ML22188A086

SLRA - Audit Report

ML22188A086
Person / Time
Site:	Saint Lucie
Issue date:	07/07/2022
From:	Harris B NRC/NRR/DNRL/NLRP
To:	Coffey B Florida Power & Light Co
Thomas V
References
EPID NO. L-2021-SLR-0002
Download: ML22188A086 (138)

Text

July 7, 2022 Mr. Bob Coffey Executive Vice President, and Chief Nuclear Officer Florida Power & Light Company 700 Universe Blvd Mail Stop: EX/JB Juno Beach, FL 33408

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2021-SLR-0002)

Dear Mr. Coffey:

By letter dated August 3, 2021 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML21215A314), as revised by letter dated October 12, 2021 (ML21285A107) and supplemented by letters dated April 7, 2022 (ADAMS Accession No. ML22097A202), April 13, 2022 (ADAMS Accession No. ML22103A014) and May 12, 2022 (ADAMS Accession No. ML22139A083), Florida Power & Light Company (FPL or the applicant) submitted an application for the subsequent license renewal of Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Units. 1 and 2 (St. Lucie), to the U.S.

Nuclear Regulatory Commission (NRC). FPL submitted the application pursuant to Title 10 of the Code of Federal Regulations part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal.

The NRC staff completed its aging management audit from October 4, 2021 - February 25, 2022, in accordance with the audit plan (ADAMS Accession No. ML21245A305). The audit report is enclosed.

If you have any questions, please contact me by e-mail at Brian.Harris2@nrc.gov.

Sincerely,

/RA/

Brian Harris, Senior Project Manager License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389

Enclosure:

Audit Report cc w/encl: Listserv

ML22188A086 NRR-106 OFFICE PM:NRLP:DNRL PM:NRLP:DNRL LA:NRLP:DNRL BC:NPHP:DNRL BC:NCSG:DNRL BC:NVIB:DNRL NAME VThomas BHarris YEdmonds MMitchell SBloom ABuford DATE 05/13/22 06/15/22 06/23/22 05/19/22 05/23/22 06/30/22 OFFICE BC:ESEB:DEX ABC:ELTB:DEX BC:SFNB:DSS BC:NRLP:DNRL PM:NRLP:DNRL NAME JColaccino SWyman RLukes LGibson BHarris DATE 04/14/22 05/05/22 06/30/22 07/07/22 07/07/22

Enclosure AUDIT REPORT Aging Management Audit St. Lucie Plant, Units 1 and 2 Subsequent License Renewal Application October 4, 2021 - February 25, 2022 Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF NEW AND RENEWED LICENSES Docket Nos:

50-335 and 50-389 License No:

DPR-67 and NPF-16 Licensee:

Florida Power & Light Company (FPL)

Facility:

St. Lucie Plant (SLP), Units 1 and 2 Location:

Rockville, Maryland Dates:

October 4, 2021 - February 25, 2022 Approved By:

Steven D. Bloom, Chief Corrosion and Steam Generator Branch Division of New and Renewed Licenses Angie R. Buford, Chief Vessels and Internals Branch Division of New and Renewed Licenses Joseph Colaccino, Chief Structural, Civil, Geotech Engineering Branch B Division of Engineering and External Hazards Lauren K. Gibson, Chief License Renewal Projects Branch Division of New and Renewed Licenses Steve Wyman, Acting Chief Long Term Operations and Modernization Branch Division of Engineering and External Hazards Scott T. Krepel, Chief Nuclear Systems Performance Branch Division of Safety Systems Robert G. Lukes, Chief Nuclear Methods and Fuel Analysis Branch Division of Safety Systems Matthew A. Mitchell, Chief Piping and Head Penetrations Branch Division of New and Renewed Licenses Jennifer Whitman, Chief PRA Licensing Branch B Division of Risk Assessment

Brian D. Wittick, Chief Containment & Plant Systems Branch Division of Safety Systems Reviewers:

Name Organization Naeem Iqbal PRA Licensing B (APLB)/Division of Risk Assessment (DRA)

Thinh Dinh APLB/DRA Duc Nguyen Long Term Operations & Modernization Branch (ELTB)/Division of Engineering and External Hazards (DEX)

Matthew McConnell ELTB/DEX Jorge Cintron ELTB/DEX Gurcharan (Singh) Matharu ELTB/DEX Liliana Ramadan ELTB/DEX Hari Kodali Electrical Engineering Branch (EEEB)/DEX Adakou Foli EEEB/DEX Andrew Prinaris Structural, Civil, Geotech Engineering (ESEB)/DEX Bryce Lehman ESEB/DEX George Thomas ESEB/DEX George Wang ESEB/DEX Juan Lopez ESEB/DEX Ata Istar ESEB/DEX Zuhan Xi ESEB/DEX Andrew Johnson Corrosion and Steam Generator (NCSG)/New and Renewed Licenses (DNRL)

Brian Allik NCSG/DNRL Gregory Makar NCSG/DNRL James Gavula NCSG/DNRL Leslie Terry NCSG/DNRL Lydiana Alvarado NCSG/DNRL Matthew Yoder NCSG/DNRL Paul Klein NCSG/DNRL Tony Gardner NCSG/DNRL David Pratt NCSG/DNRL Ali Rezai Piping and Head Penetrations (NPHP)/DNRL Bart Fu NPHP/DNRL Eric Reichelt NPHP/DNRL Jay Collins NPHP/DNRL Var Kalikian NPHP/DNRL Seung Min NPHP/DNRL Carolyn Fairbanks Vessels and Internals (NVIB)/DNRL Isaac Anchondo-Lopez NVIB/DNRL David Dijamco NVIB/DNRL Jim Medoff NVIB/DNRL

John Tsao NVIB/DNRL Karen Sida NVIB/DNRL On Yee NVIB/DNRL David Nold Containment and Plant Systems (SCPB)/Division of Safety Systems (DSS)

Danny Chien SPCB/DSS Derek Scully SCPB/DSS Raul Hernandez SCPB/DSS Steve Jones SCPB/DSS Angelo Stubbs SCPB/DSS Diana Woodyatt Nuclear Systems Performance (SNSB)/DSS Jeremy Dean Nuclear Methods and Fuels (SFNB)/DSS Kent Wood SFNB/DSS Brian Harris License Renewal Projects Branch (NLRP)/DNRL Vaughn Thomas NLRP/DNRL Bill Rogers NLRP/DNRL

TABLE OF CONTENTS AUDIT REPORT......................................................................................................................

TABLE OF CONTENTS...........................................................................................................

ACRONYMS............................................................................................................................

1.

Introduction.......................................................................................................................

2.

Audit Activities..................................................................................................................

SLRA AMP B2.2.1, Fatigue Monitoring................................................................................

SLRA AMP B2.2.2, Neutron Fluence Monitoring Program...................................................

SLRA AMP B2.2.3, Environmental Qualification (EQ) of Electric Equipment.......................

SLRA AMP B2.3.1, American Society of Mechanical Engineers (ASME)Section XI Inservice Inspection (ISI), Subsections IWB, IWC, and IWD............................................

SLRA AMP B2.3.2, Water Chemistry...................................................................................

SLRA AMP B2.3.3, Reactor Head Closure Stud Bolting....................................................

SLRA AMP B2.3.4, Boric Acid Corrosion...........................................................................

SLRA AMP B2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components.....

LRA AMP B2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) - 16 SLRA AMP B2.3.7, Reactor Vessel Internals.....................................................................

SLRA AMP B2.3.8, Flow-Accelerated Corrosion...............................................................

SLRA AMP B2.3.9, Bolting Integrity...................................................................................

SLRA AMP B2.3.10, Steam Generators............................................................................

SLRA AMP B2.3.11, Open-Cycle Cooling Water System..................................................

SLRA AMP B2.3.12, Closed Treated Water Systems........................................................

SLRA AMP B2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems.........................................................................................

SLRA AMP B2.3.14, Compressed Air Monitoring..............................................................

SLRA AMP B2.3.15, Fire Protection..................................................................................

SLRA AMP B2.3.16, Fire Water System............................................................................

SLRA AMP B2.3.17, Outdoor and Large Atmospheric Metallic Storage Tanks.................

SLRA AMP B2.3.18, Fuel Oil Chemistry............................................................................

SLRA AMP B2.1.19, Reactor Vessel Material Surveillance...............................................

SLRA AMP B2.3.20, One-Time Inspection........................................................................

SLRA AMP B2.3.21, Selective Leaching............................................................................

SLRA AMP B2.3.22, ASME Code Class 1 Small-Bore Piping...........................................

SLRA AMP B2.3.23, External Surfaces Monitoring of Mechanical Components...............

SLRA AMP B2.3.24, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components...................................................................................................................

SLRA AMP B2.3.25, Lubricating Oil Analysis....................................................................

SLRA AMP B2.2.26, Monitoring of Neutron-Absorbing Materials Other Than Boraflex.....

SLRA AMP B2.3.27, Buried and Underground Piping and Tanks......................................

SLRA AMP B2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks..................................................................................................

SLRA AMP B2.3.29, ASME Section XI, Subsection IWE...................................................

SLRA AMP B2.3.30, ASME Section XI, Subsection IWF...................................................

SLRA AMP B2.3.31, 10 CFR Part 50, Appendix J.............................................................

SLRA AMP B2.3.32, Masonry Walls..................................................................................

SLRA AMP B2.2.33, Structures Monitoring........................................................................

SLRA AMP B2.3.34, Inspection of Water-Control Structures Associated With Nuclear Power Plants..............................................................................................................................

SLRA AMP B2.3.35, Protective Coating Monitoring and Maintenance..............................

SLRA AMP B2.3.36, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.............................................

SLRA AMP B2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. -

74 -

SLRA AMP B2.3.38, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements............................

SLRA AMP B2.3.39, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements............................

SLRA AMP B2.3.40, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements............................

SLRA AMP B2.3.41, Metal Enclosed Bus..........................................................................

SLRA AMP B2.3.42, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements....................................................................

SLRA AMP B2.3.43, High-Voltage Insulators....................................................................

SLRA AMP B2.3.44, Pressurizer Surge Line.....................................................................

SLRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses...........................

SLRA TLAA Section 4.2.1, Neutron Fluence Projections...................................................

SLRA TLAA Sections 4.2.2 through 4.2.5..........................................................................

SLRA TLAA Section 4.3.1, Metal Fatigue of Class 1 Components....................................

SLRA TLAA Section 4.3.2, Metal Fatigue of Non-Class Components...............................

SLRA TLAA Section 4.3.3, Environmentally-Assisted Fatigue...........................................

SLRA TLAA Section 4.3.4, High Energy Line Break Analyses...........................................

SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment....................

SLRA TLAA Section 4.5, Concrete Containment Tendon Prestress..................................

SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments and Penetration Fatigue............................................................................................................................

SLRA TLAA Section 4.7.1, Leak-Before-Break of Reactor Coolant System Piping...........

SLRA TLAA Section 4.7.2, Alloy-600 Instrument Nozzle Repairs......................................

SLRA TLAA Section 4.7.3, Unit 1 Core Support Barrel Repairs...................................... - 100 -

SLRA TLAA Section 4.7.4, Reactor Coolant Pump Flywheel Fatigue Crack Growth....... - 103 -

SLRA TLAA Section 4.7.5, RCP Case N-481................................................................. - 105 -

SLRA TLAA Section 4.7.6, Crane Load Cycle Limit......................................................... - 106 -

SLRA TLAA Section 4.7.7, Flaw Tolerance Evaluation for CASS RCS Piping Components..... -

107 -

SLRA TLAA Section 4.7.8, Unit 2 Structural Weld Overlay PWSCC Crack Growth Analysis.... -

109 -

AMR Items Not Associated with an AMP......................................................................... - 110 -

3.

Supplements to the SLRA............................................................................................ - 122 -

4.

Audit Questions Provided to FPL................................................................................. - 122 -

5.

Applicant Personnel Contacted During Audit............................................................... - 123 -

6.

Exit Meeting.................................................................................................................. - 125 -

ACRONYMS ALE adverse localized environment ADAMS Agencywide Documents Access and Management System AFW auxiliary feedwater AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers BA boric acid BACC boric acid corrosion control BFB baffle-former-bolts BB baffle-to-baffle CASS Cast Austenitic Stainless Steel CFR Code of Federal Regulations CLB current licensing basis CB core barrel CB-F core barrel-to-former CID changes in dimension CRGT control rod guide tube CSS core support shield CR condition report CRDM control rod drive mechanism CRGT control rod guide tube CUF cumulative usage factor CUFen environmentally-adjusted cumulative usage factor DM dissimilar metal Dpm drops per minute EAF Environmentally-Assisted Fatigue EFPY effective full-power years EPRI Electric Power Research Institute FAC Flow-Accelerated Corrosion FE Further Evaluation FERC Federal Energy Regulatory Commission FD flow distributor FMP fatigue monitoring program ft-lb foot-pound

GALL-SLR NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal HELB high energy line break I&E inspection and evaluation IA instrument air IASCC irradiation-assisted stress corrosion cracking IMI incore monitoring instrumentation ISR/IC irradiation-enhanced stress relaxation or creep IE irradiation embrittlement ISG Interim Staff Guidance ISI inservice inspection LAR license amendment request LBB leak-before-break LDs locking devices LWs locking welds LOFT loss of fracture toughness LOM loss of material LOP loss of preload LCB lower core barrel LGA lower grid assembly LTS lower thermal shield LR license renewal LTOP low temperature overpressure protection MLDs modified locking devices MOV motor operated valve MRP materials reliability program mV milliVolt NAM no additional measures NDE nondestructive examination NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission NSSS nuclear steam supply system OBE operating basis earthquake OLDs original locking devices OpE operating experience P-T pressure-temperature PTS Pressurized Thermal Shock

PWR pressurized water reactor PWSCC primary water stress corrosion cracking RAI request for additional information RCI request for confirmation of information RCP reactor coolant pump RIS regulatory issue summary RPV reactor pressure vessel RTNDT reference temperature nil ductility RTPTS reference temperature for pressurized thermal shock RV reactor vessel RVI reactor vessel internal SCC stress corrosion cracking SE safety evaluation SER safety evaluation report SG steam generator SLR Subsequent License Renewal SLRA subsequent license renewal application SRP-SLR NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants SWGR switchgear TE thermal aging embrittlement TLAA Time-Limited Aging Analyses UFSAR Updated Final Safety Analysis Report UCB upper core barrel UGA Upper Grid Assembly USE upper-shelf energy UT ultrasonic testing UTS upper thermal shield VS void swelling VT visual examination VV vent valve WO work order WOL weld overlay

Report for the Aging Management Audit St. Lucie Plant, Units 1 and 2 Subsequent License Renewal Application

1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an aging management audit of Florida Power & Light Company (FPL, applicant) of (1) plant-specific operating experience (OpE), (2) methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR)

(Scoping and Screening Portion), and (3) aging management programs (AMPs), AMR items, Time-Limited Aging Analyses (TLAA) and associated bases and documentation as applicable (AMP and TLAA Portion) for the subsequent license renewal (SLR) of Renewed Facility Operating License Nos. DPR-67 and NPF-16 for St. Lucie Plant (SLP), Units 1 and 2.

The purpose of the plant-specific OpE portion of the audit is to identify examples of age-related degradation, as documented in the applicants corrective action program database. FPL searched their OpE database and provided the results for the associated AMPs and TLAAs for NRC staff review. Additional word searches were performed by FPL upon NRC staffs request, and the results were provided to the NRC staff for review.

The purpose of the Scoping and Screening portion of the audit is to evaluate the scoping and screening process as documented in the license renewal application, implementing procedures, reports, and drawings, such that the NRC staff:

Obtains an understanding of the process used to identify the SSCs within the scope of license renewal and to identify the structures and components subject to an AMR.

Has sufficient docketed information to allow the staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied.

The purpose of the AMP and TLAA Portion of the audit is to:

Examine FPLs AMPs, AMR items, and TLAAs for SLP; Verify FPLs claims of consistency with the corresponding NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued in July 2017, AMPs, and AMR items; and Assess the adequacy of the TLAAs.

Enhancements and exceptions will be evaluated on a case-by-case basis. The NRC staffs review of enhancements and exceptions will be documented in the safety evaluation report (SER).

The regulatory bases for the audit was Title 10 of the Code of Federal Regulations (10 CFR) part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. The staff also considered the guidance contained in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), dated July 2017, and NUREG-2191. The SRP-SLR allows an applicant to reference in its license renewal application the AMPs described in GALL-SLR Report. By referencing the GALL-SLR

Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL-SLR Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL-SLR Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL-SLR Report program. The applicant should document this determination in an auditable form and maintain the documentation onsite.

2. Audit Activities A regulatory audit is a planned, license-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain greater understanding of an application, to verify information, and, if applicable, to identify information that will require docketing to support the staffs conclusions that form the basis of the licensing or regulatory decision.

Licensing conclusions or staff findings are not made in the audit reports since licensing and regulatory decisions cannot be made solely based on an audit. Therefore, items identified but not resolved within the scope of the audit will be followed up using other NRC processes, such as requests for additional information (RAIs), requests for confirmation of information (RCIs),

and public meetings. Licensing conclusions, staff findings, and resolution of audit items will be documented in the staffs SER.

The following sections discuss the subsequent license renewal application (SLRA) areas reviewed by the staff.

SLRA AMP B2.2.1, Fatigue Monitoring Summary of Information in the Application. The SLRA states that AMP B2.2.1, Fatigue Monitoring, is an existing program with enhancements that is consistent with the program elements in GALL-SLR Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. Furthermore, the staff conducted additional OpE searches on the applicants Corrective Action Program (CAP) database.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 NEESL00008-REPT-039 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Fatigue Monitoring Revision 0 ADM-17.43 Component Cycles and Transients Revision 2 PSL-ENG-SEMJ-18-001 Changes to Component Cyclic or Transient Limits on Fatigue Re-evaluation of 2B RSG Primary Side Components Revision 0 Action Request (AR) 2374153 License Renewal Effectiveness and SLR Interview Track 11/2/2020 AR 2115822 Self-Assessment for Unit 2 IP-71003 Phase I and II License Renewal Inspection 2/2/2017 SIR-01-102 Thermal Cycle Evaluation for St. Lucie Units 1 and 2

Revision 3 Westinghouse LTR-SDA-II-20 NP St. Lucie Units 1 and 2 SLR: Primary Equipment and Piping Environmentally-Assisted Fatigue Evaluations Revision 2 SIA Calculation Package 1301103.304 Appendix L Flaw Tolerance Evaluation of Surge Line PSL Units 1 and 2 Revision 2 SIA 2001262.401 Flaw Tolerance Evaluation of St. Lucie Units 1 and 2 Surge Line Using ASME Code,Section XI, Appendix L for SLR Revision 1 CEN-387-P Pressurizer Surge Line Flow Stratification Revision 1-P-A CE Specification Number 19367-31-5 Engineering Specification for Reactor Coolant Pipe and Fittings for Florida Power and Light St. Lucie Plant Unit No. 1 Revision 14 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, detection of aging effects, and parameters monitored or inspected program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements.

The staff found that, for the monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these

program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff made the following observations.

The monitoring and trending program element of GALL-SLR Report AMP X.M1, Fatigue Monitoring Program indicates that the program provides for revisions to the fatigue analyses or other corrective actions (e.g., revising augmented inspection frequencies) on an as-needed basis if the values assumed for fatigue parameters are approached or the transient counts exceed the design or assumed quantities. In comparison, SLRA Section B.2.3.44 addresses the ASME Code, section XI, appendix L flaw tolerance analysis for the pressurizer surge line. However, SLRA section B.2.2.1 for the Fatigue Monitoring Program does not clearly describe whether the program will monitor the transient cycles, which are assumed in the appendix L analysis, to ensure the validity of the assumed transient cycles.

In relation to the acceptance criteria and corrective actions program elements, Enhancement 5 of the Fatigue Monitoring Program is to update the program governing procedure to add an additional acceptance criterion associated with high energy line break (HELB) cumulative usage factor (CUF) criteria. This enhancement is applied only to St. Lucie Unit 2 and is related to the HELB analyses addressed in SLRA Section 4.3.4. The enhancement does not clearly define the additional acceptance criterion associated with the HELB CUF. In addition, the enhancement does not clearly address any additional corrective actions that may need to be performed beyond the actions specified in the corrective actions program element if the additional criterion associated with the HELB CUF is not met.

The staff also audited the description of the SLRA Fatigue Monitoring Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.2.2, Neutron Fluence Monitoring Program Summary of Information in the Application. The SLRA states that AMP B.2.2.2, Neutron Fluence Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.M2, Neutron Fluence Monitoring, as modified by SLR-ISG-MECHANICAL-2021-02-MECHANICAL, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance, (ADAMS Accession Number ML20181A434). To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During its audit, the staff reviewed documentation contained in the SLRA and provided by FPL via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date

TR-F-MCM-004 St. Lucie, Unit 1, Post-Irradiation Evaluation of Reactor Vessel Surveillance Capsule W-97 12/1983 WCAP-12751 Analysis of the Capsule at 104° from the Florida Power and Light St. Lucie Unit No. 1 Reactor Vessel Radiation Surveillance Program 11/1990 WCAP-15446 Analysis of the Capsule at 284° from the Florida Power and Light St. Lucie Unit No. 1 Reactor Vessel Radiation Surveillance Program 05/2002 Revision 1 BAW-1880 Analysis of Capsule W-83, Florida Power and Light, St.

Lucie Unit No. 2, Reactor Vessel Materials Surveillance Program 09/ 1985 WCAP-15040, Analysis of the Capsule at 263° from the Florida Power and Light St. Lucie Unit No. 2 Reactor Vessel Radiation Surveillance Program 02/2010 Revision 1 WCAP-17939-NP Analysis of the Capsule at 97° from the Florida Power and Light St. Lucie Unit No. 2 Reactor Vessel Radiation Surveillance Program 05/2015 Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the SLRA AMP will be consistent after implementation of the identified enhancements.

SLRA AMP B2.2.3, Environmental Qualification (EQ) of Electric Equipment Summary of Information in the Application. The SLRA notes that AMP B2.2.3, Environmental Qualification of Electric Equipment, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR report X.E1, Environmental Qualification of Electric Equipment. To verify this claim of consistency, the staff audited the AMP. During the audit, the staff also reviewed the enhancement associated with this AMP. The staff will document its review of the enhancement in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date AR 02013850 U1: MSIV Solenoid Valve Coil Thermal Life (EQ) 12/17/2014

Document Title Revision /

Date AR 02128663 EQ CDBI Identified CHRRM Indication Error During DBA 04/28/2016 AR 02137338 ACE to Address Green NCV from NRC EQ CDBI 06/10/2016 AR 02128751 EQ CDBI Identified Issue Related to Program Documentation 04/29/2016 AR 02388818 OpE from PB EQ SLR NRC Review Regarding Use of EPRI NP1558 04/05/2021 AR 02214276 U2: EQ/HCV092B Replace Limit Switch 07/10/2017 AR 02347464 Rosemount Interim Eval of Deviation 03/06/2020 AR 02376733 EQ LR Effectiveness Review 11/26/2020 AR 02128612 EQ Doc Pac Did Not Specify Limiting Component 04/28/2016 N/A EQ Program Health Report 11/24/2020 NEESL00010 CALC001 PSL SLR 80Year Doses for Equipment Qualification Revision 0 PSL-ENG-LRAM00099 EQ Program-License Renewal Basis Document Revision 8 St. Lucie Plant Unit No. 2 Equipment Qualification Documentation Package Drawing No.

2998A-4511000 Equipment Qualification Report and Guidebook Revision 12 St. Lucie Plant Unit No. 1 Equipment Qualification Documentation Package Drawing No.

8770A-4511000 Equipment Qualification Report and Guidebook Revision 14 ERAA112 EQ Program Revision 5 QI2PSL6 EQ of Electric Equipment Revision 9 N/A PSL SLR EQ Program Update Review N/A

Document Title Revision /

Date Doc Pac No. 41.0 Automatic Valve Company (AVCO) Solenoid Valves NEW &

Revision 5 Doc Pac No. 5.0 Brand-Rex Cable Company Electric Cable NEW &

Revision 9 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancement.

The staff also audited the descriptions of SLRA sections 19.2.1.3, Environmental Qualification of Electric Equipment, and 19.3.4, Environmental Qualification of Electric Equipment, of appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the descriptions provided in the SRP-SLR Report.

SLRA AMP B2.3.1, American Society of Mechanical Engineers (ASME)Section XI Inservice Inspection (ISI), Subsections IWB, IWC, and IWD Summary of Information in the Application. The SLRA states that AMP B2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal.

For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-041 St Lucie Units 1 and 2 SLR Aging Management Program Basis Document - ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Revision 0:

07/27/2021 NEESL00008-REPT-005 St. Lucie Units 1 and 2 SLR Screening and Aging Management Review Results - Reactor Coolant Piping Revision 0 07/27/2021

Document Title Revision /

Date NEESL00008-REPT-003 St. Lucie Units 1 and 2 Subsequent License Renewal -

Review of Plant Modifications That Impact SLRA Revision 8 07/22/2020 4th-ISI-PSL Program Plan St. Lucie Nuclear Power Plant Unit 2 Fourth Inservice Inspection Interval Program Plan Revision 3 08/25/2020 5th Interval -ISI-PSL-1-Program Plan Fifth Inservice Inspection Interval Program Plan for St.

Lucie Nuclear Power Plant Unit 1 Revision 0 02/10/2018 PSL-ENG-SESJ-15-003 St. Lucie Unit 1, SL1-26 Outage, Owners Activity Report, Form OAR-1 07/22/2015 PSL-ENG-SESJ-17-001 St. Lucie Unit 1, SL1-27 Outage, Owners Activity Report, Form OAR-1 02/01/2017 PSL-ENG-SESJ-18-005 St. Lucie Unit 1, SL1-28 Outage, Owners Activity Report, Form OAR-1 07/06/2018 ISI-PSL-1-2019 St. Lucie Unit 1, SL1-29 Outage, Owners Activity Report, Form OAR-1 02/14/2020 PSL-ENG-SESJ-16-001 St. Lucie Unit 2, SL2-22 Outage, Owners Activity Report, Form OAR-1 01/14/2016 PSL-ENG-SESJ-17-004 St. Lucie Unit 2, SL2-23 Outage, Owners Activity Report, Form OAR-1 06/15/2017 PSL-ENG-SESJ-18-006 St. Lucie Unit 2, SL2-24 Outage, Owners Activity Report, Form OAR-1 12/10/2018 PLS-ENG-SESJ-20-002 St. Lucie Unit 2, SL2-25 Outage, Owners Activity Report, Form OAR-1 06/10/2020 STD-M-027 Engineering Program for ASME Section XI Repair and Replacement Revision 6 05/13/2014 0005760 St. Lucie Plant Implementation Guidelines of the ASME Section XI Repair and Replacement Program Revision 22 01/25/2019 CR-02323559-02 Boric Acid Make-up Pump 2A Active Leakage at Pump Casing (St Lucie Unit 2) 08/06/2019 AR 02279817 Boric Acid Leak at Pressurizer to Instrument Nozzle During the ISI Bare Metal Visual Inspection of the Pressurizer Level Nozzle (St Lucie Unit 2) 09/11/2018

Document Title Revision /

Date AR 02279817-01 Engineering Final Disposition: Boric Acid Leak at Pressurizer to Instrument Nozzle Revision 2 09/17/2018 ADAMS Accession No. ML18351A242 LER 2018-001-01 for St. Lucie, Unit 2, Pressurizer Instrument Nozzle Leak Due to Primary Water Stress Corrosion Cracking 12/17/2018 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also audited the description of the SLRA AMPB2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report/SRP-SLR.

SLRA AMP B2.3.2, Water Chemistry Summary of Information in the Application. The SLRA states that AMP B2.3.2, Water Chemistry is an existing program with enhancements that is consistent with the program elements in GALL-SLR Report AMP XI.M2, Water Chemistry, as modified by SLR-ISG-2021-02-MECHANICAL, Updated Aging Management Criteria for Mechanical Portions of SLR Guidance, dated February 2021 (ML20181A434). To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date Report No.

NEESL0008-REPT-042 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document Water Chemistry Revision 0 ER-AA-110-005 Reactor Vessel Integrity Program Revision 05 ADM - 17.38 St. Lucie Reactor Vessel Integrity Program Revision 02 EC-00287790 St. Lucie Reactor Vessel Integrity Program -

License Renewal Basis Document Revision 00

WCAP-15446 Analysis of Capsule 284 from the Florida Power Light Company St. Lucie Unit 1 Reactor Vessel Radiation Surveillance Program Revision 01 PSL-ENG-SESJ 016 License Amendment Request Evaluation for RCS Pressure/Temperature Limits and LTOP applicable for 55 Effective Full-Power Years Revision 01 EC-289817 St Lucie Unit 2 Input Parameters EFPY Pressure-Temperature (P-T) Limits and LTOP Requirements Revision 00 L-2015-160 St Lucie Unit 2 Reactor Vessel Surveillance Capsule 97 Degree Report Submittal Docket No.

50-389 05/21/2015 EC-294196 Florida Power and Light St Lucie Unit 2 Revision 01 CRTD Consensus on Operating Practices For the Control of Feed Water Chemistry in Modern Industrial Boilers Volume 34 SRL Document Changes: X1.M2 Water Chemistry Table 2-29 SRL-Mechanical-2020-XX Updated Aging Management Criteria for Mechanical Portions of SLR Guidance Interim Staff Guidance 06/2020 Assessment AR 402040402040License Renewal Focused Self-Assessment 09/16/2010 AR # 02229642 Revision 8 Gap Analysis October 11, 2017 EPRI Primary 3002000505 Pressurized Water Reactor Primary Water Chemistry Guidelines Volume 1 Revision 7 04/2014 EPRI Secondary Pressurized Water Reactor Secondary Water Chemistry Guidelines Revision 7 02/2009 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also audited the description of the SLRA Water Chemistry program provided in the UFSAR supplement in Appendix A of the SLRA. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The SLRA states that AMPB2.3.3, Reactor Head Closure Stud Bolting, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-SLR Report AMP XI.M3, Reactor Head Closure

Stud Bolting. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision /

Date NEESL00008-REPT-062 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document -

Reactor Head Closure Stud Bolting Revision 0 NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 NRC Regulatory Guide 1.65 Materials and Inspections for Reactor Vessel Closure Studs Revision 1 AR 01774125 Corrosion and nicks on RPV nuts 12/17/2020 (AR date) 06/7/2012 (event date)

AR 01915467 Reactor vessel closure head stud #49 did not thread in flange 11/30/2020 (AR date) 10/26/2013 (event date)

NRC Safety Evaluation (ADAMS Accession No. ML21027A226)

St. Lucie Plant, Units. 1 and 2 - Approval of Alternative to ASME Code,Section XI to Use an Alternative Inservice Inspection Schedule for the Reactor Vessel Closure Head Bolting (EPID L-2020-LLR-0020) 02/17/2021 Volumetric examination records Documented results of volumetric examinations performed for the 54 reactor head closure studs and 54 threads-in-flange various

During the audit, the staff verified the applicants claim that the scope of program, parameters monitored or inspected, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff noted the exceptions to the preventive actions, detection of aging effects and corrective actions program elements and verified the applicants claim that the aspects of these three program elements not associated with the exceptions identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP or will be consistent after implementation of the enhancements (in the preventive actions and corrective actions program elements) stated in the SLRA. During the audit, the staff identified an exception associated with the monitoring and trending program element.

In addition, the staff determined that for the detection of aging effects and monitoring and trending program elements, the staff will consider issuing an RAI in order to obtain the information necessary to verify whether the exception to the program elements is acceptable.

During the audit, the staff made the following observations:

In NEESL00008-REPT-062, Revision 0, the applicant referred to the ASME Code, section XI, Table IWB-2500-1 for examination of the reactor head closure studs for the detection of aging effects and monitoring and trending program elements. The applicant is taking exception to the detection of aging effects program element because of an alternative inspection schedule in lieu of that specified in ASME Code, section XI, table IWB-2500-1.

The NRC-approved this alternative in the safety evaluation dated February 17, 2021, listed in the documents the staff reviewed.

The staff noted that, per the safety evaluation dated February 17, 2021, the alternative is authorized only through the fifth 10-year inservice inspection interval of Unit 1 and only through the fourth 10-year inservice inspection interval of Unit 2.

In AR 01915467, the applicant documented the OpE on the Unit 1 reactor vessel closure head stud #49 not threading into the flange. The applicant stated that the stud was eventually threaded into the flange after repeated cleaning of the stud.

The staff also audited the description of the SLRA Reactor Head Closure Stud Bolting AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.4, Boric Acid Corrosion Summary of Information in the Application. The SLRA states that AMP B2.3.4, Boric Acid Corrosion is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M10, Boric Acid Corrosion. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the Boric Acid Corrosion program. These documents were provided by the applicant or were identified by the staff to be relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision/Date NEESL00008-REPT-043 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Boric Acid Corrosion Revision. 0 ER-AP-116-1000-10000 Boric Acid Corrosion Control Desk-top Instruction, Boric Acid Corrosion Control Program Implementation Revision. 0 ER-AP-116-1000 Boric Acid Corrosion Control Program Revision 5 ER-AP-116 Boric Acid Corrosion Control Revision 3 PSL-ENG-LRAM-00-090 Boric Acid Wastage Surveillance Program - License Renewal Basis Document Revision 7 Revision 8 ER-AP-116-1000-F01 Boric Acid Leak Screening Revision 3 NEESL00008-REPT-038 SLR Aging Effects OpE Revision 0 AR 02115822 Self-Assessment for Unit 2 IP-71003 Phase I & II License Renewal Inspection 1/30/2017 AR 02140203 Majority of Boric Acid Leaks Identified by Engineering 7/5/2016 AR 02263431-01 Cognitive Trend Identified by MRC for Boric Acid WOs Closure None AR 02310112-08 AMP Effectiveness Review and Assessment Worksheet 9/12/2019 AR 02323757 Adverse Trend in Through-Wall Boric Acid Leaks 8/7/2019 AR 02325987 Inadequate Initial Assessment and Response to Boric Acid Identification 6/11/2020 AR 02181945 SL1-28 1B2 RCP Boric Acid Cleanup 1/26/2017 AR 02381822 License Renewal Aging Management Program Effectiveness Review Roll Up 11/2/2020 None PSL Program Owner Interview Form, Boric Acid Corrosion None None Master System Health Report, PSL, Boric Acid Corrosion (2015-2020) 11/24/2020 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are or will be consistent, after implementation of the identified enhancements, with the corresponding elements of the GALL-SLR Report AMP.

The staff also audited the description of the SLRA Boric Acid Corrosion program provided in the UFSAR supplement in appendix A of the SLRA. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The SLRA states that AMPB2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-induced Corrosion in Reactor Coolant Pressure Boundary Components. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. The staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Relevant Documents Reviewed Document Title Revision / Date NEESL00008-REPT- 044 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-induced Corrosion in Reactor Coolant Pressure Boundary Components Revision 0 07/28/2021 ER-SR-107 Alloy 600 Management Program - The applicant has maintained a fleetwide program based on MRP-126, Materials Reliability Program Generic Guidance for Alloy 600 Management, and updated on a periodic basis Revision 5 09/24/2019 AR02279817 Bare metal visual examination performed on the Unit 2 pressurizer level nozzle identified boric acid leak at the piping-to-pressurizer interface. Engineering evaluation determined a through-wall flaw in Alloy 600 weld pad. The weld pad was replaced with Alloy 690 material.

09/11/2018 AR02303281 Regulatory Issue Summary (RIS) 2018-06, Clarification of the Requirements for Reactor Pressure Vessel Upper Head Bare Metal Visual Examinations, has been incorporated into St.

Lucies ISI program.

02/25/2019

NEESL00008-REPT- 044 Electric Power Research Institute (EPRI) Technical Report (TR) 3002017288, Materials Reliability Program: Guideline for Nondestructive Examination of Reactor Vessel Upper Head Penetrations, Revision 1 (MRP-384), dated 2019 has been incorporated into St. Lucies ISI program.

Revision 0 07/28/2021 AR00381980 EPRI TR 1018181, Nondestructive Evaluation:

Guideline for Conducting Ultrasonic Examinations of Dissimilar Metal Welds, dated 2009 has been incorporated into St. Lucies ISI program.

12/07/2009 AR02061596 RIS 2015-10, Applicability of ASME Code Case N-770-1 as Conditioned in 10 CFR 50.55a, Codes and Standards, to Branch Connection Butt Welds, has been reviewed and determined that it is not appliable because St. Lucie has no Alloy 600 branch connections.

07/21/2015 LTR-SDA-20-097-NP St. Lucie, Units 1 and 2 SLR: Alloy 600 Half-Nozzle Repair Flaw Evaluation.

Revision 1 03/2021 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP.

During the audit, the staff made the following observations:

The staff verified that the program basis document provides supporting evidence that a mitigation by component replacement with Alloy 690/52/152 materials accompanied with an augmented inservice inspection (ISI) performed as part of this AMP has been effective in detecting the PWSCC in the nickel-alloy welds and components as well as in identifying the presence of boric acid residues. As an example:

o The applicant has incorporated Regulatory Issue Summary (RIS) 2018-06, Clarification of the Requirements for Reactor Pressure Vessel Upper Head Bare Metal Visual Examinations, into its ISI program.

o The applicant has incorporated EPRI technical report (TR) 3002017288, Materials Reliability Program: Guideline for Nondestructive Examination of Reactor Vessel Upper Head Penetrations, Revision 1 (MRP-384), as an industry initiative under Nuclear Energy Institute (NEI) 03-08 implementation criteria, into its ISI program.

The staff interviewed the applicants staff to verify (a) the applicants review of the recent industry OpE documented in EPRI TR 3002012244, Revision 3, Nondestructive Evaluation: Guideline for Conducting Ultrasonic Examinations of Dissimilar Metal Welds, for applicability and implementation into its ISI program, and (b) if the applicable guidance has not been implemented, when would the applicant be planning on implementing the guidance. The applicant stated that it will provide response to the requested information by supplementing its submittal.

The staff interviewed the applicants staff and verified that the applicant has reviewed RIS 2015-10 for applicability to St. Lucie.

The staff also audited the description of the SLRA Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-induced Corrosion in Reactor Coolant Pressure Boundary Components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA AMP B2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

Summary of Information in the Application. The SLRA states that AMP B2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel, is an existing program that is consistent with the program elements in GALL-SLR report AMP XI.M12, Thermal Aging Embrittlement of CASS. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. The staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Relevant Documents Reviewed Document Title Revision /

Date NEESL00008-REPT-078 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Revision 0, 07/28/2021 Structural Integrity Report No.

2001262.402 Flaw Tolerance Evaluation of St. Lucie, Units 1 and 2 CASS Components for SLR Revision 1, 07/15/2021 Westinghouse Report (WCAP)-

18617-P St. Lucie Units 1 and 2 SLR: Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis Revision 1, 06/03/2021 Report No.

1301079.402 Development of a CASS Aging Management Program for St. Lucie, Units 1 and 2 Task 5 Report Revision 0, 09/2015 During the audit, the staff verified applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit, the staff made the following observations:

The staff noted that St. Lucie, Units 1 and 2 primary loop coolant systems have elbows and straight piping made of centrifugally cast A-351 grade CF8A material that are thermally aged during service. The applicant used GALL-SLR screening criteria based on the molybdenum content, casting method, and ferrite content to assess the susceptibility of cast elbow and pipe components at St. Lucie to thermal aging embrittlement. The applicant has chosen a plant-specific flaw tolerance evaluation to demonstrate that the thermally-embrittled CASS material has tolerance for large flaws.

As part of the original license renewal application, the applicant performed a baseline ultrasonic examination of the CASS components (i.e., surge line, safety injection nozzle safe-end, reactor coolant pump suction and discharge safe-end locations) susceptible to thermal aging embrittlement. The result of the applicants baseline volumetric examinations completed for Unit 1 in 2015 and Unit 2 in 2017 revealed no crack like indications that exceed the initial postulated flaw size of 25 percent through-wall thickness assumed in the flaw tolerance evaluation.

The staff noted that the applicant utilized NUREG-4513, revisions 1 and 2 for the fracture toughness correlation, and the results were compared. During the staffs interview of the applicants staff, the applicant confirmed that (a) it is aware of the errata issued by the NRC in 2021 for NUREG-4513, revision 2 (ML16145A082), and (b) it used the correct symbols (i.e., the errata corrected the symbols from 15 effective full-power years (EFPY) to read 15 EFPY for CF8M materials) in its flaw tolerance evaluation.

The staff also audited the description of the SLRA Thermal Aging Embrittlement of CASS provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR report.

If further information is needed to complete the staffs SE input, the staff will consider issuing RAIs.

SLRA AMP B2.3.7, Reactor Vessel Internals Summary of Technical Information in the Application. The SLRA states that the AMP in SLRA appendix B, section B2.3.7, Reactor Vessel Internals (SLRA pages B B-74) is an existing program that, with enhancements, will be consistent with the program elements in GALL-SLR report AMP XI.M16A, PWR Vessel Internals, as updated in NRC Interim Staff Guidance (ISG) No. SLR-ISG-2021-01-PWRVI. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancement in the SER. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program. The staffs audit only addressed the status of the applicants AMP (as modified by the results of applicants gap analysis defined in SLRA appendix C) prior to incorporation of the program elements of the AMP into the implementation procedures for the AMP. The staff will address issues identified but not resolved in this audit report or more complex RVI management issues (including the gap analysis result impacts on the inspection and evaluation [I&E] protocols of the AMP) in the SER.

Appropriate Background Information. The applicants AMP is defined as a living, risk-informed, sampling-based condition monitoring program (i.e., augmented I&E program) that is based on the latest staff-approved version of EPRI Materials Reliability Program (MRP) report MRP-227, Revision 1-A, and any industry supplemental guidelines issued and used to supersede or supplement the I&E guidelines in MRP-227. The applicant implements the program in accordance with the industry initiative protocols in the applicable version of NEI Report No. NEI

03-08, Guideline for the Management of Materials Issues, used for the CLB and the implementation of the guidance in chapter 7 of the current version of MRP-227, Revision 1-A, being used for the AMP.

For Combustion Engineering Company (CE)-designed reactors like the units at St. Lucie Station, the program places each RVI component into one of the four EPRI MRP-defined inspection categories (as defined in Section 1) [page 1-2] of the applicable MRR-227 version used for the AMP. The programmatic inspection-categorization of each component is based on a number of risk-informed assessment factors including (but not necessarily limited to): (1) failure modes, effects, and criticality analysis of the component, (2) a component-specific susceptibility assessment of the components material of fabrication to those aging mechanisms that are defined in section 3.2 of the applicable MRP-227 version used for the AMP; and (3) a functionality assessment of the intended function(s) of the component, and whether failure of component would impact those intended function(s) or the intended function(s) of another component that serves a safety related function for the facility, as defined in 10 CFR 54.4.

The guidelines in chapter 2 and the flowcharts in figures 2-1 and 2-2 of the applicable MRP-227 version define how these assessments interact with one another and factor in the final EPRI MRP risk-informed inspection-categorization for a specified RVI component in the St. Lucie reactor unit designs. The result of this four-step sample selection process is a set of Primary category RVI components in the units that are inspected because they are expected to be the leading component locations for potential initiation and growth of the age-related degradation effects, with another set of Expansion category internals component locations that are specified for either inspections or evaluations should the indications of aging in the linked Primary component type be more severe than anticipated. The degradation effects in a third set of internals locations are deemed to be adequately managed by Existing Programs, such as American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),

section XI, Examination Category B-N-3, examinations of core support structures. A fourth set of internals locations are deemed to require no aging management activities for the subsequent period of extended operation and are placed No Additional Measures category for the program.

The applicant addresses its component-specific categorization bases in the AMP, where the bases for the categorizations and the results of the categorizations are defined in either MRP-227, revision 1-A, or else as updated in the RVI gap analysis for AMP (as provided in SLRA appendix C) for components with programmatic I&E criteria that required adjustments from those defined for the component type in MRP-227, revision 1-A based on 80-year assessment considerations.

Audit Activities. During the audit, the staff reviewed the applicants AMP and the SLRAs gap analysis basis for categorizing placing each of the RVI components into the Primary, Expansion, Existing Programs, or NAM category of the AMP. The staff interviewed the applicants personnel and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date Updated Final Safety Analysis Reports Sections St. Lucie Updated Final Safety Analysis Report (Unit 1) section 4.2.2, Reactor Vessel Internals 12/31/2019 St. Lucie Updated Final Safety Analysis Report (Unit 1) section 4.2.3, Reactivity Control System 12/31/2019 Applicable SLRA Sections SLRA appendix A, UFSAR Supplement section 19.2.2.7 Reactor Vessel Internals Revision 0 SLRA appendix B, AMP section B.2.3.7 Reactor Vessel Internals Revision 0 SLRA appendix C Licensee Specific Activities Relative to RVI (i.e., RVI AMP Gap Analysis Basis)

Revision 0 SLRA section 3.1.2.2.9 Aging Management of Pressurized Water Reactor Vessel Internals (Applicable to Subsequent License Renewal Periods Only)

Revision 0 Basis Document Records and Relevant NRC, NEI, EPRI MRP, Vendor, or PWROG Documents NRC NUREG-2191, Volumes 1 and 2 Generic Aging Lessons Learned for GALL-SLR 07/2017 Enercon Report No.

NEESL00008-REPT-045 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document -

Reactor Vessel Internals Revision 0 NextEra Energy Engineering Evaluation No.

PSL-ENG-LRAM-15-002 Reactor Vessel Internals Inspection Program -

License Renewal Basis Document Revision 6 EPRI Non-Proprietary Report No. 3002017168 Material Reliability Program: Pressurized Water Reactor Internals I&E Guidelines (MRP-227, Revision 1-A 12/2019 (ML20175A112)

NEI Report No. 03-08 Guideline for the Management of Materials Issues Revision 3, 12/2017 (ML19079A253)

NEI Report No. 14-12 NEI, Aging Management Program Effectiveness Revision 1, 09/2020 (ML15090A665)

NRC ISG No. SLR-ISG-2021-01-PWRVI Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized Water Reactors 01/2021 (ML20217L203)

NRC SE for MRP-227, Rev. 1-A Final SE for EPRI Topical Report MRP-227, Revision 1, Materials Reliability Program:

Pressurized Water Reactor Internals I&E Guideline 04/25/2019 (ML19081A001)

NRC Verification Letter to EPRI MRP U.S. Nuclear Regulatory Commission Verification Letter for Electric Power Research Institute Report MRP-227, Revision 1, 02/19/2020 (ML20006D152)

Document Title Revision / Date Materials Reliability Program: Pressurized Water Reactor Internals I&E Guideline EPRI Proprietary Report No. 3002010399 Materials Reliability Program: Inspection Standard for PWR Internals (MRP-228, Rev.

3) 11/2018 (Non-publicly available; ML19081A064; a redacted, publicly available version of the report is available.

ML19081A058)

EPRI report No.

MRP 2018-022 Interim Guidance for the Pressurized Water Internals I&E Guidelines, MRP-227-A, For SLR - Westinghouse and Combustion Engineering-Designed Reactor Vessel Internals Revision 0 (ML19081A061)

EPRI e-Mail to NextEra Energy FW: Interim Guidance to MRP-227-A NEI 03-08 Needed Requirements for U.S. Domestic PWR Plants Implementing Flexible Power Operations (MRP 2019-002) 03/07/2019 EPRI MRP Interim Guidance No. MRP 2019-002 Interim Guidance to MRP-227-A NEI 03-08 Needed Requirements for U.S. Domestic PWR Plants Implementing Flexible Power Operations 03/06/2019 EPRI MRP Interim Guidance No. MRP 2019-001 Materials Reliability Program: Inspection Standard for PWR Internals - 2017 Update (MRP-228, Rev. 3) 01/21/2019 EPRI Report No.

MRP 2020-015 Biennial report of Recent MRP-227-A Reactor Internals Inspection Results 08/14/2020 (ML20229A000)

NRC SE to Mr. M. Nazar, President and Chief Nuclear Officer, Nuclear Division, Florida Power and Light Company St. Lucie Plant, Unit Nos. 1 and 2 - Review of License Renewal Commitment for Reactor Vessel Internals Aging Management Plan 05/02/2018 (ML18071A002)

EPRI Proprietary report No. 3002010268 Materials Reliability Program: PWR Internals Material Aging Degradation Mechanism Screening and Threshold Values (MRP-175, Revision 1) 10/2017 (ML21215A318)

PWROG Non-Proprietary Report No. PWROG-15032-NP PA-MSC-1288, Statistical Assessment of PWR RV Internals CASS Materials Revision 0 (ML16068A245 and ML16068A246)

Westinghouse Proprietary Report No. WCAP-18452-P St. Lucie Unit 1 Core Support Barrel and Core Shroud Flaw Analysis Revision 1, 03/2020

Document Title Revision / Date (Included as a Proprietary Enclosure in NextEra Energy AR QA No.

02333990)

Westinghouse Proprietary Letter and Analysis Summary No. LTR-AMLR-18-22 (Included as a Proprietary Enclosure in both NextEra Energy AR QA Nos.

02255865 and 0000290891)

Disposition of Indications Observed in the Core Support Barrel and St. Lucie Unit 1 Revision 0, 03/30/2018 NextEra Energy Procedures St. Lucie Plant Administrative Procedure No. ADM-17.29 Reactor Vessel Internals Aging Management Procedure Revision 9 NextEra Energy ARs NextEra Energy AR QA Record No. 02278961 Responses to PTN and PSL INPO MRV Recommendations 11/07/2018 NextEra Energy AR No.

02262124-04 (PSL)

Perform Level 1 Assessment for Reactor Vessel Internals (RVI) Program, Supports INPO Material Review Visit Revision 04 NextEra Energy AR QA Record No. 02256078 Wear Identified in Core Stabilizer Lug (RSVB-

1) 04/02/2018 NextEra Energy AR QA Record No. 02256266 Wear and/or Locking Pin Protrusion on Core Stabilizer Lugs 5&6 04/02/2018 NextEra Energy AR No.

02299052 Fleet Review of MRP 2019011 Industry Letter, Communicates MRP-228, Rev. 3 Issuance, RVI Program 03/01/2019 NextEra Energy AR QA Record No. 02333990 Summary of RVI Program, MRP-227 Core Barrel Exam Results 05/05/2020 NextEra Energy AR QA Record No. 02255865 Linear Indications on Core Support Barrel -

MRP-227-A Exams 11/20/2019 NextEra Energy AR QA Record No. 0000290891 Westinghouse Evaluation of Indications in U1 Core Support Barrel Revision 0 03/31/2018 NextEra Energy AR No.

02308972 Fleet Review of MRP -2019-002 Industry Letter, NEI 03-08 Needed Requirements for U.S. Domestic Plants Implementing Flexible Power Operations, RVI Program 05/01/2019 NextEra Energy AR No.

02321810 Fleet Review of MRP 2019-009, RVI Program, NEI 03-08 Good Practice Interim Guidance Regarding PWR Core Barrel and Core Support Barrel Inspection Requirements 07/19/2019 NextEra Energy AR No.

02350217 Fleet Review of MRP 2020-007, RVI Program, NRC Acceptance of MRP-227, Rev. 1-A 03/26/2020

Document Title Revision / Date NextEra Energy AR No.

02357503 Fleet Review of MRP 2020-011, RVI Program, Notification of Recent OpE Related to Displaced PWR Clevis Insert Assembly 05/22/2020 NextEra Energy AR No.

02235785 Fleet Review of MRP 2017-024 Clevis Insert Bolt OpE, ICES # 416600 11/09 and 10/2017 During the audit, the staff verified that applicants claim that the scope of program, preventive actions, parameters monitored or inspected, and corrective actions program elements are consistent with the corresponding program elements in GALL-SLR AMP XI.M16A, PWR Vessel Internals, as updated appendix D in NRC ISG Document No. SLR-ISG-2021-01-PWRVI.

During the audit, the staff made the following observations (StaffOb - Topic in the bullet title) or the applicant made the following clarifications (AppCl - Topic in the bullet title) in regard to program element aspects of the AMP:

AppCl - Plant Record Containing the Formal Gap Analysis. The applicant clarified that the formal RVI gap analysis used for the AMP is given in EPRI Letter No. MRP 2018-022.

StaffOb - Version of NEI 03-08 Applied to the AMP. The staff observed that the applicant uses NEI 03-08, Revision 3 as the applicable NEI 03-08 version for implementing its RVIs Program. The staff observed that the NRC does not have any restrictions of the version of NEI 03-08 being applied for the program.

StaffOb - NextEra Energy AR No. 02299052; Version of MRP-228 Inspection Standard Applied to the AMP. The staff observed that, consistent with EPRI MRP Interim Guidance No. MRP 2019-001 and NextEra Energy AR No. 02299052, the applicant is applying the methodology in EPRI Proprietary report no. 3002010399 (MRP-228, Revision 3) as the nondestructive examination (NDE) standard for visual or volumetric inspections performed in accordance with the program; a publicly available, redacted version of this EPRI report is available at. ML19081A058.

StaffOb - Confirmation of SLRA Appendix C Gap Analysis Adjustments to the AMP. The staff observed that SLRA Appendix C makes the following adjustments of the MRP-227, Rev. 1-A programmatic bases for the AMP:

Core support barrel (CSB) assembly tie rod criteria; core stabilizing lug and lug shim bolt criteria. The gap analysis adjusts the AMP to establish the CSB assembly tie rods and the core stabilizing lugs and lug shim bolts as Primary category components for the program that will be implemented during the subsequent period of extended operation; Primary category basis calls for baseline VT-3 visual inspections of the components no later than 2 refueling outages from the beginning of the subsequent period of extended operation, with subsequent VT-3 examinations of the tie rods during every refueling outage. The staff observed that, for the adjusted 80-year basis, the CSB tie rods screen in for mechanisms of irradiation-assisted stress corrosion cracking (IASCC), fatigue, wear, void swelling (VS; distortion), irradiation embrittlement (IE), and irradiation-enhanced stress relaxation or creep (ISR/IC); the staff observed that the referenced lugs and lug shim bolts screen in for the mechanisms of stress corrosion cracking (SCC) and wear. The staff

did not identify any potential issues with the SLRA gap analysis programmatic bases for the CSB tie rods or the core stabilizing lugs and lug shim bolts.

CSB middle girth weld (MGW), middle axial weld (MAW), lower axial weld (LAW) criteria and lower support structure (LSS) core support column criteria. The gap analysis adjusts the AMP to elevate the CSB MGW in each unit from an Expansion category for the 60-year version of the program to a Primary category component upon entry into the subsequent period of expended operation for the 80-year version of the program. When triggered, the updated basis for the program calls for the applicant to perform visual EVT-1 inspections of the CSB MAWs and LAWs and the core support plates no later than two refueling outages from the beginning of the first license renewal period, with subsequent EVT-1 visual inspections of the CSB MAWs and LAWs (and the core support columns) to be performed on an augmented, 10-year re-inspection interval basis. For the adjusted 80-year basis, the CSB LAWs screen in the aging mechanisms of SCC, IASCC, and IE. The staff did not identify any potential issues with the SLRA gap analysis programmatic bases for the CSB MGWs, MAWs, and LAWS or the LSS core support columns.

Core shroud assembly criteria. The gap analysis adjusts the AMP to establish that the core shroud assembly (for the applicable welded shroud design in two vertical sections) is a Primary category component for the AMP that will be implemented during the subsequent period of extended operation. The staff noted that the updated basis for the program calls for the applicant to perform visual VT-1 inspections of 100 percent of the horizontal weld seam between the upper and lower shroud segments no later than two refueling outages from the beginning of the first license renewal period, with subsequent VT-1 visual inspections of the seam welds to be performed on an augmented, 10-year re-inspection interval basis. For the adjusted 80-year basis, the core shroud assembly screens in for the aging mechanisms of void swelling/distortion and IE; there are no linked Expansion category components for the Primary category core shroud assembly seam welds.

The staff noted that gap analysis-adjusted program does not include any linked Expansion category components for the core shroud assembly horizontal seam weld examinations. The staff did not identify any potential issues with the SLRA gap analysis programmatic bases for the core shroud assembly. The staff will summarize this gap analysis basis in the SER section for this AMP.

StaffOb - Augmented Inspection Criteria for CSB flexure weld. Observed that in items C7 of table 4-2 in the MRP-227, Rev. 1-A, the EPRI MRP identifies that the CSB flexure welds are to be designated as Primary category components for the program if screening of fatigue and SCC cannot be satisfied by plant-specific evaluation. If fatigue or SCC cannot be screened out by plant-specific evaluation, the EPRI calls for the CSB flexure weld to be inspected using a EVT-1 visual examination no later than two refueling outages from the license renewal period, with subsequent EVT-1 examinations to be performed on a 10-year augmented re-inspection basis. The EPRI MRP does not designate any linked Expansion category components for CSB flexure welds.

The staff observed that the information in MRP-2018 022 and the program basis document in Enercon report no. NEESL00008-REPT-045, Revision 0 did not provide sufficient supporting information to support whether the CSB flexure weld in each unit

was being established as a Primary category component for the 80-year version of the program. The staff may address this informational gap through consideration of an RAI.

StaffOb - Augmented Inspection Criteria for core support plate in the LSS. The staff observed that in item C9 of table 4-2 in MRP-227, Revision 1-A, the EPRI MRP identifies that the LSS core support plate in each unit is to be designated as a Primary category component for the program if screening of fatigue cannot be satisfied by plant-specific evaluation. If consideration of fatigue cannot be screened out by plant-specific evaluation, the EPRI calls for the LSS core support plate to be inspected using a EVT-1 visual examination no later than two refueling outages from the license renewal period, with subsequent EVT-1 examinations to be performed on a 10-year augmented re-inspection basis. The EPRI MRP does not designate any linked Expansion category components for LSS core support plates.

The staff observed that the information in MRP-2018 022 and the program basis document in Enercon report no. NEESL00008-REPT-045, revision 0 did not provide sufficient supporting information to support whether the LSS core support plate in each unit was being established as a Primary category component for the 80-year version of the program. The staff may address this informational gap through consideration of an RAI.

StaffOb - Augmented Inspection Criteria for the upper internals assembly (UIA) fuel alignment plates. The gap analysis for the AMP establishes the UIA fuel alignment plates of the units as a linked Expansion category components (i.e., in addition to the CSB lower axial welds [LAWs]) for the programmatic inspections that will be performed on the Primary category CSB MGWs during the subsequent period of extended operation. The staff noted that, upon entry into the subsequent period of extended operation, the revised Expansion category basis calls for expansion-based visual EVT-1 inspections of the UIA fuel alignment if evidence of a confirmed crack exceeding two inches in length is detected in the CSB MGW. The staff also noted that, in item C10 of Table 4-2 in MRP-227, Rev. 1-A report, the EPRI MRP designates the UIA fuel alignment plate as a Primary category component for the program if component-specific screening for fatigue cannot be satisfied by a plant-specific evaluation. Thus, the staff determined the staff would need further reconciliation on the inspection category and potential inspection criteria for the UIA fuel alignment plate in each of the units. The staff may address this informational gap through consideration of an RAI.

During the audit of program, the staff audited relevant plant-specific, and generic OpE related to program. The staff did not identify any aging effects or mechanisms outside of the those already identified for the AMP in the parameters monitored or inspected program element for the AMP.

During the audit, the staff made the following observations (StaffOb(s) - Topic in the bullet title) or the applicant made the following clarifications (AppCl - Topic in the bullet title) in regard to OpE that applies to the program:

StaffOb - NextEra Energy AR QA Record Nos. 02255865, 0000290891, 02320810, and 02333990; EPRI MRP Biennial Reports. The staff observed that EPRI Biennial Report No. MRP 2020-015 (ML20229A000) provides a summary of the applicants base line inspections that were applied to the Primary Category RVI components (including the

core shroud plate-to-former plate weld with noted flaw indications) and to the Expansion Category CSB MAWs with noted flaw indications) in year 2018. The staff noted that, collectively, the referenced AR QA records address the applicants activities to record and evaluate relevant flaw indications detected in some of the CSB MAWs, LAWs and lower girth weld, and the core shroud upper flange weld of St. Lucie Unit 1 and in 2018, and that the analyses in Westinghouse Proprietary Letter and Analysis No. LTR-AMLR-18-22 and Westinghouse Proprietary Report No. WCAP-18452, Revision 1 provide the supporting evaluations of degradation detected in the components.

The staff also observed that, collectively, these records support re-inspections of the Unit 1 CSB assembly welds and core shroud welds contained in these indications on a 10-Year augmented re-inspection basis and that the applicants treatment and basis for managing age-related degradation in the structural welds is conservative. The staff noted that the application provides sufficient explanations and justifications on the inspection categories and future inspection needs for the welds in the gap analysis for the AMP in SLRA appendix C. The staff will provide its evaluation of the OpE associated with the Unit 1 CSB welds and core shroud welds in the SER section for this AMP.

StaffOb - NextEra Energy AR No. 02321810. The staff observed that this AR provides the applicants bases for implementing the EPRI MRP good practices in MRP 2019-009 for a one-time inspection of the Unit 1 CSB assembly; the staff noted that this is in addition to the applicants basis for reinspecting known CSB welds and core shroud welds with known flaw indications, as summarized in the observations for the previous CSB and core shroud weld experience. The staff will provide its evaluation of the OpE associated with the CSB welds and core shroud welds in the SER section for this AMP.

StaffOb - NextEra Energy AR QA record nos. 02256078 and 02256266 and AR record no 02357503. The staff observed that, per these records, the applicant conservatively addresses wear-type OpE indications that were detected in some of the core stabilizer lugs. The staff noted that the record shows that the wear in the lugs appears to be a result of surface damage. However, under the gap analysis of the program, the applicant is conservatively elevating the core stabilizer lugs as new Primary category components for VT-3 type visual inspections during the subsequent period of extended operation, with inspections to be performed on a 10-year basis. The staff did not identify any issues or information gaps in regard to the records or with the applicants treatment and assessment of the relevant OpE. The staff will evaluate the core stabilizing lug experience in the SER section for this AMP.

StaffOb - Applicability of EPRI Interim Guidance MRP 2019-002. The staff observed that the interim guidance in MRP 2019-002 for applying the EPRI MRP-227, Revision 1-A I&E protocols under flexible plant operations do not need to be applied to the St. Lucie design basis for the program. The staff noted that the information in NextEra Energy AR No. 02308972 provides confirmation that the St. Lucie units operate under base-load operations, which is consistent with the plant operating assumptions in chapter 1 of MRP-227, Revision 1-A. The staff did not identify any issues or information gaps in regard to the contents of this record or with the applicants treatment and application of this record. The staff will note the unit-specific base load operations as part of the OpE evaluation in the SER section for this AMP.

StaffOb - NextEra Energy AR No. 02350217. The staff observed that this record provides the applicants basis updating the I&E criteria of the program to those that are defined in EPRI report MRP-227, Revision1-A. The staff did not identify any issues or information gaps in regard to the contents of this record or with the applicants treatment and application of this record.

The staff will evaluate the identified plant-specific OpE in the SER section for the AMP.

The staff also audited the UFSAR supplement summary description of the SLR AMP provided in SLRA section 19.2.2.7, RVIs. The staff verified this description is consistent with the description provided in the GALL-SLR table XI-01 for PWR vessel internals programs.

During the audit, the staff noted that, in the May 2, 2018, SE for the 60-year inspection plan (as defined in Engineering Evaluation No. PSL-ENG-LRAM-15-002, Revision 6), the staff included the following statement in the conclusion section of the SE:

The licensee must follow the implementation requirements as defined in Section 7.0 of MRP-227-A, which require that the NRC be notified of any deviations from the Needed requirements.

StaffOb. The staff observed that this SE statement was in conflict with License Condition Clause 3.C in Renewed Operating License Nos. DPR-67 and NPF-16 (for St. Lucie Units 1 and 2, respectively). The staff will address this matter in the UFSAR supplement subsection of SER section for this AMP.

SLRA AMP B2.3.8, Flow-Accelerated Corrosion Summary of Information in the Application. Section B2.3.8 of the SLRA states that the Flow-Accelerated Corrosion AMP is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M17, Flow-Accelerated Corrosion. To verify the programs consistency, the staff audited the SLRA AMP and reviewed the associated enhancements. The staff will document its review of the applicants enhancements to the program in the SER. At the time of the audit, the applicant had not yet revised the procedures to implement the programs enhancements. Consequently, the staffs audit only included the applicants program basis document, available procedures, and referenced documents. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant through its ePortal. For the OpE review, the applicant explained the process used to identify and evaluate pertinent OpE.

The staff evaluated the applicants methodology and reviewed the OpE documentation contained in the SLRA and ePortal. In addition, the applicant provided the results of separate OpE searches of the plant-specific database using keywords of cavitation, erode, erosion, and impinge.

The table below lists documents reviewed by the staff and found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED

Document Title Revision /

Date NEESL00008-REPT-046 Aging Management Program Basis Document - Flow-Accelerated Corrosion Revision 0 NEESL00008-REPT-038 Aging Effects OpE Revision 0 AR 2216036 Unit 2 B Component Cooling Water (CCW) heat exchanger tube failure is erosion/corrosion on inside of aluminum brass tube NA AR 586875586875Unit 2 B Intake Cooling Water (ICW) discharge line downstream of orifice identified degradation to wall thickness NA AR 1611439 Through-wall leak on Unit 2 5B air vent and nozzle due to erosion from steam bypass around orifice NA AR 1840213 ICW discharge line downstream of flow orifices has recurring leaks due to flow-induced erosion NA AR 598640598640Significant FAC wear in 1.5 ES 11-P-1-12. Elbow did not meet minimum wall and was replaced NA AR 2096105 ICW piping from Unit 2 CCW heat exchanger has cement liner degradation from erosion NA PSL-ENG-LRAM-00-091 Flow-Accelerated Corrosion Program -

[Initial] License Renewal Basis Document Revision 7 PSL-ENG-LRAM-00-114 Pipe Wall Thinning Inspection Program -

[Initial] License Renewal Basis Document Revision 7 15-0210-TR-001 System Susceptibility Evaluation (December 2016)

Revision 0 15-0210-TR-002 Flow-Accelerated Corrosion Program - Susceptible Non-Modeled Program (Dec-2016)

Revision 0 19-0152-TR-001 Erosion Inspection Plan for Five Outages (Feb-2021)

Revision 0 ER-AA-111 Flow-Accelerated Corrosion Program Revision 3 ER-AA-111-1000 Flow-Accelerated Corrosion Program Activities Revision 4 ER-AA-111-1001 Feedwater Heater Shell Inspection for Detection of Flow-Accelerated Corrosion Revision 2 L2R26 -FAC FAC Outage Final Summary Report - Refueling Outage 26 NA L1R29-FAC FAC Outage Summary Report - Refueling Outage 29 NA L1R30-FAC FAC Outage Summary Report - Refueling Outage 30 NA During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are or will be consistent with the corresponding elements of the GALL-SLR Report AMP, after completing the identified enhancements.

During the audit of the OpE program element, the staff reviewed the results of the plant-specific database searches to identify examples of age-related degradation and to support the staffs determination of the ability of the applicants program to manage the effects of aging. The staff will evaluate the identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA Flow-Accelerated Corrosion program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.9, Bolting Integrity Summary of Information in the Application. The SLRA states that AMP B2.3.9, Bolting Integrity, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M18, Bolting Integrity. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REP-047 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Bolting Integrity Revision 0 NEESL00008-REP-041 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - ASME Section XI Inservice Inspection, Subsection IWB, IWC, and IWD Revision 0 0005760_022 St. Lucie Plant Implementation Guidelines of the ASME Section XI Repair and Replacement Program Revision 22 0-GMM-99.17 Threaded Fasteners on Pressure Boundaries, Structural Steel and Plant Equipment Revision 9 4th-ISI-PSL Program Plan St. Lucie Nuclear Power Plant Unit 2 Fourth Inservice Inspection Interval Program Plan Revision 3 5th Interval-ISI-PSL-1-Program Plan Fifth Inservice Inspection Program Plan for St. Lucie Nuclear Power Plant Unit 1 Revision 0 AMD-02.01 Control of Chemicals and Materials for the Maintenance of Plant Systems Revision 8 AMD-17.33 License Renewal Systems / Programs Monitoring Revision 15 GMP-22 Plant Lubrication Manual Revision 101

NES 4.5 Visual Examination Non-Section XI Revision 4 SPEC-M-004 Maintenance Bolting Specification for St. Lucie Units 1

& 2 Revision 15 AR01912011 SL1-25 Condenser Dogbone Expansion Joint Seat Issue 10/29/2013 AR02211378 Degraded Bolt on Motor Shroud 06/27/2017 AR02321300 U1 License Renewal Walkdown-Corroded Flange Bolts 1A AFW PP 07/22/2019 AR02323021 U2 License Renewal Walkdown-Surface Corrosion on Flange Bolt 08/06/2019 AR02323023 U2 License Renewal Walkdown-Corroded Flange &

Bolts (C-90) 08/06/2019 AR02332311 1B CCW HX Multiple Channel Head Nuts Need Replacing-LRI 10/24/2019 AR02337914 U2 License Renewal Walkdown-Corroded Flange Surfaces & Bolts 12/16/2019 AR02345988 U2 PX-21-8B Blind Flange to CW-72 Has Corroded Bolts 02/27/2020 AR02355477 License Renewal Walkdown - Corrosion on the Packing Gland for Valve 05/26/2020 AR02374153 License Renewal Effectiveness Review & SLR Interview Track 01/25/2021 AR02381822 License Renewal Aging Management Effectiveness Review Rollup 01/26/2021 WO40762995-02 U1 Trestle A Train SSC-Upgrade Protective Coatings 05/06/2021 WO4019393701 U2 AFW PP 2A Suction Pipe C-54 Corroded, Clean &

Coat 11/06/2012 WO4054634801 HPSI PP 1B: Degraded Bolts on Motor Shroud 10/02/2017 WO4060828907 U1 CCW HX 1B: HX OPS PMT VT-2 02/04/2020 WR94084376 Inspect and/or Retorque All 1A/1B Cond Seal Boot Fasteners 10/15/2013 WR94196688 U1: C License Renewal Walkdown -Corroded Flange Bolts 1A AFW PP 07/17/2019 WR94196689 U1: PT-09-8A - License Renewal Walkdown -

Corroded Bolts in Support 07/17/2019 WR94197282 U2 License Renewal Walkdown-Surface Corrosion on Flange Bolt 07/31/2019 WR94197283 U2 License Renewal Walkdown-Corroded Flange &

Bolts (C-90) 07/31/2019 WR94200452 U1: CCW HX 1B - Multiple Channel HD Nuts Need Replacing; LRI 10/21/2019 WR94202545 U2: C Corroded Flange Surfaces & Bolts 12/10/2019

WR94205446 U2: PX-21-8B - Bling Flange to CW-72 Has Corroded Bolts 02/25/2020 WR94209291 U0: V15236 - Corrosion on the Packing Gland 05/04/2020 During the audit, the staff verified the applicants claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements. In addition, the staff found that for the preventive actions program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing an RAI in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff made the following observation:

The staff noted that the current program does not clearly specify if lubricants containing MoS2 or other lubricants containing sulfur have ever been used at PSL.

The staff also audited the description of the SLRA Bolting Integrity program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.10, Steam Generators Summary of Information in the Application. The SLRA states that AMP B2.3.10, Steam Generators, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M19, Steam Generators. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant through its ePortal.

For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision /

Date Action Request (AR) 02076132 SL2-22 Steam Generator Feedring Inspection Results 09/23/2015

Document Title Revision /

Date AR 02185403 Unit 2 Loose Parts System in Alarm for 2B Steam Generator 02/14/2017 AR 02256420 SL1-28 Steam Generator Secondary Side Inspection Summary Results 03/27/2018 AR 02278480 SL2-24 Steam Generator Feedring Inspection Results 09/28/2018 Intertek AIM report AES 170610264 1 Review of Degradation and Operational Assessments for St. Lucie Unit 1 Steam Generators for Cycle 27 Revision 0 report AIM 200110733-2-1 Intertek AIM Report for the Review of Degradation and Operational Assessments for St. Lucie Unit 2 Steam Generators for Cycle 24 Revision 0 NEESL00008-REPT-048 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Steam Generators Revision 0 CSI-NDE-00-07 Steam Generator Secondary Side Integrity Plan Revision 15 CSI-NDE-00-081 Strategic Plan for Steam Generator Integrity Revision 6 ER-AP-121 Steam Generator Integrity Revision 8 Steam Generator Program Owner Interview Form (Applicant Form)

N/A Master System Health Report - Steam Generators 11/24/2020 ML17117A334 St. Lucie, Unit 1 - Refueling Outage SL1-27 Steam Generator Tube Inspection Report 04/17/2017 ML17331A685 St. Lucie Nuclear Plant, Unit 1 - Review of the Fall 2016 Steam Generator Tube Inservice Inspection Report for Refueling Outage 27 12/21/2017 ML19081A146 St. Lucie, Unit 2 - Refueling Outage SL2-24 Steam Generator Tube Inspection Report 03/22/2019 ML19233A273 St. Lucie, Unit 2 - Refueling Outage SL2-24 Steam Generator Tube Inspection Report RAI Response 08/21/2019 ML19242D608 St. Lucie Nuclear Plant, Unit 2 - Review of Steam Generator Tube Inspection Report for Refueling Outage 24 09/16/2019 AES 14028596-2Q-2 Probabilistic Operational Assessment for Fan Bar Support Wear in St. Lucie Unit 1 Steam Generators at End of Cycle 24 10/2014 ML21305A868 St. Lucie Nuclear Plant, Unit 1 - Refueling Outage SL1-30 Steam Generator Tube Inspection Report 11/01/2021 1-PMM-01.05 Unit 1 Steam Generator Primary Side Maintenance Revision 2 During the audit, the staff verified the applicants declaration that the program elements:

preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of the program and parameters monitored or inspected program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the OpE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA SGs program provided in the UFSAR supplement. During the audit, the staff communicated areas where the UFSAR supplement is not consistent with the description provided in the GALL-SLR Report. Specifically, the revision of NEI 97-06 that the SGs program is based on was not cited, no discussion of tube-to-tubesheet welds being managed by the SGs program was included, statements related to tube repair were made even though St. Lucie is not approved for alternate repair criteria or alternate repair methods, the implementation schedule did not match Table XI-01 in the GALL-SLR Report, and no discussion of operational assessments as part of the SGs program was included.

SLRA AMP B2.3.11, Open-Cycle Cooling Water System Summary of Information in the Application. The SLRA states that AMP B2.3.11, Open-Cycle Cooling Water System, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System.

To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements to the GALL-SLR Report AMP in the SER. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-049 SLR Program Basis Document - Open-Cycle Cooling Water System Revision 0 ER-AA-123 NRC GL 89-13 Service Water Program - Fleet Procedure Revision 2 ER-SL-123-1000 NRC GL 89-13 Program - St. Lucie Plant Revision 1 LTAM PSL-15-0139 ICW Pipe Replacement 07/01/2015

SLR-8770-G-082_Sh2 Flow Diagram - Circulating & ICW System Revision 33 SLR-2998-G-082_Sh2 Flow Diagram - Circulating & ICW System Revision 61 AR 00585332 2A ICW Discharge Line I-30-CW-30 Downstream of Orifice SO-21 10/06/2010 AR 1740921 1A & 1B ICW Discharge Header Root Cause Determination 03/04/2012 Q1-2015 PSL Health Report - Intake Cooling Water 11/30/2020 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the SLRA Open-Cycle Cooling Water System provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.12, Closed Treated Water Systems Summary of Information in the Application. The SLRA states that AMP B2.3.12, Closed Treated Water Systems, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M21A, Closed Treated Water Systems. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-050 St. Lucie Units 1 and 2 SLR AMP Program Basis Document - Closed Treated Water Systems Revision 0 AR 02180710 Discontinued sodium nitrite addition to CCW and CTW systems in January 2017 01/20/2017 AR 02311687 Level 1 Assessment of CCW Molybdate Program 04/22/2019 AR 00406430 Apparent Cause Evaluation: PSL 2B CCW HX Inlet Line Pipe Stub Failure 03/10/2010 AR 02270544 CCW MIC Testing 06/29/2018

AR 01822401_000 2B CCW HX Outlet Piping Socket Weld Leak 11/11/2012 AR 01892787_000 Biocide Treatment to U1 CCW System 07/29/2013 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the SLRA AMP for the Closed Treated Water Systems provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. SLRA states that AMP B2.3.13 Inspection of Overhead Heavy Load and Light Loads (Related to Refueling) Handling Systems, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEEDL00008-REPT-063 St. Lucie Units 1 and 2 SLR AMP Basis Document -

Inspection of Overhead Heavy Load and Light Loads (Related to Refueling) Handling Systems Revision 0 NEEDL00008-REPT-059 St. Lucie Units 1 and 2 SLR AMP Basis Document -

Structures Monitoring Revision 0 ADM-17.32 Structures Monitoring Program Revision 7 1-PMM-74.03 Polar Crane Pre, Post, and Daily Inspections and Lubrications Revision 4 2-PMM-74.03 Polar Crane Pre, Post, and Daily Inspections and Lubrications Revision 4 1-PMM-67.10 New Fuel Handling Crane Lubrication Revision 0

2-PMM-67.06 Refueling Machine Lubrication & Inspection Revision 06 0-MMP-74.02 Spent Fuel Cast Handling Crane Inspection Revision 1C

-PMM-74.05 Overhead Crane and Hoist Inspections Revision 6 UFSAR, U1 Section 9.6, Cranes - Overhead Heavy Loads Handling Systems Amendment No. 28 UFSAR, U2 Section 9.6, Cranes - Overhead Heavy Loads Handling Systems Amendment No. 24 System Health Report 01981836 U1 Fuel Handling Building roof. Cask Crane structure is rusting mainly at the bolted connections in the concrete. If delayed, bolts and nuts must be replaced.

Safety Related structure Q3-2015 System Health Report 01981836 To be scheduled by 12/29/2015. U1 Fuel Handling Building roof. Cask Crane structure is rusting mainly at the bolted connections in the concrete. If delayed, bolts and nuts must be replaced. Safety Related structure Q4-2020 WO #: 40422582-01 U1 Spent Fuel Cask Handling Crane-Misc. Steel Corrosion 10/29/2015 AR 02420193 Degraded bolting on U1 FHB Cask Crane Structural Attachment 03/01/2022 AR 02420776 U1 CHF Cask Crane Acceptance with Deficiency 03/07/2022 WO #: 40608112-06 LR Report: U1-FH-041 -FU1 Structural Deficiency Report - Follow-up Inspection Deficiency Location: Reinforced Concrete 12/04/2014 WO #: 40608112-06 LR Report: U1-FH-041 -FU1 Structural Deficiency Report - Follow-Up Inspection Deficiency Location: Spent Fuel Cask Handling Crane 09/18/2014 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the Inspection of Overhead Heavy Load and Light Loads (Related to Refueling) Handling Systems AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.14, Compressed Air Monitoring Summary of Information in the Application. The SLRA states that AMP B2.3.14, Compressed Air Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M29, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant through its ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-064 Aging Management Program Basis Document -

Compressed Air Monitoring Revision 0 PSL-Instrument &

Service Air Master System Health Report 11/30/2020 AR-00549399 Instrument Air Self-Assessment 08/28/2007 AR-00455450 Instrument Air Self-Assessment 11/18/2008 AR- 02131721 IA Samples Have Particulate Larger Than 40 Microns 05/13/2016 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the acceptance criteria, and corrective actions program elements not associated with the enhancement identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.

During the audit of the OpE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA Compressed Air Monitoring program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.15, Fire Protection Summary of Information in the Application. The SLRA states that AMP B2.3.15, Fire Protection, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M26, Fire Protection. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP and will document its review in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant through its ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date AR 02154894 FDPR-25-109 Has Broken Springs 09/09/2016 AR 02255473 Distortion to Radiant Energy Shield on Conduit 10375X 03/21/2018 AR 02260065 Penetration FS20 in SW [Southwest] Corner of Unit 2 2A Switch Gear Room Degraded 04/17/2018 AR 02260602 Door RA36 Does Not Close Automatically 04/20/2018 AR 02274895 Loose Door Seal/Gasket on Door 152/RA-41 08/06/2018 AR 02306375 Degraded Pipe Penetration 03/19/2019 AR 02308438 RA-88 Fire Door Failed 6 Month PM [Periodic Maintenance]

04/01/2019 NEESL00008-REPT-020 St. Lucie Units 1 and 2 SLR Screening and Aging Management Review Results - Fire Protection and Service Water System Revision 0 NEESL00008-REPT-051 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Fire Protection Revision 0 FP-AA-104-1001 Fire Protection Performance and Trending Revision 4 ADM-19.00 Fire Protection Plan Revision 18 1-FMM-99.11 Fire Damper Inspection Revision 2 1-FMM-99.12 Unit 1 Fire Door Inspection Revision 5 2-FMM-99.12 Unit 2 Fire Door Inspection Revision 6 1-FMM-99.29 Halon Fire Extinguishing System Inspection Revision 4 1-FPSP-15.01 Unit 1 Fire Barrier Inspection Revision 4 2-FPSP-15.01 Fire Barrier Inspection Revision 2 Fire Protection Program Interview Form 12/01/2020 Master System Health Report - Fire Protection 11/24/2020

During the audit, the staff verified that for the program element that the applicant declared was consistent, the preventive actions program element of the SLRA AMP is consistent with the corresponding element of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements not associated with the enhancements identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.

In addition, the staff found that for the scope of the program, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the OpE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA Fire Protection program provided in the UFSAR supplement. During the audit, the staff communicated areas where the UFSAR supplement is not consistent with the description provided in the GALL-SLR Report. Specifically, the enhancement related to the aging effects that subliming, cementitious, and silicate materials used in fireproofing and fire barriers will be inspected for, and the use of the phrase abnormal degradation.

SLRA AMP B2.3.16, Fire Water System Summary of Information in the Application. The SLRA states that AMP B2.3.16, Fire Water System, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR report AMP XI.M27, Fire Water System. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP and will document its review in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant through its ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision /

Date Action Request (AR) 01613603 Fire Protection Deluge Piping is Contacting Lube Oil Piping 01/28/2011

Document Title Revision /

Date AR 01702899 Corroded Fire Suppression Piping 11/03/2011 AR 01765560 Need to Replace Deluge Piping Due to Internal Corrosion 05/09/2012 AR 01864516 Pipe Support for Hydrogen Seal Oil Deluge System Degraded 04/09/2013 AR 01879932 Small-Bore Piping and Hardware Needs Re-Coated 06/06/2013 AR 01924324 NRC IN [Information Notice] 13-06, Corrosion in Fire Protection Piping Due to Air 12/03/2012 AR 01963361 Corrosion on Fire Lines FP-84, -45, -46 & -92 in CWST [City Water Storage Tank] Area 05/02/2014 AR 02001233 Leak from Pipe Elbow Downstream of V15874 10/22/2014 AR 02002946 Fire Protection Line Corrosion 10/28/2014 AR 02106171 CR [Condition Report] 02105853 Identified a Failure of a Fire Protection Pope 01/29/2016 AR 02113578 Supply to A and B City Water Storage Tanks Degraded 02/28/2016 AR 02130089 Through-Wall Leak on Piping for Sprinkler Actuation Bell 05/05/2016 AR 02158300 40392080-01 Turbine Lube Oil Deluge Test (three through-wall leaks) 09/26/2016 AR 02189738 U2 [Unit 2]: Coatings on Fire Protection Piping in the Turbine Building 03/06/2017 AR 02189751 U2: Coatings on Fire Protection Piping on the RAB

[Reactor Auxiliary Building] Roof 03/06/2017 AR 02190938 Fire System SS15956 has Uniform Corrosion Pitting Interior 03/12/2017 AR 02221689 U-2 [Unit 2] Fire Header Corrosion Cell Required UT Thickness Eval 08/23/2017 AR 02222778 SB15204 Piping Degraded Soft Patch Leaking 08/30/2017 AR 02226103 CWST 1A External Coatings and Repairs 09/21/2017 AR 0226107 CWST 1B Need External Coatings and Repair 09/21/2017 AR 02296268 Degraded Pipe Downstream of Orifice 01/02/2019 AR 02319588 Severely Corroded Piping Downstream of SH152053 06/28/2019 AR 02323637 Severe Corrosion and Degradation on V15630 08/07/2019 AR 02323118 1A Fire Pump Recirculation Line is Extremely Degraded 09/17/2019 AR 02335426 Leak on 1B Fire Pump Recirculation Line 11/13/2019

Document Title Revision /

Date AR 02347937 TLO [Turbine Lube Oil] Reservoir Deluge Piping Through-wall Leak 03/10/2020 AR 02356642 Fire Sprinkler Valve V15846 Leaking at Approximate Rate of 1 GPM [Gallon Per Minute]

05/14/2020 AR 02359859 Coat Recirculation Piping Fittings on 1A Fire Pump 06/15/2020 AR 02369857 CWST 1A Internal Tank Corrosion 09/30/2020 AR 02411146 Replace fire Protection Test Loop Spool Piping 11/12/2021 Project Summary Report, 1A CWST Inspection, September, 2020 09/08/2020 Project Summary Report, 1B CWST Inspection, September, 2020 09/10/2020 PCR 02217561 2-FME-15.02, 12 Month Operability Test of the Fire Protection 07/28/2017 PMCR 2162545 U2: RAB: Sprinkler System Test; Frequency Change 10/14/2016 NEESL00008-REPT-065 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Fire Water System Revision 0 0-FME-15.01 Deluge and Sprinkler System Testing Revision 19 0-OSP-15.13A 1A Fire Pump Monthly Operability Test Revision 9 0-OSP-15.16 Fire Protection System Annual Flush Revision 4 0-OSP-15.18 RAB Fire Hose Station 5 Year Flush Revision 1 1-FME-15.01 12 Month Operability Test of the Diesel Generator Fire Protection System Revision 9 2-FMM-99.09 Fire Hose House Inspection (Required)

Revision 3 1-FMM-99.15 Fire Hydrant/Fire Hydrant Hose Lubrication/Inspection (Required and Other)

Revision 3 2-FMM-99.14C Unit 2 Fire Hose Stations Inspections (Required)

Revision 4 1-FMM-99.13 Fire Hose Hydro Test Revision 2 2-FME-15.02 18 Month Operability Test of the Fire Protection Sprinkler System for the Unit 2 RAB Revision 8 Fire Water System Program Interview Form N/A During the audit, the staff verified that for the program element that the applicant declared was consistent, the preventive actions program element of the SLRA AMP is consistent with the corresponding elements of the GALL-SLR report AMP.

The staff also verified the applicants claim that aspects of the detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements not associated with the enhancements identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR report AMP.

In addition, the staff found that for the scope of the program and parameters monitored or inspected program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the OpE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA Fire Water System program provided in the UFSAR supplement. During the audit, the staff communicated areas where the UFSAR supplement is not consistent with the description provided in the GALL-SLR Report. Specifically, these are the statement that the program generally follows NFPA Codes and Standards and the implementation schedule not matching Table XI-01 in the GALL-SLR report.

SLRA AMP B2.3.17, Outdoor and Large Atmospheric Metallic Storage Tanks Summary of Information in the Application. The SLRA states that, AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-052 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Outdoor and Large Atmospheric Metallic Storage Tanks Revision 0 Plant Drawing -

8770-4769 Condensate Storage Tank Revision 9

Plant Drawing -

8770-4770 Details For Cond. Storage & Diesel Oil Storage Tank Revision 6 Plant Drawing -

8770-6009 Primary Water Storage Tank Revision 0 Plant Drawing -

8770-4510 Refueling Water Tank Bottom Details Revision 5 AR - 02412597 Corrosion at Base of Unit 1 Condensate Storage Tank (CST) - SLR NRC Audit 11/30/2021 Work Order -

40356058 U1 CST Restore Protective Coating - Lic RNEW AR 2010915 04/08/2019 AR - 02412714 NRC SLR Audit - 2A DOST Base Caulking 12/01/2021 Work Order -

40743945 U0 CSST 1B-Internal Tank Weld Repair Per Eng Insp-AR 2369859 11/22/2021 Work Order -

40740914 U0 CWST 1A-Weld Buildup Corrosion Cell-West Side AR-2367375 12/06/2021 During the audit, the staff verified the applicants claim that the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP or will be consistent after implementation of the identified enhancements.

The staff also verified the applicants claim that aspects of the detection of aging effects, program element not associated with the exception identified in the SLRA are consistent with the corresponding program elements inthe GALL-SLR report AMP.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR report.

The staff made the following observations during walkdowns:

During the walkdown of the Unit 1 and Unit 2, CST, the staff noted that there is caulking installed at the interface joint between the tank bottom and the concrete foundation.

During the walkdown of the Unit 1, CST, the staff noted surface corrosion at the base of the tank. The licensee has since entered this issue into the CAP.

During the walkdown of the 2A Diesel Oil Storage Tank, the staff noted that caulking at the interface of the tank bottom and concrete was damaged. The licensee has since entered this issue into the CAP.

SLRA AMP B2.3.18, Fuel Oil Chemistry Summary of Information in the Application. The SLRA states that AMP B2.3.18, Fuel Oil Chemistry, is an existing program with enhancements that is consistent with the program elements in GALL-SLR Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the Fuel Oil Chemistry program. These documents were provided by St Lucie. The staff will document its review of this information in the SER.

Document Title Revision / Date Procedure No. CYS-SL-107 0001 Receiving Processing and Periodic Sampling of Diesel Fuel Oil Revision 10 Material Safety Data Sheet (MSDS)

LTSA - 35A (PER MIL - S 53021A)

Fuel Quality Services, Inc.

240-967-9790 05/18/2015 NEESL00008 - REPT - 052 St Lucie Units 1 and 2 SLR Aging Management Program Basis Document Outdoor and Large Atmospheric Metallic Storage Tanks Revision 0 NEESL00008 - REPT - 053 St Lucie Units 1 and 2 SLR Aging Management Program Basis Document Fuel Oil Chemistry Revision 0 Material Safety Data Sheet (MSDS)

FQS 1.5 Microbicide Fuel Quality Services, Inc.

240-967-9790 04/08/2021 Procedure No. CY-SL-102-0205 Determination of Particulate Contamination in Diesel Fuel Oil Revision 6 Procedure No. CYSL-SL-100 - 0013 Diesel fuel Oil Program Revision 1 06/30/2021 Picture 20211025_1A_DOST 2 10/29/2021 Picture 20211025_1A_DOST 10/29/2021 Picture 20211025_1B_DOST 2 10/29/2021 Picture 20211025_1B_DOST 10/29/2021

Picture 20211025_1A1 Day Tank 10/29/2021 Picture 20211025_1A2 Day Tank 10/29/2021 Picture 20211025_1B1 Day Tank 10/29/2021 Picture 20211025_1B2 Day Tank 10/29/2021 Picture 2A DOST 20211028_133958 10/29/2021 Picture 2A DOST 20211028_134001 10/29/2021 Picture 2A1 Day Tank 20211028_133105 10/29/2021 Picture 2A2 Day Tank 20211028_133017 10/29/2021 Picture 2B DOST 20211028_133510 10/29/2021 Picture 2B1 Day Tank 20211028_132513 10/29/2021 During the audit, the staff verified St. Lucies claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the OpE program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.19, Reactor Vessel Material Surveillance Summary of Information in the Application. The SLRA states that AMP B.2.3.19, Reactor Vessel Material Surveillance, is an existing program with an exception to the ten program elements in GALL-SLR Report AMP XI.M31, Reactor Vessel Material Surveillance. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the exception associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP in the SER.

Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the reactor pressure vessel material surveillance described in SLRA Section B.2.3.19. These documents were provided by FPL or were identified in the staffs search of St.

Lucies operating experience database. The staff acknowledges that operating experience related to the reactor vessel material surveillance program (which is based on the requirements 10 CFR Part 50, Appendix H) is also summarized in reactor vessel material surveillance program summary technical reports that are generated in accordance with the reporting

requirements in 10 CFR Part 50, Appendix H. These summary technical reports were included in the review and are included in the table below.

Document Title Revision /

Date TR-F-MCM-004 St. Lucie, Unit 1, Post-Irradiation Evaluation of Reactor Vessel Surveillance Capsule W-97 12/1983 WCAP-12751 Analysis of the Capsule at 104° from the Florida Power and Light St. Lucie Unit No. 1 Reactor Vessel Radiation Surveillance Program 11/1990 WCAP-15446 Analysis of the Capsule at 284° from the Florida Power and Light St. Lucie Unit No. 1 Reactor Vessel Radiation Surveillance Program 05/2002 Revision 1 BAW-1880 Analysis of Capsule W-83, Florida Power and Light, St.

Lucie Unit No. 2, Reactor Vessel Materials Surveillance Program 09/ 1985 WCAP-15040, Analysis of the Capsule at 263° from the Florida Power and Light St. Lucie Unit No. 2 Reactor Vessel Radiation Surveillance Program 02/2010 Revision 1 WCAP-17939-NP Analysis of the Capsule at 97° from the Florida Power and Light St. Lucie Unit No. 2 Reactor Vessel Radiation Surveillance Program 05/2015 Revision 0 The staff also verified the applicants claim that aspects of the scope of program, preventive actions, detection of aging effects, acceptance criteria, and corrective actions program elements not associated with the exceptions identified in the SLRA are consistent with the corresponding program elements inthe GALL-SLR Report AMP.

The staff also audited the description of the SLRA B.2.3.19, Reactor Vessel Material Surveillance, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

The staff further noted that Table 19-3 to Attachment A1 and Table 19-3 to Attachment A-2 to the St. Lucie SLRA for units 1 and 2, respectively, list subsequent license renewal commitments. Reactor Vessel Material Surveillance is listed as commitment #22 in each table.

SLRA AMP B2.3.20, One-Time Inspection Summary of Information in the Application. The SLRA states that AMP B2.3.20, One-Time Inspection, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M32, One-Time Inspection. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed

the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-055 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - One-Time Inspection Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B2.3.21, Selective Leaching Summary of Information in the Application. The SLRA states that AMP B2.3.21, Selective Leaching, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL0008-REPT-079 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Selective Leaching Revision 0

AR 02048790 NUREG 1801 Rev 2 GALL Gap Selective Leaching 05/19/2015 AR 02069522 License Renewal Destructive Examination Selective Leaching 08/26/2015 AR 02105853 Fire System Sprinkler Riser Rupture 01/27/2016 AR 02106171 CR 02105853 Identified a Failure of a Fire Protection Pipe 01/29/2016 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to verify whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP.

During the audit, the staff made the following observation:

The staff reviewed NEESL0008-REPT-079 and noted the Selective Leaching program does not include an exclusion for externally coated buried components.

The staff also audited the description of the SLRA Selective Leaching program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA Selective Leaching program. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B2.3.22, ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The SLRA states that AMP B2.3.22, ASME Code Class 1 Small-Bore Piping is an existing AMP for detecting cracking in small-bore, ASME Code Class 1 piping. It also states that the program is consistent with the 10 elements in GALL-SLR Report AMP XI.M35, ASME Code Class 1 Small-Bore Piping. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and documentation provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

Furthermore, the staff requested additional OpE searches on the applicants CAP database, and the applicant provided results and additional relevant files to the ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED

Document Title Revision /

Date 13-0334-TR-0002 Metallurgical Evaluation of Small-Bore Socket Welds from St. Lucie Unit 2 CVS and SI Systems Revision 1 06/2017 AR02211110 Unit 2 License Renewal Class 1 Small-Bore Piping Inspection Results 06/19/2017 CE#02211110 Unit 2 License Renewal Class 1 Small-Bore Piping Inspection related to NRC Commitment

1. 6 of NUREG-1779 06/20/2017 L-2015-126 License Renewal One-Time Inspection of Class 1 Small-Bore Piping Revised Commitments and Revised Inspection Plan 05/11/2015 UT report 5.4-001 Weld RC-141G-SW-8-2 Volumetric Examination of Weld RC-141G-SW-8-2 02/24/2017 UT report 5.4-002 Weld SI-191-FW-904-2 Volumetric Examination of Weld SI-191-FW-904-2 03/01/2017 NEESL0008-REPT-066 St. Lucie Units 1 and 2 SLR Small-Bore Piping 07/26/2021 AR01959057 Self-Assessment St. Lucie License Renewal Implementation 09/16/2015 AR01980340 Weld Leak on Pipe SI-237 between 2B1 SIT and V3811 03/25/2015 AR2182938 1B2 RCP Seal Cooler Leakage 02/06/2019 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

For the audit of the OpE program element, the staff reviewed the OpE provided by the applicant in the AMP basis document and on the ePortal. The staff requested multiple searches and obtained results of the OpE database using keywords: small-bore, socket weld, small-bore examination, fatigue, fatigue cracking, thermal fatigue, stress corrosion, PWSCC, SCC, crack, weld, and leak. The staff will document its review of relevant OpE in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified that this description is consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The SLRA states that AMP B2.3.23, External Surfaces Monitoring of Mechanical Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated

with this AMP. The staff will document its review of the enhancements in the SER. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit included only the program basis document, available procedures, and referenced documents. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-067 St. Lucie Units 1 and 2 SLR AMP Program Basis Document - External Surfaces Monitoring of Mechanical Components Revision 0 PSL-ED1-008 External Corrosion Monitoring Revision 8 ADM-17.28 External Corrosion Program for Insulated Piping

- Inspection Implementation Revision 5 ADM-17.33 License Renewal Systems / Programs Monitoring Revision 15 MSP-100.01 Protective Coating Surveillance Program Revision 12 SPEC-M-006 Maintenance Specification for Evaluation and Acceptance of Pipe Surface Imperfections for St.

Lucie 1 and 2 and Turkey Point 3 and 4 Revision 5 AR 01879932 Small-Bore Piping and Hardware Needs Re-Coated 06/06/2013 AR 02245978 Revise Walkdown Frequency for Outside Portions of CCW, AFW, and Condensate Systems from 5-years to 18-months 01/24/2018 AR 01959057 Focused Self-Assessment - St. Lucie License Renewal Implementation 04/17/2014 AR 02354805 Through-wall Leak on B ICW Header Line CW-13 04/29/2020 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the SLRA AMP External Surfaces Monitoring of Mechanical Components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.24, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The SLRA states that AMP B2.3.24, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL0008-REPT-080 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Revision 0 AR 01621761 SL2-19 Internal Pipe Degradation on 18-CW-24 and 16-CW-150 02/19/2011 AR 01714622 1A EDG Generator Ventilation Screen Corrosion 12/09/2011 AR 02040220 U1 HVE-6B Outside Air Duct Corrosion 04/13/2015 AR 02071667 1B IAC [Instrument Air Compressor] Discharge Elbow Has Severe Internal Corrosion 09/03/2015 AR 02312636 Debris in Unit 1 Instrument Air Emergency Cooling Head Tank 04/30/2019 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also audited the description of the SLRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.25, Lubricating Oil Analysis Summary of Information in the Application. The SLRA states that AMP B2.3.25, Lubricating Oil Analysis, is an existing program that is consistent with the program elements in GALL-SLR

Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the Lubricating Oil Analysis. These documents were provided by the applicants ePortal. The staff will document its review of relevant OpE in the SER.

Document Title Revision / Date NEESL00008-REPT-068 St Lucie Units 1 and 2 SLR Aging Management Program Basis Document Lubricating Oil Analysis Revision 0 O-PDM-99.03 Protective Maintenance Preparation and Analysis of Oil Samples Revision 3 Procedure No. MA-AA-204-1000 Preventive Maintenance and Surveillance Procedure Revision 18 During the audit, the staff verified St Lucies claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the OpE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA AMP Lubricating Oil Analysis program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.26, Monitoring of Neutron-Absorbing Materials Other Than Boraflex Summary of Information in the Application. The SLRA states that AMP B2.3.26, Monitoring of Neutron-Absorbing Materials Other Than Boraflex, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M40, Monitoring of Neutron-Absorbing Materials Other Than Boraflex. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date (TAC NO.

MB6864)

St Lucie Unit 1 Issuance of Amendment Regarding Spent Fuel Soluble Boron Credit 09/23/2004 (ML042670562)

Holtec International HI-2104753 St Lucie Unit 2 Criticality Analysis for EDU and Non EPU - Fuel 09/19/2011 Revision 2 Holtec International HI-2104714 St Lucie Unit 1 Criticality Analysis for EDU and Non EPU - Fuel 09/14/2011 Revision 2 Procedure 0-OSP-67.01 St Lucie Plant Operating Surveillance Procedure Metamic Insert Surveillance Revision 7 EC-287900 St Lucie Units 1 & 2 Metamic Insert Surveillance Program License Renewal Program Basis Document Revision 0 PSL Program Owner Interview X1.M40 Monitoring of Neutron Absorbing Materials other than Boraflex Revision 0 PSL Program Owner Interview Metamic Inserts X1.M40 Monitoring of Neutron Absorbing Materials other than Boraflex 04/16/2014 During the audit, the staff verified Applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also audited the description of the SLRA AMP Monitoring of Neutron-Absorbing Materials Other Than Boraflex program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.27, Buried and Underground Piping and Tanks Summary of Information in the Application. The SLRA states that AMP B2.3.27, Buried and Underground Piping and Tanks, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-057 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Buried and Underground Piping and Tanks Revision 0 PSL-ENG-SERS 001 PSL Asset Management Plan for the Underground Piping and Tanks Integrity Program (UPTIP)

Revision 1 ER-AA-102 Underground Piping and Tanks Integrity Program Revision 15 ER-AA-102-1000 Underground Piping and Tanks Integrity Examination Procedure Revision 6 AR 01909787 Corrosion Cells on U1 Pipe in CST Trenches (Buried Piping) 10/05/2013 AR 01910285 1A, 1B and 1C AFW [Auxiliary Feedwater] Pump Suction Piping Material Loss 10/07/2013 AR 01912046 Common AFW Discharge Recirc Line is Below Min Wall 10/14/2013 NEESL00008-REPT-018 St. Lucie Units 1 and 2 SLR Screening and Aging Management Review Results - Diesel Generators and Support Systems Revision 0 WO 40361418 01 U2 DO-65: Pressure Test Guard Pipe 12/14/2019 AR 02313688 Hydrant 27 Leaking From Underground When Opened 05/08/2019 WO 40559194 01 Pressure Test DO-64 Diesel Oil Guard Piping 02/14/2020 During the audit, the staff verified the applicants claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the preventive actions program element, sufficient information was not available to verify whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing an RAI in order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP.

During the audit, the staff made the following observations:

The staff reviewed NEESL00008-REPT-057 and noted the following: (a) all stainless steel piping is encased in concrete at PSL; (b) engineered class 1 backfill at St. Lucie is alkaline with a pH of approximately 9.0; (c) the soil contains dissolved salts, has low

resistivity, and is corrosive to cast iron; (d) for steel components, the cathodic protection acceptance criteria is -850 mV relative to a copper/copper sulfate reference electrode, instant-off; and (e) there is no underground stainless steel piping in the scope of license renewal at PSL.

The staff reviewed PSL-ENG-SERS-16-001 and noted the following: (a) safety-related stainless steel and carbon steel piping in the diesel fuel oil sub-system has none as the coating material; (b) safety-related stainless-steel piping in the auxiliary feedwater sub-system has none as the coating material; and (c) auxiliary feedwater piping within the scope of the UPTIP program is located in covered trenches that is not accessible without removal of heavy concrete covers.

The staff also audited the description of the SLRA Buried and Underground Piping and Tanks program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA Buried and Underground Piping and Tanks program. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Summary of Information in the Application. The SLRA states that AMP B2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, is a new program that will be consistent with the program elements in GALL-SLR report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, as modified by SLR-ISG-2021-02-Mechanical, Updated Aging Management Criteria for Mechanical Portions of SLR Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL0008-REPT-081 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document - Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Revision 0 AR 02255986 Coatings Stress Cracks at Unit 1 RWT [Refueling Water Tank] Bottom 03/24/2018 AR 01712438 Thru-Wall Hole in U1 ICW Line 12/04/2011

AR 01718476 1A ICW Discharge Header 30-CW-30 Internal Dive Inspection 12/21/2011 AR 01723138 1B ICW Discharge Header CW-29 Internal Dive Inspection 01/10/2012 AR 01661397 Tank [Instrument Air Emergency Cooling Head Tank]

is in Degraded Condition 06/16/2011 AR 01677951 Corrosion Identified During U2 PWST [Primary Water Storage Tank] Internals Inspection 08/15/2011 AR 01711852 1A CCW HX [Heat Exchanger] Exceeded 20 Tubes Block Criteria, Eval. Required 12/02/2011 AR 01723138 1B ICW Discharge Header CW-29 Internal Dive Inspection 01/10/2012 AR 01910617 SL1-25 Internal Pipe Inspection of 1B ICW CW-11 Discovery 10/08/2013 AR 01946359 2B CCW Heat Exchanger - SL2-21 Inspection Results 03/07/2014 AR 01950802 SL2-21 Dive Inspection 2B ICW Discharge CW-29 Satisfactory 03/22/2014 AR 02038983 1B CCW Heat Exchanger - SL 1-26 Inspection Results 04/08/2015 AR 02369857 CWST 1A Internal Tank Corrosion 09/30/2020 AR 02369859 CWST 1B Internal Tank Corrosion 09/30/2020 0-CMM-21.06 ICW System Piping Inspection and Repair Revision 10 0-PMM-14.01 CCW Heat Exchanger Clean/Repair Revision 15 0-OSP-15.16 Fire Protection System Annual Flush Revision 4 WO 40750371 01 Fire Protection System Annual Flush 12/06/2021 WO 40678939 01 Fire Protection System Annual Flush 09/08/2020 WO 40677506 01 Fire Protection System Triennial Flow Test 07/15/2020 WO 40616106 01 Fire Protection System Annual Flush 09/26/2019 NEESL00008-REPT-031 St. Lucie Units 1 and 2 SLR Screening and Aging Management Review Results - Main Feedwater and Steam Generator Blowdown System Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to verify whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing an RAI in order to obtain

the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP.

The staff also audited the description of the SLRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B2.3.29, ASME Section XI, Subsection IWE The SLRA states that AMP B2.3.29, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S1, ASME Section XI, Subsection IWE. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-069 St. Lucie Units 1 and 2 SLR Aging Management program basis document - ASME Section XI, Subsection IWE Revision 0 0005760 St. Lucie Plant Implementation Guidelines of the ASME Section XI Repair and Replacement Program Revision 22 0-GMM-99.17 Threaded Fasteners on Pressure Boundaries, Structural Steel and Plant Equipment Revision 9 NDE-4.7 NDE Manual Examination Procedure - Component, Support & Inspection: Visual Examination of Reactor Building Containment Vessel General Visual/Visual VT-1/VT-3 Revision 5 Q1-10-PR/PSL-8 St. Lucie Plant Quality Instruction Procedure: Control of Repairs and Replacements Revision 21 3rd Interval-IWE-PSL-1/2-Program Plan St. Lucie Nuclear Power Plant Units 1 and 2 3rd IWE Inspection Interval Program Plan Revision 0 AR 01608576 Containment Vessel Coatings and Moisture Barrier Deficiencies 01/13/2011

AR 01612578 Light Rust, Chipped and Blistered Paint in Escape Hatch 01/26/2011 AR 01616330 Corrosion on Containment Shell Plate 23 Elevation 02/03/2011 AR 01713469 Deficiencies in the Containment and Annulus Moisture Barrier 12/07/2011 AR 01714057 Degraded Coatings on the 23 - 45 Elevation 12/08/2011 AR 01715452 Rust and Blistering on Outer Personnel Hatch 12/13/2011 AR 01717167 Areas of Degraded Paint on Containment Dome 12/17/2011 AR 02280041 Loose Nuts on Two Studs for Penetration 67 Inside Containment 09/12/2018 AR 02333564 Chipped Coatings and Gauges Identified in Containment Liner 10/30/2019 AR 02333904 Containment Maintenance Hatch Missing Cotter Pins 11/01/2019 WO 40628038-04 U2 RCB SL2-25 Protective Coatings: Inspect/Repair 02/17/2020 WO 40690306-01 U1: Containment Maintenance Hatch Missing Cotter 11/08/2019 During the audit, the staff verified the applicants claim that the scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP.

In addition, the staff found that for the preventative actions, detection of aging effects, and corrective actions program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP.

The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff made the following observations:

The staff noted that the ASME XI, Subsection IWE program provides an enhancement to preventative actions of the storage and lubricants discussed in Section 2 of the Research Council for Structural Connections (RCSC) publication for structural bolting consisting of ASTM A325, ASTM A490, and equivalent materials. However, it does not appear that AMP includes an enhancement of preventative actions for bolting and coating material selection discussed in section 2 of RCSC publication.

The staff noted a discrepancy between AMR item 3.5.1-027 and SLRA section B.2.3.29 regarding which AMP will manage cyclic loading in metal plates and penetrations that have no current licensing basis fatigue analysis.

The staff noted in the SLRA section B.2.3.29 enhancement to Element 4 detection of aging effects that there is not sufficient information for methods used for detecting cracking and how they can detect cracking in steel, SS, and dissimilar metal weld pressure-retaining components that are subject to cyclic loading but have no CLB fatigue analysis.

The staff noted in SLRA section B.2.3.29 enhancement to Element 4 detection of aging effects that procedures will be revised to specify a one-time volumetric examination of metal shell surfaces that are inaccessible from one side if triggered by plant-specific OpE identified after the date of issuance of the first renewed license for each unit.

However, it is unclear whether each unit will be subject to the volumetric examination if the triggering OpE occurs in any one unit, or if the examination will be conducted only in the unit in which the triggering OpE occurred, or some other treatment.

The staff noted in SLRA section B.2.3.29 that acceptability of inaccessible areas of steel containment vessel is evaluated when conditions found in accessible areas indicate the presence of, or could result in, flaws or degradation in inaccessible areas. However, the staff could not locate acceptability of inaccessible areas of steel containment vessel in the procedure NDE-4.7, revision 5.

The staff noted that SLRA section 3.5.2.2.1.3 does not have information whether the concrete meets the requirements of ACI 318 or ACI 349 as cited in NUREG-1557 and guidance of ACI 201.2R, as applicable; how the concrete is monitored to ensure that it is free of penetration cracks that provide a path for water seepage to the surface of the containment shell or liner; and how OpE (the borated water spills and water ponding on the concrete floor) is addressed.

The staff noted a discrepancy between AMR item 3.5.1-010 and SLRA section 3.5.2.2.1.6 regarding which AMP will manage cracking due to SCC.

The staff also audited the description of the ASME section XI, subsection IWE program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.30, ASME Section XI, Subsection IWF Summary of Information in the Application. The SLRA states that AMP B2.3.30, ASME Section XI, Subsection IWF, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-SLR Report AMP XI.S3, ASME Section XI, Subsection IWF. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the exceptions and enhancements associated with this AMP.

The staff will document its review of the exceptions to the GALL-SLR report AMP and the enhancements in the SER. The staff will address issues identified in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-038 St Lucie Units 1 and 2 SLR Aging Effects OpE; - Aging Effect OpE for Structures, Structural Components and Commodities Revision 0 AR 1681462 Reactor Vessel Supports were not included in the Inservice Inspection Program (Cook Nuclear Plant) -

01/13/2012

Industry OpE that was applicable to PSL Units 1 and 2; ISI program updated to include RV supports in examination population AR 1716657 PSL-1 Reactor Vessel Supports Not in the ISI Program 01/30/2013 AR 01991883 OpE 312397 Seismic Support ISI for CRDM (Industry OpE from Sequoyah where CRDM support was not included in ISI program) 10/08/2014 AR 2333705 Unit 1 AFW piping and pipe support BF-5-H1 experiencing moderate surface corrosion and rusting in indoor air 10/31/2019 AR 2333706 Pipe support CH-137 on AFW line (loss of material due to general corrosion and rusting of CS AFW pipe support in indoor air and treated water leakage) 10/31/2019 AR 2269265 Unit 2 MS line pipe support 2998-MS-3023 loss of material due to wear/fretting of CS pipe supports in indoor air 06/20/2018 AR 2035611 1A CCW Supply Header to CCW pump CC-16; loss of material due to general corrosion and rusting of cs piping and pipe supports in indoor air and treated water leakage 03/26/2015 AR 2162073 Corrosion Condition of Unit 1 CCW north header supply at supports CC-26-7, -7A and -7B; general corrosion of CS pipe supports in indoor air and possible treated or saline raw water leakage 10/12/2016 AR 2269268 Severely Degraded Support ms-4102B-1934:

General and Pitting corrosion of Unit 2 MS dump valve CS pipe support in indoor air 06/20/2018 AR 2121622 Unit 2 SW piping SW-106 - loss of material due to general and crevice corrosion, rusting, and flaking of insulated SW Carbon Steel piping and pipe support in indoor air 03/30/2016 AR 2255978 CC-998-11 Was Identified as Degraded during ASME Section XI [Inspection] VT-3 identified corrosion of Unit 1 cs pipe support restraining supply header to the 1B CCW HX 04/26/2018 AR 2255979 Support CC-28-11 Was Identified with Corrosion and Incomplete 03/30/2018 AR 2333951 Spring Hanger Setting Out of Tolerance, RC-005-55A, Unit 1 11/07/2019 AR 2345514 Corrosion on Items 2 and 3 of Support C-2200-12, Unit 2 02/24/2020 AR 2347627 Support C-2200-12 Follow-up Exam Results, Unit 2 03/19/2020 WO 40495487 01 Task

Title:

SL1-29: Repair Support CC-998-11; AR2255978 DISPO EC292697 06/10/2020

W/O

Title:

1B CCW SR I-24-CC-12 Corrosion on Pipe & Support WO 40495487 02 Task

Title:

SL1-29: Support CC-998-11; Shop Coatings W/O

Title:

1B CCW SR I-24-CC-12 Corrosion on Pipe & Support 10/23/2019 WO 40516960 04 Task

Title:

U1-CC-27: Replace Struct CC-28-11; AR 2255979 W/O

Title:

L1R28 ISI ZONE 1-105 LINE CC-26 09//04/2018 WO 40690308 01 Task

Title:

U1: RC-005-55A - Adjust Spring Hanger W/O

Title:

U1: RC-005-55A - Spring Hanger Setting Out of 11//16/2019 WO 40706373 02 Task

Title:

U2: C-2200-12-Clean/Remove Corrosion to Allow Inspection W/O

Title:

U2: C-2200 Corrosion on Items 2 & 3 of Support 03//17/2020 NEESL00008-REPT-058 SLR Aging Management Program Basis Document -

ASME Section XI, Subsection IWF AMP Evaluation report, St Lucie Units 1 and 2 Revision 0 STD-C-011 Acceptance Criteria for As-Built Safety Related Piping and Pipe Supports, Discipline Standard, Civil Revision 4 5th Interval-ISI-PSL-1 Program Plan Fifth Inservice Inspection Program Plan for St. Lucie Nuclear Power Plant Unit 1 Revision 0 4th-ISI-PSL-2 Program Plan Fourth Inservice Inspection Program Plan. St. Lucie Nuclear Power Plant Unit 2 Revision 0 QI-10-PR/PSL-4 Plant Inservice Inspection, Quality Instruction Procedure, St. Lucie Plant Revision 14 QI-10-PR/PSL-8 Control of Repairs and Replacements, Quality Instruction Procedure, St. Lucie Plant Revision 21 0005760 St. Lucie Plant Implementation Guidelines of the ASME Section XI Repair and Replacement Program, Administrative Procedure Revision 22 NDE 4.3 Visual Examination VT-3, NDE Manual Examination Procedure, Component, Support and Inspection, FPL Revision 12 SPEC-C-007 Specification, Erection of Structural and Miscellaneous Steel for Turkey Point Units 3 & 4 and St. Lucie Units 1 & 2 Revision 3 FLO-8770-761 Structural Steel, EBASCO Specification 02/151970 SPEC-M-004 Maintenance Bolting Specification for St. Lucie Units 1 & 2 and Turkey Point Units 3 & 4 Revision 15 M-3.6 Bolting Material Selection Standard, FPL Company 01/18/1977 0-GMM-99.17 Threaded Fasteners on Pressure Boundaries, Structural Steel and Plant Equipment Revision 9 PSL-ENG-LRAM 119 ASME Section XI, Subsection IWF Inservice Inspection Program - Program Basis Document Revision 3 LTR-SDA-21-021-NP St. Lucie Units 1 & 2 SLR: Reactor Pressure Vessel Supports Assessment, June 2021 Revision 1

PSL1-VT-21-037-010930 Reactor Vessel Support @ 60 Degree (A1 Cold-Leg upper half) VT-3 Examination (1RO30), with photos, PSL 1 04/26/2021 PSL1-VT-21-038-010950 Reactor Vessel Support @ 300 Degree (A2 Cold-Leg upper half) VT-3 Examination (1RO30), with photos, PSL 1 04/26/2021 PSL1-VT-21-046-010930 Reactor Vessel Support @ 60 Degree (A1 Cold-Leg lower half) VT-3 Examination (1RO30), with photos, PSL 1 04/26/2021 PSL1-VT-21-047-010950 Reactor Vessel Support @ 300 Degree (A2 Cold-Leg lower half) VT-3 Examination (1RO30), with photos, PSL 1 04/26/2021 PSL1-VT-21-038-010950 Reactor Vessel Support @ 300 Degree (A2 Cold-Leg upper half) VT-3 Examination (1RO30), with photos, PSL 1 04/26/2021 PSL1-VT-18-001-010910 Reactor Vessel Support @ 180 Degree (B Hot-Leg upper half) VT-3 Examination (1RO-28), with photos, PSL 1 03/31/2018 1-001/01-001-A/01-001-B/010910 Reactor Vessel Support VT-3 Examination @ 180 Degree (B Hot-Leg) with photos, PSL 1 02/01/2012 1-001/01-001-A/01-001-B/010920 Reactor Vessel Support Magnetic Particle Examination @ 180 Degree (B Hot-Leg) with photos, PSL 1 02/01/2012 1-001/01-001-A/01-001-B/010930 Reactor Vessel Support VT-3 Examination @ 60 Degree (A1 Cold-Leg) with photos, PSL 1 02/01/2012 1-001/01-001-A/01-001-B/010950 Reactor Vessel Support VT-3 Examination @ 300 Degree (A2 Cold-Leg) with photos, PSL 1 02/01/2012 PSL2-VT-21-068-010560 Reactor Vessel Support @ 180 Degree (B Hot-Leg)

VT-3 Examination (2RO26), with photos, PSL 2 09/16/2021 PSL2-VT-21-069-010580 Reactor Vessel Support @ 60 Degree (A1 Cold-Leg)

VT-3 Examination (2RO26), with photos, PSL 2 09/16/2021 2-001/02-001-A/02-001-B/010593 Reactor Vessel Support @ 300 Degree (A2 Cold-Leg) VT-3 Examination (2RO26), with photos, PSL 2 09/21/2012 During the audit, the staff verified the applicants claim that the monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP or will be consistent after implementation of the identified enhancements.

In addition, the staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR report AMP. The staff will consider issuing RAIs, RCIs or use a voluntary supplement to obtain the information necessary to verify whether these program elements, or aspects of these program elements not associated with the exceptions identified in the SLRA, are consistent with the corresponding program elements of the GALL-SLR report AMP.

During the audit, the staff made the following observations:

The staff reviewed Maintenance Procedure 0-GMM-99.17, revision 9, and noted that the approved lubricants for threaded fasteners at PSL are Neolube for stainless steel and Fel Pro N-5000 for carbon and alloy steel.

The staff reviewed section 4.10 Operating Experience of the program basis document (PBD) NEESL00008-REPT-058 and noted that it included discussion of more specific examples (than in SLRA) of plant-specific OpE (action requests or ARs) of component supports from the applicants CAP. The staff verified during the OpE audit that these examples provided objective evidence of the program adequately managing the identified effects of aging.

The staff noted a lack of clarity in the justification provided in the SLRA with regard to inspection of Class MC component supports not being included in the scope of the IWF AMP.

The staff noted a lack of clarity on the adequacy of SLRAB2.3.30 enhancement 3 to make the preventive actions program element of the SLRA AMP consistent, as claimed, with the corresponding program element of GALL-SLR AMP XI.S3 specifically with regard to preventive actions for lubricant selection, and bolting and coating material selection for ASTM A325, A490, and equivalent bolts.

The staff reviewed the PBD and noted that there was a lack of clarity on why vibration isolation elements are not included with the scope of the SLRA IWF AMP; therefore, the staff needs additional information to verify consistency of associated SLRA AMP program elements regarding aging management of vibration isolation elements.

The staff noted a lack of clarity how PSL procedures prohibits the use of molybdenum disulfide and other lubricants containing sulfur as a preventive measure to reduce SCC of high strength bolting during the subsequent period of extended operation, as claimed in the SLRA.

The staff noted that the SLRA IWF AMP was credited for identifying visible indications of loss of fracture toughness due to IE of the reactor vessel supports. However, while SLRA table 3.5.2-1 included an AMR line item for the above, it is not clear to the staff whether the existing procedures or program elements would be sufficient to identify visible indications of loss of fracture toughness in the field.

The staff noted discrepancies in SLRA table 3.5-1 regarding AMR items 3.5-1, 085 and 3.5-1, 090 which were indicated as not used instead of not applicable since the environment (treated borated water) for these line items in the GALL-SLR Report does not exist at PSL.

The staff noted a discrepancy in SLRA table 3.5-1 regarding AMR item 3.5-1, 081 which should have stated that item 3.5-1, 081 is not used and item 3.5-1, 091 is used instead.

The staff also audited the description of the SLRA ASME Section XI, Subsection IWF AMP provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate summary description of the SLRA AMP ASME Section XI, Subsection IWF. The staff will consider issuing an RAI, or use a voluntary supplement by the applicant, in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B2.3.31, 10 CFR Part 50, Appendix J Summary of Information in the Application. The SLRA states that AMP B2.3.31, 10 CFR Part 50, Appendix J, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.S4, 10 CFR Part 50, appendix J. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-071 St. Lucie Units 1 and 2 SLR Aging Management PBD

- 10 CFR Part 50, Appendix J Revision 0 AMD-68.01 St. Lucie Plant Administrative Procedure:

Containment Leakage Rate Testing Program Revision 30 ER-AA-114 Nuclear Fleet Program

Description:

Appendix J Testing Program Revision 6 1-OSP-68.01 St. Lucie Unit 1 Operations Surveillance Procedure:

Integrated Leak Rate Test Revision 38 1-OSP-68.02 St. Lucie Unit 1 Operations Surveillance Procedure:

Local Leak Rate Test Revision 49 1-OSP-68.03 St. Lucie Unit 1 Operations Surveillance Procedure:

Airlock Periodic Leak Testing Revision 8 2-OSP-68.01 St. Lucie Unit 2 Operations Surveillance Procedure:

Integrated Leak Rate Test Revision 23 2-OSP-68.02 St. Lucie Unit 2 Operations Surveillance Procedure:

Local Leak Rate Test Revision 43 2-OSP-68.03 St. Lucie Unit 2 Operations Surveillance Procedure:

Airlock Periodic Leak Testing Revision 12 2-OSP-68.04 St. Lucie Unit 2 Operations Surveillance Procedure:

Purge Valve Leak Rate Test Revision 12 Q1-10-PR/PSL-5 St. Lucie Plant Quality Instruction Procedure:

Technical Specification Surveillance Inspection of Reactor Building Revision 19 AR 01712224 FCV-26-3 (P-52B) Containment Atmosphere Radiation Monitor Failed LLRT 01/31/2012 AR 01794724 P-41 (SE-03-2A/B) Failed LLRT 09/05/2012 AR 01817385 P-56 (FCV-25-36) Failed LLRT 11/02/2012 AR 01825722 Unit 2 Personal Airlock Inner Door Seals Excessive Leakage 11/26/2012 AR 01916343 Unit 1 Personal Airlock Inner Door Seal Failed LLRT 10/30/2013 AR 01947012 P-41 (SE-)3-2A/B) Failed LLRT 04/18/2014 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also audited the description of the SLRA 10 CFR Part 50, appendix J program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.32, Masonry Walls Summary of Information in the Application. The SLRA states that AMP B2.3.32, Masonry Walls, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR report AMP XI.S5, Masonry Walls. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-072 St. Lucie Units 1 and 2 SLR Aging Management PBD

- Masonry Walls Revision 0 PSL-ENG-LRAM 095 Engineering Evaluation Form Revision 14 AMD-17.32 Structures Monitoring Program Revision 7 AR 01752739 U1 Trestle Door 114 Support Degradation 09/17/2012 AR 02082632 Reinforced Concrete and Masonry Block Walls 10/21/2015 AR 02117242 U1 Equip Ramp to RCB is Degraded 03/21/2016 AR 02145990 Cracking on Masonry Block Walls 07/28/2016 WO 40158634-01 Spalled Concrete Around Alarm Door 114 (AR 01752739) 09/13/2013 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP or will be consistent after implementation of the identified enhancements.

The staff also audited the description of the SLRA Masonry Walls program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.2.33, Structures Monitoring Summary of Information in the Application. The SLRA states that AMP B2.3.33, Structures Monitoring, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL--SLR Report AMP and the enhancements in the SER. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. On November 30 - December 1, 2021, the staff participated in an onsite audit at PSL to gain a general overview of current conditions of the structures compared to the provided OpE, an understanding of the pattern cracking or crazed concrete cracking identified in Turbine Building and RAB, and corrosion degradation for structural and mechanical components and supports exposed to an outdoor-air environment. While onsite, the staff engaged with the applicant staff, conducted walkdowns, and reviewed additional documentation provided by the applicant. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Relevant Documents Reviewed Document Title Revision / Date NEEDL00008-REPT-059 St. Lucie Units 1 and 2 SLR Aging Management PBD - Structures Monitoring Revision 0 ADM-17.32 Structures Monitoring Program Revision 9 MSP-100.01 Protective Coating Surveillance Program Revision 12 0-GMM-99.17 Threaded Fasteners on Pressure Boundaries, Structural Steel and Plant Equipment Revision 9 M-3.6 Bolting Material Selection 01/18/1977 SPEC-C-007 Erection of Structural and Miscellaneous Steel for Turkey Point Units 3 & 4 and St. Lucie Units 1 & 2 Revision 3 SPEC-M-004 Maintenance Specification Bolting for St. Lucie Units 1 & 2 and Turkey Points Units 1 &2 Revision 15 QI-7-NSC-1 Warehouse Receipt, Storage, Issuance and Maintenance Revision 24 AR 01693560 OE34348 - Preliminary - Reduction in Concrete Properties Due to Distress from Alkali-Silica Reaction (ASR) - (Seabrook 1) 10/06/2011

AR 01725652 U1 RAB Rood Degradation (WR 94040771) 01/18/2012 AR 02124010 Corroded Pipe Support Spring Cans 04/08/2016 AR 02373360 U0 UHS Dam Spalling to Rebar Big Mud Creek Side 4th Bay 10/27/2020 AR 02271498 U2 FHB Ceiling Falling Concrete - Inspection results 07/10/2018 PSL-ENG-SENS 001 Structures Monitoring Program Generic Condition Evaluation Revision 0 ADM-17.32-2015-RPT-PSL-1-CANAL 10 CFR 54.37(A) Structural Monitoring Program, Intake and Discharge Canals 6/26/2015 ADM-17.32-2015-RPT-PSL-1-CCW 10 CFR 54.37(A) Structural Monitoring Program, CCW 8/6/2014 ADM-17.32-2015-RPT-PSL-1-CST 10 CFR 54.37(A) Structural Monitoring Program, Condensate Storage Enclosure 6/6/2014 ADM-17.32-2015-RPT-PSL-1-DOEC 10 CFR54.37(A) Structural Monitoring Program, Diesel Oil Enclosure 8/28/2014 ADM-17.32-2015-RPT-PSL-1-EDG 10 CFR 54.37(A) Structural Monitoring Program, Emergency Diesel Generator (EDG) 8/21/2014 ADM-17.32-2015-RPT-PSL-1-FHB 10 CFR 54.37(A) Structural Monitoring Program, Fuel Handling Building 11/13/2014 ADM-17.32-2015-RPT-PSL1-CPFD 10 CFR 54.37(A) Structural Monitoring Program, Condensate Polisher Filter Demineralizer 6/11/2015 ADM-17.32-2015-RPT-PSL1-INTAKE 10 CFR 54.37(A) Structural Monitoring Program Intake Structure 4/6/2015 ADM-17.32-2015-RPT-PSL1-RAB 10 CFR 54.37(A) Structural Monitoring Program, Reactor Auxiliary Building 4/13/2015 ADM-17.32-2015-RPT-PSL1-RCB 10 CFR 54.37(A) Structural Monitoring Program, Reactor Containment Building 6/3/2015 ADM-17.32-2015-RPT-PSL1-SWYD 10 CFR 54.37(A) Structural Monitoring Program, Switchyard 5/18/2015 ADM-17.32-2015-RPT-PSL1-UHS 10 CFR 54.37(A) Structural Monitoring Program, Ultimate Heat Sink / Emergency Cooling Canal 6/18/2015 ADM-17.32-2015-RPT-PSL1-YARD 10 CFR 54.37(A) Structural Monitoring Program, Yard Structures Unit 1 and Common 6/18/2015 ADM-17.32-2015-RPTPSL1-TURBINE 10 CFR 54.37(A) Structural Monitoring Program, Turbine Building 6/11/2015 ADM-17.32-2015RPT-PSL1-TRESTLE 10 CFR 54.37(A) Structural Monitoring Program, Steam Trestle 6/4/2015

ADM-17.32-2016-RPT-PSL-2-CCW 10 CFR 54.37(A) Structural Monitoring Program, Component Cooling Water 4/28/2016 ADM-17.32-2016-RPT-PSL-2-CST 10 CFR 54.37(A) Structural Monitoring Program, Condensate Storage Enclosure 4/26/2016 ADM-17.32-2016-RPT-PSL-2-DOEC 10 CFR 54.37(A) Structural Monitoring Program, Diesel Oil Enclosure 4/26/2016 ADM-17.32-2016-RPT-PSL-2-EDG 10 CFR 54.37(A) Structural Monitoring Program, Emergency Diesel Generator Building 3/31/2016 ADM-17.32-2016-RPT-PSL-2-FHB 10 CFR 54.37(A) Structural Monitoring Program, Fuel Handling Building 1/29/2016 ADM-17.32-2016-RPT-PSL-2-RAB 10 CFR 54.37(A) Structural Monitoring Program, Reactor Auxiliary Building 12/2/2015 ADM-17.32-2016-RPT-PSL-2-RCB 10 CFR 54.37(A) Structural Monitoring Program, Reactor Containment Building 9/14/2015 ADM-17.32-2016-RPT-PSL-2-SWYD 10 CFR 54.37(A) Structural Monitoring Program, Switchyard 3/23/2016 ADM-17.32-2016-RPT-PSL-2-YARD 10 CFR 54.37(A) Structural Monitoring Program, Yard 3/23/2016 ADM-17.32-2016-RPT-PSL2-INTAKE 10 CFR 54.37(A) Structural Monitoring Program, Intake Structure 8/19/2015 ADM-17.32-2016-RPTPSL2-TRESTLE 10 CFR 54.37(A) Structural Monitoring Program, Steam Trestle 5/5/2016 ADM-17.32-2016-RPTPSL2-TURBINE 10 CFR 54.37(A) Structural Monitoring Program, Turbine Building 5/24/2016 During the audit, the staff verified the applicants claim that the corrective actions program element of the SLRA AMP is consistent with the corresponding element of the GALL-SLR report AMP. In addition, the staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff made the following observations:

During the review of procedure ADM-17.32, the staff noted that the current procedure does not include some of the structures and components credited in SLRA section 2.1.4.2.1 as within the scope of the Structures Monitoring program.

The staff noted that procedure ADM-17.32 does not address cracking as a parameter to be monitored or inspected for elastomeric material.

During the review of procedure ADM-17.32, the staff noted that the current program does not clearly define the parameters to be monitored or inspected for structural bolting.

During the review of procedure ADM-17.32, the staff noted that the current procedure does not include the parameters to be monitored or inspected for concrete degradations due to ASR. The staff also noted that SLRA sections 3.5.2.2.1.8, 3.5.2.2.2.1.2, and 3.5.2.2.2.3.2 stated that this was already addressed within Structures Monitoring program.

During the review of the structural deficiency reports for the Structures Monitoring program, the staff noted that several structures were identified as having a cracking/craze patterns that were dispositioned as acceptable without further details.

During the review of the structural deficiency reports for the Structures Monitoring program, the staff noted that several structures and components were identified as having corrosion related degradations at different levels.

During its audit, the staff also performed walkdowns of yard structures, turbine building, CST enclosure, fuel handling building (exterior), reactor building (exterior), RAB (exterior), and emergency diesel generator building (exterior), and shoreline embankment.

The staff made the following observations during walkdowns:

During the walkdown of the structures from the outside, the staff noted the ongoing corrosion, at different levels, of several structural and mechanical components and supports exposed to an outdoor-air environment.

During the walkdown of the Turbine Building and RAB, the staff noted the pattern cracking or crazed concrete cracking on the top of concrete roof slab.

During the walkdown of the structures and components within the scope of subsequent license renewal, the staff noted the degradations observed during the walkdowns were found to be consistent with the OpE for which the GALL-SLR report program was evaluated.

The staff also audited the description of the SLRA Structures Monitoring program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA Structures Monitoring Program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B2.3.34, Inspection of Water-Control Structures Associated With Nuclear Power Plants Summary of Information in the Application. The SLRA states that AMP B2.3.34, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR report

AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. On November 30 - December 1, 2021, two members of the staff participated in an onsite audit at PSL in Jensen, Florida to gain a general overview of current conditions of the water-control structures as it compares to what was provided OpE. While onsite, the staff engaged with the applicant staff, conducted walkdowns, and reviewed additional documentation provided by the applicant. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-073 St. Lucie Units 1 and 2 SLR Aging Management PBD

- Inspection of Water-Control Structure Associated with Nuclear Power Plants Revision 0 NEESL00008-REPT-035 St. Lucie Units 1 and 2 SLR Screening and Aging Management Review Results - Plant Structures Revision 2 ADM-17.32 Structures Monitoring Program Revision 7 AR 02033148 Unit 1 Intake Bay 1A2 SL1-26 Inspection 03/17/2015 AR 02038640 Unit 1 Intake Bay 1B2 North Concrete Wall Delamination 04/07/2015 AR 02038775 Unit 1 Intake Bay 1B2 - Delamination at Stop LOG Guide 04/07/2015 AR 02081350 Concrete Erosion Protection with Cracks, Erosion on East and West Shoreline Embankment South of UHS Dam 10/12/2015 AR 02081674 Structural & MISC Steel Corrosion in Unit 1 Intake Structure 10/13/2015 AR 02081982 Various Concrete Components with Degradation in Ultimate Heat Sink Dam 10/14/2015 AR 02122774 Concrete Pop-outs, Corroded Embedded Steel, Cracks in Unit 2 Intake Structures 04/04/2016 WO 40458782 Unit 2 Intake Structure, Repair Concrete Pop-outs &

Cracks for AR 02122774 12/11/2017 AR 02348477 Cracking and Delamination in the Wall of Unit 2 Intake Structure 03/15/2020 AR 02081678 Various Concrete Locations with Cracks, Spalls, Pop-outs 10/13/2015

WO 40428443 Various Concrete Locations with Cracks, Spalls, Pop-outs for AR 02081678 11/18/2015 During the audit, the staff verified the applicants claim that the monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP.

During the audit, the staff identified exceptions associated with the detection of aging effects program element.

In addition, the staff found that for the scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff made the following observations:

The staff noted in plant procedure ADM-17.32, Structures Monitoring Program, Revision 7 that normally submerged areas of the intake wells will be completed once every fourth refueling outage (approximately six years) when individual wells are dewatered for maintenance. It appears to be an exception associated with the detection of aging effects program element in the Inspection of Water-Control Structures Associated with Nuclear Power Plants program.

The staff noted that the Inspection of Water-Control Structures Associated with Nuclear Power Plants program provides an enhancement to preventative actions for the use of high strength bolt storage requirements. However, it does not appear that AMP includes an enhancement of preventative actions for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of ASTM A325 and/or ASTM A490 bolts, lubricant selection, and bolting and coating material selection discussed in section 2 of Research Council for Structural Connections.

The staff also noted that AMP basis document and plant procedure ADM-17.32 lack the information of parameter monitored or inspected and acceptance criteria for the cooling canals, earthen canal dikes, and steel sheet piles.

The staff noted that the AMP does not address the aggressive groundwater/soil environment and does not describe what plant-specific actions will be implemented within the AMP to ensure and demonstrate that the AMP will adequately manage degradations for inaccessible areas exposed to an aggressive water/soil environment.

The staff further noted that SLRA sections B.2.3.34, 2.4.8, 2.4.9, and 2.4.14 call out different names for water-control structures within the scope of SLR, which require the applicant to clarify the scope of program.

The staff made the following observations during walkdowns:

During the walkdown of Unit 1 and Unit 2 intake structures and ultimate heat sink dam, the staff noted that the degradations observed during the walkdowns were found to be consistent with the OpE for which the GALL-SLR report program was evaluated.

The staff also audited the description of the SLRA Inspection of Water-Control Structures Associated with Nuclear Power Plants program provided in the UFSAR supplement. The staff

found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA Inspection of Water-Control Structures Associated with Nuclear Power Plants program. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B2.3.35, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The SLRA states that AMP B2.3.35, Protective Coating Monitoring and Maintenance, is an existing program that, with enhancements, will be consistent with NUREG-2191,Section XI.S8, Protective Coating Monitoring and Maintenance as modified by SLR-ISG-2021-03-STRUCTURES, Updated Aging Management Criteria for Structures Portions of SLR Guidance (. ML20181A381). To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the Protective Coating Monitoring and Maintenance Program. These documents were provided by the applicant and identified in the staffs search of the applicants OpE database. The staff will document its review of relevant OpE in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision /

Date NEESL00008-REPT-074 AMP Basis Document Protective Coating Monitoring and Maintenance Rev 0 AR 02281402 U2 Containment Coatings Closeout Inspection 9/27/19 AR 02334904 Containment Coatings Closeout Inspection Unit 1 11/05/19 AR 2166164 Containment Coatings Closeout Inspection Unit 1 10/28/16 AR 2187164 U2 Containment Coatings As Found Walkdown 12/15/17 AR 2257751 U1 Containment Coatings Closeout Inspection 10/31/18 AR 2347772 Containment Coatings Closeout Inspection Unit 2 03/05/20 2006-09800.R3Pt 1 of 5 Debris Generation Due to LOCA within Containment for Resolution of GL2004-02 Revision 3 2006-09800.R3Pt 2 of 5 Debris Generation Due to LOCA within Containment for Resolution of GL2004-02 Revision 3 2006-09800.R3Pt 3 of 5 Debris Generation Due to LOCA within Containment for Resolution of GL2004-02 Revision 3 2006-09800.R3Pt 4 of 5 Debris Generation Due to LOCA within Containment for Resolution of GL2004-02 Revision 3

Document Title Revision /

Date 2006-09800.R3Pt 5 of 5 Debris Generation Due to LOCA within Containment for Resolution of GL2004-02 Revision 3 Calc No 2006-158981 Debris Generation Due to a LOCA within Containment for Resolution of GL 2004-02 Revision 2 Procedure No.

ADM-27.10 Implementation Controls for the Application of Protective Coatings Revision 16 Program No.

EN-AA-104 Conduct of Engineering Revision 16 Program No.

ER-AA-109 Nuclear Fleet Protective Coatings Revision 4 SPEC-C-034 Specification: Protective Coatings for Service Level I Applications Inside the Reactor Containment Building Revision 9 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP. During the audit of the OpE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific OpE in the SER.

The staff also audited the description of the SLRA AMP Protective Coating Monitoring and Maintenance program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.36, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA notes that AMP B2.3.36 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification (EQ) Requirements, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities: During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The staff also conducted an onsite audit to perform plant walkdowns of relevant areas. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the

pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program.

Document Title Revision / Date AR 00581873 Cable Connecting Rows on Battery Require Replacement 09/20/2010 AR 01815200 Degraded Insulation on 2 A Condensate Pump Feeders 11/19/2012 AR 01905927-20 PSL -1 Spec-E-022 Containment Cable Inspections U1 and U2 03/2005 SPEC-E-022 Containment - Cable Inspection Program St Lucie Units 1 and 2 10/2017 NEESL00008-REPT-075 St. Lucie Units 1 and 2 SLR Aging Management PBD - Electrical Insulation For Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 Inspection Report 05000335/2015010 St Lucie Plant, Unit 1 - U.S. Nuclear Regulatory Commission Post-Approval Site Inspection for License Renewal, Inspection report 05000335/2015010 01/4/2016 ER-AA-106 Cable Condition Monitoring Program Revision 5 EN-AA-206 Nuclear Fleet Process Description, Non-safety Related Revision 12 UFSAR Unit 1 UFSAR 02/26/2021 AR 1815200 U2 Repair Cond 2A Pump Cable Repair WO 40119245 10/25/2012 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements.

During the onsite portion of the audit the staff performed interviews and walkdowns of the facility. Specifically, the staff conducted onsite walkdowns of the 230 kV switchyard and cable raceways and examined an open electrical manhole.

The staff also audited the descriptions of SLRA section 19.2.2.36, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3 37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Summary of Information in the Application. The SLRA notes that AMP B2.3.37 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification (EQ) Requirements used in instrumentation circuits, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E2, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements used in instrumentation circuits. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant has not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed only the applicants basis document as well as the available current relevant maintenance procedures.

Audit Activities: During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision/Date AR 4152634152632005-3048-Area Radiation Monitor RIS 26-24-2 3/17/2005 AR 01627407 Found Degraded cable and Insulation brittle for TE-1121Y 11/19/2012 AR 01904161 Int Range-Wide Range Power Recorder Reading 9/18/2013 AR 02272292 RIM-26-29Ch 1 cable was broken 08/20/2018 AR 02280431 Power Range Detector #8 09/17/2018 AR 02076275 Radiation degraded connector and brittle cable RIM 72-001. Pre-Service Test Fail 12/14/2015

NEESL00008-REPT-076 ST. Lucie Units 1 and 2 SLR Aging Management PBD - Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Revision 0 Inspection Report 05000389/2017009 St Lucie Plant, Unit 2 - U.S. Nuclear regulatory Commission Post-Approval Site inspection for License Renewal, Inspection Report 05000389/2017009 11/30/2017 SPEC-E-022 Containment - Cable Inspection Program St Lucie Units 1 and 2 10/2017 EC-289491 Containment Cable Inspection Program - License Renewal Basis Document Revision 0 UFSAR Unit 1 UFSAR 02/26/2021 AR 01965957 Batch (P) SMI-64.05A-D-Nuc Instr. Channel Calibration 07/23/2014 AR 01797219 Support testing of Detectors That were Affected by CSR Leak 08/29/2012 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP. The staff also audited the descriptions of SLRA section 19.2.2.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits, provided in appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.38, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA notes that AMP B2.3.38, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR report AMP XI.E3A, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG202104-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the SLR Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed all the

documents necessary to implement this program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and documents provided by the applicant via the ePortal.

The staff also conducted an onsite audit to perform plant walkdowns of relevant areas. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Tittle Revision/Date NEESL00008REPT077 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document-Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 EQ Requirements 11/17/2020 AR01729388 Megger Submerged Cables in Manhole M299V 03/13/2013 AR01854721 Unit 1 Manhole M156 Degraded Drain 03/14/2013 AR01862103 MII143 Standing Water 04/28/2014 AR01892123 Degraded Cable Supports in Security Manhole M291 07/30/2013 AR02330577 U2 Manhole Program Cannot be Established PMID 4851601 02/19/20 WO 4050469301 U1: Safety Related/Non-Safety Related Manhole 09/25/17 WO 40609577 U2: RCA Area Security Manhole Inspections 06/03/2019 WO 4070571101 U1; Sec Manhole M143 Inspection 02/12/21 PSL Health Report Cable Health 2019 Q4 11/25/2020 PSL Health Report Cable Health 2020 Q4 11/25/2020 ERAA106 Cable Condition Monitoring Program Revision 5 SPEC-E022 Containment Cable Inspection Program St.

Lucie Units 1 and 2 Revision 4 SCEG032 Cable Condition Monitoring Program (CCMP)

Revision 3 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP as modified by SLR-ISG202104-ELECTRICAL.

As indicated above, the applicant noted in the SLRA that AMP B2.3.38 will be consistent with the program elements in GALL-SLR Report AMP XI.E3A as modified by SLR-ISG202104-ELECTRICAL. However, based on its review of the SLRA, the staff found that the language in AMP B2.3.38 is not consistent with SLR-ISG202104-ELECTRICAL as certain terms such as potentially are not included within SLRA AMPB2.3.38. Based on this, during a breakout discussion the staff requested the applicant to explain the apparent deviations from SLR-

ISG202104-ELECTRICAL. In response to the staffs request, the applicant noted that it would review SLRA AMP B2.3.38 to ensure consistency with SLR-ISG202104-ELECTRICAL and provide a supplement to the SLRA if necessary. The staff will document its review of any supplemental information provided by the applicant in the SER.

During the onsite portion of the audit the staff performed interviews and walkdowns of the facility. Specifically, the staff examined cables, connections, and manholes that are in the scope of SLR. During a walkdown, the staff examined an open electrical manhole associated with this AMP. The staff did not observe any signs of cable submergence or degradation of cables in this manhole.

The staff also audited the descriptions of SLRA section 19.2.2.38, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. With the exceptions noted above regarding inconsistencies with SLR-ISG202104-ELECTRICAL, the staff verified that the descriptions are consistent with the description provided in the GALL-SLR report as modified by SLR-ISG202104-ELECTRICAL.

SLRA AMP B2.3.39, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA notes that AMP B2.3.39, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3B, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG202104-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the SLR Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The staff also conducted an onsite audit to perform plant walkdowns of relevant areas. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Tittle Revision/Date AR02331603 MH Drainage Flow Path to ECB#1 does not Exist-MHS Can Drain 01/23/2020 WO 40665085 01 U1: Clean/Inspect RCA Security Manholes 05/16/2020 AR02144946 MHole 291, Cable Supports are Degraded 07/25/2016 AR01892123 Degraded Cable Supports in Security Manhole M291 07/30/2013

AR02330577 U2 Manhole Program Cannot be Established PMID 48516 02/19/2020 AR02388893 GL 20071 Cable Manhole Inspection Program Revision 1 NEESL00008REPT082 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document-Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 GL200701 ML071290529 Response to NRC Generic Letter 200701 Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients 05/06/2007 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP as modified by SLR-ISG202104-ELECTRICAL.

During the onsite portion of the audit, the staff performed interviews and walkdowns of the facility. Specifically, the staff examined cables, connections, and manholes that were in the scope of SLR. During a walkdown, the staff examined an open electrical manhole associated with this AMP. The staff did not observe any signs of cable submergence or degradation of cables in this manhole.

The staff also audited the descriptions of SLRA section 19.2.2.39, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the description provided in the GALL-SLR report as modified by SLR-ISG202104-ELECTRICAL.

SLRA AMP B2.3.40, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA notes that AMP B2.3.40, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR report AMP XI.E3C, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG202104-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of SLR Guidance specified in NUREG-2191 (GALL-SLR). To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant has not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. During audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The staff also conducted an onsite audit to perform plant walkdowns of the relevant areas. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the

pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision/Date NEESL0008REPT 83 St. Lucie Units 1 and 2 SLR Aging Management Program Basis Document-Electrical Insulation for Inaccessible Low-Voltage Power Cables not subject to 10CFR50.49 Environmental Qualification Requirements Revision 0 ADM09.01 Severe Weather Preparations Revision 2 SCEG032 Cable Condition Monitoring Program (CCMP)

Revision 3 SPEC-E022 Containment Cable Inspection Program St. Lucie Units 1 &2 Revision 4 AR23388893 GL200701 Cable Manhole Inspection Program 02/08/2022 AR02330577 U2 Manhole Program cannot be established PMID 481601 02/19/2020 AR02333241 Medium Volt Cable Program not implemented as required at PSL 02/27/2020 AR02038272 PSL Health Report Cable Health 2015_2020 11/25/2020 AR02331603 MH Drainage Flow Path to ECB#1 does not exist-MHS cannot drain 01/23/2020 AR02363654 U1: Manhole 110 sump pump not working 07/28/2020 AR02144946 MHole 291 cable supports are degraded 07/25/2016 EC273408 PSL health report cable health 2019 Q4 11/25/2020 WO4004541502 Repair ECB#1 Pipe entry from other manhole locations 03/09/2022 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR report AMP as modified by SLR-ISG202104-ELECTRICAL.

During the onsite portion of the audit the staff performed interviews and walkdowns of the facility. Specifically, the staff examined cables, connections, and manholes that were in the scope of SLR. During a walkdown, the staff examined an open electrical manhole associated with this AMP. The staff did not observe any signs of cable submergence or degradation of cables in this manhole.

The staff also audited the descriptions of SLRA section 19.2.2.40, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the description provided in the SRP-SLR report as modified by SLR-ISG202104-ELECTRICAL.

SLRA AMP B2.3.41, Metal Enclosed Bus Summary of Information in the Application. The SLRA notes that AMP B2.3.41, Metal Enclosed Bus, is a new program (portions of which were previously conducted as part of the Periodic Surveillance and Preventative Maintenance Program [PSPM]) that will be consistent with the program elements in GALL-SLR Report AMP XI.E4, Metal Enclosed Bus. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant has not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the information provided by the applicant, available procedures, and referenced documents.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The staff also conducted an onsite audit to perform plant walkdowns of the relevant areas. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. The table below lists the documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

Document Tittle Revision/Date 0-GME-100.13 Cable, Motor and Bus Hi-Pot/Surge Testing Instructions Rev.1 08/2016 0-PME-53.11 Non-Segregated Bus Inspections Rev.2 05/2020 AR02103279 Degraded Section of Bus at 1B SUT 6.9kV NSB Riser 01/2016 AR02324951 License Renewal PSPM AMP Effectiveness Review 08/2019 EC 294393 EVALl-PSL-ENG-LRAM-00-096 Rev. 14 Periodic Surveillance and Preventive Maintenance Program -License Renewal Basis Document Revision 0 NEESL00008-REPT-084 SLR Aging Management PBD - Metal Enclosed Bus Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the onsite portion of the audit, the staff performed interviews and walkdowns of the facility. Specifically, the staff looked at exposed metal enclosed buses, cables, connections, and electrical manholes associated with SLR. The staff was unable to walkdown and observe internal elements of metal enclosed buses associated with this AMP since the PSL units were online and access to enclosed buses was not available. No adverse or abnormal conditions with equipment associated with metal enclosed buses were observed during the walkdowns.

The staff also audited the descriptions of SLRA sections 19.2.2.41, Metal Enclosed Bus, provided in appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2,

Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the description provided in the GALL-SLR Report.

SLRA AMP B2.3.42, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA notes that AMP B2.3.42, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant has not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date NEESL00008-REPT-038 St Lucie Units 1 and 2, SLR Aging Effects OpE Revision 0 NEESL00008-REPT-086 St. Lucie Units 1 and 2 SLR Aging Management PBD - Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Revision 0 AR 01755959 1A Transformer Cooler Relay Failed 04/2012 AR 01790101 PSL 3832 - 1C Static Inverter Capacitor Terminal Increased Temp.

08/2012 AR 01807910 Broken Connector J3 on A Channel NI Safety Drawer 09/2012 AR 01827489 PSL 3832 - Battery/Hydraulic Crimper failed Calibration 11/2012 AR 01845949 PSL 3832 - Battery Charger Thermal Anomaly During Load Test 02/2013 AR 02076275 1B2 Degraded Connector and Brittle Cable RIM-26-72 09/2015

Document Title Revision / Date 0-PDM-99.02 Thermography Acquisition / Analysis/Trending Revision 1 SCEG-32 Cable Condition Monitoring Program (CCMP)

Revision 3 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also audited the descriptions of SLRA section 19.2.2.42, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the description provided in the GALL-SLR report.

SLRA AMP B2.3.43, High-Voltage Insulators Summary of Information in the Application. The SLRA notes that AMP B2.3.43, High-Voltage Insulators, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E7, High-Voltage Insulators, as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the SLR Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant has not yet fully developed all the documents necessary to implement this program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and documents provided by the applicant via the ePortal.

The staff also conducted an onsite audit to perform plant walkdowns of relevant areas. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date PSL Program Owner Interview St. Lucie High-Voltage Insulators N/A NEESL00008-REPT-038 St Lucie Units 1 and 2, SLR Aging Effects OpE Revision 0 NEESL00008-REPT-087 St. Lucie Units 1 and 2 SLR Aging Management PBD - High-Voltage Insulators Revision 0

Document Title Revision / Date AR02224588 Unit 1 shutdown due to degraded PSL switchyard conditions 09/2017 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP as modified by the SLR-ISG-2021-04-ELECTRICAL.

During the onsite portion of the audit, the staff performed interviews and walkdowns of the facility. Specifically, the staff examined exposed metal enclosed buses, cables, insulators, overhead lines, control cabinets, high-voltage (HV) switchgear, connections, and electrical manholes associated with SLR. The staff discussed the preventive maintenance program for HV insulators and the salt laden environment at PSL. The applicant explained their preventive maintenance program and specific actions taken after a severe weather event, such as a hurricane, and an in-situ sample insulator installed in the switchyard that can be laboratory tested to detect adverse impacts of the environment on a generic basis. The staff noted that maintenance performed on the HV insulators is condition-based. The switchyard has a weather station that monitors contamination levels and based on summary reports, appropriate actions can be taken to replace or clean contaminated insulators. During the switchyard walkdown, the staff did not observe any adverse or abnormal conditions with HV insulators and associated equipment.

The staff also audited the descriptions of SLRA Section 19.2.2.43, High-Voltage Insulators, provided in the appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2 Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the description provided in the GALL-SLR Report as modified by SLR-ISG-2021-04-ELECTRICAL.

SLRA AMP B2.3.44, Pressurizer Surge Line Summary of Information in the Application. The SLRA states that AMP B2.3.44, Pressurizer Surge Line, is an existing plant-specific aging management program. The staff audited the SLRA AMP to determine consistency with SRP-SLR Section A.1.2.3, Aging Management Program Elements. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. Furthermore, the staff conducted additional OpE searches on the applicants CAP database.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED

Document Title Revision / Date NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 NEESL00008-REPT-023 St. Lucie Units 1 and 2 SLR Aging Management PBD - Pressurizer Surge Line Revision 0 AR 2061624 Implementation of the Pressurizer Surge Line Inspection Program - AMP 7/21/2015 AR 2374153 License Renewal Effectiveness Review and SLR Interview Track 11/2/2020 SIA 1301103.401-NP Flaw Tolerance Evaluation of St. Lucie Surge Line Welds Using ASME Code Section XI, Appendix L Revision 0 SIA 2001262.401 Flaw Tolerance Evaluation of St. Lucie Units 1 and 2 Surge Line Using ASME Code,Section XI, Appendix L for SLR Revision 1 SIA 2001262.320 (redacted)

Flaw Tolerance Evaluation for St. Lucie Nuclear Plant, Units 1 and 2 Revision 1 SIA 1301103.304 appendix L Flaw Tolerance Evaluation of Surge Line PSL Units 1 and 2 Revision 2 CE Specification Number 19367-31-5 Engineering Specification for Reactor Coolant Pipe and Fittings for Florida Power and Light St.

Lucie Plant Unit No. 1 Revision 14 CEN-387-P Pressurizer Surge Line Flow Stratification Revision 1-P-A L-2019-134 NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 22 Annual Submittal 7/12/2019 L-2015-272 Submittal of Pressurizer Surge Line Welds Inspection Program 10/29/2015 During the audit, the staff reviewed SLRA section B2.3.44 to verify that the applicant followed the guidance in SRP-SLR section A.1.2.3 for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element of the SLRA AMP.

SLRA section B.2.3.44 provides the overall program description and OpE program element of the Pressurizer Surge Line Program. However, SLRA section B.2.3.44 does not clearly describe the other program elements of the Pressurizer Surge Line Program even though this program is a plant-specific program that is not generically described in the GALL-SLR Report. Therefore,

the staff found that additional information may be needed in relation to the program elements that are clearly described in SLRA section B.2.3.44.

The staff also audited the description of the SLRA Pressurizer Surge Line Program provided in the UFSAR supplement. The staff verified this description is an adequate summary description of the program, consistent with the guidance in the SRP-SLR.

SLRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses Summary of Information in the Application. SLRA section 4.1, Identification of Time-Limited Aging Analyses, discusses the methodology for the identifying of TLAAs in the SLRA. To verify the implementation of the applicants methodology to identify TLAAs in accordance with 10 CFR Part 54, the staff performed an audit. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists a document that was reviewed by the staff and was found relevant to the program.

The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-037 ST. Lucie Units 1 and 2 SLR Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 1 During the audit, the staff verified that the applicant has provided its basis and methodology for identifying TLAAs in accordance with disposition of 10 CFR 54.21(c).

During the audit, the staff made the following observations:

The staff reviewed NEESL00008-REPT-037 and confirmed that current licensing basis and design basis documentation were searched to identify potential TLAAs. The staff noted that specific key words were used during this search that would identify potential TLAAs.

The staff reviewed NEESL00008-REPT-037 and confirmed that each potential TLAA was reviewed against the six criteria of 10 CFR 54.3(a) and that those that met all six criteria were identified as TLAAs, which require evaluation for the subsequent period of extended operation.

The staff reviewed NEESL00008-REPT-037 and confirmed that a search of docketed licensing correspondence, the operating license, and the UFSAR identified the active exemptions currently in effect pursuant to 10 CFR 50.12.

The staff reviewed NEESL00008-REPT-037 and confirmed that these exemptions were then reviewed to determine whether the exemption was based on a TLAA and that two applicable 10 CFR 50.12 exemption that involves a TLAA was included in the SLRA.

SLRA TLAA Section 4.2.1, Neutron Fluence Projections Summary of Information in the Application. The SLRA states that AMP B2.2.2, Neutron Fluence Monitoring, and AMP B2.3.19, Reactor Vessel Material Surveillance, are part of the St. Lucie Units 1 & 2 AMP. The staff audited the SLRA AMP. During the audit, the staff also reviewed the exceptions and enhancements associated with this AMP and provided in GALL-SLR Report AMP X.M2, Neutron Fluence Monitoring. The staff will address issues identified in this audit report in the SER.

Neutron irradiation embrittlement is a TLAA to be evaluated for the subsequent period of extended operation for all ferritic materials that have a neutron fluence greater than 10^17 n/cm2 (E >1 MeV) at the end of the subsequent period of extended operation. Certain aspects of neutron irradiation embrittlement are TLAAs as defined in 10 CFR 54.3. TLAAs are required to be evaluated in accordance with 10 CFR 54.21(c)(1). This TLAA is addressed separately in Section 4.2, Reactor Pressure Vessel Neutron Embrittlement Analysis, of the SRP-SLR.

Audit Activities. During its audit, the staff interviewed the applicants documentation contained in the SLRA and provided by the applicant via the ePortal. This information was reviewed in conjunction with the Irradiation Effects on Concrete and RV Steel Supports, documented in Section 2, AMR Items Not Associated with an AMP, of this report.

The relevant sections of SRLA are:

3.1.2.2.3, Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation 3.5.2.2.2.7, Expected Further Evaluation for Loss of Fracture Toughness due to Irradiation Embrittlement of Reactor Pressure Vessel (RPV) Supports from NRC Review of the Previous SLRAs 4.2, Reactor Vessel Neutron Embrittlement Analysis (entire section)

For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the SLRA and ePortal. The table below lists documents (in addition to those listed in Section 2, AMR Items Not Associated with an AMP, of this report) that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date WCAP-18124-NP-A Fluence Determination with RAPTORM3G and FERRET - Supplement for Extended Beltline Materials Revision 0, Supplement 1-P LTR-REA-21-1-NP St. Lucie Units 1 & 2 Subsequent License Renewal:

Unit 1 Reactor Vessel, Vessel Support, and Bioshield Concrete Exposure Data Revision 1 LTR-SDA-21-021-P St. Lucie Units 1&2 Subsequent License Renewal:

Reactor Pressure Vessel Supports Assessment Revision 1

SLRA TLAA Sections 4.2.2 through 4.2.5 Summary of Information in the Application. The staffs audit addresses the following TLAAs collectively due to their relationship in analyzing the reactor vessel neutron embrittlement:

SLRA section 4.2.2, Pressurized Thermal Shock discusses the analysis for assessing the pressurized thermal shock (PTS) of the RPV as required by 10 CFR 50.61. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).

SLRA section 4.2.3, Upper-Shelf Energy discusses the analysis for assessing the projected reduction in the upper-shelf energy (USE) properties of RPV base metal and weld components. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).

SLRA section 4.2.4, Adjusted Reference Temperature discusses the analysis for assessing the use of adjusted reference temperature (ART) limits to adjust the pressure-temperature limit curves to account for irradiation effects. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).

SLRA section 4.2.5, Pressure-Temperature (P-T) Limits and Low Temperature Overpressure Protection (LTOP) Setpoints discusses the assessment of P-T limits and LTOP setpoints for the RPV. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date WCAP-18609-NP St. Lucie Units 1 & 2 SLR: Time-Limited Aging Analyses on Reactor Vessel Integrity Revision 2 NEA150217 - 646530901 (offsite box number)

St. Lucie 1 Reactor Vessel Material Certification Reports - 19367 - 74167 Revision 0 NEA150218 - 646530901 (offsite box number)

St. Lucie 2 Reactor Vessel Material Certification Reports - 71172 Revision 0 During the audit of the applicable TLAAs, the staff verified that the applicant provided the basis to support its disposition of 10 CFR 54.21(c)(1)(ii) for PTS, USE and ART and 10 CFR 54.21(c)(1)(iii) for P-T limits and LTOP setpoints. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition as described above. In order to obtain the necessary information, the staff will consider issuing an RAI.

During the audit, the staff made the following observations:

The staff verified that the material information (e.g., initial RTNDT, %Cu, %Ni, initial USE, margin values) for the Beltline materials for Unit 1 and Unit 2 contained in applicant SLRA Tables (Unit 1 -tables 4.2.2-1, 4.2.3-1, 4.2.4-3 and 4.2.4-5; Unit 2 - tables 4.2.2-2, 4.2.3-2, 4.2.4-4 and 4.2.4-6) are consistent with the applicants current licensing basis (e.g., UFSAR, license amendments revising Pressure-Temperature Limits).

The staff verified that the material information (e.g., initial RTNDT, %Cu, %Ni, initial USE) for the Extended Beltline materials for Unit 1 contained in SLRA Tables 4.2.2-1, 4.2.3-1 4.2.4-3 and 4.2.4-5 were based on information from certified material test reports, fabrication records, and/or database containing reactor vessel material information for the specific material with the exception of two reactor vessel materials. Additionally, based on this verification, the staff observed that the appropriate margin value consistent with Regulatory Guide 1.99, Rev. 2, were applied for each Unit 1 reactor vessel material for the purposes of addressing PTS and ART. For two reactor vessel materials (i.e.,

Upper to Intermediate Shell Girth Weld Seam 8-203 and Upper Shell Axial Weld Seams 1-203 A, B, & C), the staff will consider issuing an RAI to obtain the necessary information.

The staff verified that the material information (e.g., initial RTNDT, %Cu, %Ni, initial USE) for the Extended Beltline materials for the Extended Beltline materials for Unit 2 contained in SLRA tables 4.2.2-2, 4.2.3-2, 4.2.4-4 and 4.2.4-6 were based on information from certified material test reports, fabrication records, an NRC-approved topical report, and/or database containing reactor vessel material information for the specific material. Additionally, based on this verification, the staff observed that the appropriate margin value consistent with Regulatory Guide 1.99, Rev. 2, were applied for each reactor vessel material for the purposes of addressing PTS and ART.

The staff also audited the description of the SLRA TLAA section 4.2.2, 4.2.3, 4.2.4 and 4.2.5 provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.1, Metal Fatigue of Class 1 Components Summary of Information in the Application. SLRA section 4.3.1, Metal Fatigue of Class 1 Components, discusses the fatigue analysis for class 1 piping and components. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. Furthermore, the staff conducted additional OpE searches on the applicants CAP database.

The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 AR 2374153 License Renewal Effectiveness and SLR Interview Track 11/2/2020 NEESL00008-REPT-037 St. Lucie Units 1 and 2 SLR Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 1 SIR-01-102 Thermal Cycle Evaluation for St. Lucie Units 1 and 2 Revision 3 CEN-387-P Pressurizer Surge Line Flow Stratification Evaluation Revision 1-P-A CEN-387-NP Pressurizer Surge Line Flow Stratification Evaluation Revision 1-NP-A CN-SDA-II-20-026 St. Lucie Unit 1 and Unit 2 80-year Transient Cycle Projections Revision 2 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

SLRA Tables 4.3.1-1 and 4.3.1-2 describe the design transients for St. Lucie Units 1 and 2, respectively. These tables indicate that some transients will not be monitored in the Fatigue Monitoring Program (e.g., plant loading, five percent/minute and 10 percent step load increase transients). In addition, tables 1 and 2 of the Westinghouse LTR-SDA-II-20-32-NP report indicate that these design transients were excluded from cycle monitoring because the transients resulted in a fatigue usage less than 0.1 or large margins were present with respect to actual cycle counts versus allowable cycle limits. The staff found a need to clarify that the basis of excluding these transients from fatigue monitoring is valid for 80 years of operation (e.g., demonstration of the conservatism associated with the 80-year estimated cycles compared to the design cycles to confirm a large cycle margin).

As discussed above, SLRA tables 4.3.1-1 and 4.3.1-2 describe the 80-year projected cycles for the design transients of St. Lucie Units 1 and 2, respectively. These table do not include the bolt-up transient for the reactor vessel. In comparison, the following reference evaluates the design basis thermal cycles for the current licensing basis (

Reference:

SIR-01-102, revision 3, Thermal Cycle Evaluation for St. Lucie Units 1 and 2). This reference includes the bolt-up transient as a design transient. The SIR-01-102 report also explains that the transient is excluded from cycle counting based on a large cycle margin in the current licensing basis. The staff found a need for the applicant to clarify why SLRA tables 4.3.1-1 and 4.3.1-2 do not identify the bolt-up transient as a design transient in contrast with the SIR-01-102 report and the basis of excluding this transient from cycle counting for the 80-year operation.

SLRA section 4.3.1 states that the transients, which are included in the current Fatigue Monitoring program but not included in the original St. Lucie LRA, are presented in SLRA tables 4.3.1-3 and 4.3.1-4 for St. Lucie Units 1 and 2, respectively. SLRA tables 4.3.1-5 and 4.3.1-6 describe the 80-year projections for the additional transients (e.g., loss of letdown flow transient) that support the 80-year fatigue evaluations for St. Lucie Units 1 and 2, respectively. However, the SLRA does not clearly discuss whether the Fatigue Monitoring Program will monitor these additional transients.

The staff also audited the description of the SLRA fatigue TLAA for Class 1 components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.2, Metal Fatigue of Non-Class Components Summary of Information in the Application. SLRA Section 4.3.2, Metal Fatigue of Non-Class 1 Components, discusses the fatigue analysis for non-Class 1 piping systems. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii) for the hot-leg sample lines and 10 CFR54.21(c)(1)(i) for the other non-Class 1 piping systems. To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. Furthermore, the staff conducted additional OpE searches on the applicants CAP database.

The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 AR 2374153 License Renewal Effectiveness and SLR Interview Track 11/2/2020 NEESL00008-REPT-037 St. Lucie Units 1 and 2 SLR Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 1 NEESL00008-CALC-002 St. Lucie Unit 1 Analysis of RCS Hot-Leg Sample Lines for SLR Revision 0 NEESL00008-CALC-003 St. Lucie Unit 2 Analysis of RCS Hot-Leg Sample Lines for SLR Revision 0

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its dispositions of 10 CFR 54.21(c)(1)(ii) for the hot-leg sample lines and 10 CFR 54.21(c)(1)(i) for the other non-Class 1 piping systems. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI.

During the audit, the staff made the following observations. The staff will consider issuing an RAI to address the potential concerns associated with these observations.

SLRA Table 4.3.3-2 indicates that the reactor coolant sampling line is subject to approximately 29200 cycles for 80 years of operation. Accordingly, the applicant used a stress range reduction factor of 0.7 for the sample lines, which allows thermal cycles up to 45000. However, the SLRA does not clearly discuss how the stress analysis for sample lines with the stress range reduction factor (0.7) meets a relevant acceptance criterion.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the fatigue TLAA for the non-Class 1 components. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement description.

SLRA TLAA Section 4.3.3, Environmentally-Assisted Fatigue Summary of Information in the Application. SLRA Section 4.3.3, Environmentally-Assisted Fatigue, discusses the environmentally-assisted fatigue (EAF) for reactor coolant pressure boundary components. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. Furthermore, the staff conducted additional OpE searches on the applicants CAP database.

The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 AR 2374153 License Renewal Effectiveness and SLR Interview Track 11/2/2020

Document Title Revision /

Date NEESL00008-REPT-037 St. Lucie Units 1 and 2 SLR Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 1 Westinghouse Calculation Note CN-SDA-II-20-022 St. Lucie Units 1 and 2 SLR: Primary Equipment and Piping EAF Screening Evaluation Revision 1 Westinghouse Report LTR-SDA-II-20-31-NP St. Lucie Units 1 and 2 Subsequent License Renewal: Primary Equipment and Piping EAF Evaluations Revision 2 BWXT Report MSLEF-SR-01-NP St. Lucie Unit 1 Replacement Steam Generator EAF Report Revision 0 Framatome Document No. 86-9329647-000 St. Lucie SLR CUFen Evaluations Summary 07/15/2021 SIA Report 2001262.403 Summary of Fatigue Usage for Charging Nozzle at St. Lucie Units 1 and 2 for Subsequent License Renewal Revision 0 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.

During the audit, the staff made the following observations. The staff will consider issuing RAIs to address the potential concerns associated with these observations.

The Framatome 86-9329644-001 report summarizes the EAF analysis for St. Lucie Unit 2 replacement steam generators, Unit 1 and 2 replacement reactor vessel closure heads, Unit 2 pressurizer repairs, Unit 2 weld overlays and Unit 2 auxiliary spray line reducer

(

Reference:

Framatome Document Number 86-9329644-001, St. Lucie SLR CUFen Evaluations Summary, July 15, 2021). Table 5-2 of the Framatome report specifies the reduced cycles of the transients that are used in the environmental cumulative usage factor (CUFen) calculations, as reduced from the design cycles. Some of these transients, which involve reduced cycles, will not be monitored in the Fatigue Monitoring Program, as indicated in SLRA section 4.3.1. The staff found a need for the applicant to clarify the basis for excluding the transients with the reduced cycles from fatigue monitoring.

The staff also noted that the primary coolant pump starting/stopping transient (also designated as the DP transient) is used in the EAF analysis for the St. Lucie Unit 2 steam generator tube-to-tubesheet weld. However, SLRA section 4.3.1 and Framatome 86-9329644-001 report do not clearly address whether the pump transient for St. Lucie Unit 2 will be monitored in the Fatigue Monitoring Program. In addition, SLRA Section 4.3.1 and

Framatome report, tables 5-2 and 5-3 address pressurizer spray nozzle transients.

However, these tables do not clearly discuss whether the following transients, which involve reduced cycles in the CUFen calculations, will be monitored in the Fatigue Monitoring Program: (1) spray nozzle transient (also called the spray nozzle transient 17A/B/C); (2) main spray initiation transient; (3) auxiliary spray at power 1 and auxiliary spray at power 2 transients; and (4) main spray term in cooldown transient.

The staff also audited the description of the SLRA EAF TLAA for reactor coolant pressure boundary components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.4, High Energy Line Break Analyses Summary of Information in the Application. SLRA section 4.3.4, High Energy Line Break Analyses, discusses the HELB TLAA for St. Lucie Unit 2 piping systems. The applicant dispositioned the HELB TLAA in accordance with 10 CFR54.21(c)(1)(iii) for the ASME Code Class 1 piping and in accordance with 10 CFR54.21(c)(1)(i) for the non-Class 1 piping.

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. Furthermore, the staff conducted additional OpE searches on the applicants CAP database.

The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 NEESL00008-REPT-037 St. Lucie Units 1 and 2 SLR Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 1 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i) for the Unit 2 non-Class 1 piping and 10 CFR 54.21(c)(1)(iii) for the Unit 2 class 1 piping. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI.

During the audit, the staff made the following observations. The staff will consider issuing an RAI to address the potential concerns associated with these observations.

SLRA section 4.3.4 indicates that the postulation of HELB locations is, in part, based on the CUF criterion for class 1 piping (i.e., CUF greater than 0.1). However, the applicant did not

clearly address whether the 80-year operation may increase the CUF values at the class 1 piping locations above the CUF threshold of 0.1 for HELB postulation such that additional break locations may need to be evaluated in the HELB analysis.

The staff also audited the description of the SLRA HELB TLAA for reactor coolant pressure boundary components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. SLRA Section 4.4, Environmental Qualifications (EQ) of Electrical Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant electrical and instrument and control (I&C) equipment. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. During its audit, the staff interviewed the applicants staff, and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date AR 02013850 U1: MSIV Solenoid Valve Coil Thermal Life (EQ) 12/17/2014 AR 02128663 EQ CDBI Identified CHRRM Indication Error During DBA 04/28/2016 AR 02137338 ACE to Address Green NCV from NRC EQ CDBI 06/10/2016 AR 02128751 EQ DCBI Identified Issue Related to Program Documentation 04/29/2016 AR 02388818 OE from PB EQ SLR NRC Review Regarding Use of EPRI NP1558 04/05/2021 AR 02214276 U2: EQ/HCV092B Replace Limit Switch 07/10/2017 AR 02347464 Rosemount Interim Eval of Deviation 03/06/2020 AR 02376733 EQ LR Effectiveness Review 11/26/2020 AR 02128612 EQ Doc Pac Did Not Specify Limiting Component 04/28/2016 N/A EQ Program Health Report 11/24/2020

Document Title Revision /

Date NEESL00010CAL C001 PSL SLR 80Year Doses for Equipment Qualification Revision 0 PSL-ENG-LRAM00099 EQ Program-License Renewal Basis Document Revision 8 St. Lucie Plant Unit No 2 Equipment Qualification Documentation Package Drawing No. 2998A-4511000 Equipment Qualification Report and Guidebook Revision 12 St. Lucie Plant Unit No 1 Equipment Qualification Documentation Package Drawing No. 8770A-4511000 Equipment Qualification Report and Guidebook Revision 14 ERAA112 EQ Program Revision 5 QI2PSL6 EQ of Electric Equipment Revision 9 N/A PSL SLR EQ Program Update Review N/A Doc Pac No. 41.0 AVCO Solenoid Valves NEW &

Revision 5 Doc Pac No. 5.0 Brand-Rex Cable Company Electric Cable NEW &

Revision 9 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). The staff notes that the applicant generated AR 02388818 to evaluate whether the recent revision to EPRI NP1558, A Review of Equipment Aging Theory and Technology, has any adverse effects on the qualification of electric equipment at St. Lucie Nuclear Plant, Units 1 and 2 (specifically related to the activation energy used to determine the qualification of components). The staff finds that this corrective action should be adequate to ensure the continued environmental qualification of electric equipment is within the scope of this TLAA.

The staff also audited the descriptions of SLRA sections 19.2.1.3, Environmental Qualification of Electric Equipment, and 19.3.4, Environmental Qualification of Electric Equipment, of appendixes A1, Unit 1 Updated Final Safety Analysis Report Supplement, and A2, Unit 2

Updated Final Safety Analysis Report Supplement. The staff verified that the descriptions are consistent with the descriptions provided in the SRP-SLR Report.

SLRA TLAA Section 4.5, Concrete Containment Tendon Prestress St. Lucie Units 1 and 2 containments utilize a reinforced concrete design without the use of prestressed tendons. Therefore, the loss of tendon prestress is not applicable to the St. Lucie containment shield buildings.

SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments and Penetration Fatigue Summary of Information in the Application. SLRA section 4.6 Containment Liner, Metal Containments and Penetrations Fatigue discusses the analysis for fatigue of the metal containment vessel (thus no containment liner) and penetrations. The applicant dispositioned the TLAA for the metal containment and penetrations in accordance with 10 CFR 54.21(c)(1)(i).

To verify that the applicant provided a basis to support its disposition of the TLAAs, the staff audited the above TLAAs. The staff will address issues identified during the audit in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-037 SLR Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 1 PSL-1FSC-01-020 Steel Containment Fatigue Evaluation, PSL Unit 1 09/18/2001 PSL-2FSC-01-021 Steel Containment Fatigue Evaluation, PSL Unit 2 09/18/2001 PSL-69-5065 Nuclear Containment Vessel Stress Report, Unit 1 Revision 2 PSL-73-7302 Stress Report for PSL 2, For EBASCO Inc. & FPL Co. Steel Containment Vessel Stress Report (3 Volumes) Unit 2 Revision 1 FLO-2998.124 EBASCO Specification Containment Piping Penetration Assemblies for St Lucie Plant, Unit No. 2 (containment sump anchors instead on fuel transfer tube positioner in Unit 1)

Revision 4 FLO-8770.124 EBASCO Specification Containment Piping Penetration Assemblies, for St Lucie Plant Unit No. 1

[Equipment required by spec are fuel transfer tube penetration assembly, flued head piping penetration assemblies, expansion bellows, removable steel Revision 5

protective covers over bellows, and fuel transfer tube positioner]

PSL-ENG-LRTA 051, Attachment 8.5-1 Evaluation of Containment Bellows Revision 0 Drawing 8770-G-213, Sheet 1 of 4 Reactor Containment Building Piping Penetrations, St Lucie Plant, Unit 1 Revision 6 Drawing 8770-G-213, Sheet 2 of 4 Reactor Containment Building Piping Penetrations),

St Lucie Plant, Unit 1 (Fuel Transfer Tube)

Revision 7 Drawing 8770-G-213 Sheet 3 of 4 Reactor Containment Building Piping Penetrations (Type I & Type III), St Lucie Plant, Unit 1 Revision 8 Drawing 8770-G-213, Sheet 4 Reactor Containment Building Piping Penetrations (Shield Wall Pipe Sleeves), St Lucie Plant, Unit 1 Revision 6 2998-G213 Sheet 1 of 4 Reactor Containment Building Piping Penetrations (Type II & Type IV Penetration), St Lucie Plant, Unit 2

Revision 6 2998-G213 Sheet 2 of 4 Reactor Containment Building Piping Penetrations, St Lucie Plant, Unit 2 (FTT)

Revision 6 2998-G213 Sheet 3 Reactor Containment Building Piping Penetrations (Type I & Type III), St Lucie Plant, Unit 1 Revision 9 2998-G213 Sheet 4 Reactor Containment Building Piping Penetrations (Shield Wall Pipe Sleeves), St Lucie Plant, Unit 2 Revision 8 UFSAR, Appendix 3G Appendix 3G - Piping Penetrations Calculations, PSL Unit 1 UFSAR 05/2020 (Amendment No. 30)

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs during the audit.

During the audit, the staff made the following observations:

The staff noted that SLRA section 4.6 (Penetrations Fatigue) cited NUREG-1779 as the technical input information source for the TLAA, which is the NRC staffs SER related to the license renewal of St Lucie Nuclear Plant and not a CLB document for St Lucie.

Therefore, it was not clear what the source of input cycles stated above is that was used for the TLAA for fatigue of containment penetrations. It was also not clear whether the containment penetrations fatigue applies to only containment piping (mechanical) penetrations.

The staff noted that SLRA Section 4.6 (Penetrations Fatigue - Type I through Type IV) lacked clarity with regard to: (i) what type of fatigue analysis (e.g., CUF, fatigue waiver, implicit) was performed for the containment penetrations and what fatigue parameter (e.g., CUF, fatigue waiver parameters, cracking) was evaluated against what acceptance criteria; (ii) what is the expected number of cycles of the transient considered in the design for 80 years of operation to justify that the cycles considered in the design are bounding for SPEO; and (iii) the justification for the conclusion that the fatigue analysis for the referenced penetrations is bounded by that of the associated piping systems,

especially considering that their design criteria and codes of record are different. Further, the statement regarding being bounded also appears to be contradictory to a related statement in SLRA section 3.5.2.2.1.5 that fatigue waiver analyses were performed on mechanical penetrations.

The staff noted that SLRA table 3.5.2-1 does not include AMR line item(s) corresponding to table 3.5-1, item 3.5-1, 009 for the containment vessel. The staff also noted that SLRA table 3.5-1, item 3.5-1, 027 included a contradictory statement that a fatigue analysis was not performed for the containment vessel, which appears to be an error.

The staff also audited the descriptions of the SLRA TLAA Containment Liner Plate, Metal Containments and Penetrations Fatigue provided in the UFSAR supplement in section 19.3.5 of SLRA appendices A1 and A2. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA TLAA Containment Liner Plate, Metal Containments and Penetrations Fatigue. The staff will consider issuing an RAI and/or use a voluntary SLRA supplement offered by the applicant during the audit in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement descriptions.

SLRA TLAA Section 4.7.1, Leak-Before-Break of Reactor Coolant System Piping Summary of Information in the Application. SLRA section 4.7.1, Leak-Before-Break of Reactor Coolant System Piping, discusses the leak-before-break (LBB) analysis for the reactor coolant system piping. St. Lucie dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that St. Lucie provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. The staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. The staff conducted its review of the St. Lucie OpE database using keywords: crack, leak rate, leak-before-break, RCS piping, rupture.

During the audit breakout session, the staff interviewed the St. Lucie staff and reviewed documentation provided by St. Lucie. The staff reviewed the following relevant documents:

Relevant Documents Reviewed Documents Title Revision/Date CEN-367-A LBB Evaluation of Primary Coolant Loop Piping in Combustion Engineering-Designed Nuclear Steam Supply Systems Revision 0 02/1991 WCAP-18617-NP St. Lucie Units 1 & 2 SLR: Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis Revision 1 06/2021 WCAP-18617-P St. Lucie Units 1 & 2 SLR: Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis Revision 1 06/2021

NUREG/CR-4513 Estimation of Fracture Toughness of Cast Stainless Steels During Thermal Aging in LWR Systems Revision 1 05/1994 NUREG/CR-4513 Estimation of Fracture Toughness of Cast Stainless Steels During Thermal Aging in LWR Systems Revision 2 05/2016 NUREG-0800, Section 3.6.3 LBB Evaluation Procedures Revision 1 03/2007 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). The staff found sufficient information was available to complete its review of the applicants basis for its TLAA disposition. If further information is needed to complete the staffs SE input, the staff will consider issuing RAIs.

The staff also audited the description of the SLRA TLAA LBB provided in the UFSAR supplement. The staff verified that this description is consistent with the information provided in the UFSAR supplement of the SLRA TLAA LBB. If further information is needed to complete the staffs SE input, the staff will consider issuing RAIs.

SLRA TLAA Section 4.7.2, Alloy-600 Instrument Nozzle Repairs Summary of Information in the Application. The SLRA states that TLAA 4.7.2, Alloy 600 Instrument Nozzle Repairs, discusses the analysis for the following small-bore Alloy 600 nozzles that have been repaired, either due to leakage or as a preventative measure.

Unit 1 Instrument Identification numbers PDT-1121D, TE-1112HA, TE-1112HB, TE-1112HC, TE-1112HD, TE-1111X, TE-1122HA, TE-1122HB, TE-1122HC, TE-1122HD, TE-1121X, PDT-1111A, PDT-1111B, PDT-1111C, PDT-1111D, PDT-1121A, PDT-1121B, PDT-1121C and RC-143.

Unit 2 Instrument Identification numbers PZR Upper Head Steam Space A, PZR Upper Head Steam Space B, PZR Upper Head Steam Space C, PZR Upper Head Steam Space D, RC-105, RC-130, TE-1101, TE-1112HA, TE-1111X, TE-1122HC, TE-1122HD, TE-1121X, TE-1112HB, TE-1112HC, TE-1112HD, TE-1122HA, TE-1122HB, PDT-1121B, PDT-1111A, PDT-1111B, PDT-1111C, PDT-1111D, PDT-1121A, PDT-1121C, PDT-1121D, RCS Hot-Leg Flow Nozzle Sample Line and 30 pressurizer heater sleeves.

The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(i).

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. The staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Relevant Documents Reviewed

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Document Title Revision / Date CE Owners Group Topical Report, CE NPSD-1198-P Low-Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs CEOG Revision 00 02/08/2001 Westinghouse Report LTR-SDA-20-097-NP St. Lucie Units 1 & 2 SLR: Alloy 600 Half-Nozzle Repair Flaw Evaluation Revision 3 09/15/2021 Westinghouse Report LTR-SDA-20-097-P St. Lucie Units 1 & 2 SLR: Alloy 600 Half-Nozzle Repair Flaw Evaluation (Proprietary)

Revision 3 09/16/2021 Westinghouse Calculation Note, CN-CI-02-71 Summary of Fatigue Crack Growth Evaluation Associated with Small-Diameter Nozzles in CEOG Plants Revision 2 12/09/2005 WCAP-15973-P-A Low-Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs Revision 0 2/2005 Westinghouse Calculation Note CN-CI-02-69 Evaluation of Fatigue Crack Growth Associated with Small-Diameter Nozzles for St. Lucie 1 & 2 (Proprietary)

Revision 0 10/09/2002 Westinghouse Calculation Note CN-SDA-II-20-026 St. Lucie Unit 1 and Unit 2 80-Year Transient Cycle Projections Revision 2 07/12/2021 CE Design Analysis A-CEoG-9449-1242 Evaluation of the Corrosion Allowance for Reinforcement and Effective Weld to Support Small Alloy 600 Nozzle Repairs Revision 00 06/13/2000 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

SLRA TLAA Section 4.7.3, Unit 1 Core Support Barrel Repairs Summary of Information in the Application. SLRA section 4.7.3 contains a description of the applicants TLAA related to Unit 1 Core support barrel (CSB) repairs (henceforth termed the Unit 1 Core Support Barrel Repair TLAA). The applicant dispositioned the Unit 1 CSB repairs in accordance with 10 CFR 54.21(c)(1)(ii) because the applicant has projected the CSB repair plug and patch deflections through the SPEO in accordance with 10 CFR 54.21(c)(1)(ii). The applicant analyzed the CSB degradation as shown in Westinghouse letter reports LTR-SDA 104-NP (non-proprietary) and LTR-SDA-20-104-P (proprietary), which are presented in Enclosures 4 and 5 of the SLRA, respectively. The applicant determined that the Unit 1 CSB repair plug and patch deflections are acceptable for 80 years of plant operation. To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

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Audit Activities. During the audit, the staff reviewed relevant documents contained in the SLRA, the applicants ePortal and previously submitted materials. The staff discussed matters related to this TLAA with the applicant during the staffs virtual audit breakout session meeting that was held with the applicant on January 18, 2022. The table below lists documents that were reviewed by the staff and were found relevant to the Unit 1 CSB repairs TLAA. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision /

Date FPL Letter L-2019-013 Evaluation of CSB Spring 2018 Inspection Results (. ML19044A636 and ML19044A638) 2/11/2019 FPL Letter L-2019-130 St. Lucie Unit 1 Revised Plant-Specific Evaluation of the CSB Spring 2018 Inspection Results (. ML19232A095 and ML19232A096) 8/19/2019 FPL Letter L-2020-066 WCAP-18452-P, Revision 1, St. Lucie Unit 1 CSB and Core Shroud Flaw Analysis (ML20134J047 and ML20134J048) 4/30/2020 St Lucie SLRA Enclosure 4 Attachment 12 Westinghouse Letter LTR-SDA-20-104-NP, Rev 3 St. Lucie Units 1&2 SLR: Evaluation of Time-Limited Aging Analysis of the RVIs, September 14, 2021 (Non-proprietary)

Revision 3 9/14/2021 St Lucie SLRA Enclosure 5 Attachment 7 Westinghouse Letter LTR-SDA-20-104-P, Rev 3

St. Lucie Units 1&2 SLR: Evaluation of Time-Limited Aging Analysis of the RVIs, September 14, 2021 (proprietary)

Revision 3 9/14/2021 Westinghouse Calculation Note, F-ME-C-000019 Evaluation of CSB Repair Plug Preloads for RSG and License Renewal," in ePortal.

Revision 0, 9/20/2001 Westinghouse Calculation Note, CN-RIDA-09-4 "St. Lucie Unit 1 EPU Evaluation of CSB Repair Plug Preload," in ePortal.

Revision 0, 3/31/2009 Westinghouse Calculation Note, CN-RIDA-09-9 "St. Lucie Unit I EPU RVIs Stress Analysis," as modified by: (a) Assessment Record, CN-RJDA-09-9-R1-ASMT-1," in ePortal.

Revision 1, 8/30/2013 Combustion Engineering Calculation, 19367-640-60 "Calculation of Minimum Allowable Plug Flange Deflections," in ePortal.

Revision 01, 9/10/1985

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Document Title Revision /

Date Combustion Engineering Document, 19367-MD-GI-0I "Guidelines for Post Installation Inspection of CSB Plugs and Patches," in ePortal.

Revision 05, 10/23/1985 During the audit, the staff observed the following:

The staff observed that, in the SLRA, the applicant manages applicable aging effects in the CSB assembly components as part of the applicants SLRA bases for implementing its RVIs Program, which the SLRA states is an Existing AMP for the facility (SLRA AMP B2.3.7). However, the staff also observed that the applicant is not crediting its RVIs AMP for management of loss of preload due to irradiation-assisted stress relaxation or creep in the installed Unit 1 CSB repair plugs and support lug patches. The staff observed that, instead, the applicant is using the Unit 1 CSB Repair TLAA in section 4.7.3 of the SLRA as the basis for managing this aging effect in these components. The staff notes that section 1.2.1 of NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, indicates that TLAAs may be used as an alternative option (i.e., in lieu of using an AMP or defined aging management activities) for managing the aging effects in accordance with the requirements in 10 CFR 54.21(a)(3) and thus finds this approach acceptable.

The staff observed that SLRA section 4.7.3 states that the applicant installed the Unit 1 CSB repair plugs and patches as part of the past corrective actions for resolving degradation in CSB assembly-to-thermal shield support lug interfaces in 1983, where the cracking was detected in the CSB assembly in areas adjacent to the thermal shield lugs and the CSB was determined to have separated from the thermal shield lugs. The staff observed that the applicant implemented the following corrective actions for resolving this OpE event to ensure and maintain the core support function of the CSB assembly:

Removed the Unit 1 thermal shield as a design modification for the RVIs design of the unit.

Installed crack arrest holes in portions of the CSB that contains through-wall crack indications and implemented machining to remove non-through-wall cracks detected in the CSB assembly (i.e., for the cracks detected in the regions of the CSB adjacent to the thermal shield support lugs).

Installed plugs in the CSB crack arrest holes and patches to the damaged support lug tear areas.

Performed a time-dependent analysis (Combustion Engineering Calculation No.

19367-640-60) to assess potential loss of preload that might occur in the CSB support lug patches and crack arrest hole plugs over time. The staff noted that, for the objectives of the SLRA, the applicant is using the updated loss of preload analysis in Westinghouse Letter No. LTR-SDA-20-104-P, revision 3, as the basis for the CSB Repair Plug TLAA that is evaluated in SLRA section 4.7.3 and for projecting the applicable preload analysis out to the end of the subsequent period of extended operation.

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During the audit of the subject TLAA, the staff verified that the applicant has provided its basis that supports its disposition of Unit 1 CSB repairs in accordance with 10 CFR 54.21(c)(1)(ii).

The staff will provide its safety evaluation of the Unit 1 CSB Repair TLAA in section 4.7.3 of the SER.

The staff notes that the TLAA of the CSB repair is related to the AMR of RVI components. As such, below is the staffs audit of RVI AMR that is associated with the Unit 1 CSB repair.

Staff Review of AMR Item for RVI Components Summary of Information in the Application. During the AMR audit, the staff reviewed the component-specific or commodity group-based line items for RVI components and plant documentation associated with SLRA able 3.1.2-2, Reactor Vessel Internals - Summary of Aging Management Evaluation, against component-specific AMR screening results for RVI components in SLRA able 2.3.1-2, Reactor Vessel Internals Components Subject to Aging Management Review.

Relevant Documents Reviewed Document Title Revision / Date NRC SLR-ISG Document No.

SLR-ISG-2021-01-PWRVI Updated Aging Management Criteria for RVI Components for Pressurized Water Reactors (ML20217L203) 01/08/2021 NUREG-2191, Volume 1 Generic Aging Lessons Learned for GALL-SLR Report (ML17187A031) 02/07/2017 EPRI Report No. 3002017168 Materials Reliability Program:

Pressurized Water Reactor Internals I&E Guidelines MRP-227, Revision 1-A (ML20175A112) 12/2019 The staff also audited the summary description of the Unit 1 CSB Repair TLAA provided in the UFSAR supplement in SLRA, appendix A1, section 19.3.6.3. The staff verified that the summary description is consistent with the description provided in section 4.7, Other Plant-Specific Time-Limited Aging Analyses, of the SRP-SLR. The staff will provide its evaluation of the UFSAR supplement for Unit 1 Core Support Repair TLAA in section 4.7.3 of the SER.

SLRA TLAA Section 4.7.4, Reactor Coolant Pump Flywheel Fatigue Crack Growth Summary of Information in the Application. SLRA section TLAA 4.7.4, Reactor Coolant Pump Flywheel Fatigue Crack Growth (henceforth RCP flywheel TLAA), discusses the fatigue crack growth analyses for the reactor coolant pump (RCP) flywheel at St Lucie Units 1 and 2. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i). To verify that the applicant provided an acceptable technical basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. During the audit, the staff reviewed relevant documents provided by the applicant in its ePortal, previously submitted materials, and SLRA. The staff discussed matters related to this TLAA with the applicant during the staffs virtual audit breakout session meeting

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that was held with the applicant on January 18, 2022. The staff reviewed the following relevant documents.

RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date Atomic Energy Commission (AEC) Safety Guide 141 RCP Flywheel Integrity (ML12305A254)

Revision 0, 10/27/1971 NRC Regulatory Guide 1.14 RCP Flywheel Integrity, Revision 1, August 1975 (ML003739936)

Revision 1 08/1975 Unit 1 UFSAR section 1.7, including Table 1.7-11 Design Compliance with AEC Safety Guides, Information Guides and Code of Federal Regulations Cross References, (. ML20141L646)

Amendment No.

30, 5/2020 Unit 2 UFSAR, section 1.8, including Table 1.8-1 Applicable NRC Regulatory Guides (ML20268A117)

Amendment No.

26, 9/2020 Unit 1 UFSAR Section 5.5.5.3, RCP Flywheel Analysis (ML20141L651)

Amendment No.

30, 5/2020 Unit 2 UFSAR Section 5.4.1.1, RCP Flywheel Integrity (. ML20268A125)

Amendment No.

26, 9/2020 NUREG-1779 Section 4.1.2, SER Related to the License Renewal of St Lucie Units 1 and 2 (. ML032940205)

Revision 1 9/2003 Topical Report SIR-94-080-A Relaxation of RCP Flywheel Inspection Requirements (ML20211N486 for the cover letter and ML20211N492 for the report)

Revision1 10/14/1997 NRC Safety Evaluation NRC SE of topical report SIR-94-080, Relaxation of RCP Flywheel Inspection Requirements (ML20013C086) 5/21/1997 FPL Letter L-2019-091 License Amendment Request to modify RCP inspection program in Technical Specifications (ML19282D338) 10/9/2019

1. Unit 1 UFSAR table 1.7-1 references the applicants basis for conforming to staffs original guidelines in AEC Safety Guide 14, RCP Flywheel Integrity. Per the information in SLRA Section 4.7.4, the applicant applies the updated basis for AEC Safety Guide 14 in NRC Regulatory Guide 1.14, as referenced in the first-and second-line item entries in the above table. The applicant is permitted to use the updated guidance in NRC RG 1.14 in lieu of the prior guidance for RCP flywheel integrity in AEC Safety Guide 14.

During the audit, the staff made the following observations:

The staff observed that applicants basis for performing an analysis of fatigue crack growth in the RCP flywheel rotors and discs was originally performed as an original design basis calculation for conforming to AEC Safety Guide 14, as referenced in the table above. The

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staff noted that per the information in SLRA section 4.7.4, the applicant references use of the updated staff guidance for RCP flywheel integrity in NRC Regulatory Guide 1.14.

The staff observed that the RCP flywheel fatigue crack growth analysis that forms the basis for the RCP flywheel TLAA (applicable to Units 1 and 2) is given in topical report SIR-94-080-A, revision 1. The staff observed that the time-dependent flaw growth analysis in SIR-94-080-A, revision 1, was approved in an NRC SE dated May 21, 1997. The staff noted that although the referenced NRC SE for the topical report was related to a license amendment for the Arkansas Nuclear One, Units 1 and 2, the NRCs SE is also applicable to the RCP flywheel fatigue flaw growth analyses at St. Lucie Units 1 and 2.

In the SE of the topical report, the staff made the following statement regarding the use of SIR-94-080-A for the RCP flywheel inspection intervals at St. Lucie Units 1 and 2:

Licensees for ANO-2, Palisades. Millstone 2, Waterford 3, and St. Lucie 1 & 2 who plan to submit a plant-specific application of this topical report need to verify the reference temperature RTNDT for their RCP flywheels. Also, if these licensees have flywheels made of materials other than SA 533 B and SA 508, they need to justify the use of the KIC v.s. (T - RTNDT) curve in appendix A of section XI of the ASME Code to derive their respective KIC values.

The staff observed that the applicant addressed the above matters for St. Lucie Unit 2 in the applicants license amendment request of October 10, 2019, for St. Lucie Unit 2, which formed the basis for maintaining re-inspections of the Unit 2 RCP flywheels on a 10-year re-inspection interval basis.

During the audit of the TLAA, the staff verified that the applicant has provided its technical basis that supports its disposition of RCP flywheel fatigue crack growth in accordance with 10 CFR 54.21(c)(1)(i).

The staff will evaluate this TLAA and the relationship of these observations to the TLAA in SER section 4.7.4.

The staff also audited the summary description of the TLAA for the RCP flywheel fatigue crack growth analyses provided in the UFSAR supplement in SLRA appendix A1, Section 19.3.6.4 for Unit 1 and appendix A2, Section 19.3.6.3 for Unit 2. The staff verified these summary descriptions are consistent with the generic description provided in section 4.7, Other Plant-Specific Time-Limited Aging Analyses, of the SRP-SLR. The staff will provide its evaluation of the UFSAR supplement for the Units 1 and 2 RCP flywheel fatigue crack growth analyses TLAA in section 4.7.4 of the SER.

SLRA TLAA Section 4.7.5, Reactor Coolant Pump Code Case N-481 Summary of Information in the Application. SLRA section 4.7.5, Reactor Coolant Pump Code Case N-481, discusses the analysis for the acceptability of applying code case N-481 to the reactor coolant pump casings at St. Lucie. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the

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OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date Westinghouse Letter Report LTR-SDA-20-099-P Revision 2 St. Lucie Units 1&2 Subsequent License Renewal:

Task 9E RCP Casing Code Case N-481 Evaluation Revision 2 09/15/2021 ASME Code Case N-481 Alternative Examination Requirements for Cast Austenitic Pump Casings,Section XI, Division 1 03/28/2004 Combustion Engineering Owners Group CEN-412, Revision 2 Relaxation of Reactor Coolant Pump Casing Inspection Requirements Revision 2 04/1993 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports the disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the SLRA reactor coolant pump code case N-481 provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.7.6, Crane Load Cycle Limit Summary of Information in the Application. SLRA section 4.7.6, Crane Load Cycle Limits, discusses the analyses of crane load cycles for cranes that comply with NUREG-0612 and are in the scope of SLR, including the reactor building polar cranes, spent fuel handling machines, turbine building gantry cranes, and others. The applicant dispositioned the TLAAs in accordance with 10 CFR 54.21(c)(1)(i). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision / Date NEESL00008-REPT-037 St. Lucie Units 1 and 2 SLR TLAA and Exemptions Based on Time-Limited Assumptions Revision 01 CMAA Specification No. 70 ONS Crane Manufacturers Association of America, Inc. Specification No. 70 1975

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NUREG-1779 SER Related to the License Renewal of St. Lucie Nuclear Plant, Units 1 and 2, Section 4.6.2, Crane Load Cycle Limit 07/2003 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants 07/1980 PSL UFSAR, Unit 1 Section 9.6.3, Implementation of NUREG-0612 Guidelines Section 18.3.6, Crane Load Cycle Limit Amendment 23 Amendment 20 PSL UFSAR, Unit 2 Section 9.6.3, Implementation of NUREG-0612 Guidelines Section 18.3.6, Crane Load Cycle Limit Amendment 24 Amendment 25 UFSAR, U1, Sec.

18.3.6 Crane Load Cycle Limit Amendment No.

20 UFSAR, U2, Sec.

18.3.6 Crane Load Cycle Limit Amendment No.

25 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

The staff also audited the description of the SLRA Crane Load Cycle Limit TLAA provided in the UFSAR supplement. The staff verified this description is consistent with the guidance provided in the SRP-SLR section 4.7.3.

SLRA TLAA Section 4.7.7, Flaw Tolerance Evaluation for CASS RCS Piping Components Summary of Information in the Application. SLRA section 4.7.7, Flaw Tolerance Evaluation for CASS RCS Piping Components, discusses the applicants TLAA evaluation for the reactor coolant piping components fabricated from CASS materials. The section addresses the susceptibility of the CASS components to thermal aging embrittlement and the associated flaw tolerance analysis. The applicant dispositioned this TLAA in accordance with 10 CFR 54.21(c)(1)(ii), stating that the analysis has been projected to the end of the subsequent period of extended operation. To verify that the applicant has provided a valid basis to support its disposition of this TLAA, the staff audited the TLAA.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Document Title Revision /

Date NEESL00008-REPT-078 St. Lucie Units 1 and 2 SLR Aging Management PBD -

Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Revision 0, 7/28/2021

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Document Title Revision /

Date NEESL00008-REPT-037 SLR Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 1 Structural Integrity Report No.

2001262.402 Flaw Tolerance Evaluation of St. Lucie, Units 1 and 2 CASS Components for SLR Revision 1, 7/15/2021 Structural Integrity Report No.

1301079.402 Flaw Tolerance Evaluation of St. Lucie Units 1 and 2 CASS Components Revision 0, 11/5/2020 During the audit of TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RCIs, RAIs and/or use a voluntary SLRA supplement offered by the applicant during the audit.

During the audit, the staff made the following observations:

The staff reviewed the TLAA basis document Structural Integrity Report No.

2001262.402, Revision 1, Flaw Tolerance Evaluation of St. Lucie Units 1 and 2 CASS Components for SLR, dated July 15, 2021. The staff noted that tables 3 through 6 of the report contain the 60-year CASS evaluation results for Safety Injection Nozzle Safe Ends, Surge Lines, and RCP Safe Ends. The tolerable flaw depth in Safety Injection Nozzle Safe Ends and Surge Lines is 0.98 inches. At the bounding stress paths, the final flaw depth in the Safety Injection Nozzle Safe Ends would reach 0.91 inches in 480 months and in the Surge Lines it would reach 0.97 inches in 252 months. In contrast, table 9 of the report shows the same CASS re-evaluation results for the same components but for 80 years of operation. These crack growth results show that, after 960 months, the final limiting flaw depth following the bounding stress path would only reach 0.45 inches, less than half of the tolerable flaw depth of 0.98 inches that was previously estimated.

The NRC staff noted that aside from the updated 80-year projected cycles and applying the fatigue crack growth law of ASME code case N-809, Reference Fatigue Crack Growth Rate Curves for Austenitic Stainless Steels in Pressurized Water Reactor Environments, the remaining inputs to the 80-year flaw evaluation were similar to those for 60-years. However, the results suggest that operating period more than three times longer than the previously evaluated limiting time would result in a flaw less than half of the previously evaluated flaw depth. Additionally, SLRA section 4.7.7 states, For the SPEO, the SI Report used an updated version of crack growth software pc-Crack, which eliminated some of the unnecessary conservatisms in the PEO report. Apparently, this new version eliminates some of the unnecessary conservatisms by allowing the user to input rise time and metal temperature when doing the calculations. However, it was not clear to the staff: (a) what conservatisms were removed, (b) how these conservatisms decrease the maximum flaw growth so greatly from the previous analysis that 80-year operation is now justified, and (c) how the removal of these conservatisms will ensure safe operation of the plant up to 80 years.

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During the audit of the OpE associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff did not identify any additional aging effects that would have an impact on the applicants evaluation of the TLAA.

The staff also audited the UFSAR supplement description of the SLRA TLAA Flaw Tolerance Evaluation for CASS RCS Piping, provided in sections 19.3.6.7 and 19.3.6.6 of SLRA appendices A1 and A2. The staff found that sufficient information was not available to determine whether the descriptions provided in the UFSAR supplements were an adequate description of the SLRA TLAA on the flaw tolerance analysis for CASS RCS piping components. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement descriptions.

SLRA TLAA Section 4.7.8, Unit 2 Structural Weld Overlay PWSCC Crack Growth Analysis The SLRA states that TLAA 4.7.8, Unit 2 Structural Weld Overlay PWSCC Crack Growth Analysis, discusses the analysis for the following Unit 2 dissimilar metal welds.

Pressurizer surge nozzle Pressurizer relief valve nozzle Hot-leg shutdown cooling nozzles Hot-leg surge nozzle Hot-leg drain nozzle The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(iii).

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. The staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.

Relevant Documents Reviewed Document Title Revision / Date Framatome Document No.

86-9329648-000 St. Lucie SLR Crack Growth Analysis Summary -

Non-Proprietary 07/02/2021 Framatome Document No.

86-9329645-000 St. Lucie SLR Crack Growth Analysis Summary -

Proprietary 07/01/2021

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Document Title Revision / Date ASME Code Case N-770-5 ASME/BPVC CASE N-770, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation ActivitiesSection XI, Division 1 Revision 5 11/07/2016 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI.

During the audit, the staff made the following observations:

From review of Document No. 86-9329645-000, the staff noted in Section 2.4, PWSCC Crack Growth Mechanisms, the primary water SCC (PWSCC) crack growth rate for Alloy 52M that the applicant used. The NRC has not endorsed this crack growth rate and is currently reviewing its adequacy.

The staff interviewed the applicant to verify: (a) if the NRC endorses a different crack growth rate, what actions would the applicant take to address the revised rate, and (b) where this process is documented in the applicants procedures.

AMR Items Not Associated with an AMP SLRA AMR FE 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation and 3.5.2.2.2.7, Expected Further Evaluation for Loss of Fracture Toughness due to IE of RPV Supports from NRC Review of the Previous SLRAs Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:

SLRA table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation, which cites primary shield wall concrete exposed to indoor air uncontrolled environment.

SLRA table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation, which cites RV steel supports and bolting exposed to indoor air uncontrolled environment.

SLRA table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation, which cites sliding surfaces (Lubrite) exposed to indoor air uncontrolled environment.

SLRA table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation, which cites RCS Class 1 steel supports exposed to indoor air uncontrolled environment.

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SLRA table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation, which cites RCS Class 1 steel supports exposed to air with borated water leakage environment.

SLRA table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation, which cites steel anchorage/embedment exposed to indoor air uncontrolled and air with borated water leakage environments.

SLRA table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation, which cites ASME Class 1 structural bolting exposed to indoor air uncontrolled environment.

In addition, the staff reviewed:

SLRA table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation, which cites for concrete primary shield wall exposed to indoor air uncontrolled environment has plant-specific note that states irradiation of the concrete primary shield wall is addressed in section 3.5.2.2.2.6 and is managed by the Structures Monitoring (B.2.3.33) AMP.

SLRA table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation, which cites RV steel supports and bolting exposed to indoor air uncontrolled environment has a plant-specific note that states that the loss of fracture toughness aging effect due to IE of the steel reactor vessel supports and bolting is addressed in section 3.5.2.2.2.7 and is managed by the ASME Section XI, Subsection IWF (B.2.3.30)

AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to SLRA AMRs 3.5.2.2.2.6 and 3.5.2.2.2.7. The staff will document its review of this information in the SER.

Relevant Documents Reviewed Document Title Revision / Date NEESL00008-Rept-098 St. Lucie Units 1 and 2 SLR Primary Shield Wall Irradiation Evaluation Revision 0 Enercon Addendum to NEESL00008-Rept-098 PSW CLB History Slides 02/17/2022 EPRI Report 3002002676 Expected Condition of Reactor Cavity Concrete After 80 Years of Radiation Exposure 02/2014 EPRI Report 3002011710 Irradiation Damage of the Concrete Biological Shield 05/2018 EPRI Report 3002013995 Irradiation Damage of the Concrete Biological Shield 07/2018

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Journal of Advanced Concrete Technology Vol. 14 Review of the Current State of Knowledge on the Effects of Radiation on Concrete (pages 368-383) 07/2016 N/A E-mail from H. Gordon to S. Jacques and S.

Franzone: 8064534 (Dynamic Friction and Wear of a Solid Film Lubricant During Radiation Exposure in a Nuclear Reactor) 02/10/2022 NASA TN D-6940 Dynamic Friction and Wear of a Solid Film Lubricant During Radiation Exposure in a Nuclear Reactor 09/1972 FLO-8770.473 EBASCO Specification Concrete - NNS Class:

Seismic, St. Lucie Plant Unit 1, 1974 - 890,000KW Installation Revision 6 FLO-2998.473 EBASCO Specification Concrete - NNS Class:

Seismic, St. Lucie Plant Unit 2, 890,000KW Revision 4 FLO 2998-761 EBASCO Specification Structural Steel, Florida Power and Light, Class: Seismic Category I, Non-Seismic Category, NN Safety, St. Lucie Plant Unit 2, 890,000KW Revision 4 FLO 2998-761 EBASCO Specification Structural Steel (Visual Weld Acceptance Criteria), Florida Power and Light, Class: Seismic Category I, Non-Seismic Category, NN Safety, St. Lucie Plant Unit 2, 890,000KW Revision 6 FLO 8770-761 EBASCO Specification Structural Steel Hutchinson Island Plant, 1973 -890 MW Installation Revision 2 8770-16346 St. Lucie Unit1 2 Civil Engineering Design Criteria, EBASCO Backfit Engineering, Florida Power and Light 04/22/2007 Addendum, FLO 8770-761 Addendum to EBASCO Specification FLO 8770-761 - Class I Structures and Components Revision 2 FPL Book C412 Florida Power and Light, St. Lucie Unit 1, Reactor Building Cavity Wall - North Anna Analysis, Final Report.

Revision 0 DBD-CNTMT-1 Maximum Lubrication Plate Temperature, System Parameter Worksheet, St. Lucie Unit 1, Containment Systems, Design Basis Document Revision 7 DBD-CNTMT-2 Maximum Lubrication Plate Temperature, System Parameter Worksheet, St. Lucie Unit 2, Containment Systems, Design Basis Document Revision 7 PSLWEC-21-0039 FPL Request for Information to Westinghouse Revision 0 PSLWEC-21-0066 FPL Request for Information to Westinghouse Revision 0

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WCAP-18623-P (PROPRIETARY)

St. Lucie Units 1 & 2 SLR: Fracture Mechanics Assessment of RPV Structural Steel Supports Revision 1 INSPECTIONS/WORK ORDERS MIL-STD-271D, N-121 Magnetic Particle Inspection. Newport News Shipbuilding and Dry Dock Company Revision D-3 (1969)

NAVSHIPS 0900-000-1000, N-123 Magnetic Particle Acceptance Standards (Welds, Castings, and Wrought Materials). Newport News Shipbuilding and Dry Dock Company Revision E-3 (1969)

Procedure W-7/107/207 Instructions for Stress Relief Control of Welded Assemblies. Newport News Shipbuilding and Dry Dock Company Revision B (1972)

MSMA-36 Procedure Specifications for Manual-Shielded Metal Arc Welding - Fillet and Groove Welds.

PEDEN Steel Company 05/20/1970 SA-36 Procedure Specifications for Submerged Arc Welding - Fillet and Groove Welds. PEDEN Steel Company 02/17/1972 SAT-F-36, SAS-G-36, SAA-F-36, SAS-F-36 Various Procedures for Mechanized Welding.

PEDEN Steel Company 1969-1972 R-79-964 FPL, Unit 2, Receipt Inspection Report (Inspections: magnetic particle, ultrasonic, visual inspections. Certifications: mill tests, material certifications, welding materials. heat treatment, NDE and welding personnel qualifications -

Lakeside Bridge and Steel) 06/06/1979 AR 01716657 PSL-1 Reactor Vessel Supports Not in the ISI Program 01/21/2013 010950/010930/010910 4.3-057/-058/-059 PSL-1, Reactor Vessel Support @180 Deg.

(1A1&1A2 Cold-Leg, 1B Hot-Leg) VT-3 Examination Record, Mechanical and Welded Attachments 01/27/2012 010920 PSL-1, Reactor Vessel Support Attachment @180 Deg. (B Hot-Leg) Magnetic Particle Examination 01/27/2012 SL1-010910 WO 40516972 PSL1-VT-18-001, Reactor Vessel Support @180 Deg. (B Hot-Leg) VT-3 Examination Record (ASME XI, 2001 Ed/2003 Add, F-A/F1.40) 03/31/2018 SL1-010920 WO40516972 PSL1-MT-18-002, Reactor Vessel Support @180 Deg. (B Hot-Leg) Magnetic Particle Examination (ASME XI, 2001 Ed/2003 Add, B-K/B10.10) 03/31/2018 SL1-010930 WO 40709203 PSL1-VT-21-037, Reactor Vessel Support @60 Deg. (A1 Cold-Leg) VT-3 Examination Record, (ASME XI, 2007 Ed/2008 Add, F-A/F1.40) - Upper and Lower Half Reports 04/24/2021

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SL1-010950 WO 40709203 PSL1-VT-21-038, Reactor Vessel Support @300 Deg. (A2 Cold-Leg) VT-3 Examination Record, (ASME XI, 2007 Ed/2008 Add, F-A/F1.40) - Upper and Lower Half Reports 04/24/2021 010580 4.3-032 PSL-2, Reactor Vessel Support @60 Deg. (A1 Cold-Leg) Visual Examination Record, VT-3, Mechanical and Welded Attachments 09/20/2012 010560 4.3-035 PSL-2, Reactor Vessel Support @180 Deg. (B Hot-Leg) Visual Examination Record, VT-3, Mechanical and Welded Attachments 09/22/2012 010593 4.3-033 PSL-2, Reactor Vessel Support @300 Deg. (A2 Cold-Leg) Visual Examination Record, VT-3, Mechanical and Welded Attachments 09/20/2012 DRAWINGS DWG 2998-G-529 (EBASCO)

FPL Co. (FPL) St. Lucie Plant (PSL), 1983 -

890,000KW Extension - Unit 2. Reactor Building, Reactor Primary Shield & Refuel. Cavity Masonry Revision 4 DWG 2998-G-530 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Reactor Primary Shield & Refuel Cavity Masonry, SH 2 Revision 5 DWG 2998-G-533 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Reactor Primary Shield & Refuel Cavity Reinf., SH 1 Revision 2 DWG 2998-G-534 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Reactor Primary Shield & Refuel Cavity Reinf., SH 2 Revision 2 DWG 2998-G-535 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Reactor Primary Shield & Refuel Cavity Reinf., SH 3 Revision 4 DWG 2998-G-553 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Reactor Primary Shield & Refuel Cavity Reinf., SH 4 Revision 2 DWG 2998-G-065 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

General Arrangement. Reactor Building, Floor Plans SH 1 Revision 30 DWG 2998-G-066 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

General Arrangement. Reactor Building, Floor Plans SH 2 Revision 13 DWG 2998-G-067 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

General Arrangement. Reactor Building, Sections, SH 1 Revision 20

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DWG 2998-G-068 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

General Arrangement. Reactor Building, Sections, SH 2 Revision 16 DWG 2998-G-497 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Interior Base Concrete, Plan Reinf. SH 1 Revision 5 DWG 2998-G-514 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Interior Base Concrete, Sect. &

Dets Reinf. SH 6 Revision 3 DWG 2998-G-518 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Internal Conc. Plans & Sect.

Mas., SH 1 Revision 2 DWG 2998-G-519 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Internal Conc. Plans & Sect.

Mas., SH 2 Revision 1 DWG 2998-G-794 (EBASCO)

FPL, PSL, 1983 - 890MWe Extension - Unit 2.

Reactor Building, Equipment Supports, SH 2 Revision 3 DWG 8770-G-529 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Reactor Primary Shield & Refuel. Cavity Masonry Revision 2 DWG 8770-G-530 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Reactor Primary Shield & Refuel Cavity Masonry, SH 2 Revision 2 DWG 8770-G-533 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Reactor Primary Shield & Refuel Cavity Reinf., SH 1 Revision 1 DWG 8770-G-534 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Reactor Primary Shield & Refuel Cavity Reinf., SH 2 Revision 1 DWG 8770-G-535 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Reactor Primary Shield & Refuel Cavity Reinf., SH 3 Revision 1 DWG 8770-G-541 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Operating Floor Plan & Sect.

Masonry Revision 4 DWG 8770-G-065 (EBASCO)

FPL, PSL, 1976 - 890,000KW Installation - Unit 1.

General Arrangement. Reactor Building, Floor Plans SH 1 Revision 28 DWG 8770-G-066 (EBASCO)

FPL, PSL, 1976 - 890,000KW Installation - Unit 1.

General Arrangement. Reactor Building, Floor Plans SH 2 Revision 15

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DWG 8770-G-067 (EBASCO)

FPL, PSL, 1976 - 890,000KW Installation - Unit 1.

General Arrangement. Reactor Building, Sections, SH 1 Revision 17 DWG 8770-G-068 (EBASCO)

FPL, PSL, 1976 - 890,000KW Installation - Unit 1.

General Arrangement. Reactor Building, Sections, SH 2 Revision 19 DWG 8770-G-497 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Interior Base Concrete, Plan Reinf. Sheet 1 Revision 4 DWG 8770-G-502 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building. Interior Base Concrete Sect. & Det., SH 5 Revision 1 DWG 8770-G-518 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Internal Conc. Plans & Sect. Mas., SH 1 Revision 3 DWG 8770-G-519 (EBASCO)

FPL, Hutchinson Island Plant - 1973 - 890,000KW Installation - Unit 1. Reactor Building, Internal Conc. Plans & Sect. Mas., SH 2 Revision 3 DWG 8770-G-794 (EBASCO)

FPL, PSL, 1973 - 890,000 KW Installation - Unit 1.

Reactor Building, Equipment Supports, SH 1, SH 2, SH 7, SH 8, Revision 5 DWG 8770-G-794 (EBASCO)

FPL, PSL, 1973 - 890,000 KW Installation - Unit 1.

Reactor Building, Equipment Supports, SH 3, SH 4, SH 9 Revision 2 DWG 8770-G-794 (EBASCO)

FPL, PSL, 1973 - 890,000 KW Installation - Unit 1.

Reactor Building, Equipment Supports, SH 5 Revision 3 DWG 8770-G-794 (EBASCO)

FPL, PSL, 1973 - 890,000 KW Installation - Unit 1.

Reactor Building, Equipment Supports, SH 6 Revision 6 DWG 8770-G-794 (EBASCO)

FPL, PSL, 1973 - 890,000 KW Installation - Unit 1.

Reactor Building, Equipment Supports, SH 1-10 Revision 5 DWG-72-3860, 22/5 (CBI)

Details of Reactor Supports, FPL, EBASCO Services, Hutchinson Island Plant (Unit 1)

Revision 3 DWG-72-3860, 25/1 (CBI)

Reinforcement Bar Holes for Reactor Support Assemblies, FPL, EBASCO Services, Hutchinson Island Plant (Unit 1)

Revision 1 DWG-72-3860, 23/3 (CBI)

Details for Reactor Supports, FPL, EBASCO Services, Hutchinson Island Plant (Unit 1)

Revision 3 DWG-72-3860, 21/3 (CBI)

Reactor Supports for FPL, EBASCO Services, Hutchinson Island Plant (Unit 1)

Revision 3 DWG 9126-902 (Lakeside Bridge &

Steel)

Reactor Supports Unit 2, Assembly Plan, EBASCO Services, Hutchinson Island Plant Revision 2

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DWG 9126-1 (Lakeside Bridge &

Steel)

Reactor Supports Unit 2, Support Columns A &

B, EBASCO Services, Hutchinson Island Plant Revision 1 DWG 9126-2 (Lakeside Bridge &

Steel)

Reactor Supports Unit 2, Reactor Supports, EBASCO Services, FPL, Hutchinson Island Plant Revision 3 DWG 9126-3 (Lakeside Bridge &

Steel)

Reactor Supports Unit 2, Reactor Supports, EBASCO Services, FPL, Hutchinson Island Plant Revision 3 DWG 9126-4 (Lakeside Bridge &

Steel)

Reactor Supports Unit 2, Anchor Bolts. EBASCO Services, FPL, Hutchinson Island Plant Revision 1 E-233-507 (Combustion Engineering)

FPL, Reactor Vessel 1. Vessel Supports for 172.

D. PWR, Final Machining.

Revision 3 E-STD-220-002 (Combustion Engineering)

FPL, Reactor Vessel 1. Vessel Support Details Revision 1 E-STD-220-003 (Combustion Engineering)

FPL, Reactor Vessel 2. Vessel Support Arrangement and Installation Revision 1 E-71172-171-010 (Combustion Engineering)

FPL, Reactor Vessel 2. Vessel Supports, Final Machining Revision 1 E-13172-340-002 (Combustion Engineering)

FPL, Reactor Vessel 2. Vessel Support Details Revision 1 E-13172-340-003 (Combustion Engineering)

FPL, Reactor Vessel 2. Vessel Support Arrangement and Installation Revision 1 During the audit, the staff made the following observations for SLRA sections 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete due to Radiation and 3.5.2.2.2.7 Expected Further Evaluation for Loss of Fracture Toughness due to IE of Reactor Vessel (RV)

Supports from NRC Review of the First Three SLRAs, hereinafter referenced as FE sections:

(a) The staff noted that the SLRA FE Sections did not include sufficient information regarding the following:

Alignment with Unit 1 and Unit 2 UFSARs, as applicable, (e.g., design codes used, loading conditions used).

(b) The staff noted that SLRA section 3.5.2.2.2.6 did not include sufficient information regarding the following:

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Description of the reactor cavity concrete aligning it with PSL Unit 1 and 2 drawings and UFSARs, as applicable.

Information that the structural design for the two Units PSWs/LCC differs (e.g., different reinforcing grade steels used) and as to why Units 1 design bounds (controls) assessment of SLRA section 3.5.2.2.2.6.

Details of the controlling Units (i.e., PSL Unit 1) design (e.g., PSW/LCC concrete compressive strength(s), aggregate(s) used in concrete mix, rebar steel grade(s) used).

Which of the analyses and loading conditions included in the UFSAR have been used in the original analysis [analysis of record (AOR)] of the PSW/LCC under CLB loading conditions to evaluate radiation induced effects on reactor cavity concrete IR

[Interaction Ratio] = applied stresses/allowable stresses) associated with the governing failure mode of 0.77.

(c) The staff noted that the SLRA section 3.5.2.2.2.7 did not include sufficient information regarding the following:

Information on the RV support analysis and assumption used (e.g., separate beam column analyses, LOCA loads used in loading combinations).

Details on the reactor support slide plate configuration, on the lubricant used to facilitate nozzle sliding, and whether radiation effects could affect their intended function.

Information on the application of the site specific ASME Section XI, subsection IWF program to the RV structural steel assembly support components (e.g., for the purpose of inspections, all three supports are considered as one) and further clarification of NDEs (other than visual) used and continued to be used during the subsequent period of extended operation.

The effects of partial penetration weldments (i.e., fillet or groove welds) in the RV structural steel assembly, as shown for example in EBASCO Drawing Nos. 8770-G-794 and 2998-G-794, on the stresses on the RV structural steel assembly, especially at the locations of highest stress discussed in Section 6.2 of LTR-SDA-21-NP, revision 1 (Enclosure 4, Attachment 3 to the SLRA, ML21215A320) for the non-proprietary version and section 6.2 of LTR-SDA-21-P, Revision 1 (Enclosure 5, to the SLRA,. ML21215A322) for the proprietary version.

(d) The staff also noted the need for the SLRA FEs to include:

Reference(s) to core design procedures.

Clarity on the uncertainty on the reported ex-vessel fluence and gamma dose in SLRA table 3.5.2.2-2 augmented by uncertainties and its effects on the PSW/LCC AOR calculations, as discussed in the breakout sessions.

Clarity on the uncertainty on the reported ex-vessel fluence and gamma dose in SLRA tables 3.5.2.2-3 and 3.5.2.2-4, its effects and RV structural steel assembly, and whether it aligns with that assumed in the Point Beach structural steel fracture

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mechanics calculations with which the PSL fracture mechanics evaluation asserts its conservatism.

Additional AMR line items, for example, to manage the effects of aging for reduction/loss of fracture toughness of the RV structural steel support assembly due to radiation exposure.

Readdress the ex-vessel estimated/calculated fluence uncertainty for concrete material properties degradation, as the breakout sessions discussed uncertainties on fluence/gamma dose, not reflected in the SLRA, may lead the calculated fluence to exceed threshold(s) of concern identified in NUREG-2192.

Review effects of uncertainty in radiation on the AOR including on the Stress Interaction Ratios (IR=applied stresses/allowable stresses) of PSW/LCC.

Further explain that the normalized ratios in SLRA table 3.5.2.2-5 are based on linear and nonlinear elastic fracture mechanics when compared to the to the linear elastic fracture mechanics RV structural steel assessment at Point Beach.

Confirm relevance of ASME section XI, subsection IWF service conditions at PSL with those at Point Beach Nuclear Plant (PBN), since the applicant has based its fracture mechanics evaluation to the guidance provided in NUREG-1509 by comparison to PBN evaluation.

The staff will consider issuing RCIs and RAIs subsequent to its review and evaluation of applicants voluntarily offered SLRA supplement to obtain the necessary information related to the staffs observations above.

SLRA AMR Further Evaluation 3.6.2.2.2, Reduced Insulation Resistance Due to Age Degradation of Cable Bus Arrangements Caused by Intrusion of Moisture, Dust, Industrial Pollution, Rain, Ice, Photolysis, Ohmic Heating and Loss of Strength of Support Structures and Louvers of Cable Bus Arrangements Due to General Corrosion and Exposure to Air-Outdoor Summary of Information in the Application. During the audit, the staff reviewed the information associated with the following five AMR items discussed in SLRA 3.6.2.2.2 further evaluation section:

SLRA table 3.6.1-027, Cable bus: external surface of enclosure assemblies galvanized steel; aluminum; air - indoor controlled or uncontrolled (air - outdoor)

SLRA table 3.6.1-029, Cable bus: electrical insulation insulators - exposed to air -

indoor controlled or uncontrolled, air - outdoor SLRA table 3.6.1-030, Cable bus: external surface of enclosure assemblies composed of steel exposed to air - indoor uncontrolled or air - outdoor SLRA table 3.6.1-031, Cable bus external surface of enclosure assemblies composed of galvanized steel; aluminum exposed to air - outdoor SLRA table 3.6.1-032, Cable bus: external surface of enclosure assemblies: composed of steel; air - indoor controlled Audit Activities: During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA. The applicant did not provide any documents on the ePortal or any OpE data for this AMR item.

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The staff conducted an onsite audit and discussed maintenance practices associated with cable buses and metal enclosed buses that perform similar functions with the applicant. The staffs observed that the installed cable bus system appeared well maintained, and that the applicant was in the process of replacing all metal enclosed bus (6.9 kiloVolt (kV) [not within the scope of SLR] and 4.16 kV [within the scope of SLR]) with cable bus (either 750 MCM or 500 MCM medium-voltage power cable).

The staff reviewed the applicants further evaluation in SLRA section 3.6.2.2.2, Reduced Insulation Resistance Due to Age Degradation of Cable Bus Arrangements Caused by Intrusion of Moisture, Dust, Industrial Pollution, Rain, Ice, Photolysis, Ohmic Heating and Loss of Strength of Support Structures and Louvers of Cable Bus Arrangements Due to General Corrosion and Exposure to Air-Outdoor. This input will be used in SER section 3.6.2.2.2.

SLRA AMR Further Evaluation (FE) 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following five AMR items discussed in SLRA 3.6.2.2.3 FE section:

SLRA table 3.6.1-004, Transmission conductors composed of aluminum exposed to air-outdoor SLRA table 3.6.1-005, Transmission connectors composed of aluminum exposed to air-outdoor SLRA table 3.6.1-006, Switchyard bus and connections composed of copper and bronze; with aluminum hardware exposed to air - outdoor SLRA table 3.6.1-007, Transmission conductors composed of aluminum exposed to air-outdoor SLRA table 3.6.1-021, Transmission conductors composed of aluminum exposed to air-outdoor Audit Activities: During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and documents provided by the applicant via the ePortal.

The table below lists documents that were reviewed by the staff and were found relevant to the AMR items. These documents were provided by the applicant.

Document Title Revision /

Date NEESL00008-REPT-038 St Lucie Units 1 and 2, SLR Aging Effects OpE Revision 0

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Document Title Revision /

Date NEESL00008-REPT-036 St. Lucies Units 1 and 2 SLR Screening Results and Aging Management Review - Electrical Commodities Revision 1 During the audit, the staff made the following observations:

The staff noted that the overhead conductors at St. Lucie are All Aluminum Alloy Conductors compared to Aluminum Conductor Steel Reinforced that has been evaluated for degradation due to environmental factors by Ontario Hydro and accepted by NRC staff. The staff will address this difference in the SER.

SLRA AMR FE, SCC and Loss of Material for Stainless Steel, Nickel Alloys, and Aluminum Alloys Summary of Information in the Application. The SLRA addresses FE of cracking due to SCC, and loss of material due to pitting and crevice corrosion, of stainless steel, nickel alloys, and aluminum alloys in the Engineered Safety Features systems, Auxiliary systems, and Steam and Power Conversion systems. The SLRA sections for these FE discussions are: 3.2.2.2.2, 3.2.2.2.4, 3.2.2.2.8, 3.2.2.2.10, 3.3.2.2.3, 3.3.2.2.4, 3.3.2.2.8, 3.3.2.2.10, 3.4.2.2.2, 3.4.2.2.3, 3.4.2.2.7, and 3.2.2.2.9.

Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. For the OpE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OpE. Afterwards, the staff conducted its review of the applicants methodology and OpE by reviewing documentation contained in the SLRA and ePortal. The staff audited this topic to determine if the information in the SLRA is consistent with the FE information in the SRP-SLR Report.

The table below lists documents that were reviewed by the staff and were found relevant to these FE sections. The staff will document its review of this information in the SER.

Relevant Documents Reviewed Document Title / Description Revision / Date NEESL00008-REPT-038 St. Lucie Units 1 and 2 SLR Aging Effects OpE Revision 0 NEESL00008-REPT-052 St. Lucie Units 1 and 2 SLR Aging Management PBD

- Outdoor and Large Atmospheric Metallic Storage Tanks Revision 0 PSL-ENG-SERS 001 PSL Asset Management Plan for the UPTIP Revision 1

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3. Supplements to the SLRA By letters dated April 7, 2022 (ML22097A202), April 13, 2022 (ML22103A014) and May 12, 2022 (ML22139A083), FPL voluntarily submitted Supplements 1,2, and 3 to the SLRA resulting from discussions held during the audit.

4. Audit Questions Provided to FPL Over the course of the audit, the NRC staff provided audit questions to FPL to facilitate the audit discussions.

Subject Area Meeting Date Questions Provided to FPL Breakout Session: TRP 30 - Fuel Oil Chemistry 02/01/22 ML22013A317 Breakout Session: TRP 29 - Atmospheric Metallic Tanks 01/25/22 ML22010A094 Breakout Session: TRP 11 - Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-induced Corrosion in Reactor Coolant Pressure Boundary Components 01/24/22 ML21354A837 Breakout Session: TRP 33 - Selective Leaching 01/31/22 ML22010A100 Breakout Session: TRP 14 - Buried Piping 01/20/22 ML21351A239 Breakout Session: Corrosion OpE 01/19/22 ML22013A282 Breakout Session: TRP 15 - Internal Coatings 01/20/22 ML21351A241 Breakout Session: TRP 38 - Internal Surfaces 01/31/22 ML22010A097 Breakout Session: TRP 84 - SS Nickel-Alloy Aluminum Alloy Further Evaluations 02/03/22 ML22013A307 Breakout Session: TRP 60 - Fatigue Monitoring 01/27/22 ML22013A301 Breakout Session: TRP 143.4 - High Energy Line Break Analyses 01/28/22 ML22013A305 Breakout Session: TRP 143.1 - Metal Fatigue of Class 1 01/28/22 ML22013A302 Breakout Session: TRP 143.3 - Environmentally-Assisted Fatigue 01/27/22 ML22013A304 Breakout Session: TRP 143.2 - Non-Class 1 Fatigue Analyses 01/28/22 ML22013A303 Breakout Session: TRP 19 - Steam Generators 02/10/22 ML22130A654 ML22130A660 Breakout Session: TRP 26 - Fire Protection 01/19/22 ML21351A248 Breakout Session: Fire Protection Scoping and Screening 01/24/22 ML21356A577 Breakout Session: TRPs 148.3, Unit 1 CSB Repair Plug Preload Relaxation and 148.4, RCP Flywheel Fatigue Crack Growth 01/18/22 ML21356A011 Breakout Session: TRP 148.1, LBB of Reactor Coolant System Piping 01/18/22 ML21351A238 Breakout Session: TRP 20 - Open-Cycle Cooling Water 02/01/22 ML22013A316

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Breakout Session: Scoping and Screening - Reactor Coolant System 02/02/22 ML22012A391 Breakout Session: TRP 17 - Flow-Accelerated Corrosion 02/07/22 ML22130A654 ML22130A663 Breakout Session: Structural Scoping and Screening 01/19/22 ML22013A277 Breakout Session: TRP 45 - Masonry Walls 01/25/22 ML22013A293 Breakout Session: TRP 77 - Corrosion Structural 01/27/22 ML22013A297 Breakout Session: TRP 27 - Fire Water System 02/07/22 ML22130A654 ML22130A667 Breakout Session: TRP 140.1 - Plant-Specific AMP, Pressurizer Surge Line 02/24/22 ML22130A654 ML22130A661 Breakout Session: TRP 147.8 and 23 - Crane and Inspection of Load Handling 01/27/22 ML22130A654 ML22130A665 Breakout Session: TRP 3 - RPV Closure Head Studs 02/01/22 ML22012A263 Breakout Session: TRP 10 - Boric Acid Corrosion 01/26/22 ML22010A096 Breakout Session: TRP 53.3 - Electrical 01/13/22 ML22130A654 ML22130A669 Breakout Session: TRP 76 - Irradiated Concrete 02/09/22 ML22130A654 ML22130A670 Breakout Session: TRP 43 - ASME Section XI, Subsection IWF 02/01/22 ML22130A654 ML22130A668 Breakout Session: TRP 142 - RV Neutron Embrittlement Analyses 02/14/22 ML22130A654 ML22130A674 Breakout Session: TRP 74 - Concrete 01/31/22 ML22013A296 Breakout Session: TRP 47 - Water-Control Structures 01/24/22 ML22013A295 Breakout Session: TRP 18 - Bolting Integrity 01/25/22 ML22013A284 Breakout Session: TRP 46 - Structures Monitoring 01/26/22 ML22013A294 Breakout Session: TRP 146 - Containment Liner Plate, Metal Containments, and Penetration Fatigue Analyses 02/02/22 ML22130A654 ML22130A671 Breakout Session: TRP 41 - ASME XI, Subsection IWE 01/31/22 ML22013A292 Breakout Session: TRP 16 - PWR Vessel Internals 02/03/22 ML22130A654 ML22130A673 Breakout Session: TRP 148.6 - Flaw Tolerance Evaluation for CASS RCS Piping Components 02/17/22 ML22130A654 ML22130A672 Breakout Session: TRP 1 - ASME XI - ISI 01/25/22 ML22003A038

5. Applicant Personnel Contacted During Audit Name Affiliation Glenn Andrews FPL Paul Atkinson FPL Scott Boggs FPL Edwin Burgos FPL Eric Christopher FPL John Daily FPL Leonard Davis FPL

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Lahcen Elaadi FPL Steve Franzone FPL Michael Friedman FPL Daniel Griffin FPL Jay Kabadi FPL Charles Kato FPL Joe Loor FPL William Maher FPL Wendall Moore FPL Kevin Muggleston FPL Richard Orthen FPL Basil Pagnozzi FPL Swadesh (Chuck) Ramdeen FPL Carrie Roberts FPL Andrew Rode FPL Donna Slivon FPL Gary Thomas FPL Kester Thompson FPL Maribel Valdez FPL Shane (Chris) Webb FPL Name Affiliation Philip Barnes ENERCON Bruce Beisler ENERCON Matt Brunton ENERCON Andrew Cianek ENERCON Clay Corley ENERCON Steve Cornell ENERCON Spencer Feuerstein ENERCON Jeff Gromatzky ENERCON Aaron Halstrom ENERCON Stephen Hale ENERCON Jim Hamlen ENERCON Dave Hartmangruber ENERCON Jeffrey Head ENERCON Ronald Hepp ENERCON JR (Jack) Hoffman ENERCON Allison Hoke ENERCON Farrah Khanpour ENERCON Tanton Mattson ENERCON Mitch McFarland ENERCON Ian Miller ENERCON William Moody ENERCON Brian Norman ENERCON Anthony Ploplis ENERCON Duygu Saydam ENERCON Troy Skillen ENERCON Steve Sklaventis ENERCON Caleb Trainor ENERCON

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Matt Wilkinson ENERCON Mark Windsor ENERCON Name Affiliation Benjamin Amirir Westinghouse Dulai Bhowmick Westinghouse Nicholas Bisceglia Westinghouse Gordon Hall Westinghouse Susan Jaques Westinghouse Stephen Longwell Westinghouse Brett Lynch Westinghouse Tim Nowicki Westinghouse Maya Chandrashekhar Framatome Dave Skulina Framatome Pavan Thallapragada Framatome Nat Cofie Structural Integrity Associates Dave Gerber Structural Integrity Associates Terry Herman Structural Integrity Associates Kevin Wong Structural Integrity Associates SM Fluit BWXT D Hartman BWXT

6. Exit Meeting An exit meeting was held with the applicant on February 28, 2022, to discuss the results of the regulatory audit. The staff is considering the issuance of RAIs and RCIs to support the completion of the staffs SLRA review.