L-2024-165, Report of 10 CFR 50.59 Plant Changes, Tests and Experiments Made

Report of 10 CFR 50.59 Plant Changes, Tests and Experiments Made

ML24288A013
Person / Time
Site:	Saint Lucie
Issue date:	10/14/2024
From:	Mack K Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2024-165
Download: ML24288A013 (1)

Text

October 14, 2024

• l=PL.

L-2024-165 10 CFR 50.59(d)

U.S. Nuclear Regulatory Commission Attn : Document Control Desk Washington, D.C. 20555

Re: St. Lucie Uni t 1 Docket No. 50 - 335 Report of 10 CFR 50.59 Plant Changes

Pursuant to 1 O CFR 50.59(d)(2), Florida Power & Light Company (FPL) is submitting a report of changes, tests and experiments made on Unit 1 during the period from October 5, 2022 through April 13, 2024. The report includes a summary of each evaluation and provides the bases for the determination that the change, test, or experiment does not require a license amendment. This submittal correlates with the information included in Amendment 33 of the St. Lucie Unit 1 Updated Final Safety Analysis Report (UFSAR), submitted under a separate cover.

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

Sincerely,

i?eethAck 1~L~

Director Licensing & Regulatory Compliance Florida Powe r & Light Company

Attachment:

Changes, Tests and Experiments made as allowed by 10 CFR 50.59 during the period of October 5, 2022 through April 13, 2024

cc : USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Plant USNRC Resident Inspector, St. Lucie Nuclear Plant L-2024-0165 Attachment Page 1 of 10

CHANGES, TESTS AND EXPERIMENTS MADE AS ALLOWED BY 10 CFR 50.59 DURING THE PERIOD OF OCTOBER 5, 2022 THROUGH APRIL 13, 2024 L-2024-165 Attachment Page 2 of 10

INTRODUCTION

This report is submitted in accordance with 10 CFR 50.59 (d)(2) which requires that:

i) changes in the facility as described in the FSAR (as updated);

ii) changes in procedures as described in the FSAR (as updated); and iii) tests and experiments not described in the FSAR (as updated)

that are conducted without prior Commission approval be reported to the Commission in accordance with 1 O CFR 50.90 and 50.4. This report is intended to meet these requirements for the period of May 18, 2021 through October 4, 2022.

This report is divided into three (3) sections:

1. Summaries of changes to the facility as described in the Updated Final Safety Analysis Report (UFSAR) performed by a permanent modification are summarized.

2. Summaries of changes to the facility or procedures as described in the UFSAR, and for tests and experiments not described in the UFSAR, which are not performed by a permanent modification.

3. A summary of any fuel reload 10 CFR 50.59 evaluation.

Sections 1, 2 and 3 summarize specific 1 O CFR 50. 59 evaluations for the specific changes. Each of these 1 O CFR 50.59 evaluations concluded that the change did not require a change to the plant technical specifications, and prior NRC approval was not required.

L-2024-165 Attachment Page 3 of 10

TABLE OF CONTENTS

PAGE SECTION 1 PERMANENT MODIFICATIONS 4 None

SECTION 2 10 CFR 50.59 EVALUATIONS 5 1-PTP-128 Preoperational Test Procedure Rev 0 EC 298475 Implementation of Topical Report EMF-2310 Rev O EC 299107 Response Time for Rosemount Transmitters Rev 1

SECTION 3 FUEL RELOAD EVALUATION 9 EC 299207 St. Lucie Unit 1 Cycle 32 Reload Rev 2 L-2024-165 Attachment Page 4 of 10

SECTION 1

PERMANENT MODIFICATIONS None L-2024-165 Attachment Page 5 of 10

SECTION 2

50.59 EVALUATIONS L-2024-165 Attachment Page 6 of 10

1-PTP-128 Rev 0

SUMMARY

The proposed activity is the performance of Preoperational Test Procedure 1-PTP-128, "Unit 1 Cable Spreading Room Door Fan Test for Clean Agent Fire Suppression System", in support of EC 296612.

This EC will replace the existing Halon 1301 fire suppression system in the Unit 1 Cable Spreading Room (CSR) with a clean agent Novec 1230 system.

A 1 OCFR50.59 Evaluation was required because the test requires blocking airflow at fire dampers on the CSR and Battery Rooms 1 A and 1 B ventilation supply from fans HVS-5A/5B, stopping of the CSR exhaust fan HVE-11, with damper L-9 closure, and stopping of the battery room exhaust fans RV-1 and RV-2, which will isolate supply and exhaust airflow for these rooms. The battery room exhaust ventilation is provided to prevent hydrogen buildup. In addition, the required pressurization of the CSR may affect the ability to maintain adequate differential pressure between the Control Room and the CSR.

The proposed activity, including the required isolation of the ventilation system, are not initiators for accidents described in the UFSAR. The proposed activity does not result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the UFSAR because the affected room temperatures battery rooms hydrogen concentration, and the Control Room to CSR differential temperatures, battery rooms hydrogen concentration, and the Control Room to CSR differential pressure will be monitored during the test. If conditions warrant, the test will be stopped, and CSR and battery rooms ventilation will be restored to normal operating status in a timely manner to prevent adverse conditions. SSCs within the affected rooms will continue to be capable of performing their design functions.

There is no increase in the consequences of accidents or malfunctions previously evaluated in the UFSAR because SSCs within the affected rooms will continue to be capable of performing their design functions and the activity does not result in a new pathway for release of radioactive materials and there is no change in the radiological consequences of a malfunction of equipment important to safety.

The proposed activity does not create the possibility for an accident of a different type or a malfunction of SSCs with a different result than previously evaluated in the UFSAR because SSCs within the affected rooms will continue to be capable of performing their design functions. Also, the activity will not create any new systems interactions or new SSC malfunctions.

The proposed activity does not affect the design basis limit for a fission product barrier as described in the UFSAR since SSCs within the affected rooms will continue to be capable of performing their design functions. The proposed activity does not result in a departure from a method of evaluation described in the UFSAR described in the UFSAR.

Based on this evaluation, a license amendment is NOT required to implement 1-PTP-128.

EC 298475 Rev 0

SUMMARY

The implementation of Topical Report (TR) EMF-2310, Revision 1, Supplement 2P, Revision 0, for Biasi CHF Correlation design limits in the post-scram Main Steam Line Break analyses for St. Lucie Units 1 and 2 is a new methodology. According to NEI 96-07 (Section 4.3.8), in order to demonstrate L-2024-165 Attachment Page 7 of 10

that the change is not considered a departure from a method of evaluation described in the UFSAR be met:

used in establishing the design bases or the safety analyses, all of the following must

• Use of a new NRG-approved methodology,

• Such use is based on sound engineering practice,

• Appropriate for the intended application and

• Within the limitations of the applicable SER.

(1) The NRC approved the TR EMF-2310, Rev. 1, Supp. 2P, Rev. 0 via NRC SER dated February 9, 2023, "FINAL SAFETY EVALUATION FOR FRAMATOME TOPICAL REPORT EMF-2310, REVISION 1 SUPPLEMENT 2P, REVISION 0, "SRP CHAPTER 15 NON-LOCA METHODOLOGY FOR PRESSURIZED WATER REACTORS"." The topical was developed by Framatome and provides a design limit for the Biasi CHF correlation suitable for application to HTP and HMP grids, specifically for the Post-Scram Main Steam Line Break (MSLB) analysis.

(2) The methodology was developed and used by Framatome based on sound engineering practice.

This TR (EMF-2310 - Revision 1, Supplement 2P, Revision 0) is a supplement to EMF-2310, Revision 1. The original TR was initially approved by the NRC in 2001, with Revision 1 being approved in 2004. This TR provides a design limit for the Biasi CHF correlation suitable for application to HTP and HMP grids, specifically for the Post-Scram Main Steam Line Break (MSLB) analysis.

Framatome applied the Biasi correlation within its initially approved application domain with an extension of the domain to higher pressures in the new methodology. To support the extension to higher pressures, Framatome provided a significant amount of validation data demonstrating that the correlation can be conservatively applied in the new pressure region. The Framatome analysis showed that the Biasi correlation is more conservative (i.e., will predict less margin to CHF) than was predicted by the previously approved CHF correlation. In addition, Framatome biased and applied correction factors appropriately in the methodology when needed, and it has demonstrated that the Biasi application will result in conservative predictions of DNB margin. The NRC performed a very rigorous validation process to approve the new methodology, as documented in the SER, which also reinforces the conclusion that Framatome used sound engineering in the development and use of the new methodology.

(3) The methodology is appropriately used for its intended application, as it was approved by the NRC for the new design limits for Framatome post-scram MSLB analyses, suitable for application to HTP and HMP grids, and is applicable to St. Lucie Units 1 and 2 as shown in Table 2-3 of the Topical Report, which is referenced in Section 2.0- Summary and Range of Applicability, as well as Section 7.5 - Intended Application.

(4) And finally, the limitations and conditions established in the NRC SER and Topical Report have been met for the latest cycle analyses of record in both units as documented in Reference 1.

In conclusion, the new methodology used in the post-scram MSLB event for St. Lucie Units 1 and 2 with new design limits for the Biasi CHF correlation does not constitute a departure from a method of evaluation described in the UFSAR used in establishing the design bases or in the safety analyses.

No 1 OCFR50.90 is required for implementation of the changes in this activity.

L-2024-165 Attachment Page 8 of 10

EC 299107 Rev 1

SUMMARY

Accident analyses discussions in Unit 1 UFSAR Sections 15.2.1.2.1, 15.2.1.2.2, 15.2.2.2, 15.2.5.2.1, 15.2.8.2.3, 15.3.4.2, 15.4.5.2 and Unit 2 UFSAR Sections 15.1.1.2, 15.1.2.2, 15.1.3.2, 15.1.5.2, 15.2.3.2, 15.2.9.2, 15.3.2.2, 15.3.3.2, 15.4.1.2, 15.4.2.2, 15.4.8.2, 15.6.1.2 state that, "The reactor protection system trip setpoints and response times were conservatively biased to delay the actuation of the trip function." Use of a response time based on an allocated value or a value based on statistical analysis of historical data for the transmitter type and model is the methodology used in establishing design bases values. Unit 1 UFSAR Sections 13.8.2.1.1 & 13.8.2.2.1 and Unit 2 UFSAR Sections 13.7.2.1.1 & 13.7.2.2.1 currently allow use of allocated response time for Rosemount 1150 series pressure transmitters, based on explicit reference to Topical Report CE NPSD-1167 and engineering evaluation PSL-ENG-SEIS-03-043. The addition of engineering evaluation PSL-ENG-SEIJ-23-001 to the St. Lucie Unit 1 and Unit 2 UFSAR Sections 13.8.2.1.1 & 13.8.2.2.1 and 13. 7.2.1.1 & 13. 7.2.2.1, respectively, expands allowable use of allocated pressure sensor response time in Reactor Protection System and Engineered Safety Feature Action System applications to include Rosemount series 3150 and 3051 N pressure transmitters.

There are no Technical Specification additions, deletions, or modifications required. The change allowing use of allocated response times for Rosemount series 3150 and 3051 N pressure transmitters in Reactor Protection System and Engineered Safety Feature Actuation System applications does not result in departure from a method of evaluation described in the UFSAR. The NRC has previously approved these specific components and methodology, with direct applicability to the St. Lucie Unit 1 and Unit 2 applications demonstrated in engineering evaluation PSL-ENG-SEIJ-23-001. Therefore, a license amendment request is not required.

L-2024-165 Attachment Page 9 of 10

SECTION 3

FUEL RELOAD EVALUATION L-2024-165 Attachment Page 10 of 10

EC 299207 Rev 2

SUMMARY

The St. Lucie Unit 1 Reactor Core contains 217 fuel assemblies. The primary design change to the core is the replacement of 89 Framatome burned fuel assemblies. The new fuel assemblies will be used along with 88 once burned assemblies and 40 twice burned assemblies. The re-configuration of the reactor core is necessary to enable Unit 1 to operate at full power for Cycle 32. This reload complies with applicable Technical Specifications and design basis limits therefore, as per 1 O CFR 50.59(c)(2) criteria, no prior NRC approval is needed for the implementation of this reload EC.