L-2024-155, Subsequent License Renewal Application, Third Annual Update

Subsequent License Renewal Application, Third Annual Update

ML24271A063
Person / Time
Site:	Saint Lucie
Issue date:	09/27/2024
From:	Mack K Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2024-155
Download: ML24271A063 (1)

Text

September 27, 2024 L-2024-155 10 CFR 54.17

• l=PL..

U.S. Nuclear Regulatoi-y Commission Attn: Document Control Desk 11545 Rockville Pike One \\Vh.ite Flint North Rockville, 1YID 20852-2746

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

SUBSEQUENT LICENSE RENEWAL APPLICATION -THIRD ANNUAL UPDATE

References:

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-2022-163 dated September 28, 2022, Subsequent License Renewal Application -First Annual Update (ADAMS Accession No. ML22271A399)

3. FPL letter L-2023-131 dated September 28, 2023, Subsequent License Renewal Application -Second Annual Update (ADAMS Accession No. ML23271A117)

4. FPL letter L-2024-121 dated July 30, 2024, St. Lucie Unit 1 Subsequent License Renewal Commitment

1. 30 Revision (ADAMS Accession No. ML24212A194)

FPL, the owner and licensee for St. Lucie Nuclear Plant (PSL) Units 1 and 2, has submitted a revised subsequent license renewal application (SLRA) for the Facility Operating Licenses for PSL Units 1 and 2 (Reference 1), first annual update (Reference 2), and second annual update (Reference 3). The License Renewal Rule, 10 CFR 54.21(b), requires that each year following submittal of an LRA, and at least 3 months before scheduled completion of the NRC review, an update to the LRA must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA including the Updated Final Safety Analysis Repo1t Supplement.

In accordance with the License Renewal Rule, FPL has performed the third annual review of PSL Units 1 and 2 CLB changes since SLRA submittal to determine whether any sections of the SLRA were materially affected by these changes. As a result of this annual review, FPL identified changes to materially affecting SLRA content due to Reference 4. A description of these changes and the corresponding affected SLRA content revisions are provided in Attachments 1 and 2 to this letter, respectively.

For ease of reference, the index of attached information is provided on page 3 of this letter. Attachment 2 includes associated revisions to the SLRA (Enclosure 3 Attachment 1 of Reference 1) denoted by strikethrough ( deletion) and/ or bold red underline (insertion) text. Previous SLRA revisions are denoted by bo ld black text. SLRA table revisions are included as excerpts from each affected table.

Florida Pow e r & Light Company

15430 Endeavor Drive,Jupiter, FL 33478 St. Lucie Nuclear Plant Units 1 and 2 L-2024-155 Dockets 50-335 and 50-389 Page 2 of3

Should you have any questions regarding this submittal, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.

I declare under penalty of perjuty that the foregoing is Uue and correct.

Executed on the 27th day of September 2024.

Sincerely,

Director, Regulatory Affairs

Attachments (2)

cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant Chief, USNRC, Division of New and Renewed Licenses Senior Project Manager, USNRC, Division of New and Renewed Licenses Chief, Bureau of Radiation Control, Florida Department of Health St. Lucie Nuclear Plant Units 1 and 2 L-2024-155 Dockets 50-335 and 50-389 Page 3 of3

Attachment No. Subject 1 Current Licensing Basis (CLB) Change Affecting the SLRA 2 Affected SLRA Content Revisions St. Lucie Nuclear Plant Units 1 and 2 L-2024-155 Dockets 50-335 and 50-389 Attachment 1 Page. 1 of 1

CURRENT LICENSING BASIS (CLB) CHANGE AFFECTING THE SLRA

PSL 1 and 2 CLB Change Screening / Aging SLRA Sections Affected Management Review/

Program (AMR /AMP)

Documents Affected

Change to the regulatory commit-NEESLOOOOS-REPT-057 Appendix A 1, Section 19.2.2.27 ment for installing a cathodic pro-Appendix A 1, Table 19-3 tection system for St. Lucie Unit

1. The change affects SLRA Unit Appendix B, Section B.2.3.27 1 Updated Final Safety Analysis Report Supplement, Appendix A 1, and Aging Management Pro-grams, Appendix B.

St. Luci e Nuclear Plant Units 1 and 2 L-2024-155 Dockets 50-335 and 50 -38 9 Attachme nt 2 Page 1 of 5 Affected SLRA Content Revisions

SLRAAppendixA1, Section 19.2.2.27, pageA1-31, is revised as follows:

19.2.2.27 Buried and Underground Piping and Tanks

The PSL Buried and Underground Piping and Tanks AMP is a new AMP. This a condition moni -

toring AMP that manages the aging effects associated with the external surfaces of buried and underground piping.

There are no buried or underground tanks at PSL.

This AMP manages the external surface condition of buried and underground piping for loss of material and cracking for the external surfaces of buried piping fabricated of steel (cast iron, carbon steel, ductile iron) and stainless steel through preventive measures (e.g., coat -

ings, backfill, and compaction), mitigative measures (e.g., electrical isolation between piping and supports of dissimilar metals, etc.), and periodic inspection activities (e.g., direct visual inspection of external surfaces, protective coatings, wrappings and quality of backfill} during opportunistic or directed excavations. The number of inspections is based on the effective -

ness of the preventive and mitigative actions.

Inspections are conducted by qualified individuals. Where the coatings, backfill or the condi-tion of exposed piping does not meet acceptance criteria, such that the depth or extent of degradation of the base metal could have resulted in a loss of pressure boundary function when the loss of material rate is extrapolated to the end of the SPEO, an increase in the sam-ple size is conducted. Direct visual inspections are performed on the external surfaces, pro-tective coatings, wrappings, quality of backfill and wall thickness measurements using NOE techniques. Additional inspections are performed on steel piping in lieu of fire main testing.

The table below provides additional information related to inspections. Preventive Action Category F has been selected for monitoring steel piping during the initial monitoring period since the proposed cathodic protection system will not be operational during that time pe-riod. Upon entering the SPEO, Preventive Action Category Chas been selected for buried steel piping after the cathodic protection system has been in service for approximately § years for Unit 1 and 10 years for Unit 2 and annual effectiveness reviews are performed.

However, if these conditions were to change, the Preventive Action Category would require reevaluation and could potentially change.

The number of inspections for each 10-year inspection period, beginning--+/-G §_ years before the start of SPEO for Unit 1 and 10 years before the SPEO for Unit 2, are based on the in -

spection quantities noted in NUREG-2191, Table XI.M41-2, adjusted for a 2-Unit plant site.

St. Lucie Nuclear Plant Units 1 and 2 L-2024-155 Dockets 50-335 and 50-389 Attachment 2 P age 2 of 5 Affected SLRA Content Revisions

SLRA Appendix Al, Table 19-3 (Item 30), page Al-98 is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity (Section) Section

30 Buried and Underground Piping XI.M41 Implement the new PSL Buried and Underground Piping and Tanks AMP. Program inspections begin~ § and Tanks (19.2.2.27 ) a) Install cathodic protection systems and perform effectiveness reviews in years before the SPEO. lnspec-accordance with Table XI.M41-2 in NUREG-2191,Section XI.M41. tions that are to be completed b) If after five years of operation the cathodic protection system does prior to the SPEO are completed not meet the effectiveness acceptance criteria defined by NUREG-2191, 6 months prior to the SPEO or no Tables XI.M41-2 and -3 (-850 mV relative to a CSE, instant off, for at later than the last refueling out-least 80% of the time, and in operation for at least 85% of the time), age prior to the SPEO.

FPL commits to performing two additional buried steel piping inspec-Install cathodic protection sys-tions beyond the number required by Preventive Action Category F re-terns at least ~ §_years before suiting in a total of 13 inspections being completed 6 months prior to the SPEO.

the SPEO. The cathodic protection criterion listed above will continue Program and SLR enhancements to be used after five years through the end of the SPEO. are implemented 6 months prior c) Perform periodic pressure testing and blow-out testing (purging) with to the SPEO, i.e.:

air or nitrogen of the annular volume between the underground stain-PSLl: 09/01/2035 less steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to exceed 5 years with the first occurrence prior to the SPEO. The annular vol-ume between the fuel oil piping and guard piping will be pressurized to 110 percent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated components) with test pressure being held for a continu-ous eight hour interval.

St. L u cie Nucl ea r P lant U ni ts 1 and 2 L-2024-15 5 D oc kets 50 -33 5 and 50- 389 A t tac h ment 2 Page 3 of 5 Affected SLRA Content Revisions

SLRA Section B.2.3.27, page B-215 is revised as follows :

B.2.3.27 Buried and Underground Piping and Tanks

Program Description The PSL Buried and Underground Piping and Tanks AMP is a new condition monitoring AMP that manages the aging effects associated with the external surfaces of buried and under -

ground piping such as loss of material and cracking. It addresses piping composed of steel (carbon steel, cast iron, and ductile iron) and SS materials that are within the scope of Subse-quent License Renewal. There are no buried or underground tanks at PSL.

There are no polymeric, cementitious, or additional metallic materials other than the steel metals stated above for the in-scope systems, therefore, the aging management of these ma-terials is not applicable. The interior surfaces of the coated, cement lined cast iron fire water system piping is managed by the PSL Internal Coatings/Linings for In-Scope Piping, Piping Com -

ponents, Heat Exchangers, and Tanks {Section B.2.3.28 ) AMP.

The objective of this program is accomplished through the use of preventive, mitigative, in-spection, and in some cases, performance monitoring activities. The PSL Buried and Under-ground Piping and Tanks AMP includes (a) preventive measures to mitigate degradation (e.g.,

external coatings/wrappings), (b) visual inspections of external surfaces of buried components for evidence of coating/wrapping damage, and (c) visual inspections of external surfaces of buried components for evidence of degradation, if the coating or wrapping is damaged or the pipe is uncoated or unwrapped, to manage the effects of aging. The periodicity of these in-spections will be based on plant OE and opportunities for inspection such as scheduled maintenance work. These inspections will occur once prior to the SPEO and at least every 10 years during the SPEO. If an opportunity for inspection of nonleaking piping occurs prior to the scheduled inspection, the opportunistic inspection can be credited fo r satisfying the scheduled inspection if the GALL-SLR AMP XI.M41 criteria are met.

The PSL Buried and Underground Piping and Tanks AMP manages applicable aging effects such as loss of material, cracking, and blistering. Depending on the material, preventive and mitiga-tive techniques may include using external coatings, cathodic protection, and quality backfill.

Depending on the material and environment, inspection activities may include electrochemi-cal verification of the effectiveness of cathodic protection, nondestructive evaluation of pipe wall thicknesses, pressure testing and blow-out testing, and visual inspections of the pipe from the exterior.

PSL currently does not have an active cathodic protection system fo r buried and underground piping.

Backfill specifications, average pH of soil samples, the use of guard pipe and coatings was previous justification for not having a need for an active cathodic protection system for buried steel piping. In accordance with the recommendations of NUREG-2191 AMP XI.M41, a cathodic protection system will be installed at least 6 years before the SPEO for Unit 1 and at least 10 years before the prior to SPEO for Unit 2.

SLRA Section B.2.3.27, page B-216 is revised as follows:

selected for buried steel piping after the cathodic protection system has been in service for St. Lucie Nuclear Pl ant Units 1 and 2 L-2024-155 Dockets 50-335 and 50-389 Attachment 2 Page 4 of 5 Affected SLRA Content Revisions

approximately 10 years and annual effectiveness reviews are performed. However, if these conditions were to change, the Preventive Action Category would require reevaluation and could potentially change.

The number of inspections for each 10-year inspection period, beginning 6 years before the SPEO for Unit 1 and 10 years before the SPEO for Unit 2, are based on the inspection quanti-ties noted in NUREG-2191, Table XI.M41-2, adjusted for a 2-Unit plant site.

Material No. of Inspections Notes Steel (buried) 11

• prior to the SPEO (Cate-Includes 2 additional inspections to gory F} meet the requirements of NUREG-2191 4 in each 10-year period in Section XI.M41, paragraph 4.e.i the SPEO (Category C} regarding the aging effects associated with fire mains.

Steel (underground) 3

Stainless steel (un-Pressure testing per note Perform periodic pressure testing and derground) blow-out testing (purging) with air or nitrogen of the annular volume be-tween the underground stainless steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to ex-ceed 5 years with the first occurrence prior to the SPEO. The annular volume between the fuel oil piping and guard piping will be pressurized to 110 per-cent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated compo-nents) with test pressure being held for a continuous eight hour interval.

Stainless steel (bur-2 ied)

St. Lucie Nuclear Plant Units 1 and 2 L-2023-131 Dockets 50-335 and 50-389 Attachment 2 Page 5 of 5 Affected SLRA Content Revisions

SLRA Section B.2.3.27, page B-216 (cont'd) is revised as follows:

• If after five years of operation the cathodic protection system does not meet the effectiveness ac-ceptance criteria defined by NUREG-2191, Tables XI.M41-2 and -3 (-850 mV relative to a CSE, instant off, for at least 80 percent of the time, and in operation for at least 85 percent of the time), FPL com-mits to performing two additional buried steel piping inspections beyond the number required by Pre-ventive Action Category F resulting in a total of thirteen (13) inspections being completed six months prior to the SPEO. The cathodic protection criterion listed above will continue to be used after five years through the end of the SPEO.

This AMP does not provide aging management of selective leaching. The PSL Selective Leaching of Materials (Section B.2.3.21 ) AMP is applied in addition to this program for appli-cable materials and environments.

The PSL Buried and Underground Piping and Tanks AMP requires the creation of new gov-erning and inspection procedures consistent with NUREG-2191,Section XI.M41, as well as a new sampling plan and work orders to support the new inspections. A new cathodic protec-tion system will also be installed, and an effectiveness review per Table XI.M41-2 of NUREG-2191,Section XI.M41 will be performed throughout each of the 10-year inspection periods.

Initial inspections begin 6 years before the SPEO for Unit 1 and 10 years before the SPEO for Unit 2 and are completed no later than six months prior to entering the SPEO or no later than the last RFO prior to the SPEO.

NUREG-2191 Consistency

The PSL Buried and Underground Piping and Tanks AMP will be consistent with exception to the 10 elements of NUREG-2191,Section XI.M41, "Buried and Underground Piping and Tanks."

Exceptions to NUREG-2191

An exception to the NUREG-2191 recommendation of coating buried stainless steel as a preventive action will be taken with respect to the Unit 1 stainless steel AFW pump recirculation piping and condensate system (AFW pump suction) piping buried beneath the Unit 1 turbine building. This exception is justified due to the low number of chlorides within the soil, the low likelihood of stagnant moisture due to the concrete floor slab shielding, good soil/backfill drainage, and no history of negative OE for buried stainless steel piping at St.

Lucie.