ML22039A196

License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application

ML22039A196
Person / Time
Site:	Saint Lucie
Issue date:	02/09/2022
From:	Lance Rakovan NRC/NMSS/DREFS/ELRB
To:	Coffey R Florida Power & Light Co
Rakovan L,NMSS/REFS/ELRB
References
EPID L-2021-SLE-0003
Download: ML22039A196 (26)

Text

February 9, 2022 Robert Coffey Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company 700 Universe Boulevard Mail Stop: EX/JB Juno Beach, FL 33408

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - LICENSE RENEWAL REGULATORY AUDIT REGARDING THE ENVIRONMENTAL REVIEW OF THE SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NO. L-2021-SLE-0003) (DOCKET NUMBERS: DPR-67 AND NPF-16)

Dear Robert Coffey:

By letter dated August 3, 2021, (Agencywide Documents Access and Management System (ADAMS) Accession Package No. ML21215A314), Florida Power and Light Company submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for subsequent license renewal of Renewed Facility Operating License Nos. DPR-67 and NPF-16, St. Lucie Plant, Units 1 and 2 (St. Lucie), respectively, pursuant to Section 103 of the Atomic Energy Act of 1954, as amended Title 10 of the Code of Federal Regulations Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

The NRC staff has initiated the environmental review for the subsequent license renewal of St.

Lucie, Units 1 and 2. The environmental audit will be conducted remotely by the NRC staff due to the COVID-19 public health emergency, during the week of February 28, 2022. The environmental audit activities will be conducted in accordance with the enclosed environmental audit plan (Enclosure 1). The NRC staff requests the information presented in the environmental audit needs list (Enclosure 2) be made available on the St. Lucie online reference portal (ADAMS Accession No. ML21246A131), to the extent possible, prior to the audit. A draft schedule of tours and meetings is provided in (Enclosure 3).

R. Coffey 2 If you have any questions, please contact me via e-mail at Lance.Rakovan@nrc.gov.

Sincerely, Lance J. Rakovan, Acting Chief Environmental Review License Renewal Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. DPR-67 and NPF-16

Enclosures:

As stated cc w/encls: Listserv

ML22039A196 OFFICE NE/PM:ELRB:REFS LA:REFS/ERMB BC:ELRB:REFS NE/PM:ELRB:REFS NAME LRakovan AWalker-Smith LRakovan LRakovan DATE 2/8/2022 2/9/2022 2/9/2022 2/9/2022 Audit Plan Subsequent License Renewal Environmental Review St. Lucie Plant, Units 1 and 2 February 28 - March 4, 2022 Division of Materials and License Renewal Office of Nuclear Reactor Regulation Enclosure 1

SUBSEQUENT LICENSE RENEWAL ENVIRONMENTAL AUDIT PLAN ST. LUCIE PLANT, UNITS 1 AND 2

1. Background

By letter dated August 3, 2021 (Agencywide Documents Access and Management System Package Accession No. ML21215A314), Florida Power and Light (FPL) submitted an application for the subsequent license renewal of Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant (St. Lucie), Units 1 and 2 to the U.S. Nuclear Regulatory Commission (NRC). The staff is reviewing the information in the environmental report (ER) of the subsequent license renewal application per Title 10 of the Code of Federal Regulations (10 CFR) Part 51.

The NRC staff is conducting an environmental audit of the St. Lucie site to improve understanding, to verify information, and to identify information for docketing to support the preparation of the environmental impact statement. Specifically, the NRC staff will be identifying pertinent environmental data, reviewing the facility, and seeking clarifications regarding information provided in the ER.

2. Environmental Audit Bases License renewal requirements for ERs are specified in 10 CFR Part 51, Postconstruction ERs.

As specified by 10 CFR 51.53(c): Operating license renewal stage, (1) Each applicant for renewal of a license to operate a nuclear power plant under Part 54 of this Chapter shall submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage." Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.

The NRC staff is required to prepare a site-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. During the scoping process required in 10 CFR Part 51, the NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.

3. Environmental Audit Scope The scope of this environmental audit is to identify new and significant issues and issues which can be eliminated from further study. The NRC staff will also identify environmental resources that must be described and evaluated in the Supplemental Environmental Impact Statement.

Audit team members will review the documents and other requested information made available on the St. Lucie online reference portal Identified on the environmental audit needs list (Enclosure 2) and discuss any questions and additional information needs with the applicants subject matter experts.

4. Information and Other Material Necessary for the Environmental Audit As identified on the environmental audit needs list (Enclosure 2).

5. Environmental Audit Team Members and Resource Assignments The NRC environmental audit team members and their assignments are shown below.

Discipline Team Members Environmental Review Supervisor Ted Smith Environmental Project Manager Lance Rakovan Back-up Environmental Project Manager James Park Air Quality and Noise, including Greenhouse Nancy Martinez Gas Emissions and Climate Change Aquatic Resources Briana Arlene Cumulative Impacts Bob Hoffman Environmental Justice Nancy Martinez Fuel Cycle Phyllis Clark Geologic Environment Lifeng Guo, Kevin Folk Historic and Cultural Resources Nancy Martinez, Bob Hoffman Human Health, including Microbiological Beth Alferink, Don Palmrose Hazards Land Use and Visual Resources Caroline Hsu, Jeff Rikhoff Postulated Accidents Phyllis Clark Replacement Power Alternatives Bob Hoffman Severe Accident Mitigation Alternatives Bill Rautzen Socioeconomics Nancy Martinez Special Status Species & Habitats Briana Arlene Spent Nuclear Fuel Phyllis Clark Terminating Power Plant Operations and Beth Alferink, Kevin Folk Decommissioning Terrestrial Resources Caroline Hsu Waste Management (rad and non-rad) Phyllis Clark Water Resources - Groundwater Lifeng Guo, Kevin Folk Lifeng Guo, Nancy Martinez, Water Resource - Surface Water Kevin Folk

6. Logistics The environmental audit will be conducted remotely due to the COVID-19 public health emergency, from February 28 - March 4, 2022. An entrance meeting will be held with plant management at the beginning of the audit. An exit meeting will be held at the end of this audit.

7. Special Requests The NRC staff requests that the applicant make available on the St. Lucie online reference portal, the information identified on the environmental audit needs list (Enclosure 2). St. Lucie

staff who are subject matter experts in the disciplines identified on the environmental audit needs list should be available for interviews and tours.

8. Deliverables An audit summary report will be issued by NRC staff within 90 days from the end of the environmental audit.

St. Lucie Information Needs Please be prepared to discuss the following issues and make the following available during the environmental virtual audit.

Tours Please provide subject matter experts to lead the following tours:

Title or Number Features Observed Essential Optional Participants Participants

1. General site tour a. Exterior grounds All

b. Transmission lines, including transition from in-scope to offsite

c. Interim storage of spent nuclear fuel (ISFSI)

d. Plant views from publicly accessible areas

e. Meteorological tower

f. Location of nearby noise sensitive receptors

2. Plant intake and a. Cooling water intake structure, including Beth Alferink discharge tour intake velocity caps, intake pipes, intake Briana Arlene canal, marine organism barrier nets, Phyllis Clark and intake wells Lifeng Guo

b. Discharge structure, including discharge Caroline Hsu canal, discharge pipes, and area of Nancy Martinez thermal effluent dispersion Don Palmrose

c. Accessible permitted outfall locations

3. Radwaste tour a. Liquid radwaste system - discharge Beth Alferink locations Phyllis Clark

b. Gaseous radwaste system - discharge Lifeng Guo locations Don Palmrose

4. Groundwater a. Plant structures, systems, and Lifeng Guo tour components (SSC) that are identified as potential sources for groundwater contamination, and their locations.

b. Locations/areas with past releases, including the diesel tank area, the turbine lube oil area, and the mixed plume area.

Enclosure 2

Title or Number Features Observed Essential Optional Participants Participants

5. Visual Photos of St. Lucie from publicly accessible Caroline Hsu Resources areas where plant structures or operations are visible. Specifically, please provide the following:

a. From public roads such as State Road A1A

b. From the viewpoint of recreational water users on the Indian River Lagoon

c. From the viewpoint of recreational water users on the Atlantic Ocean

d. From areas of the mainland such as from SR-707 or Indian River Drive

e. From county, state, or Federal parks, recreation areas, preserves, beaches etc.

f. From residential areas, for example the nearest resident to St. Lucie on Hutchinson Island or residences on the mainland from which St. Lucie is visible.

g. From any other publicly accessible area where plant structures or operations are visible.

6. Historic and a. Tour of accessible cultural resources Robert Hoffman Cultural Resources within the St. Lucie property. Nancy Martinez

b. Photos of the five cultural resources identified in Section 3.8.3 of the (ER) and the prehistoric site identified in Section 3.8.5 of the ER

c. b. Include a map identifying the locations of onsite cultural resources as part of this tour.

Audit Meetings Please provide for breakout meetings with the subject matter expert(s) and/or the contractor(s) responsible for the following topics who can also discuss the corresponding information requests as described in the Questions and Documents Needs section below. These meetings will be used as needed to resolve or clarify any outstanding data needs or questions arising from the environmental audit.

• Aquatic resources, terrestrial resources, special status species and habitats (can be combined into one ecology meeting or separated out, depending on applicant and contractor availability).

• Historic and Cultural Resources

• Surface water hydrology including surface water withdrawals (e.g., circulating water and service water systems), effluent discharges, and water quality monitoring (can also be combined with aquatic resources).

• Replacement power alternatives.

• Land use and visual resources.

• Air quality and noise

• Socioeconomics, with a specific focus on property tax payments.

• Groundwater hydrology, quality, and impact assessment portions of the ER and the plants groundwater protection program and affected groundwater resources. Please discuss potential contaminant sources associated the plant SSC as that may be relevant to impact to groundwater at the site.

• Radiological environmental monitoring program, liquid (radiological and non-radiological) and gaseous effluent release programs, and waste management (radiological and non-radiological) programs.

• Discussion with plant personnel knowledgeable of radiological protection and radwaste systems (note: From past audit experience, most, if not all, of this information is discussed on the requested tours if the knowledgeable plant personnel participate in those tours. If that will be the case, NRC wont necessarily need separate breakout meetings for the discussions listed below.)

o Radiation protection program: Overview of the program with emphasis on the as low as reasonably achievable (ALARA) program to control worker radiation exposure (annual dose goals and status). Are there any proposed changes or upgrades to the program being considered during the license renewal term?

o Radioactive solid waste: review how the plant plans to handle low-level radioactive waste (Class A, B, and C, mixed waste, and spent nuclear fuel) during the license renewal term (onsite storage, potential expansion of storage facilities, and disposal options). Are there any proposed changes or upgrades to the program being considered during the license renewal term?

• Radioactive gaseous and liquids effluents: review how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are ALARA. Are there any proposed changes or upgrades to the program being considered during the license renewal term?

• Transmission line clearance, electric shock safety programs, and any updates on microbiological hazards since submission of the subsequent license renewal environmental report.

• The status of projects and actions contributing to cumulative impacts.

Questions and Document Needs Specific questions, requests, and document needs are provided below by resource area.

General (Lance Rakovan/All)

GEN-1 Please provide any relevant updates to Table 9.1-1. If any permits have expired since submitting the license renewal application to the NRC, please provide the status of those permits and/or renewals.

Air Quality and Noise, including Greenhouse Gas Emissions and Climate Change (Nancy Martinez)

Audit Needs AQN-1 Section 3.3.3.2 of the ER states that there have been no notices of violations or non-compliances associated with St. Lucie air emissions between 2015-2019. Has FPL received notices of violation or non-compliance associated with St. Lucies air permit since 2019?

AQN-2 Section 3.4 of the ER states that between 2015 and 2019 there have been no noise complaints received from offsite residences as it related relates to St. Lucie plant operations. Have there been any such noise complaints since 2019?

Document Needs AQN-3 ER

Reference:

FPL. 2007. Site Certification Application, St. Lucie Uprate Project.

December 2007.

Aquatic Resources (Briana Arlene)

Audit Needs AQ-1 ER, Revision 1, Section 2.2.3.1 states: Modeling studies presented by the U.S.

Atomic Energy Commission and the NRC in the operating stage final environmental statements indicate that under typical conditions, the areas of the thermal plumes to the 2° F isotherm (above ambient) from the St. Lucie Units 1 and 2 diffusers would be approximately 180 acres and 75 acres, respectively. Please provide the area of the thermal plume under current (i.e., post-extended power uprate (EPU)) operating conditions.

AQ-2 ER, Revision 1, Sections 3.7.7.1.1 and 4.6.1.4 describe an impingement study conducted for Unit 1 from 1976-1978. Have any more recent impingement studies been conducted at St. Lucie? If so, please provide copies of these studies for NRC staff review.

AQ-3 The NRCs 2003 final supplemental environmental impact statement for license renewal of St. Lucie (NUREG-1437, Supplement 11, p. 4-11) states the following.

Pursuant to a special condition of the St. Lucie Unit 2 site certification issued by the Florida Department of Environmental Protection (FDEP) in compliance with Florida law (FDEP 1976), a mitigation program was implemented whereby Florida Power

and Light Company (FPL) periodically traps fish from the intake canal, tags them, and releases them in the ocean. This program is carried out at the behest of the Florida Fish and Wildlife Conservation Commission (FFWCC). Although the special condition specified that this mitigation take place during construction of St. Lucie Unit 2, FPL has continued the program beyond the construction period. Collections are made on a quarterly to a monthly basis, with a goal of tagging and releasing 1000 fish per year. FPL cooperates with various institutions to provide specimens for display and research.

Does FPL still implement this mitigation program? Does FPL intend to continue this program during the proposed subsequent license renewal term?

Document Needs None Cumulative Impacts (Bob Hoffman)

Audit Needs CI-1 Please provide the name, description, location, and status of any additional past, present, or reasonably foreseeable projects or actions that have been identified since the ER was prepared. Similarly, please provide any known updates of projects that were identified in the ER as conceptual or for which the need had yet to be determined.

CI-2 Section 3.1.4 of the ER discusses improvements to transmission lines at St Lucie that were initiated in late 2016. Please indicate the date(s) these improvements were completed.

Document Needs None Environmental Justice (Nancy Martinez)

Audit Needs None Document Needs None Fuel Cycle (Phyllis Clark)

Audit Needs

None Document Needs None Geologic Environment (Lifeng Guo/Kevin Folk)

Audit Needs None Document Needs None Historic and Cultural Resources (Nancy Martinez/Bob Hoffman)

Audit Needs HCR- 1 Section 3.8.5 of the ER states that there have been four previous cultural resource investigations conducted within the St. Lucie property. Additionally, Section 3.8.5 of the ER states that a cultural resource survey was conducted in the vicinity of the St.

Lucie property in 2007 (Florida Master Site File [FMSF] Survey 14038). Attachment D to the ER provides a copy of letter from FPL to the Florida State Historic Preservation Office (SHPO). The letter identifies that there have been 13 cultural resource surveys conducted within close proximity to the St. Lucie site, 5 of which were conducted within portions of the 1,132-acre property. Furthermore, the letter to the SHPO identifies that FMSF Survey 14038 is one of the five cultural resource surveys conducted within the 1,132-acre property.

a. Please clarify and identify the total number of cultural resource surveys conducted within the 1,132-acre site property.

b. Please provide an unredacted copy for review of all cultural resource surveys conducted within the 1,132-acre site property.

HCR- 2 Attachment D of the ER provides letters FPL sent to the Florida State Historic Preservation Officer and Federally recognized tribes on April 14, 2021. Please provide copies of any correspondence or communications that FPL has had with these parties subsequent to issuance of the April 14, 2021, letters. If meetings or teleconferences were held, please provide a brief summary of these discussions.

HCR-3 Section 3.8.6 of the ER states that there is no cultural resource management plan nor unanticipated discoveries plan in place at St. Lucie. Section 3.8.6 of the ER

further states that inadvertent discovery of human remains is handled via 872.05 Florida Statutes.

a. Please describe administrative controls, procedures, or protocols in place to ensure that human remains are handled via 872.05 Florida Statutes in the event of inadvertent discovery related to land disturbing activities.

b. Please describe how inadvertent cultural resource discoveries, in addition to human remains, would be treated during land-disturbing activities.

c. Please describe how employees and staff involved in potential land-disturbing activities are trained to identify historic or cultural resources.

HCR-4 Approximately what percentage of land within the 1,1321-acre St. Lucie site boundary is undisturbed? Please provide a map identifying disturbed and undisturbed areas within the plant site.

HCR-5 Approximately what percentage of land within the 1,1321-acre St. Lucie site boundary has been surveyed?

HCR-6 Table 3.8-1 of ER provides architecture and history inventory entries within a 6-mile radius of St. Lucie. The table does not list State Road A1A (Site ID SL1648). Is there a reason FPL did not include this roadway in Table 3.8-1?

HCR-7 Section 3.8.3 of the ER states that for site ID SL00011, there is insufficient information to determine eligibility. Table 3.8-2 of the ER, however, states site SL00011 has not been evaluated by the SHPO. Please clarify the National Register of Historic Places status and/or SHPO evaluation regarding site SL00011.

Document Needs HCR-8 Please provide an unredacted copy of the following ER reference: AHCI (Archaeological and Historical Conservancy, Inc.). 2008. A Phase 1 Cultural Resource Survey and Assessment of Florida Power & Light Corporation Wind Turbine Parcel, St Lucie, Florida.

Human Health, including Microbiological Hazards (Beth Alferink/Don Palmrose)

Audit Needs HH-1 Please have St. Lucie subject matter experts available to discuss the clearance evaluation that was performed related to the in-scope transmission lines and how that has changed from the initial license renewal to the subsequent license renewal submission. Specifically, provide clarification of Section 4.9.2 related to the National Electrical Safety Code line clearance and the 5mA induced current requirements with respect to the elevated tower connection sections. Also, please clarify which electric lines are discussed in Section 4.9.2.4 and how those apply to the power line clearance evaluation.

HH-2 Please have St. Lucie subject matter experts available to discuss the electrical safety program along with related Occupational Safety and Health Administration regulations as implemented at the site.

HH-3 Please provide any updates concerning waterborne diseases in the vicinity of the plant since the submission of the subsequent license renewal ER, in addition to having staff available to discuss in coordination with ecology meetings, if necessary.

HH-4 FDEP2020d links to a site that shows the permit is currently pending state review.

Please provide the current status of the state review or anticipated approval period (may be included in Table 9.1-1 discussions).

Document Needs HH-5 Attachment E includes a letter from the licensee to State, but no reply is included.

Please share the States reply to this letter.

HH-6 References related to industrial wastewater cannot be easily retrieved from the publicly linked server. Please provide copies of these references (FEDP 2016a and 2020c) for review.

Land Use and Visual Resources (Caroline Hsu/Jeff Rikhoff)

Audit Needs LU-1 Section 3.1.4 in the ER describes a 2016 power line project in which one of three power lines coming to St. Lucie was moved to a more diverse substation. Please describe how construction and operation of the 2016 power line project changed/affected onsite and offsite land use.

a. Please provide maps showing the previous power line and the moved power line, including the right-of-ways.

b. Describe the right-of-way for the moved power line including its area, length, former land use category, current land use category, and whether flood plains or wetlands are included or affected.

c. Describe the land used for the construction and operation of the moved power line including area, location, former land use category, current land use category, and whether wetlands were affected.

LU-2 Section 3.1.4 in the ER describes a 2016 transmission line project in which a new transmission line was added that runs under the Indian River Lagoon to the St. Lucie site. Please describe how the construction and operation of the new transmission line changed/affected onsite and offsite land use.

a. Please provide maps showing the new transmission line including the right-of-way.

b. Describe the right-of-way of the new transmission line including its area, length, former land use category, current land use category, and whether flood plains or wetlands are included or affected.

c. Describe the land used for the construction and operation of the new transmission line including area, location, former land use category, current land use category, and whether wetlands were affected.

LU-3 Section 3.1.4 in the ER describes a possible need to expand the ISFSI and that if this expansion occurs, it would likely be on already disturbed land. If an ISFSI expansion occurs during the subsequent license renewal period, is there sufficient land on the St.

Lucie site to accommodate the construction and operation of the ISFSI expansion? How much land may be required for construction and operation of a possible ISFSI expansion? Would any wetlands be impacted?

LU-4 Section 3.1.4 in the ER describes a 2020 pilot project off the shoreline in the Atlantic Ocean performed in part to stop beach erosion. Since the previous St. Lucie license renewal application, how much beach erosion has occurred in the St. Lucie waterfront area? On average, how many feet of beach has been lost in the last 20 years? Is there an average yearly erosion rate?

VIS-1 Visibility from State Road A1A:

a. Please confirm or update that when approaching from the south on State Road A1A, the St. Lucie plant is not visible until approximately 0.75 miles (1.2 km) from the main entrance to the site. Please confirm or update and describe the view is blocked by vegetation from the west site of the road.

b. Please confirm or update that when approaching the plant from the north on State Road A1A, the units are not visible until approximately 0.5 miles (0.8 km) from the site entrance.

VIS-2 Please describe the activity and use of the Indian River Intracoastal Waterway in front of the plant. Is this area accessible to and used by recreational water users?

VIS-3 Please describe the activity and use of the Atlantic Ocean in front of the plant. Is this area accessible to and used by recreational water users?

VIS-4 As stated in the ER between 2000 and 2019, the population of St. Lucie County increased from 192,695 persons to 328,297 persons, which is a 70 percent population increase. St. Lucie plant structures have been visible to private residences, especially from Indian River Drive in Fort Pierce and Port St. Lucie.

Since the previous license renewal application, have more residential homes been constructed that have a view of St. Lucie plant structures or operations? Where are these homes located?

VIS-5 Please provide photos from publicly accessible areas from which the St. Lucie plant structures or activities (e.g., lights) are visible. Photos should include from vantage points listed in the Tours table, item 5, Visual Resources as well as from other vantage points which the applicant finds appropriate.

Document Needs None

Postulated Accidents (Phyllis Clark)

Audit Needs None Document Needs None Replacement Power Alternatives (Bob Hoffman)

Audit Needs ALT-1 Describe how the geographic characteristics of FPLs service territory, as the term is used in Chapters 2 and 7 of the ER, have changed with the integration of FPL and Gulf Power into a single electric operating system effective January 1, 2022.

ALT-2 Sections 7.2.2 and 7.2.3 of the ER cite the FPL Ten Year Power Plant Site Plan for 2020-2029 (FPL 2020d) as the reference supporting the determination as to whether certain replacement power technologies would be reasonable alternatives. In April 2021, FPL subsequently filed the 2021-2030 Ten Year Power Plant Site Plan with the Florida Public Service Commission. Please describe how this latest plan affects the underlying bases supporting FPLs selection of the range of reasonable alternatives to St Lucie relicensing.

ALT-3 Section 7.2.1 of the ER identifies energy alternatives that FPL considers reasonable, all of which would be located offsite of the St. Lucie plant. Please discuss the constraining factors which preclude the consideration of siting replacement power alternatives at the St. Lucie site.

ALT-4 Section 7.2.3.4 of the ER states that the solar alternative is comprised of approximately 95 solar photovoltaic facilities, each having an approximately 75 megawatt nameplate capacity and 56 MW battery storage. Please indicate how these numerical factors are calculated to support replacement of St. Lucies 1,968 MW net generation.

Document Needs None Severe Accident Mitigation Alternatives (Bill Rautzen)

Audit Needs

SAMA-1 In the ER, FPL indicated that it is following the guidance in Nuclear Energy Institute (NEI) 17-04, Model SLR New and Significant Assessment Approach for SAMA, Revision 1, for providing SAMA new and significant information. NEI 17-04 specifies, Further documentation of the new and significant information review is listed in Section 3.5.2. Furthermore NEI 17-04 indicates, Such documentation should be available to the NRC [U.S. Nuclear Regulatory Commission] either in the SLR [Subsequent License Renewal] ER (at the SLR applicant's discretion), or in supplemental information for review via E-document reading room, audit, and RAIs [requests for additional information].

Specifically, the staff would like to briefly discuss the probabilistic risk assessment (PRA) revisions and changes to the risk models since the 40-to year license renewal application (focusing on changes made at the plant that have significantly reduced or increased risk).

SAMA-2 NEI 17-04 Section 3.1 Data Collection specifies:

Use the latest risk models that are available for internal events (including internal flooding) and for each of the external events contributors identified for evaluation in NEI 05-01 [Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document, Revision A, November 2005].

NEI 05-01 specifies:

The IPEEE [Individual Plant Examination of External Events] identified the highest risk externally initiated accident sequences and potential means of reducing the risk posed by those sequences. Typically, the following external events were evaluated:

• Internal fires

• Seismic events

• Other external events such as high wind events, external flooding, transportation and nearby facility accidents Explain how Other external events such as high wind events, external flooding, transportation and nearby facility accidents were considered in the PSL SAMA New and Significant Evaluation? Discuss options considered to reduce risk due to each of these external events.

SAMA-3 Were there any St. Lucie or other facility external event SAMAs evaluated? If so, briefly describe. If not, indicate the reason why not.

SAMA-4 The NRC approved an 11.85 percent power uprate for both St. Lucie units 1 and 2 in 2012. It is stated in Section 4.15.2 of the FPL ER that:

As part of the uprate, FPL implemented some plant changes to offset any potential increase in core damage frequency (CDF) and large, early release frequency (LERF), and ultimately reduced the CDF and LERF compared to pre- EPU values.

and:

In addition, since the EPU, the PRA was updated to include impacts related to the EPU, so the effects of the EPU are also included in the quantitative SLR SAMA evaluations.

Table E-14 of the 2013 Generic Environmental Impact Statement (GEIS) presents the change in LERF calculated by each licensee that has been granted a power uprate of greater than 10 percent. Table E-14 shows that the increase in LERF ranges from a minimal impact to an increase of about 30 percent (with a mean of 10.5 percent). Please provide the specific CDF and LERF values to confirm values are within the values calculated in the GEIS. Also, be prepared to discuss the plant changes and the PRA updates as related to the 2012 EPU.

SAMA-5 Section 4.15.3 of the FPL ER provides a summary of the information assessed for new and significant information. Did FPL evaluate all the items in the 2013 GEIS SAMA Summary Table E-19 (including low power, uncertainties, and the BEIR Report)?

SAMA-6 Please be prepared to briefly discuss the population increase as it relates to being within the values evaluated in the GEIS Document Needs None Socioeconomics (Nancy Martinez)

Audit Needs SOC-1 Table 3.9-2 of the ER provides FPLs annual property tax payments for 2015 through 2019. Please provide FPLs property tax payments for St. Lucie for 2020 and 2021, if available.

SOC-2 Besides St. Lucie County, please describe any other sizeable annual support payments (e.g., emergency preparedness fees and payments or fees because of the independent spent fuel storage installation), one-time payments, or other forms of non-tax compensation (if any) provided to local organizations, communities, and

jurisdictions (e.g., State, municipalities, incorporated places, and school districts) on behalf of St. Lucie.

Document Needs None Special Status Species & Habitats (Briana Arlene)

Audit Needs SSH-1 ER, Revision 1, Section 4.6.6.5.1, subsection Bird Collisions with Plant Structures and Transmission Lines states that FPL maintains a corporate avian protection plan.

Please provide a copy of this plan for NRC staff review.

SSH-2 Please provide the status of FPLs FFWCC Marine Turtle Permit listed in ER Table 9.1-1. The table states that the permit expired on December 31, 2020. Please provide a copy of the current permit for NRC staff review.

SSH-3 Please provide the status of FFWCC Special Activity License for tag, release, and recapture of fish and invertebrates listed in ER Table 9.1-1. The table states that the license expired on April 28, 2018. Please provide a copy of the current license for the NRC staff review.

SSH-4 ER, Revision 1, Section 3.7.8.1.4 describes six instances of West Indian manatees entering the St. Lucie intake canal (one in 2003, two in 2006, two in 2008, and one in 2010). Please provide the following additional information concerning these events.

a. The exact dates of capture.

b. The age, size, condition, and any other recorded data on each manatee.

c. Concerning the 2010 manatee capture, provide written support, if available, for the statement, the FFWCC indicated that the death was likely due to cold temperature stress.

SSH-5 Further describe FPLs coordination with the U.S. Fish and Wildlife Service (FWS) and FFWCC concerning manatee captures. Did FWS recommend that FPL obtain an incidental take permit under Endangered Species Act (ESA) Section 10 or coordinate with the NRC to conduct ESA Section 7 consultation and obtain biological opinion to address incidental take? Did the FWS recommend that FPL consult under the Marine Mammal Protection Act to obtain an Incidental Harassment Authorization or Letter of Authorization to address injury, disturbance, or mortality? Provide copies of any relevant correspondence between FPL and these agencies.

SSH-6 ER, Revision 1, Section 4.6.6.4.2 states that FPL anticipates continued compliance with all regulatory requirements associated with protected species for the SPEO

[subsequent period of extended operation]. Adherence to these controls, as well as compliance with applicable laws and regulations, should prevent potentially adverse

impacts to this species. Please further describe these controls and provide copies of any site procedures or guidance applicable to this statement.

SSH-7 ER, Revision 1, Attachment C, contains letters from FPL to the National Marine Fisheries Service and FWS dated April 14, 2021. Please provide copies of these agencies responses. Please also provide copies of any other relevant correspondence between FPL and these agencies relevant to the potential effects of subsequent license renewal on federally listed species, designated critical habitat, and essential fish habitat.

Document Needs None Spent Nuclear Fuel (Phyllis Clark)

Audit Needs SNF-1 Given the current frequency of moving spent nuclear fuel from the pool to the ISFSI, please provide an estimate of the number of years of operation St. Lucie has before the ISFSI reaches its full capacity and a new ISFSI pad would need to be constructed.

SNF-2 Please provide the number of spent fuel storage pads and number of containers in the storage casks, as well as the number of fuel assemblies each canister can store.

Also, please provide documentation that there is enough storage capacity to store spent nuclear fuel for the subsequent license renewal period. If there is not enough storage capacity, provide the expansion plan to store spent nuclear fuel for the subsequent license renewal period.

Document Needs None Terminating Power Plant Operations and Decommissioning (Beth Alferink/Kevin Folk)

Audit Needs None Document Needs None

Terrestrial Resources (Caroline Hsu)

Audit Needs TER-1 Section 3.1.4 in the ER describes a 2016 power line and transmission line project.

a. Were the new power line and transmission line right-of-ways evaluated for impact on State-endangered terrestrial plant and animal species and other protected species such as birds protected under the Migratory Bird Treaty Act or the Bald and Golden Eagle Protection Act? If so, were any of the above protected species detected in the right-of-ways or affected by the construction or operation of the new power and transmission lines?

b. Please describe the mowing/cutting practices and herbicide use in the right-of-ways. What practices are used to avoid impacting protected species when maintaining the right-of-ways?

c. What is the impact of the new transmission lines and towers or power lines on bird collisions?

TER-2 Section 3.7.8.5 in the ER states, Currently, FPL maintains a migratory bird special purpose utility permit which involves the tracking and uploading of data for handling of any injured or deceased bird found within the PSL site. Injured birds are transported to rehab facilities when feasible. A yearly report is submitted to USFWS to maintain compliance with federal regulations.

a. Please provide a copy of the migratory bird special purpose utility permit MB697722-0.

b. Please provide the yearly reports submitted to the USFWS for the past 10 years.

TER-3 The ER cites extensively the 2001 Foster and Wheeler survey, St. Lucie Power Plant and Transmission Line, Threatened and Endangered Species Survey.

Have any surveys or studies on State protected species or species protected under the Migratory Bird Treaty Act or Bald and Golden Eagle Protection Act been conducted since 2001 by either FPL or another entity? Please provide any known avian or terrestrial ecology studies performed in the last 10 years.

Document Needs None Waste Management (rad and non-rad) (Phyllis Clark)

Audit Needs WM-1 If there have been any reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement since the ER was written, please provide a description of the releases. Please be prepared to discuss your plan to handle unplanned releases of radioactive materials.

WM-2 If there have been any reportable inadvertent nonradioactive releases that would be classified as an incidental spill which would trigger a notification requirement since the ER was written, please provide a description of spills/releases. Please be prepared to discuss your plan to handle inadvertent nonradioactive releases.

WM-3 St. Lucie is subject to the reporting provisions of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Any discharges of oil in such quantities that may be harmful to the public health or welfare or the environment must be reported to Environmental Protection Agencys National Response Center. In section 9.5.3.7 of the ER, the applicant discusses reportable spills and states that for the 5-year period of 2016-2020, there were no reportable spills/no releases. If there have been any reportable spills/releases which would trigger this notification requirement since the ER was written, please provide a description of any spills/releases.

WM-4 St. Lucie is subject to the reporting provision under Florida Administrative Code 62-780 and under the site conditions of certification. This reporting provision requires that any spills of materials having potential to significantly pollute surface or groundwaters and which are not confined to a building or similar containment structure be reported to the FDEP Office of Emergency Response by telephone immediately after discovery of such spill, followed by a detailed written report.

Section 9.5.3.8 of the ER states that between the 5-year period of 2016 to 2020, there has been one release at St. Lucie that triggered the notification requirement (on October 22, 2019). The ER states that the spill was attributed to a lift pump station at the north lift station which experienced failure, allowing approximately 400 gallons of untreated domestic wastewater to overflow the sump and collect on the surrounding grass, with some of the water draining onto adjacent concrete and through a drainage culvert into the intake canal. Wastewater that had pooled on the ground was removed, but water that reached the canal was unrecoverable. The ER states that St. Lucie replaced the lift pump indicators and audio, and visual level indication was entered into the work week process for repairs. An evaluation of the remaining lift pump stations at the site was also conducted and no other issues were noted. The ER also states that the FDEP waived the requirement of a formal report, and notification of the spill to the NRC was not required.

Please explain why the FDEP waived the requirement of a formal report, and why notification of the spill to the NRC was not required. In addition, if there have been any reportable spills which would trigger this notification requirement since the ER was written, please provide a description of any spills/releases.

WM-5 Licensees are required to consider pollution prevention measures as dictated by the Pollution Prevention Act (Public Law 101 5084) and the Resource Conservation and Recovery Act of 1976, as amended (Public Law 94 580). The Resource Conservation and Recovery Act (RCRA) governs the disposal of solid waste. In addition, in accordance with the RCRA Section 3002(b) and 40 CFR 262.27, a small or large quantity generator must certify that a waste minimization program is in place to reduce the volume and toxicity of the waste generated to the degree determined to be economically practical.

The ER states that St. Lucie is meeting this requirement as procedural measures are in place to minimize hazardous waste generated to the maximum extent practical.

Please provide the specific procedural measures referred to in Section 9.5.13.

Document Needs:

WM-6 Provide procedures related to the radioactive and nonradioactive Waste Management Program, Waste Minimization Program, and Stormwater Pollution Prevention Plan.

WM-7 Drawings and photos that are highlighted/marked showing the flow paths for releases and rad and non-rad waste paths. Please have St. Lucie subject matter experts available to discuss the flow paths.

Water Resources - Groundwater (Lifeng Guo/Kevin Folk)

Audit Needs GW-1 In 2010, FPL implemented a Groundwater Protection Program (ER Section 3.6.2.4).

Please provide site hydrogeologic characterization report(s), including assessment of potential contaminant sources associated with the plant SSC, and considerations in the groundwater monitoring network design, including a figure or figures involving the SSC and wells.

GW-2 Please provide the date of the last monitoring event that a complete analysis of radionuclides (tritium, gamma and difficult-to-detect radionuclides) was performed at the site (ER Section 3.6.2.4)

GW-3 Please provide the FPL baseline hydrogeological assessment (August 22, 2006),

which is related to the site investigation and remediation near the DTA (ER Section 3.6.3.2).

Document Needs None Water Resource - Surface Water (Lifeng Guo/Nancy Martinez/Kevin Folk)

Audit Needs SW-1 Clarify discrepancy on the number of outfalls. The ER states the current National Pollutant Discharge Elimination System (NPDES) permit authorizes discharges from four outfalls (Sec. 3.6.1.2.1). But Table 3.6-1 lists five outfalls. St. Lucies revised FPL industrial wastewater facility permit (IWFP)/NPDES permit approved on May 21, 2020 expired in November 2021. Clarify whether FPL has filled to renew the NPDES permit (FDEP, 2002b) (ER Sections 3.6.1.2.2 and 9.5.3.3, Table 6.1).

SW-2 Provide an update to St. Lucies surface water withdrawal summary to include data for calendar year 2021 (ER Section 3.6.3.1, and Table 3.6-3b).

SW-3 The ER summarizes historical regulatory infractions including notices of violation issued to FPL for the period 2016-2020 (ER Sections 3.6.1.2.5, 9.5). As applicable, provide an updated summary of and describe any Notices of Violation; nonconformance notifications; or related infractions received from regulatory agencies associated with permitted effluent discharges, sanitary sewage systems, groundwater or soil contamination, as well as any involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) received since 2020. In addition, summarize any self-reported IWFP/NPDES permit infractions since end of 2020 (i.e., including any disclosed in Discharge Monitoring Reports). Provide copies of relevant correspondence to and from the responsible regulatory agencies.

SW-4 The ER states that the recent dredging of the intake canal was performed in 2019.

Provide a brief assessment of future need of dredging to remove sediment build-up in the vicinity of the intake and discharge during the license renewal period (ER Section 3.6.1.2.4).

SW-5 Clarify the nominal capacity of the eight circulating water pumps and the three intake cooling water systems described in ER Section 2.2.3.

Document Needs SW-6 Renewal application for IWFP/NPDES permit No. FL0002208 (ER Section 3.6.1.2.1, and 9.5.3.3).

SW-7 The operating agreement between the FDEP and participating agencies identifies the final order issued as part of the power plant siting act as the 401 Certification for St. Lucie power plant (PA 74-02, issued 09/17/2008) (ER Section 9.5.3.2).

St. Lucie Plant General Environmental Audit Schedule Monday, February 28, 2022 START END ACTIVITY 9:00 am ET 9:30 am ET Entrance meeting between NRC and FPL representatives 9:30 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC and FPL subject matter experts (SMEs)

Tuesday, March 1, 2022 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC and FPL SMEs Wednesday, March 2, 2022 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC and FPL SMEs Thursday, March 3, 2022 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC and FPL SMEs Friday, March 4, 2022 START END ACTIVITY 9:00 am ET 11:00 am ET Virtual tours/virtual meetings between NRC and FPL SMEs 11:00 am ET 11:30 am ET Exit meeting between NRC and FPL Enclosure 3