L-2021-008, Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 2020

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Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 2020
ML21029A085
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 01/29/2021
From: Godes W
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2021-008
Download: ML21029A085 (4)


Text

January 29, 2021 L-2021-008 10 CFR 50.4 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 2020 Pursuant to the guidance of NRC Regulatory Issue Summary (RIS) 2000-17, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, and NRC endorsed Nuclear Energy Institute (NEI) 99-04, Guidelines for Managing NRC Commitment Changes, attached is a summary of St. Lucie commitments that were changed in accordance with the NextEra Energy Fleet NRC commitment management procedure during calendar year 2020.

Please contact Richard Sciscente at (772) 467-7156 if there are any questions regarding this submittal.

Sincerely, Wyatt Godes Licensing Manager St. Lucie Plant WG/rcs Attachment (3 Pages)

Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

St. Lucie Units 1 and 2 L-2021-008 Docket Nos. 50-335 and 50-389 Attachment Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 2020 Source Document(s) Brief Commitment Summary Change Summary &

Bases for the Change Florida Power & Light Upon NRC approval of WCAP- Change Summary (FPL) letter L-2017- 17788, Comprehensive This commitment has been 210 dated December Analysis and Test Program for rescinded.

20, 2017, Updated GSl-191 Closure, the Bases for the Change Final Response to completed in-vessel blockage The commitment is appropriate for NRC Generic Letter analysis for St. Lucie will be rescission since the NRC revised 2004-02 reviewed and if warranted, a their approach to the post LOCA in-reanalysis will be performed vessel debris methodology outlined within six months following in WCAP-17788. In lieu of WCAP approval of the WCAP-17788 approval, in June 2019 the NRC methodology. issued a technical evaluation report (TER) which concluded that post-LOCA debris inside the reactor vessel is of low safety significance (ML19073A044).

Additionally, in September 2019 the NRC issued guidance for demonstrating compliance with 10 CFR 50.46(b)(5) drawing upon the WCAP-17788 methodology for evaluating the effects of in-vessel debris (ML19228A011 ).

In a December 2019 audit report (ML19217A003), the NRC requested supplemental information that was provided by FPL via letter L-2020-165 dated December 4, 2020, Supplement to Updated Final Response to NRC Generic Letter 2004-02. This supplement included no new commitments.

St. Lucie Units 1 and 2 L-2021-008 Docket Nos. 50-335 and 50-389 Attachment Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 2020 Source Document(s) Brief Commitment Summary Change Summary &

Bases for the Change FPL letter L-92-39 For Unit 1: With one instrument Change Summary dated February 21, bus inverter not connected to Extend AOT from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 1992, Generic Letter its associated DC bus Follow days.

91-11 Response. Unit 2 120 VAC Inverter Power Bases for the Change AOTs (restore in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) The time limits for inverter restoration are similar to actual Technical Specification limits that may be extended provided risk is within the limits provided by RG-1.174 and RG-1.177. The change implements a risk-informed extension of the time limits for inverter restoration.

The requirements for Generic Letter 91-11 continue to be met as the change in commitment still imposes time limitations for an out of service safety related inverter. Surveillance requirements are not changed.

A safety evaluation within the approved commitment change checklist assessed a single instrument bus being maintained on its bypass bus with a loss of offsite power event and a worst-case additional single failure. The impact of the instrument bus to de-energizing for 10 seconds while the associated emergency diesel generator starts and loads does not impact the ability for the reactor protection system or the engineered safety features actuation system to actuate and perform their design functions.

St. Lucie Units 1 and 2 L-2021-008 Docket Nos. 50-335 and 50-389 Attachment Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 2020 Source Document(s) Brief Commitment Summary Change Summary &

Bases for the Change FPL letter L-2016-067 Per L-2016-067, St. Lucie Change Summary dated March 29, 2016, Nuclear Units 1 and 2 St. Lucie has not implemented the Schedule committed to meeting the automatic trip function of the Commitment Change generic schedule provided in OPCPS. St. Lucie has selected to to NCR Bulletin 2012- the current revision of the NEI use the risk-based analysis option 01 - Design Industry OPC Initiative -- to justify elimination of the Vulnerability in Revision 1, dated March 2015, automatic trip function of the Electric Power or any subsequent revisions OPCPS and rely on the alarm Systems issued by NEI. function and subsequent operator actions.

FPL letter L-2018-196 Per L-2018-196, St. Lucie dated November 12, revised the OPC Bases for the Change 2018, Revised implementation schedule per The most recent iteration of the NEI Implementation Revision 2 of NEI OPC OPC Initiative (Revision 3)

Schedule for Open Industry Initiative to extend the incorporates an option for plants to Phase Condition monitoring period before perform a risk evaluation under (OPC) implementing the automatic trip certain boundary conditions to function. support manual response to an OPC. This option provides alternatives to enabling the automatic isolation of OPC. St.

Lucie deleted the trip function of the OPCPS and now relies on the Control Room alarms and operator manual actions upon detection of an OPC.