ML26043A420

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Request for Additional Information Regarding License Amendment Request to Implement 10 CFR 50.69
ML26043A420
Person / Time
Site: Turkey Point  
Issue date: 02/12/2026
From: Blake Purnell
Plant Licensing Branch II
To: Valdez M
Florida Power & Light Co
Buckberg, P. NRR/DORL 415-1383
References
EPID L-2025-LLA-0101
Download: ML26043A420 (0)


Text

From:

Blake Purnell To:

Valdez, Maribel Cc:

Phillabaum, Jerry; Mack, Jarrett; Mack, Kenneth; David Wrona

Subject:

Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information Regarding License Amendment Request to Implement 10 CFR 50.69 Date:

Thursday, February 12, 2026 9:03:00 AM Attachments:

RAI - TP 50.69 LAR.pdf Ms. Valdez,

By application dated June 30, 2025 (ML25182A034), Florida Power & Light Company (FPL) submitted a license amendment request (LAR) for Turkey Point Nuclear Generating Unit Nos. 3 and4 (Turkey Point). The proposed amendments would allow the licensee to implement Title 10of the Code of Federal Regulations (10CFR) 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 is reviewing the LAR and has determined that the additional information is needed for the staff to complete its review. A response to the attached request for additional information (RAI) is requested to be provided no later than March13, 2026. This RAI is based on a question the NRC staff asked during the ongoing virtual audit. A draft of this RAI was provided to FPL on January29, 2026. On February6, 2026, the NRC staff and FPL representatives discussed the draft RAI and FPLs draft response. Please contact me if you have any questions.

Sincerely,

Blake Purnell, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ph: 301-415-1380

Docket Nos. 50-250 and 50-251 EPID L-2025-LLA-0101

OFFICE NRR/DORL/LPL2-2/PM NRR/DRA/APLC/BC NRR/DORL/LPL2-2/BC NAME BPurnell BPascarelli DWrona DATE 2/12/26 1/29/26 1/29/26

REQUEST FOR ADDITIONAL INFORMATION PROPOSED AMENDMENT 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 By application dated June 30, 2025 (ML25182A034), Florida Power & Light Company (FPL) 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 [SSCs] for nuclear power reactors, at Turkey Point.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the LAR and has determined that the additional information below is needed for the staff to complete its review.

Regulatory Basis Regulatory Guide (RG) 1.201, Revision 1, Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to their Safety Significance, dated May 2006 (ML061090627), endorses the Nuclear Energy Institute (NEI) guidance document NEI 00- 04, Revision 0, 10 CFR 50.69 SSC Categorization Guideline, dated July 2005 (ML052910035), subject to specific NRC regulatory positions and clarifications, as one acceptable method for use in complying with the requirements in 10 CFR 50.69. Section 5.4, Assessment of Other External Hazards, of NEI 00-04 provides guidance on the assessment of other external hazards (excluding fire and seismic) in the 10 CFR 50.69 categorization of SSCs.

RG 1.200, Revision 2, "An Approach for Determining Technical Adequacy of Probabilistic Risk Assessment [PRA] Results for Risk-Informed Activities," dated March 2009 (ML090410014) endorses, with staff clarifications and qualifications, the American Society for Mechanical Engineers (ASME) and American Nuclear Society (ANS) joint standard RA-Sa-2009, Addenda to ASME/ANS RA-S-2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications (ASME/ANS PRA Standard).

Section 8-2, Technical Requirements for External Flood Events PRA At-Power, of the ASME/ANS PRA Standard indicates that certain flooding phenomena can be screened out using the screening methods in Part 6, Requirements for Screening and Conservative Analysis of Other External Hazards At-Power, of the standard. Part 6 provides criteria for screening along with associated supporting requirements and peer-review.

Request for Additional Information In the enclosure of the LAR, the licensee states that all non-seismic external hazards are screened for applicability to Turkey Point using a plant-specific evaluation in accordance with Generic Letter 88-20, Supplement 4, Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities - 10 CFR 50.54(f), dated June 28, 1991 (ML031150485),

and updated to use the criteria in the ASME PRA Standard. Attachment 4, "External Hazards Screening," of the LAR enclosure identifies that screening Criterion C1 was used for external flooding. Attachment 5, "Progressive Screening Approach for Addressing External Hazards," of the LAR enclosure describes Criterion C1 as event damage potential is less than events for which plant is designed, which is essentially the same criterion as supporting requirement EXT-B1, Criterion 1, from the ASME PRA standard. In the comments for the external flooding hazard (Attachment 4), the licensee states, in part, that (1) the external flooding hazard was evaluated as bounded by the storm surge hazard and (2) the frequency of such an event is estimated to be 10-6 to 10-4 per year. These statements align more closely with Criteria C2 and C4 (Attachment 5).

In addition, Attachment 4 of the LAR enclosure identifies that the hurricane and tsunami external hazards are bounded by the storm surge external hazard, which was screened using Criterion PS4. Criterion PS4 is the bounding mean core damage frequency (CDF) is less than 10-6 per year, which is essentially the same criterion as supporting requirement EXT-C1, Criterion C, from the ASME PRA Standard. In the comments for the storm surge hazard (Attachment 4), the licensee states that a storm surge was estimated to have an upper bound recurrence frequency of 10-4 per year with a lower bound on the estimate of 10-6 per year. As part of the NRC staff audit for this LAR (ML25262A105), the staff reviewed the licensees document PTN-BFJR-17-051, PTN Other External Events Screening, which describes the basis for the quantitative screening of the storm surge hazard. However, this document does not explain how the storm surge recurrence frequencies resulted in a CDF less than the quantitative screening threshold or a bounding mean CDF less than 1E-6 per year.

Provide justification for the use of Criterion C1 for the external flooding hazard (e.g., a comparison of the design basis external flood to the height of the plant floodwall) or identify, with appropriate justification, an alternative criterion for screening the external flooding hazard.

Additionally, demonstrate that the upper and lower bound recurrence frequencies for the storm surge hazard result in a bounding mean CDF less than 10-6 per year such that the storm surge hazard can be screened from the 10 CFR 50.69 evaluations. The response may include any plant-specific data, modeling assumptions, recurrence frequency estimates, storm surge evaluations, or other information.