include the licensees assessments of internal events (including internal flooding), fire, PRAs, as well 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 as described in the LAR.
The audit team will engage with the licensee to discuss these topics as needed.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff will request information and interviews throughout the audit period as needed.
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 2 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 1 week of the date of the NRC staffs request. 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 the NRC staff.
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR:
Blake Purnell, Plant Licensing Branch II-2; blake.purnell@nrc.gov Adrienne Brown, PRA Licensing Branch A (APLA); adrienne.driver@nrc.gov Drew Childs, APLA; arthur.childs@nrc.gov Daniel Silverstein, PRA Licensing Branch C (APLC); daniel.silverstein@nrc.gov Ellery Coffman, APLC; ellery.coffman@nrc.gov Steven Alferink, APLC; steven.alferink@nrc.gov The NRC staff may request access for additional staff as the audit progresses.
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 virtually by interviews with the licensees subject matter experts. This audit will begin when the licensees electronic portal is made available to the NRC staff, which should be within 2 weeks of the date of this audit plan, and last through November 2025.
The NRCs 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 any scheduled audit meeting.
7.0 SPECIAL REQUESTS The following conditions associated with the online web-based electronic portal should be maintained while the NRC staff on the audit team have access to the online portal:
The electronic portal will be password-protected, and separate passwords will be assigned to each member of the audit team.
The electronic portal will be sufficiently secure to prevent the NRC staff from printing, saving, downloading, or collecting any information from the portal.
Conditions on the use of the 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 on the audit team (listed above). The NRC project manager will provide the licensee with 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 NRCs 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, and issue such RAIs separately 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.
Attachment INITIAL AUDIT ITEMS LIST Item #
Audit Item 1
Reports of peer reviews (i.e., full-scope, focused-scope, and newly developed methods), self-assessments, and facts and observations (F&Os) closure reviews for the internal events, internal flooding, and fire PRAs cited in the LAR that have occurred since the issuance of the license amendments for the Turkey Point RICT program.
2 For the internal events, internal flooding, and fire PRAs, plant-specific documentation related to the identification and disposition of key assumptions and sources of uncertainty for the proposed 10 CFR 50.69 program.
3 All documents that support the closure of Implementation Items Nos. 1-6 in Section 4.0 of the safety evaluation for the Turkey Point RICT program.
4 Documentation supporting the screening decisions for the external flooding, hurricane, storm surge, and tsunami external hazards cited in attachment 4 of the LAR. For example, the external flooding assessment, storm surge evaluation, or any supporting calculations or references to support the screening criteria identified in attachment 4.
ML25262A105 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL3/LA NRR/DRA/APLA/BC NAME BPurnell ABaxter RPascarelli DATE 9/19/2025 09/23/2025 9/17/2025 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL2-2/PM NAME DWrona BPurnell DATE 9/23/2025 9/23/2025