L-2023-082, Subsequent License Renewal Application Revision 1, Supplement 5

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Subsequent License Renewal Application Revision 1, Supplement 5
ML23165A114
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 06/14/2023
From: Strand D
Florida Power & Light Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2023-082
Download: ML23165A114 (1)
v • d • e


Text

L-2023-082 10 CFR 54.17 June 14, 2023

U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11545 Rockville Pike One White Flint North Rockville, MD 20852-2746

St. Lucie Nuclear Plant Units 1 and 2 Dockets 50-335 and 50-389 Renewed Facility Operating Licenses DPR-67 and NPF-16

SUBSEQUENT LICENSE RENEWAL APPLICATION REVISION 1 - SUPPLEMENT 5

Reference:

1. Florida Power & Light Company (FPL) letter L-2021-192, Subsequent License Renewal Application - Revision 1, October 12, 2021 (ADAMS Package Accession No. ML21285A106)
2. FPL letter L-2022-043, Subsequent License Renewal Application Revision 1 - Supplement 1, April 7, 2022 (ADAMS Accession No. ML22097A202)
3. FPL Letter L-2022-108 dated July 11, 2022 - Subsequent License Renewal Application -

Aging Management Requests for Additional Information (RAI) Set 2 Response (ADAMS Accession No. ML22192A078)

4. FPL Letter L-2022-115 dated August 9, 2022 - Subsequent License Renewal Application -

Aging Management Requests for Additional Information (RAI) Set 3 Response and Submittal of Superseded Response for One Set 2 RAI and One Supplement 1 Attachment (ADAMS Accession No. ML22221A134)

5. FPL Letter L-2022-154, Subsequent License Renewal Application Revision 1 - Supplement 4, September 22, 2022 - (ADAMS Accession No. ML22265A134)
6. FPL Letter L-2023-059 dated April 21, 2023 - Subsequent License Renewal Application -

Aging Management Requests for Additional Information (RAI) Set 4 Supplemental Response (ADAMS Accession No. ML23111A129)

Florida Power & Light Company (FPL), owner and licensee for the St. Lucie Nuclear Plant (PSL)

Units 1 and 2, has submitted a revised and supplemented subsequent license renewal application (SLRA) for the Facility Operating Licenses for PSL Units 1 and 2 (References 1-6). The two attachments to this letter provide a fifth supplement to the SLRA. Attachment 1 provides clarification of SLRA Unit 1 Commitments 13 and 24. Attachment 2 provides clarification of SLRA Unit 2 Commitments 1, 13, 20, 24, 25, and 36. Both attachments contain the final clean version of each commitment, incorporating all prior revisions from previous supplements and responses to RAIs.

Florida Power & Light Company

15430 Endeavor Drive, Jupiter, FL 33478

St. Lucie Nuclear Plant Units 1 and 2 L-2023-082 Dockets 50-335 and 50-389 Attachment 1

SLRA Supplement 5 Attachment 1 Clarification of PSL Unit 1 SLRA Commitments

(5 pages follow)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023- 082 Attachment 1 Page 1 of 5

Clarification of PSL Unit 1 Commitment No. 13

Affected SLRA Sections: Appendix A1, Section 19.4, Table 19-3, Commitment No. 13

Issue

The response to Supplement 1, Attachment 1 8, page 30 of 38 (Ref. 1) made the appropriate changes to the Implementation Schedule for Commitment No. 13, but inadvertently deleted the comma after the words No later than 6 months prior to the SPEO. The response to RAI Set 2,, page 9 of 57 (Ref. 2) added the comma back to the Implementation Schedule for Commitment No. 13. The response to RAI Set 3, Attachment 7 (Ref. 3), superseded the previously submitted response to Supplement 1, Attachment 18 (Ref. 1). However, the response to RAI Set 3, Attachment 7 (Ref. 3) is consistent with the changes made to the Implementation Schedule for PSL Unit 1 Commitment No. 13 provided in RAI Set 2, Attachment 5 (Ref. 2).

Resolution

For clarification, the final version of SLRA Appendix A1, Section 19.4, Table 19-3, Commitment No. 13, with all the appropriate revisions, is provided on the following page.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023- 082 Attachment 1 Page 2 of 5

SLRA Appendix A1, Section 19.4, Table 19-3, page A1-71, is clarified as follows:

Table 19-3 List of Unit1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 13 Steam Generators XI.M19 a) Continue the existing PSL Steam Generators AMP. No later than 6 months prior to (19.2.2.10) the SPEO, i.e.:

PSL1: 09/01/2035 St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023- 082 Attachment 1 Page 3 of 5

Clarification of PSL Unit 1 Commitment No. 24

Affected SLRA Sections: Appendix A1, Section 19.4, Table 19-3, Commitment No. 24

Issue

The response to Supplement 1, Attachment 7, page 7 of 33 (Ref. 1 ), made changes to the Implementation Schedule of Commitment No. 24. The response to RAI Set 4 Supplemental Response, Attachment 3, page 34 of 41 (Ref. 4), made changes to the commitment scope of Commitment No. 24, but, inadvertently omitted the Implementation Schedule changes previously made by Supplement 1, Attachment 7 (Ref. 1).

Resolution

For clarification, the final version of SLRA Appendix A1, Section 19.4, Table 19-3, Commitment No. 24, with all the appropriate revisions, is provided on the following page.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023- 082 Attachment 1 Page 4 of 5

SLRA Appendix A1, Section 19.4, Table 19-3, page A1-89, is clarified as follows:

Table 19-3 List of Unit1 SLR Commitments and Implementation Schedule

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 24 Selective Leaching XI.M33 Implement the new PSL Selective Leaching AMP, including the Program inspections begin 10 (19.2.2.21) following additional action: years before the SPEO.

a) To confirm that loss of material due to selective leaching is Inspections that are to be an aging effect unique to the external surfaces of the Unit 1 completed prior to the SPEO EDG copper alloy with greater than 15 percent zinc radiator are completed 6 months prior to tubes, PSL will perform a one-time inspection of a the SPEO or no later than the representative sample of Unit 1 and 2 copper alloy with last refueling outage prior to the greater than 15 percent zinc components exposed to an air -SPEO.

outdoor external and air - outdoor internal environments, as Program and SLR applicable, prior to the SPEO. This inspection will be enhancements are performed in accordance with the Selective Leaching AMP implemented 6 months prior to and will be considered a separate inspection population. the SPEO, i.e.:

PSL1: 09/01/2035

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023- 082 Attachment 1 Page 5 of 5

References

1. FPL Letter L-2022-043 dated April 7, 2022 - Subsequent License Renewal Application Revision 1 - Supplement 1 (ADAMS Accession No. ML22097A202)
2. FPL Letter L-2022-108 dated July 11, 2022 - Subsequent License Renewal Application

- Aging Management Requests for Additional Information (RAI) Set 2 Response (ADAMS Accession No. ML22192A078)

3. FPL Letter L-2022-115 dated August 9, 2022 - Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 3 Response and Submittal of Superseded Response for One Set 2 RAI and One Supplement 1 Attachment (ADAMS Accession No. ML22221 A134)
4. FPL Letter L-2023-059 dated April 21, 2023 - Subsequent License Renewal Application

- Aging Management Requests for Additional Information (RAI) Set 4 Supplemental Response (ADAMS Accession No. ML23111A129)

St. Lucie Nuclear Plant Units 1 and 2 L-2023-082 Dockets 50-335 and 50-389 Attachment 2

SLRA Supplement 5 Attachment 2 Clarification of PSL Unit 2 SLRA Commitments

(19 pages follow)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 1 of 19

Clarification of PSL Unit 2 Commitment No. 1

Affected SLRA Sections: Appendix A2, Section 19.4, Table 19-3, Commitment No. 1

Issue

The response to Supplement 4, Attachment 1, page 2 of 5 (Ref. 1) added a new item a) to the commitment scope of Commitment No. 1. However, the new item a) was inadvertently not denoted by bold red underline (insertion) text.

Resolution

For clarification, the final version of SLRA Appendix A2, Section 19.4, Table 19-3, Commitment No. 1, with all the appropriate revisions, is provided on the following pages.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 2 of 19

SLRA Appendix A2, Section 19.4, Table 19-3, page A2-65, is clarified as follows:

Table 19-3 List of Unit2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 1 Fatigue Monitoring (19.2.1.1) X.M1 Continue the existing PSL Fatigue Monitoring AMP, including No later than 6 months prior to enhancement to: the SPEO, i.e.:

a) Update the AMP governing procedure to take action to revise the PSL2: 10/06/2042 affected St. Lucie Unit 2 Class 1 piping fatigue analyses before 80- year plant design cycle limits are exceeded, and identify any new break locations (CUF > 0.1) requiring evaluation for impac t on essential SSCs, including evaluation for associated dynamic affects (jet impingement, reactive forces and pipe whip, compartment pressure and environmental conditions), as required.

b) Update the plant procedure to monitor chemistry parameters that provide inputs to F en factors used in CUFen calculations.

c) Update the plant procedure to identify and require monitoring of the 80- year projected plant transients that are utilized as inputs to CUF en calculations. These transients include:

  • The primary coolant pump starting/stopping transient.
  • The auxiliary spray at power 1, auxiliary spray at power 2, and main spray term in cooldown transients.

d) Update the plant procedure to monitor and track the following transients during the SPEO:

  • Loss of charging
  • Loss of letdown
  • Loss of regenerative heat exchanger (short-term)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 3 of 19

Table 19-3 List of Unit2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section)

  • Loss ofativheat*clong -t Ue the plt predureo identifyrtivti optionsoifnentpecificie limits are o

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 4 of 19

Clarification of PSL Unit 2 Commitment No. 13

Affected SLRA Sections: Appendix A2, Section 19.4, Table 19-3, Commitment No. 13

Issues

1. The response to Supplement 1, Attachment 1 8, page 32 of 38 (Ref. 2) inadvertently referred to PSL Unit 1 in the header of Table 19-3.
2. The response to Supplement 1, Attachment 18, page 32 of 38 (Ref. 2 ) made the appropriate changes to the Implementation Schedule for Commitment No. 13, but inadvertently deleted the comma after the words No later than 6 months prior to the SPEO. The response to RAI Set 2, Attachment 5, page 35 of 57 (Ref. 3 ) added the comma back to the Implementation Schedule for Commitment No. 13. The response to RAI Set 3, Attachment 7 (Ref. 4 ), superseded the previously submitted response to Supplement 1, Attachment 18 (Ref. 2). However, the response to RAI Set 3, Attachment 7 (Ref. 4 ) is consistent with the changes made to the Implementation Schedule for PSL Unit 2 Commitment No. 13 provided in RAI Set 2, Attachment 5 (Ref. 3).
3. The response to RAI Set 3, Attachment 7, page 18 of 23 (Ref. 4) inadvertently referred to PSL Unit 1 in the header of Table 19 -3.

Resolutions

1. The Table 19-3 header in the response to Supplement 1, Attachment 1 8, page 32 of 38 (Ref. 2) should have referred to PSL Unit 2.
2. For clarification, the final version of SLRA Appendix A2, Section 19.4, Table 19-3, Commitment No. 13, with all the appropriate revisions, is provided on the following page.
3. The Table 19-3 header in the response to RAI Set 3, Attachment 7, page 18 of 23 (Ref.
4) should have referred to PSL Unit 2.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 5 of 19

SLRA Appendix A2, Section 19.4, Table 19-3, page A2-72, is clarified as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section)

13 Steam Generators XI.M19 a) Continue the existing PSL Steam Generators AMP. No later than 6 months prior to (19.2.2.10) the SPEO, i.e.:

PSL2: 10/06/2042

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 6 of 19

Clarification of PSL Unit 2 Commitment No. 20

Affected SLRA Sections: Appendix A2, Section 19.4, Table 19-3, Commitment No. 20

Issue

The response to Supplement 1, Attachment 7 ( Ref. 2) made inconsistent changes to the Implementation Schedule for PSL Unit 1 Commitment 20 (page 4 of 33) and PSL Unit 2 Commitment 20 (page 16 of 33). Specifically, the PSL Unit 1 Commitment 20 Implementation Schedule (page 4 of 33) deleted the words No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:. However, the PSL Unit 2 Commitment 20 Implementation Schedule (page 16 of 33) inadvertently did not delete these same words.

Resolutions

For clarification, the final version of SLRA Appendix A2, Section 19.4, Table 19-3, Commitment No. 20, with all the appropriat e revisions, is provided on the following pages.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 7 of 19

SLRA Appendix A2, Section 19.4, Table 19-3, starting on page A2-83, is clarified as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 20 Outdoor and Large XI.M29 Continue the existing PSL Outdoor and Large Atmospheric Metallic Program inspections or tests Atmospheric Metallic Storage Storage Tanks AMP, including enhancement to: begin 10 years before the Tanks ( 19.2.2.17) a) Create a new procedure, and/or associated preventive SPEO. One-time maintenance activities, to: inspections begin 5 years prior to the SPEO.

  • Address the interfaces, handoffs, and overlaps between theInspections or tests that are PSL Outdoor and Large Atmospheric Metallic Storage to be completed prior to the Tanks AMP and the following AMPs: SPEO are completed 6 months prior to the SPEO or o PSL Structures Monitoring AMP; no later than the last o PSL External Surfaces Monitoring of Mechanicalrefueling outage prior to the Components AMP; SPEO.

o PSL Water Chemistry AMP; Program and SLR enhancements are o PSL One-Time Inspection AMP,implemented 6 months prior o PSL Internal Coatings/Linings for In-Scope Piping,to the SPEO, i.e.:

Piping Components, Heat Exchangers, and Tanks PSL2: 10/06/2042 AMP; and o PSL ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD AMP.

  • Direct periodic (18-month interval) visual inspection of tank-to-concrete caulking/sealants, with mechanical manipulation as appropriate. Update or reactivate existing caulking/sealant inspection preventive maintenance activities and create new caulking/sealant inspection preventive maintenance activities as needed. These caulking/sealant inspections are performed by the PSL Structures Monitoring AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 8 of 19

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section)

  • Dirth -yetom tckness meemef WT, U2 PWST, d the U2 CST, iow -frequency tromagnetictiET)iith fl -

UT e*inatio assy, atiscre taio iifie LFET.

  • Direct baseline one-time interior visual inspections of the U2 RWT. Direct 10- year surface examination inspections of the stainless steel U2 RWTs interior nonwetted surface and exterior surface for evidence of loss of material and cracking. The surface examinations will inspect 25 1-square-foot sections or 25 1-linear-foot sections of welds.

If evidence of cracking is identified, then a surface examination is also performed to determine the extent of the cracking.

  • Clarify that subsequent inspections are conducted in different locations unless this AMP includes a documented basis for conducting repeated volumetric and surface inspections in the same location.
  • Clarify that inspections and tests are performed by personnel qualified in accordance with site procedures to perform the specified task.
  • Clarify that inspections and tests within the scope of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) follow procedures consistent with the ASME Code, including ASME Code Section XI. Non-ASME Code inspections and tests follow site procedures that include considerations such as lighting, distance offset, surface coverage, presence of protective coatings, and cleaning processes.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 9 of 19

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section)

  • Cry hat where prtical,ified degrion is tilhe nt sclptio te one-tipections,deifi adatiois prt to thPEO.
  • Clarify that results are evaluated against acceptance criteria to confirm or adjust timing of subsequent inspections, or in the case of one-time inspections, schedule follow-up inspections.
  • State the acceptance criteria as follows:

o No degradation of paints or coatings (e.g., cracking, flakes, or peeling), or the U2 PWST internal floating roof; o No non-pliable, cracked, or missing caulking/sealant for the tank bottom interface; o No indications of cracking of a stainless steel tank (U2 RWT), and; o Measuredor projected tank bottom thickness must be greater than 87.5% of the nominal plate thickness.

  • State the appropriate corrective actions to perform for when degradation (e.g., sealant/caulking flaws, paint/coating flaws, loss of material, cracking, etc.) is identified, which include the following:

o Report degradation via a condition report (CR) then perform an engineering evaluation or repair/replace the degraded component as needed.

o Repair or replace the degraded component as determined by engineering evaluation and perform St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 10 of 19

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) follow -up examinations. For one -time inspections that do not meet acceptance criteria, inspections are subsequently conducted at least at 10-year inspection intervals.

o For other sampling-based inspections (e.g., 20%, 25 locations) the smaller of five additional inspections or 20% of the inspection population is conducted. If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause is conducted to determine the further extent of inspection.

The additional inspections include inspections at all of the Units with the same material, environment, and aging effect combination.

Sample expansion inspections that happen in the next inspection interval are part of the preceding interval.

b) Perform baseline one-time interior visual inspections of the U2 RWT. Perform 10- year surface examination inspections of the stainless steel U2 RWTs interior nonwetted surface and exterior surface for evidence of loss of material and cracking. The surface examinations will inspect 25 1-square-foot sections or 25 1-linear-foot sections of welds. If evidence of cracking is identified, then a surface examination is also performed to determine the extent of the cracking.

c) Perform 10- year LFET tank bottom thickness examinations of the U2 RWT, U2 PWST, and the U2 CST, with follow -onUT at discrete locations.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 11 of 19

Clarification of PSL Unit 2 Commitment No. 24

Affected SLRA Sections: Appendix A2, Section 19.4, Table 19-3, Commitment No. 24

Issues

1. The response to RAI Set 4 Supplemental Response, Attachment 3, page 37 of 41 (Ref.
5) inadvertently referred to PSL Unit 1 in the header of Table 19-3.
2. The response to Supplement 1, Attachment 7, page 19 of 33 (Ref. 2 ), made changes to the Implementation Schedule of Commitment No. 24. The response to RAI Set 4 Supplemental Response, Attachment 3, page 37 of 41 (Ref. 5 ), made changes to the commitment scope of Commitment No. 24, but, inadvertently omitted the Implementation Schedule changes previously made by Supplement 1, Attachment 7 (Ref. 2 ).

Resolutions

1. The Table 19-3 header in the response to RAI Set 4 Supplemental Response, Attachment 18, page 37 of 41 (Ref. 5) should have referred to PSL Unit 2.
2. For clarification, the final version of SLRA Appendix A2, Section 19.4, Table 19-3, Commitment No. 24, with all the appropriate revisions, is provided on the following page.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 12 of 19

SLRA Appendix A2, Section 19.4, Table 19-3, page A2-89, is clarified as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 24 Selective Leaching XI.M33 Implement the new PSL Selective Leaching AMP, including the Program inspections begin 10 (19.2.2.21) following additional actions: years before the SPEO.

a) To confirm that loss of material due to selective leaching is Inspections that are to be an aging effect unique to the external surfaces of the Unit 1 completed prior to the SPEO EDG copper alloy with greater than 15 percent zinc radiator are completed 6 months prior to tubes, PSL will perform a one-time inspect ion of athe SPEO or no later than the representative sample of Unit 1 and 2 copper alloy with last refueling outage prior to the greater than 15 percent zinc components exposed to an air -SPEO.

outdoor external and air - outdoor internal environments, as Program and SLR applicable, prior to the SPEO. This inspection will be enhancements are performed in accordance with the Selective Leaching AMP implemented 6 months prior to and will be considered a separate inspection population. the SPEO, i.e.:

b) In addition, PSL will perform a one-time inspection of thePSL2: 10/06/2042 Unit 2 EDG Admiralty brass radiator tubes exposed to an air -

indoor uncontrolled external environment prior to the SPEO.

This inspection will be performed in accordance with the Selective Leaching AMP and will be considered a separate inspection population.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 13 of 19

Clarification of PSL Unit 2 Commitment No. 25

Affected SLRA Sections: Appendix A2, Section 19.4, Table 19-3, Commitment No. 25

Issue

The response to Supplement 1, Attachment 7, page 20 of 33 (Ref. 2) revised the first sentence of the Implementation Schedule for Commitment 25 to state Program inspections are completed 6 years before the SPEO. This verbiage conflicts with NUREG-2191, Table XI-01 for AMP XI.M35, which states, Program is implemented and inspections are completed within 6 years before the subsequent period of extended operation.

Resolution

For clarification, the final version of SLRA Appendix A2, Section 19.4, Table 19-3, Commitment No. 25, to include the word within, is provided on the following page.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 14 of 19

SLRA Appendix A2, Section 19.4, Table 19-3, page A2-90, is clarified as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 25 ASME Code Class 1 XI.M35 Continue the existing PSL ASME Code Class 1 Small-Bore Piping Program inspections are Small-Bore Piping AMP, which includes: completed within 6 years before (19.2.2.22) a) Perform one-time inspection of small - bore piping using thethe SPEO. Inspections that are methods, frequencies, and acceptance criteria as outlined in to be completed prior to the NUREG - 2191,Section XI.M35.SPEO are completed 6 months prior to the SPEO or no later b) Evaluate the results to determine if additional or periodic than the last refueling outage inspections are required and perform any required additional prior to the SPEO.

inspections. Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:

PSL2: 10/06/2042 St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 15 of 19

Clarification of PSL Unit 2 Commitment No. 36

Affected SLRA Section: Appendix A2, Section 19.4, Table 19-3, Commitment No. 36

Issue

The response to RAI Set 2, Attachment 16, pages 10, 11 and 12 of 13 (Ref. 3) inadvertently referred to PSL Unit 1 in the header of Table 19-3.

Resolution

The Table 19-3 header in the response to RAI Set 2, Attachment 16, pages 10, 11 and 12 of 13 (Ref. 3) should have referred to PSL Unit 2.

For clarification, the final version of SLRA Appendix A2, Section 19.4, Table 19-3, Commitment No. 36, with Unit 2 added to the header of Table 19-3, is provided on the following pages.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 16 of 19

SLRA Appendix A2, Section 19.4, Table 19-3, pages A2-103 and A2-104, are clarified as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section)

36 Structures Monitoring XI.S6 Continue the existing PSL Structures Monitoring AMP, including No later than 6 months prior to (19.2.2.33) enhancement to: the SPEO, i.e.:

a) Monitor and inspect steel edge supports on masonry walls. PSL2: 10/06/2042 b) Specify the use of high-strength bolt storage requirements discussed in Section2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High -Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Inspect concrete structures for increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.

d) Inspect elastomers for loss of material and cracking.

e) Inspect stainless steel and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.

f) Include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

g) Specify that all bolting is monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.

h) Include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.

i) Include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 17 of 19

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels. W hen leakage volumes allow, assessment may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.

j) Develop a new implementing procedure or attachment to an existing implementing procedure to address agingmanagement of inaccessible areas exposed to groundwater/soil and water -

flowing. The document will include guidance to conduct a baseline visual inspection, pH analysis, and a chloride concentration test prior to the SPEO at a location close to the coastline/intake and a location in the main plant area for comparison. The baseline inspection results will be used to conduct a baseline evaluation that will determine the additional actions (if any) that are warranted. Additionally, the baseline evaluation results will set the subsequent inspection requirements and inspection intervals (not to exceed 5 years). Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed. Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval.

k) Require inspections of the Condensate Storage Tank (CST) and Auxiliary Feedwater (AFW) Structures and Piping Inspections in the Trenches every third refueling outage, which will ensure that these inspections are performed at least once per 5 years.

l) Include stainless steel ASME Class 1, 2, or 3 support members, welds, bolted connections, or anchorage in the engineering evaluation of acceptance criteria, expansion criteria, and examination frequency if cracking due to SCC in the uncontrolled St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 18 of 19

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) indoor and outdoor air at PSL is detected for stainless steel mechanical or non-ASME structural components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50- 389 L-2023-0 82 Attachment 2 Page 19 of 19

References

1. FPL Letter L-20 22-15 4 dated September 22, 2022 - Subsequent License Renewal Application Revision 1 - Supplement 4 (ADAMS Accession No. ML22265A134)
2. FPL Letter L-20 22-04 3 dated April 7, 2022 - Subsequent License Renewal Application Revision 1 - Supplement 1 (ADAMS Accession No. ML22097A202)
3. FPL Letter L-20 22-10 8 dated July 11, 2022 - Subsequent License Renewal Application

- Aging Management Requests for Additional Information (RAI) Set 2 Response (ADAMS Accession No. ML22192A078)

4. FPL Letter L-20 22-11 5 dated Aug ust 9, 2022 - Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 3 Response and Submittal of Superseded Response for One Set 2 RAI and One Supplement 1 Attachment (ADAMS Accession No. ML22221A1 34)
5. FPL Letter L-20 23-05 9 dated April 21, 2023 - Subsequent License Renewal Application

- Aging Management Requests for Additional Information (RAI) Set 4 Supplemental Response (ADAMS Accession No. ML23111A129)

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