ML24255A309

SLRA - Revised SE Letter

ML24255A309
Person / Time
Site:	Saint Lucie
Issue date:	09/30/2024
From:	Michele Sampson NRC/NRR/DNRL
To:	Coffey R Florida Power & Light Co
References
Download: ML24255A309 (1)

Text

Mr. Robert Coffey Vice President, Nuclear &

Chief Nuclear Officer Florida Power & Light Company 700 Universe Boulevard Mail Stop: EX/JB Juno Beach, FL 33408

SUBJECT:

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 - SUPPLEMENT TO REVISION 1 OF THE SAFETY EVALUATION FOR THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW RESULTING FROM A COMMITMENT CHANGE

Dear Mr. Coffey:

By letter dated August 3, 2021 (Agencywide Documents Access and Management System Package Accession No. ML21215A314), as revised by letter dated October 12, 2021 (ML21285A107) and supplemented by letters dated April 7, 2022 (ML22097A202), April 13, 2022 (ML22103A014), May 19, 2022 (ML22139A083), June 13, 2022 (ML22164A802), July 11, 2022 (ML22192A078), August 9, 2022 (ML22221A134), September 8, 2022 (ML22251A202),

September 19, 2022 (ML22262A149), September 22, 2022 (ML22265A134), September 28, 2022 (ML22271A399), October 26, 2022 (ML22299A037), March 27, 2023 (ML23086B990),

April 21, 2023 (ML23111A129), April 30, 2023 (ML23109A113),June 14, 2023 (ML23165A114) and July 13, 2023 (ML23194A211), Florida Power & Light Company (FPL or the applicant) submitted an application for the subsequent license renewal (SLR) of Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Unit Nos. 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 SLR.

The NRC staff determined that the application was complete and acceptable for docketing as communicated by letter dated September 24, 2021 (ML21246A091) and noticed in the Federal Register on August 16, 2021 (86 FR 45768). The staff completed its review of the St. Lucie Subsequent License Renewal Application (SLRA) and issued the safety evaluation (SE) report on September 1, 2023 (ML23219A003).

On July 30, 2024, FPL submitted a letter (ML24212A194) notifying the NRC of a commitment change for St. Lucie, Unit 1. For Commitment Number 30 regarding the Buried and Underground Piping and Tanks, the schedule to install cathodic protection systems no later than 10 years prior to the subsequent period of operation (SPEO) is changed to 6 years prior to the SPEO. Section 3.0.3.3.23 and Table A.1 - Commitment 30, of the SE is hereby revised to reflect the schedule change, as shown in the enclosure. The Staff understands that this modification will be reflected in the next revised UFSAR Supplement for St. Lucie SLR.September 30, 2024 If you have any questions regarding this matter, please contact the SLR project manager, Mr.

Vaughn Thomas, by email at Vaughn.Thomas@nrc.gov.

Sincerely, Michele Sampson, Director Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389 Enclosure Section 3.0.3.3.23 and Table A.1 cc w/encl: Listserv Signed by Sampson, Michele on 09/30/24

SUBJECT:

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 - SUPPLEMENT TO REVISION 1 OF THE SAFETY EVALUATION FOR THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW RESULTING FROM A COMMITMENT CHANGE DATED:

SEPTEMBER 30, 2024 DISTRIBUTION:

E-MAIL:

PUBLIC RidsNrrDnrl Resource RidsNrrPMSt.Lucie Resource RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsRgn2Dnms Resource RidsRgn2Drp Resource RidsRgn2Drs Resource RidsRgn2Ora Resource RidsRgn2Opa Resource RidsNrrOd Resource VThomas, NRR/DNRL LGibson, NRR/DNRLLRakovan, NMSS/REFS TSmith, NMSS/REFS MSampson, NRR/DNRL SLee, NRR/DNRL NJordan, NRR/DORL DWrona, NRR/DORL ANaber, OGC MWoods, OGC RSkokowski, OEDO TKeene, OEDO SBurnell, HQ/OPADMcIntyre, HQ/OPA LWilkins, OCA DGasperson, RII/OPA JPelchat, RII/FCO DScrenci, RI/OPA JHickman, RII/DRP DDumbacher, RII/DRP Kenneth.Mack2@fpl.com ADAMS ML24255A309 OFFICE DNRL/NLRP:PM DNRL/NLRP:LA OGC DNLR/NLRP:BC NAME VThomas KBratcher STurk LGibson DATE 9/11/2024 9/11/2024 9/24/2024 9/27/2024 OFFICE DNRL:D NAME MSampson DATE OFFICIAL RECORD COPY9/30/24 3.0.3.3.23 Buried and Underground Piping and Tanks

SLRA section B.2.3.27 describes the new buried and underground piping and tanks program as consistent with GALL-SLR Report AMPXI.M41, Buried and Underground Piping and Tanks, except for the exception identified in the SLRA (the exception was added by letter dated September8,2022 (ML22251A202) in response to RAI B.2.3.27-1a). The applicant amended this SLRA section by letters dated April7,2022 (ML22097A202) and September8,2022 (ML22251A202).

Staff Evaluation. During the audit (ML22188A086), the staff reviewed the applicants claim of consistency with the GALL-SLR Report. The staff compared 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 to the corresponding program elements of GALL-SLR Report AMPXI.M41.

The staff finds that the preventive actions program element, as modified by response to RAIB.2.3.27-1 (ML22164A802), is acceptable because it is consistent with GALL-SLR Report AMPXI.M41 recommendations: (a) buried metallic piping (excluding a portion of buried stainless steel (SS) piping, which the staff addresses in the exception below) is either concrete encased or externally coated with epoxy, coal tar epoxy, or fusion bonded epoxy; (b) portions of buried fire protection system piping (not covered by [a] above) are externally coated in accordance with NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances; and (c) underground steel piping is externally coated with zinc or coal tar epoxy.

The staff also reviewed the portions of the preventive actions program element associated with the exception to determine whether the program will be adequate to manage the aging effects for which it is credited. The staffs evaluation of this exception follows.

Exception 1. As amended by letter dated September8,2022 (ML22251A202), SLRA section B.2.3.27 includes an exception to the preventive actions program element related to buried SS piping buried beneath the Unit 1 turbine building, which could not be confirmed as externally coated. The staff reviewed this exception against the corresponding program element in GALL-SLR Report AMPXI.M41 and finds it acceptable as follows. In its response to RAI B.2.3.212 (ML22164A802), the applicant provided results from soil corrosivity testing conducted between 2011 and 2014. The applicant clarified (in its response to RAI B.2.3.27-1a) that the soil sample in which detectable levels of chlorides and sulfates were measured was near the intake cooling water piping on the intake side of the plant where saltwater intrusion had occurred and was not located near the subject uncoated SS piping. Based on the review of the soil corrosivity testing data (excluding the outlier soil sample noted above), the staff noted that soil can be considered moderately corrosive (the second least aggressive out of four categories) to SS when scoring in accordance with Table 9-4, Soil Corrosivity Index from BPWORKS, of Electric Power Research Institute (EPRI) Report 3002005294, Soil Sampling and Testing Methods to Evaluate the Corrosivity of the Environment for Buried Piping and Tanks at Nuclear Power Plants.

Enclosure In addition, as noted in the third supplement to NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, soil is considered aggressive for uncoated SS when soil resistivity is less than 1,000 ohm-cm, pH is less than 4.5, and chlorides are more than 500 parts per million. The staff noted the measured values of soil resistivity, pH, and chlorides were within these limits, confirming that the soil is nonaggressive for uncoated SS. Furthermore, the staff did not identify instances of age-related degradation in buried SS piping during the audit. Based on the nonaggressive environment and acceptable OE, the staff finds that two inspections of buried SS piping in each 10-year period (consistent with GALL-SLR Report Table XI.M412, Inspection of Buried and Underground Piping and Tanks) provides reasonable assurance that the effects of aging will be adequately managed during the SPEO.

The staff conducted an audit to verify the applicants claim of consistency with the GALL-SLR Report. Based on a review of the SLRA (as amended), and the applicants responses to RAIs B.2.3.27-1, B.2.3.27-2, and B.2.3.21-2, the staff finds 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 for which the applicant claimed consistency with the GALL-SLR Report are consistent with the corresponding program elements of GALL-SLR Report AMP XI.M41.

The staff also reviewed the exception between the applicants program and GALL-SLR Report XI.M41 associated with the preventive actions program element, and its justification, and finds that the AMP, with the exception, is adequate to manage the applicable aging effects.

Operating Experience. SLRA section B.2.3.27 summarizes OE related to the buried and underground piping and tanks program. The staff reviewed OE information in the lapplication and during the audit. As discussed in the audit report (ML22188A086), the staff reviewed plant OE information provided by the applicant to: (a) identify examples of age-related degradation, as documented in the applicants corrective action program database; and (b) provide a basis for the staffs conclusions on the ability of the applicants proposed AMPs to manage the effects of aging in the subsequent period of extended operation.

The staff did not identify any OE indicating that the applicant should modify its proposed program. Based on the audit and review of the application, the staff finds that the conditions and OE at the plant are bounded by those for which the buried and underground piping and tanks program was evaluated.

UFSAR Supplement. SLRA appendix A1, section 19.2.2.27 and appendix A2, section 19.2.2.27 provide the UFSAR supplement for the buried and underground piping and tanks program. The staff reviewed this UFSAR supplement description of the program and noted that it is consistent with the recommended description in GALL-SLR Report Table XI-01. As amended by letter dated July 30, 2024 (ML24212A194), the staff also noted the applicant committed to the following: (a) implement the new buried and underground piping and tanks program no later than six months prior to the subsequent period of extended operation for managing the effects of aging for applicable components; (b) install cathodic protection systems at least 6 years (for Unit 1) or 10years (for Unit 2) before the subsequent period of extended operation; (c) begin program inspections 6 years (for Unit 1) or 10years (for Unit 2) before the subsequent period of extended operation; and (d) complete the first 10-year interval inspections six months prior to the SPEO or no later than the last refueling outage prior to the subsequent period of extended operation. The staff finds that the information in the UFSAR supplement is an adequate summary description of the program.

Conclusion. Based on the review of the applicants buried and underground piping and tanks program, the staff concludes that those program elements for which the applicant claimed consistency with the GALL-SLR Report are consistent. The staff also reviewed the exception, and finds that with the exception implemented, the AMP will be adequate to manage the applicable aging effects. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the subsequent period of extended operation, as required by 10CFR54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10CFR54.21(d).

Table A.1 - Commitment 30

NUREG Item -2192 Implementation No. Program/Topic Section Commitment Schedule Source 30 Buried and XI.M41 Implement the new PSL Buried and Underground Piping Program inspections SLRA Rev. 1 Underground Piping and Tanks AMP. begin 6 years before ML21285A110 and Tanks a) Install cathodic protection systems and perform the SPEO. SLRA Supplement 1 (19.2.2.27) effectiveness reviews in accordance with Table Inspections that are ML22097A202 XI.M41-2 in NUREG-2191,Section XI.M41. to be completed prior Letter to the SPEO are ML24212A194 b) If after five years of operation the cathodic completed 6 months protection system does not meet the prior to the SPEO or effectiveness acceptance criteria defined by no later than the last NUREG-2191, Tables XI.M41-2 and -3 (-850 mV refueling outage prior relative to a CSE, instant off, for at least 80% of to the SPEO.

the time, and in operation for at least 85% of the Install cathodic time), FPL commits to performing two additional protection systems at buried steel piping inspections beyond the least 6 years before number required by Preventive Action Category the SPEO.

F resulting in a total of 13 inspections being Program and SLR completed 6 months prior to the SPEO. The enhancements are cathodic protection criterion listed above will implemented 6 continue to be used after five years through the months prior to the end of the SPEO. SPEO, i.e.:

c) Perform periodic pressure testing and blow-out PSL1: 09/01/2035

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