ML18199A603

Audit Summary for Duane Arnold and Point Beach, License Amendment Requests to Adopt Title 10 of the Code of Federal Regulations Part 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power

ML18199A603
Person / Time
Site:	Point Beach, Duane Arnold
Issue date:	07/26/2018
From:	Mahesh Chawla Plant Licensing Branch III
To:	Nazar M Nextera Energy
Chawla M
References
CAC MG0196, CAC MG0197, CAC MG0199, EPID L-2017-LLA-0283, EPID L-2017-LLA-0284
Download: ML18199A603 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 26, 2018 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy Point Beach, LLC NextEra Energy DuaneArnold, LLC Mail Stop: NT3/JW 15430 Endeavor Drive Jupiter, FL 33478

SUBJECT:

AUDIT

SUMMARY

FOR DUANE ARNOLD ENERGY CENTER AND POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE AMENDMENT REQUESTS TO ADOPT TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 50, SECTION 50.69, "RISK- INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS FOR NUCLEAR POWER PLANTS" (CAC NOS. MG0199, MG0196, AND MG0197; EPID L-2017-LLA-0283 AND L-2017-LLA-0284)

Dear Mr. Nazar:

A U.S. Nuclear Regulatory Commission (NRC) audit team, consisting of the NRC staff and contractors from the Pacific Northwest National Laboratories, conducted a regulatory audit based on licensing amendment requests (LARs) for NextEra Energy's Duane Arnold Energy Center (DAEC) and NextEra Energy's Point Beach Nuclear Plant (PBNP), Units 1 and 2, to adopt Title 10 of Code of Federal Regulations (10 CFR 50.69), "Risk-Informed Categorization And Treatment Of Structures, Systems, And Components (SSCs) for Nuclear Power Plants."

The audit was based on NRC's review of DAEC LAR dated August 31, 2017, available in Agencywide Documents Access and Management System (ADAMS) Accession No. ML17243A469, and PNPB LAR dated August 31, 2017, ADAMS Accession No. ML17243A201, and PNPB supplement dated October 26, 2017, ADAMS Accession No. ML17299A012. The audit took place on April 24 -26, 2018, at the NextEra Energy Offices 700 Universe Blvd, Juno Beach, FL.

The audit summary report is provided as an enclosure to this letter.

M. Nazar If you have any questions, please contact me at (301) 415-8371 or Mahesh.Chawla@nrc.gov.

Sincerely, Mahesh Chawla, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-331, 50-266, and 50-301

Enclosure:

Audit Summary cc: ListServ

AUDIT

SUMMARY

REPORT FOR DUANE ARNOLD ENERGY CENTER AND POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE AMENDMENT REQUEST TO ADOPT TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 50, SECTION 50.69, "RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS FOR NUCLEAR POWER PLANTS" DOCKET NOS. 50-331, 50-266 AND 50-301 EPID L-2017-LLA-0283 AND L-2017-LLA-0284 INTRODUCTION By letters dated August 31, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17243A469) for Duane Arnold Energy Center (DAEC) and (ADAMS Accession No. ML17243A201) for Point Beach Nuclear Power Plant (PBNP), NextEra Energy submitted license amendment requests (LARs) to adopt Title 10 of Code of Federal Regulations (10 CFR) Section 50.69, "Risk-Informed Categorization And Treatment Of Structures, Systems, And Components (SSCs) for Nuclear Power Plants." PNPB provided supplemental information in a letter dated October 26, 2017 (ADAMS Accession No. ML17299A012).

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensee's submittal and determined that a regulatory audit would assist in the timely completion of the subject LAR review process. The NRC staff developed a draft request for additional information (RAI) needed to conduct the audit and the questions were transmitted to the licensee on April 18, 2018, via email (ADAMS Accession No. ML18108A310), to discuss the requested technical information.

The audit was conducted April 24 through 26, 2018, at the NextEra Energy Offices located at 700 Universe Blvd, Juno Beach, FL. The audit was performed consistent with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). The audit supported the staffs review of the licensee's submittal.

Enclosure

AUDIT ACTIVITIES AND OBSERVATIONS The audit was to review the current program for compliance with the Commission's requirements in 10 CFR, Section 50.69, focusing on the categorization of SSCs associated with risk-informing special treatment 1 requirements with a specific concentration on the Facts and Observations report and probabilistic risk assessment (PRA) acceptability. The main purpose of the audit was to gain an understanding of the information needed to support the staff's licensing decision and to finalize requests for additional information (RAls) as needed using the process in accordance with NRR Office Instruction LIC-101, "License Amendment Review Procedures."

The audit team consisted of NRC Headquarters staff, Region Ill, and contractor support from Pacific Northwest National Laboratories (PNNL). During the audit, team members participated in technical discussions according to the audit plan provided to the licensee.

Technical discussions focused on the following major review areas: (1) technical adequacy of the internal events and fire PRA, (2) categorization process overview, and (3) review of the audit questions with the licensee. In addition to reviewing the RAls, NRC staff discussed non-PRA methods used for evaluating the risk from external hazards.

During the audit, the NRC staff discussed several questions associated with the LAR and identified new information needed for staff to reach a licensing decision.

CONCLUSION At the conclusion of the audit, the team participated in a summary exit meeting with the NextEra on April 26, 2018. The NRC staff provided a brief discussion of the audit objectives that were met and details on the path forward and there were no open items and no deviation from the audit plan.

During the audit, the NRC staff did not make any regulatory decisions regarding the proposed LAR. The staff noted that upon completion of the audit, the draft RAls would be revised, as necessary, and issued as final. The licensee would be expected to provide the needed information on the docket.

,Special treatment (in the rule) refers to those regulatory requirements that provide increased assurance. beyond normal industry practices. that SSCs perform their design basis functions. and consists of the following requirements: (i) 10 CFR part 21 regarding immediate reporting requirement of noncompliance and defects representing "substantial safety hazard"; (ii) a portion of 10CFR 50.46a(b) regarding the design of vents and associated controls, instruments, and power sources and the need for these components to conform to 10 CFR 50 Appendix B; (iii) 10 CFR 50.49 regarding environmental qualification requirements; (iv) 10 CFR 50.55(e) regarding reporting requirement of design or manufacturing defects representing "substantial safety hazard"; (v) certain requirements of 10 CFR 50.55a regarding in-service inspection. and repair and replacement requirements; (vi) 10CFR 50.65 for maintenance rule, except for paragraph(a)(4); (vii) 10 CFR 50. 72 regarding immediate notification of report events involving certain SSCs; (viii) 10 CFR 50.73 regarding licensee event reporting system to report events involving certain SSCs.; (ix) Appendix B to 10 CFR part 50 regarding the quality assurance program; (x) certain containment leakage testing requirements; and (xi) certain requirements of Appendix A to 10 CFR part 100 regarding seismic qualification.

LIST OF PARTICIPANTS NRC Audit Team

• Stacey Rosenberg NRC Branch Chief

• Leslie Fields NRC Audit Team Leader

• Mihaela Biro NRC Audit Technical Lead

• Stephen Dinsmore NRC PRA

• Todd Hilsmeier NRC PRA

• Mahesh Chawla NRC DORL PNNL Audit Team

• Garill Coles, PNNL PRA Bernard Grenier, NRC, ORA (Observer)

John Hanna, Region Ill (Attendance)

NextEra Energy Team

• Gary Kilby, Licensing

• Ted Kulczycky, PRA

• Loren Keistand, PRA

• Keith Vincent, PRA

• Anil Julka, PRA DOCUMENTS REVIEWED DURING THE AUDIT The licensee provided an extensive list of supporting documents (e.g., analyses, calculations, reports, drawings, and procedures) on the DAEC and PNPB document portals which were made available during the audit week.

The following documents were reviewed during the audit:

• PBN-BFJR-17-041, Revision 0, NextEra Fleet Probabilistic Risk Assessment Group, Independent Review of PBN Internal Events and Internal Flood PRA Peer Review Findings Resolutions Point Beach Units 1 and 2, August 2017.

• NEECORP000012-REPT-002, Revision 0, Enercon, Point Beach Units 1 and 2 Fire Probabilistic Risk Assessment Peer Review Findings Closure, September 5, 2017.

• NEECORP000012-REPT-001, Enercon, Duane Arnold Internal Events and Fire Probabilistic Risk Assessment Peer Review Findings Closure, August 31, 2017.

ML18199A603 *via memorandum OFFICE NRR/DORULPL3/PM NRR/DORULPL3/LA NRR/DRA/APLA/BC* NRR/DORULPL3/BC NAME MChawla SRohrer SRosenberg JDWrona DATE 07/23/18 07/19/18 07/10/18 07/26/18