L-2017-165, Report of 10 CFR 50.59 Plant Changes
| ML17265A053 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/20/2017 |
| From: | Synder M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2017-165 | |
| Download: ML17265A053 (13) | |
Text
September 20, 2017 L-2017-165 10 CFR 50.59(d)
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 2 Docket No. 50-389 Report of 1o CFR 50.59 Plan,t Changes Pursuant to 10 CFR 50.59(d)(2), the attached report contains a brief description of any changes, tests and experiments, including a summary of the evaluation of ~ach, which were made on Unit 2 during the period of Amendment No. 24 (October 26, 2015 through March 22, 2017) dated September 2017. This submittal correlates with the information included in Amendment 24 of the Updated Final Safety Analysis Report submitted under a separate cover letter.
Should you have arw questions regarding this submittal, please contact Mr. Michael J.
Snyder, Licensing Manager, at 772-467-7036.
Sincerely, ,
\-Jl ~o.rJ:- 1,) I~ ~ oIt---
Michael J. Snyder Licensing Manager St. Lucie Plant MJS/rcs Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Plant USNRC Senior Resident Inspector, St. Lucie Plant Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 2of13 Enclosure ST. LUCIE UNIT 2 DOCKET NUMBER 50-389 CHANGES, TESTS AND EXPERIMENTS MADE AS ALLOWED BY 10 CFR 50.59
-FOR THE PERIOU OF OCTOBER 26, 2015 THROUGH MARCH 22, 2017 (13 PAGES INCLUDING COVER)
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 3of13 Enclosure INTRODUCTION This report is submitted in accordance with 10 CFR 50.59 (d)(2), which requires that:
i) changes in the facility as described in the SAR; ii) changes in procedures as described in the SAR; and iii) tests and experiments not described in the SAR that are conducted without prior Commission approval be reported to the Commission in accordance with 10 CFR 50.90 and 50.4. This report-is intended to meet these requirements for Amendment 24 addressing the period of October 26, 2015 through March, 2017.
This report is typically divided into three (3) sections:
First, changes to the facility as described in the Updated Final Safety Analysis Report (UFSAR) performed by a Permanent Modification are addressed.
Second, changes to the facility I procedures as described in the UFSAR, or tests/experiments not described in the UFSAR, which are not performed by a Permanent Modification, are addressed.
Third, a summary of any Fuel Reload 10 CF~ 50.59 evaluation is addressed.
Sections 1, 2 and 3 summarize specific 10 CFR 50.59 evaluations that evaluated the specific change(s). Each of these 10 CFR 50.59 evaluations concluded that the change does not require a change to the plant technical specifications, and prior NRC approval is not required.
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 4of13 Enclosure TABLE OF CONTENTS PAGE SECTION 1 PERMANENT MODIFICATIONS 5 EC 278372, R1 UNIT 2 FUEL HANDLING BUILDING VENT 6 STACK RADIATION MONITOR REPLACEMENT EC 283094, R1 UNIT 2 UFSAR UPDATE FOR STEAM 8 GENERATOR STRUCTURAL CODES EC 286271, RO REVISE RCP FLYWHEEL_ MATERIAL 9 EC 288609, R2 CONNECTION OF TEMPORARY AIR 10 COMPRESSORS TO SUPPORT UNIT 2 INSTRUMENT AIR COMPRESSOR REPLACEMENT SECTION 2 10 CFR 50.59 EVALUATIONS 12 NONE 12 SECTION 3 FUEL RELOAD EVALUATIONS 13 EC 287528, R2 ST. LUCIE UNIT 2 CYCLE 23 RELOAD 13
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 5of13 Enclosure SECTION 1 PLANT CHANGE I MODIFICATJONS
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 6of13 Enclosure EC 278372, REVISION 1 UNIT 2 FUEL HANDLING BUILDING VENT STACKRADIATION MONITOR REPLACEMENT
SUMMARY
The Unit 2 Fuel Handling Building (FHB) Vent Radiation Monitor, RM-26-12, was replaced with a new monitor due to obsolescence and continuing maintenance issues. The replacement monitor was installed in the same room as the existing monitor: inside the FHB stack radiation monitoring room (FHB-j:)enthouse) on the FHB roof at elevation 62'.
The replacement monitor radiation measurement and detection capabilities are functionally identical to the existing monitor. The only aspect of this modification that "screened in" was the replacement-of the-fan/louver room cooling with a wall mounted A/C unit and the closing of the outside air openings. All other aspects of EC 278372 screened out.
With the existing fan/louver room cooling system, even if ihe fan fails there would still be some air flow and cooling. Closing off the outside air openings creates a configuration such that all room cooling could be lost if the A/C unit fails. Loss of the A/C unit, in turn, could allow the room temperature to exceed 120°F, which is the vendor's stated upper limit for the process and environmental temperature range.
It was conservatively assumed that operation above 120°F would eventually degrade the monitor and could cause a monitor failure.
In order to ensure that a failure of the A!C-unit does not go undetected for more than one shift, the Unit 2 field tours procedure has been updated to require a check of the temperature twice per day as part of their rounds, and EC 278372 installs a new thermometer specifically for this purpose. If the operator identifies that the room temperature is in excess of 110°F, the operator will notify maintenance tl'lat the A/C unit requires repair or replacement. In the interim between when the high temperature in the room is identified and the A/C unit is repaired or replaced, the door to the room may be opened to reduce the room temperature.
RM-26-12 is not required for compliance with the Technical Specifications. The monitor is not credited for any mitigating actions for the consequences of a Fuel Handling Accident (FHA).
RM-26-12 is required by the ODCM to be operable at all times when releases are being made through the Fuel Handling Building Vent. However, this is not a function important to safety.
St. Lacie Unit 2 L-2017-165 Docket No. 50-389 Page 7of13 Enclosure Since neither the loss of the A/C nor possible ensuing loss of monitor RM-26-12 OPERABILITY affects accident or malfunctions previously evaluated in the UFSAR, creates a new type of event not previously evaluated in the UFSAR, increases impact on fission product barriers or impacts a method of evaluation described in the UFSAR, it was concluded that a license amendment is not required.
Because the proposed change does not require a change to the technical specifications and does not meet any of the criteria in 10 CFR 50.59(c)(2), the change can be made without obtaining a license amendment pursuant to 10 CFR 50.90.
St. Lucie Unit 2 L-2017-165 Docket No. -so-389 Page 8of13 Enclosure EC 283094, REVISION 1 UNIT 2 UFSAR UPDATE FOR STEAM GENERATOR STRUCTURAL CODES
SUMMARY
EC 283094 is an addendum tO the permanent modification that replaced Unit 2 original steam generators (OSG) with replacement steam generator (RSG). The Unit 2 UFSAR was changed to add footnotes that delineate how specific computer codes apply to the OSGs, not the RSGs. The footnote also incorporates (by reference) the revised 10 CFR 50.59 evaluation containing the RSG computer codes into the UFSAR.
The 10 CFR 50.59 evaluation for the St. Lucie Unit 2 RSGs which is documented in Section 2.8.8 of the RSG Licensing Report (AREVA document 77-5069878-004),
was revised to identify/address the "metnods of evaluation!' (per 10 CFR o0.59(c)(2)(viii)) of the software codes used for safety, structural and thermal-hydraulic analysis described in the UFSAR that are applicable to the RSGs. The corresponding AREVA methods and software codes used for the RSGs are identified. All items fell into one of two categories:
- 1) The AREVA code I methodology has been previously approved by the NRC for its stated application, or
- 2) The UFSAR does not describe the methodology used to evaluate the original steam generators (OSGs), and therefore the AREVA methodology is not subject to evaluation under 10 CFR 50.59(c)(2)(viii).
Therefore it is concluded that use of the AREVA codes and methods does not result in a departure from a method of evaluation described in the UFSA~ used in establishing the design bases or in the safety analyses.
Because the proposed change does not require a change to the technical specifications and does not meet any oHhe criteria in-10 CFR 50.59(c)(2), the change can be made without obtaining a license amendment pursuant to 10 CFR 50.90. '
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 9of13 Enclosure EC 286271, REVISION-0 REVISE RCP FLYWHEEL MATERIAL
SUMMARY
EC 286271 is an addendum to the permanent modifications that replaced reactor coolant pump (RCP) motors in St. Lucie Unit 2 with motors from Unit 1 including the flywheels. The Unit 1 and Unit 2 UFSARs describe different materials for the RCP motor flywheels. The described Unit 1 flywheel material is ASTM A516 Grade 65.
The described Unit 2 flywheel material is ASTM A543 Class 1*Type B. The change to the flywheels was not evaluated or documented in the ECs for these RCP replacements. The toughness of the ASTM A516 Grade 65 material as described in the Unit 1 UFSAR is less than the toughness described for the flywheels in the Unit 2 UFSAR. The toughness of the Unit 1 flywheel material described in the Unit 1 UFSAR is at least 90 KSl"in at the operating temperature of 100°F which is less than the value of at least 100 KSl"in at the normal operating temperature described in the Unit 2 UFSAR. In addition, the Unit 2-UFSAR describes that the flywheels were tested at the design overspeed. lhe Unit 1 UFSAR describes that the flywheels were not tested at the design overspeed. The 50.59 screening identified that these differences adversely affect the design function as described in-the UFSAR.
The function of the flywheels is unchanged by the change in material. The 50.59 evaluation determined that the change in the flywheel material for Unit 2 from ASTM A543 Class 1 Type B to ASTM A516 Grade 65 with the properties described in the Unit 1 UFSAR will not result in a more than minimal increase in the likelihood of a malfunction of the flywheel.
There are no accidents evaluated in the UFSAR wher-e the radiological release would be altered by the material of the flywheel. The coast-down characteristics of the pump are not affected by the change. The proposed activity will not result in an increase in the radiological consequences of an accident previously evaluated in the UFSAR.
There are no malfunctions of equipment evaluated in the UFSAR that would be affected by the change in the flywheel material.
Because the proposed change does not require a change to the technical specifications and does not meet any of the criteria in-10 CFR 50.59(c)(2), the change can be made without obtaining a license amendment pursuant to 10 CFR 50.90.
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 10of13 Enclosure EC 288609, REVISION 2 CONNECTION OF TEMPORARY AIR COMPRESSORS TO SUPPORT UNIT 2 INSTRUMENT AIR COMPRESSOR REPLACEMENT
SUMMARY
EC 288609 supports the ongoing implementation of the permanent modification that is replacing the Un*t 2 instrument air compressors by providing temporary air compressors and dryers-(TAC/Ds) to supply compressed air to the instrument air system (IAS). From the time the existing compressors were disconnected until the new compressors and equipment are turned over to operations, instrument-air will be supplied by three, redundant, ~ 200% capacity, temporary compressors and two dryers via temporary hoses.
One electrically driven compressor, two diesel driven compressors, and two dryers are installed. If the electrically driven compressor tfips off line, the redundant diesel powered compressors will start automatically to-supply compressed air to the IAS.
Each diesel powered compressor has a nominal 8-hour fuel supply. Temporary air hoses will be run to complete the connection from the temporary air dryers to the instrument air system.
Instrument air controls and setpoints are unchanged.
The Unit 1 to Unit 2 cross tie is unchanged. The TAC/Ds have enough capacity to supply the instrument air needs for both units if necessary. Thus cross tie capabilities are unaffected.
Although the IAS is not safety-related, does not perform or support a UFSAR described design function, is not required to bring the plant to a safe shutdown condition or maintain the plant in a safe shutdown condition, and is not required to cope with design basis accidents, it is important to maintaining the plant in a stable condition during at-power operation.
The temporary hoses meet the design pressure and temperature ratings for the system and have been adequately supported to provide commensurate reliability as the installed equipment. It is concluded that redundancy and defense in depth are maintained, and that the likelihood of a complete loss of the air supply to the IAS is not measurably increased. Therefore, the proposed activity does not result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated-in the UFSAR.
The temporary compressors are much newer and have been determined to be more reliable than the existing compressors.
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 11 of 13 Enclosure Using temporary compressors and dryers to provide air to the IAS has a less than minimal effect on the IAS reliability, and -no effect on the consequences of a loss of instrument air. Therefore, it is concluded that a license amendment is not required.
Because the proposed change does not require a change to the technical specifications and does not meet any of the criteria in 10 CFR 50.59(c)(2), the change can be made without obtaining a license amendment pursuant to 10 CFR 50.90.
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 12of13° Enclosure SECTION 2 50.59 EVALUATIONS NONE For the time period of this report, there were no changes to the facility (outside of the plant design modifications discussed in Section 1) as described in the UFSAR performed by a 10 CFR 50.59 Evaluation.
St. Lucie Unit 2 L-2017-165 Docket No. 50-389 Page 13of13 Enclosure SECTION 3 CORE RELOAD EVALUATION EC 287528, REVISION 2 ST. LUCIE UNIT 2 CYCLE 23 RELOAD
SUMMARY
St. Lucie Unit 2 Cycle 23 Core Reload involved implementation of new fuel design (AREVA fuel) which is covered under the 50.92 process and approved by the NRG in License Amendment 182. Other cycle specific changes did not require a 10 CFR 50:59 Evaluation. The discussions within this EC, along with the 10 CFR 50.59 Applicability I Screening which were performed, justify that the design and operation of the Cycle 23 reload core will meet the 10 CFR 50.59 (c)(2) criteria. The core reload activities can be implemented with no changes to the St. Lucie Unit 2 Technical Specifications outside of those approved by the NRG in License Amendment 182. The safety analyses results are within the design basis, within the acceptance limits provided by the NRG regulatory criteria and within the criteria provided by 10 CFR 50.59. Therefore, prior NRG approval is not required for implementation of this EC outside of the fuel design change approved by the NRG in License Amendment 182.