ML21245A305
| 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 AUDIT 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 Aging 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 appropriate. 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 Office of Nuclear 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 Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, (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 Nuclear 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, structures, and components (SSCs) to be included within the scope of subsequent license renewal and subject to an aging management review (AMR), and (2) the applicants aging management 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 Learned 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 implementation of the methodology. The review is performed by evaluating the scoping and screening process 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 SSCs within the scope of license renewal and to identify the structures and components subject to an AMR; and
- Has sufficient docketed information to allow the NRC staff to reach a conclusion on the adequacy of the scoping and screening methodology and results, 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 consistency with the corresponding GALL-SLR Report AMPs, and AMR items; and (c) assess the adequacy 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, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience (OE)) of the AMPs against the elements of the associated AMP described in the GALL-SLR Report. In addition, the NRC staff will verify that the 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 documents and related references for AMPs, AMR items, and TLAAs, and interview applicant representatives to obtain additional clarification.
The NRC staff will use risk insights to inform the prioritization of its review of documentation associated with AMPs, AMR items, and TLAAs and to focus the breadth 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 CFR Part 54 is a deterministic rule and the NRC staff must conclude that there is reasonable assurance that activities will continue to be conducted in accordance with the current licensing 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 scheduled and coordinated between the staff and the applicant. The three Aging Management Audit parts include:
- Part 1 - In-Office Technical Review Audit During the In-Office Technical Review Audit, technical staff will review the SLRA, as supplemented and revised, the AMP basis documents and other FPL supporting documents, as appropriate and requested, on the applicants electronic portal (ePortal).
The project team would like continued FPL document review capability via the ePortal.
Document requests for upload to the ePortal shall be made as needed via the NRC safety project manager to the appropriate applicant licensing manager.
Regarding OE portion of the audit, the staff will review:
(1) Applicants Process to Identify OE Used in Development of AMPs. The staff requests that the applicant provides a presentation on the process 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-out documents (e.g., reports of inspections, assessments, AMP effectiveness reviews) is in alignment with information contained in the corrective action program (CAP) database and how the process described in (1) along with the use of the report-out information would include any pertinent OE otherwise contained 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 should be considered for developing the SLRA. Additionally, the applicant should provide examples of the report-out documents and corresponding corrective action reports.
(3) Staffs Review of Age-Related OE Contained in the CAP Database.
Following the applicants presentations on the process to identify and evaluate OE as well as the information included in the report-out documents, the staff should determine if there are any specific areas of OE that have not been sufficiently addressed or if there is a need to sample the information discussed by the applicant to verify the applicants results. If the staff identifies such a need, the staff will have an opportunity to perform an independent review of age-related OE contained in the CAP database, as necessary, to provide reasonable assurance that the applicant has adequately identified and evaluated pertinent OE in the development of the SLRA in Part 2 of the Aging Management 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 Management Audit. The identified areas may include OE that should be further considered 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 needed. Due to ongoing health guidelines related to travel and gatherings, the St. Lucie On-Site Audit may be conducted using telecommunications when appropriate.
The On-Site Audit is performed, in part, by an integrated review team, which will include an OE review as well as observations of areas, equipment conditions, 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 assurance that the applicant has adequately identified and evaluated pertinent OE in the development 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/corrective action reports, and to obtain additional clarification related to the SLRA safety review with applicant.
The NRC staff would like to hold breakout sessions, via electronic 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 the license renewal review.
Breakout sessions for various technical review areas will occur at predesignated time slots during the audit, with preassigned NRC and FPL representatives. 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 included in the audit report. All breakout sessions will be coordinated via the NRC safety project manager and the FPL licensing manager.
- 5. Information and Other Material Necessary for the Regulatory Audit Throughout the Aging Management Audit, the staff will review the SLRA, as supplemented and revised, the AMP basis documents and other applicant supporting documents as appropriate and requested, which have been uploaded to the ePortal.
The staff may request additional applicant documents to be added 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 applicant.
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 telecommunications from October 4, 2021 to February 25, 2021, with potentially a portion 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 end of the audit via telecommunications.
- 8. Special Requests The NRC staff requests the applicant to make available the license renewal application program basis documentation and drawings, and other documents as requested.
- 9. Deliverables An audit report should be issued to the applicant within 90 days from the end of the Aging Management Audit.