ML21245A305

Aging Management Audit Plan Regarding the Subsequent License Renewal Application Review

ML21245A305
Person / Time
Site:	Saint Lucie
Issue date:	09/24/2021
From:	Lauren Gibson, Rodriguez H NRC/NRR/DNRL/NLRP
To:	Coffey R Florida Power & Light Co
Rodriguez H,
References
Download: ML21245A305 (9)

Text

September 24, 2021

Mr. Robert Coffey Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company 700 Universe Boulevard Mail Stop: EX/JB June Beach, FL 33408

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - AGING MANAGEMENT AUDI T PLAN REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Coffey:

By letter dated August 3, 2021 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML21215A314), the Florida Power & Light Company (FPL or the applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Units 1 and 2 (St. Lucie).

The NRC plans to conduct an A ging Management Audit from October 4-February 25, 2021, in accordance with the enclosed regulatory audit plan. The Aging Management Audit will be conducted at NRC Headquarters and St. Lucie site, as appropriat e. If you have any questions, please contact Lois James at 301-415-3306 or by e-mail at Lois.James@nrc.gov.

Sincerely,

/RA/

Lauren K. Gibson, Chief License Renewal Projects Branch Division of New and Renewed Licenses OfficeofNuc lear Reactor Regulation

Docket Nos. 50-335 and 50-389

Enclosure:

Aging Management Audit Plan

ML21245A305 *via e-concurrence NRR-106 OFFICE PM/NLRP/DNRL LA/NLRP/DNRL PM/NLRP/DNRL BC/NLRP/DNRL NAME HRodriguez SGreen LJames LGibson DATE 9/3/2021 9/3/2021 9/8/2021 9/24/21 Audit Plan St. Lucie Plant, Units 1 and 2 Subsequent License Renewal Application Aging Management Regulatory Audit October 4, 2021 - February 25, 2021

Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

Enclosure Audit Plan St. Lucie Plant, Units 1 and 2 Subsequent License Renewal Application Aging Management Regulatory Audit

1. Background

By letter dated August 3, 2021 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML21215A314), the Florida Power & Light Company (FPL or the applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Units 1 and 2 (St. Lucie). The staff is reviewing this application in accordance with the guidance in NUREG-2192, Standard Review Pl an for Review of Subsequent License Renewal Applications for Nuclear Power Plant s, (SRP-SLR).

In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Part 54, Requirements for Renewal of Operating Licenses for Nu clear Power Plants, NRC staff will perform an aging management regulatory audit to gain a better understanding of (1) the applicants methodology to identify the systems, struct ures, and components (SSCs) to be included within the scope of subsequent license renewal a nd subject to an aging management review (AMR), and (2) the applicants aging manageme nt programs (AMPs),

AMR items, time-limited aging analyses (TLAAs), and associated bases and documentation as applicable.

2. Regulatory Audit Bases

License renewal requirements are specified in 10 CFR Part 54. Guidance is provided in the SRP-SLR and NUREG-2191, Revision 0, Generic Aging Lessons Lear ned for Subsequent License Renewal (GALL-SLR) Report, dated July 2017.

3. Regulatory Audit Scope of Review

Scoping and Screening Review

The purpose of the scoping and screening review is to evaluate the applicants scoping and screening methodology used to identify SSCs within the scope of subsequent license renewal and subject to AMR, as well as the results of the implementatio n of the methodology. The review is performed by evaluating the scoping and screening pro cess and results, as documented in the subsequent license renewal application (SLRA), implementing procedures, reports, and drawings, such that the NRC staff:

• Obtains an understanding of the process used to identify the SS Cs within the scope of license renewal and to identify the structures and component s subject to an AMR; and

• Has sufficient docketed information to allow the NRC staff to r each a conclusion on the adequacy of the scoping and screening methodology and resul ts, as documented in the SLRA.

AMP, AMR, and TLAA Review

The scope of the AMP, AMR, and TLAA review is to: (a) examine the applicants AMPs, AMR items, and TLAAs; (b) verify the applicants claims of consiste ncy with the corresponding GALL-SLR Report AMPs, and AMR items; and (c) assess the adequac y of the TLAAs.

Enhancements and exceptions will be evaluated on a case-by-case basis with the results documented in the safety evaluation.

The NRC staff will audit Program Elements 1 - 10 (scope, preven tive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrat ive controls, and operating experience (OE)) of the AMPs against the elements of the associ ated AMP described in the GALL-SLR Report. In addition, the NRC staff will verify that t he conditions at the plant are bounded by the conditions for which the GALL-SLR Report program was evaluated.

The NRC staff will also examine the applicants program bases d ocuments and related references for AMPs, AMR items, and TLAAs, and interview applic ant representatives to obtain additional clarification.

The NRC staff will use risk insights to inform the prioritizati on of its review of documentation associated with AMPs, AMR items, and TLAAs and to focus the bre adth and depth of its review of plant specific operating procedures and OE. However, the NRC staffs review is not limited to risk-significant systems and components because 10 C FR Part 54 is a deterministic rule and the NRC staff must conclude that there is reasonable a ssurance that activities will continue to be conducted in accordance with the current licensi ng basis and the effects of aging will be managed during the subsequent period of extended operation for all structures and components within the scope of 10 CFR Part 54.

The NRC staff has reviewed the list of risk-significant systems and components provided by the applicant to inform the establishment of priorities for the performance of the scoping and screening review.

4. Audit Activities

The Aging Management Audit will consist of three parts, to be s cheduled and coordinated between the staff and the applicant. The three Aging Managemen t Audit parts include:

• Part 1 - In-Office Technical Review Audit

During the In-Office Technical Review Audit, technical staff wi ll review the SLRA, as supplemented and revised, the AMP basis documents and other FPL supporting documents, as appropriate and requested, on the applicants ele ctronic portal (ePortal).

The project team would like continued FPL document review capab ility via the ePortal.

Document requests for upload to the ePortal shall be made as ne eded via the NRC safety project manager to the appropriate applicant licensing m anager.

Regarding OE portion of the audit, the staff will review:

(1) Applicants Process to Identify OE Used in Development of A MPs. The staff requests that the applicant provides a presentation on the proc ess used to

identify and evaluate the pertinent OE that was used to inform the development of the AMPs as discussed in the SLRA and basis documentation.

(2) Use of OE Contained in AMP Report-Out Documents. The staff requests that the applicant discuss how the OE contained in the AMP report-ou t documents (e.g., reports of inspections, assessments, AMP effectiveness r eviews) is in alignment with information contained in the corrective action p rogram (CAP) database and how the process described in (1) along with the us e of the report-out information would include any pertinent OE otherwise contai ned in the CAP database. The applicant should demonstrate that OE identified by the process or included in the report-out documents is bounding of OE that sho uld be considered for developing the SLRA. Additionally, the applican t should provide examples of the report-out documents and corresponding correcti ve action reports.

(3) Staffs Review of Age-Related OE Contained in the CAP Datab ase.

Following the applicants presentations on the process to ident ify and evaluate OE as well as the information included in the report-out docume nts, the staff should determine if there are any specific areas of OE that hav e not been sufficiently addressed or if there is a need to sample the info rmation discussed by the applicant to verify the applicants results. If the sta ff identifies such a need, the staff will have an opportunity to perform an independ ent review of age-related OE contained in the CAP database, as necessary, to prov ide reasonable assurance that the applicant has adequately identified and eval uated pertinent OE in the development of the SLRA in Part 2 of the Aging Manage ment Audit.

At the conclusion of the In-Office Technical Review Audit, the staff will identify any areas requiring inclusion in the On-Site Audit, Part 2 of the Aging M anagement Audit. The identified areas may include OE that should be further consider ed and the need for observation of areas, equipment conditions, or configurations.

• Part 2 - On-Site Audit

The purpose of the On-Site Audit is to make visual observations of areas, equipment conditions, and configurations, and conduct and OE review, as n eeded. Due to ongoing health guidelines related to travel and gatherings, the St. Luc ie On-Site Audit may be conducted using telecommunications when appropriate.

The On-Site Audit is performed, in part, by an integrated revie w team, which will include an OE review as well as observations of areas, equipment condit ions, and configurations, as needed.

On an as needed basis, the staff should perform an independent review of age-related OE contained in the CAP database to provide reasonable assuranc e that the applicant has adequately identified and evaluated pertinent OE in the dev elopment of the SLRA.

• Part 3 - In-Office Breakout Sessions

During the In-Office Breakout Sessions, the NRC staff will have the opportunity to discuss various basis documents, references, condition/correcti ve action reports, and to obtain additional clarification related to the SLRA safety revi ew with applicant.

The NRC staff would like to hold breakout sessions, via electro nic means, of communication with FPL and St. Lucie subject matter experts to discuss various basis documents, references, condition/corrective action reports, and interview FPL representatives to obtain additional clarification related to t he license renewal review.

Breakout sessions for various technical review areas will occur at predesignated time slots during the audit, with preassigned NRC and FPL representa tives. NRC staff will provide discussion topics and technical requests and questions to the NRC safety project manager, who will then relay the information to the FPL licensing manager. Any information requests transmitted to the applicant will be inclu ded in the audit report. All breakout sessions will be coordinated via the NRC safety projec t manager and the FPL licensing manager.

5. Information and Other Material Necessary for the Regulatory Aud it

Throughout the Aging Management Audit, the staff will review th e SLRA, as supplemented and revised, the AMP basis documents and other app licant supporting documents as appropriate and requested, which have been uploade d to the ePortal.

The staff may request additional applicant documents to be adde d to the ePortal during the course of the audit. The staff requests for ePortal additions shall be made, as needed, to the safety project manager, who will provide the requests to the ap plicant.

All documents used as the basis for the staffs review will be documented in the audit report.

6. Team Members

Team Member Branch/Division Hector Rodriguez-Luccioni License Renewal Projects Branch/Division of New and Renewed Licenses (DNRL)

Naeem Iqbal PRA Licensing B (APLB)/Division of Risk Assessment (DRA)

Thinh Dinh APLB/DRA Duc Nguyen Long Term Operations and Modernization Branch (ELTB)/Division of Engineering and External Hazards (DEX)

Matthew McConnell ELTB/DEX Jorge Cintron ELTB/DEX Gucharan Matharu ELTB/DEX Liliana Ramadan ELTB/DEX Hari Kodali Electrical Engineering Branch (EEEB)/DEX Adakou Foli EEEB/DEX Andrew Prinaris Structural, Civil, Geotech Engineering (ESEB)/DEX Bryce Lehman ESEB/DEX George Thomas ESEB/DEX George Wang ESEB/DEX Ata Istar ESEB/DEX Zuhan Xi ESEB/DEX Juan Lopez ESEB/DEX Andrew Johnson Corrosion and Steam Generator (NCSG)/DNRL

Brian Allik NCSG/DNRL Greg Makar NCSG/DNRL Jim Gavula NCSG/DNRL Leslie Terry NCSG/DNRL Lydiana Alvarado NCSG/DNRL Matt Yoder NCSG/DNRL Paul Klein NCSG/DNRL Tony Gardner NCSG/DNRL Andrew Johnson NCSG/DNRL David Pratt NCSG/DNRL Ali Rezai Piping and Head Penetrations (NPHP)/DNRL Bart Fu NPHP/DNRL Eric Reichelt NPHP/DNRL Jay Collins NPHP/DNRL Var Kalikian NPHP/DNRL Seung Min NPHP/DNRL Carolyn Fairbanks Vessels and Internals (NVIB)/DNRL Isaac Anchondo NVIB/DNRL David Dijamco NVIB/DNRL Jim Medoff NVIB/DNRL John Tsao NVIB/DNRL Karen Sida NVIB/DNRL On Yee NVIB/DNRL David Nold Containment and Plant Systems (SCPB)/Division of Safety Systems (DSS)

Danny Chien SPCB/DSS Derek Scully SCPB/DSS Raul Hernandez SCPB/DSS Steve Jones SCPB/DSS Diana Woodyatt Nuclear Systems Performance (SNSB)/DSS Jeremy Dean Nuclear Methods and Fuels (SFNB)/DSS Kent Wood SFNB/DSS

7. Logistics

The Aging Management Audit will be conducted primarily using te lecommunications from October 4, 2021 to February 25, 2021, with potentially a portio n of the On-Site Audit (Aging Management Audit Part 2), as determined appropriate, conducted at the applicants facility.

Entrance and exit briefings will be held at the beginning and e nd of the audit via telecommunications.

8. Special Requests

The NRC staff requests the applicant to make available the lice nse renewal application program basis documentation and drawings, and other documents a s requested.

9. Deliverables

An audit report should be issued to the applicant within 90 day s from the end of the Aging Management Audit.