ML25078A071
| ML25078A071 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/02/2025 |
| From: | Lance Rakovan NRC/NMSS/DREFS/EPMB1 |
| To: | Coffey R Florida Power & Light Co |
| References | |
| EPID L-2021-SLE-0003 | |
| Download: ML25078A071 (1) | |
Text
Robert Coffey Executive Vice President Nuclear Officer Florida Power and Light Company Nuclear Division and Chief 700 Universe Blvd., Mail Stop: EX/JB Juno Beach, FL 33408
SUBJECT:
ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2 - LICENSE RENEWAL REGULATORY AUDIT REGARDING THE ENVIRONMENTAL REVIEW OF THE SUBSEQUENT LICENSE RENEWAL APPLICATION SUPPLEMENT (EPID NUMBER: L-2021-SLE-0003)
Dear Robert Coffey:
By letter dated August 3, 2021, Agencywide Documents Access and Management System (ADAMS) Package Accession number (ML21215A314), Florida Power & Light Co. (FPL) submitted an application for subsequent renewal of Renewed Facility Operating License Nos. DPR-67 and NPF-16 for St. Lucie Nuclear Plant, Units 1 and 2 (St. Lucie),
respectively, 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 (SLR).
Per the NRCs March 3, 2025, letter, the NRC staff has restarted the environmental review of FPLs SLR environmental report. To supplement the environmental audit held February 28 - March 3, 2022, the NRC staff will conduct a remote supplemental environmental audit the week of April 21, 2025, as well as a site visit at a date yet to be determined. The environmental audit activities will be conducted in accordance with the enclosed Environmental Audit Plan (see Enclosure).
To the extent possible, the NRC staff requests the information identified in the Environmental Audit Needs List (see Enclosure) be made available on the St. Lucie online reference portal prior to the audit. A draft schedule of tours and meetings is provided in the enclosure.
April 2, 2025
R. Coffey 2
If you have any questions, please contact me via email at Lance.Rakovan@nrc.gov.
Sincerely, Lance J. Rakovan Senior Environmental Project Manager Environmental Project Management Branch 1)
Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. DPR-67 and NPF-16
Enclosure:
As stated cc: w/encl: Listserv Kenneth.Mack2@fpl.com Jerry.Phillabaum@fpl.com MBrunton@enercon.com Signed by Rakovan, Lance on 04/02/25
Enclosure Audit Plan Subsequent License Renewal Supplemental Environmental Review St. Lucie Nuclear Plant, Units 1 and 2 Week of April 21, 2025 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
2 SUBSEQUENT LICENSE RENEWAL ENVIRONMENTAL AUDIT PLAN ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2
1. Background
By letter dated August 3, 2021 (Agencywide Documents Access and Management System (ADAMS) Package ML21215A314), Florida Power & Light Co. (FPL) submitted an application for subsequent renewal of Renewed Facility Operating License Nos. DPR-67 and NPF-16 for St.
Lucie Nuclear Plant, Units 1 and 2 (St. Lucie), respectively, to the U.S. Nuclear Regulatory Commission (NRC). NextEra Energy, Inc. (NextEra) submitted the application pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal (SLR). A Federal Register Notice (86 FR 45768) dated August 16, 2021, noted the receipt and availability of the application.
NextEra letter dated July 3, 2024 (ML24185A079) requested that the NRC staff provide a plan for completing the environmental review for St. Lucie. As part of that review, the NRC staff is conducting a supplementary environmental audit of St. Lucie to improve understanding, to verify information, and to identify information for docketing to support the preparation of the environmental impact statement. Specifically, the NRC staff will be identifying pertinent environmental data, reviewing the facility, and seeking clarifications regarding information provided in the environmental report.
- 2. Environmental Audit Bases License renewal requirements for environmental reports are specified in 10 CFR 51, Postconstruction environmental reports. As specified by 10 CFR 51.53(c): Operating license renewal stage, (1) Each applicant for renewal of a license to operate a nuclear power plant under part 54 of this chapter shall submit with its application a separate document entitled "Applicant's Environmental ReportOperating License Renewal Stage." Review guidance for the staff is provided in NUREG-1555, supplement 1, revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.
On August 6, 2024, the NRC published a final rule in the FR (89 FR 64166) revising its environmental protection regulations in 10 CFR 51, Environmental protection regulations for domestic licensing and related regulatory functions. The final rule was updated with a correction to appendix B of subpart A on August 21, 2024 (89 FR 67522). The final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power plant for up to an additional 20 years, for either an initial license renewal or a single SLR term. The NRC also published a revised Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (NUREG-1437, Revision 2), which provides the technical basis for the final rule.
While compliance by license renewal applicants is not required until 1 year from the date of publication, the final rule became effective on September 5, 2024, for the NRC staff. Therefore, the staff must consider and analyze the environmental issues contained in the final rule and consider any new and significant information associated with the SLR.
- 3. Environmental Audit Scope The scope of this environmental audit is to identify new and significant issues and issues which can be eliminated from further study since the environmental audit conducted February 28 -
March 3, 2022. The NRC staff will also identify environmental resources that must be described and evaluated in the Supplemental Environmental Impact Statement. Audit team members will
3 review the documents and other requested information made available on the St. Lucie online reference portal Identified on the environmental audit needs list (see below) and discuss any questions and additional information needs with the applicants subject matter experts.
- 4. Information and Other Material Necessary for the Environmental Audit As identified on the environmental audit needs list (see below).
- 5. Environmental Audit Team Members and Resource Assignments The environmental audit team members and their assignments are shown in the table below.
Discipline Team Members Environmental Review Supervisor Steve Koenick Environmental Project Manager Lance Rakovan Air Quality Nancy Martinez Aquatic Resources Briana Arlene Cumulative Impacts Peyton Doub Federally Protected Ecological Resources Briana Arlene (ESA NMFS)
Mitchell Dehmer (ESA FWS)
Shannon Healy (EFH)
Geologic Environment Gerry Stirewalt Greenhouse Gases/Climate Change Nancy Martinez Groundwater Gerry Stirewalt Historic and Cultural Resources Jeff Rikhoff Human Health Leah Parks Land Use and Visual Resources Caroline Hsu Meteorology and Climatology Nancy Martinez Noise Nancy Martinez Postulated Accidents William Rautzen Replacement Power Alternatives Peyton Doub Severe Accident Mitigation Alternatives William Rautzen Socioeconomics Caroline Hsu Spent Nuclear Fuel Leah Parks Surface Water Lloyd Desotell Termination of Operations and Decommissioning Leah Parks Terrestrial (Land Cover and Habitat)
Caroline Hsu Uranium Fuel Cycle Leah Parks Waste Management (rad and non-rad)
4
- 6. Logistics The environmental audit will be conducted remotely the week of April 21, 2025, in addition to a site visit at a date yet to be determined. An entrance meeting will be held with plant management at the beginning of the audit and an exit meeting will be held at the end of this audit.
7.
Special Requests Florida Power & Light Co. staff and contractors who are subject matter experts in the disciplines identified on the environmental audit needs list should be available for interviews and tours.
8.
Deliverables An audit summary report will be issued by NRC staff within 90 days from the exit meeting.
5 St. Lucie Nuclear Plant, Units 1 and 2 Supplemental Audit and Site-Specific Information Needs The U.S. Nuclear Regulatory Commission (NRC) staffs St. Lucie Nuclear Plant, Units 1 and 2 (St.
Lucie) audit requests are described below in three categories: tours, meetings, and information needs. Information needs are identified as either resource-specific questions or document requests. Please arrange for the tours and meetings to occur during the virtual environmental audit or site visit as noted. Additionally, we ask that you provide responses to the information needs on the electronic portal and make subject matter experts available to discuss these items with the NRC staff.
Virtual Tours Please arrange for, and provide appropriate subject matter experts to contribute to, the following virtual tours. For the virtual tours, please provide photographs, diagrams, location maps, and/or callouts for specific components that would be of interest for the features noted.
Title or Number Features Observed NRC Participants
- 1. General site tour Virtual walk-through of the following via photographs and/or diagrams:
Major plant features, such as turbine and auxiliary buildings Low-level waste facility Intake and discharge canals Switchyard and in-scope transmission lines Independent Spent Fuel Storage Installation (ISFSI)
Plant views from publicly accessible areas Locations with terrestrial habitats representative of those present on the site All
6
- 3. Radwaste tour Virtual walk-through of the following via photographs and/or diagrams:
Liquid radwaste system - discharge locations Gaseous radwaste system - discharge locations Low-Level Radioactive Waste (LLW) Storage Area (Radwaste Building) and Mixed Waste Storage Area Lloyd Desotell Leah Parks Gerry Stirewalt
- 4. Water resources tour Virtual walk-through of the following via photographs and/or diagrams:
Monitoring wells, including the 10 that are sampled by Florida Department of Health on a quarterly basis Trace of groundwater flow paths along which tritium migrates Underdrain system relevant manholes and piezometers Water balance/flow paths for the evaporation/percolation pond system National Pollutant Discharge Elimination System outfalls and their sampling locations Radiological environmental monitoring program surface water sampling locations Mangrove flushing area Artificial reef ball project Lloyd Desotell Gerry Stirewalt
- 2. Plant intake and discharge tour Virtual walk-through of the following via photographs and/or diagrams:
Location of ocean intake velocity caps Headwall structures Intake canal, including 5 and 8 sea turtle barrier nets Locations on intake canal banks where sea turtle nests have been discovered and relocated Intake wells, traveling screens, and other important features of cooling water intake system with respect to impingement or entrainment of aquatic organisms Discharge canal and location of discharge pipes Location where sea turtles are typically released back to the ocean Beach locations of sea turtle nesting surveys Service water pumphouse Location of Big Mud Creek Emergency Cooling Water Intake Briana Arlene Mitchell Dehmer Lloyd Desotell Shannon Healy Leah Parks Gerry Stirewalt
7
- 5. Visual resources tour Photos of St. Lucie from publicly accessible areas where plant structures or operations are visible.
Specifically, please provide the following:
From public roads such as State Road A1A From the viewpoint of recreational water users on the Indian River Lagoon From the viewpoint of recreational water users on the Atlantic Ocean From areas of the mainland such as from SR-707 or Indian River Drive From county, state, or Federal parks, recreation areas, preserves, beaches etc.
From residential areas, for example the nearest resident to St. Lucie on Hutchinson Island or residences on the mainland from which St. Lucie is visible.
From any other publicly accessible area where plant structures or operations are visible.
8 In-person Tours Please arrange for, and provide appropriate subject matter experts to contribute to, the following in-person tours as part of the NRCs site visit.
Title or Number Features Observed NRC Participants 1.
General site tour Major plant features, such as turbine and auxiliary buildings Low-level waste facility and Mixed-Waste storage locations, if applicable Intake and discharge canals Switchyard and in-scope transmission lines ISFSI Locations with terrestrial habitats representative of those present on the site All 2.
Plant intake and discharge tour Location of ocean intake velocity caps Headwall structures Intake canal, including 5 and 8 sea turtle barrier nets Locations on intake canal banks where sea turtle nests have been discovered and relocated Intake wells, traveling screens, and other important features of cooling water intake system with respect to impingement or entrainment of aquatic organisms Discharge canal and location of discharge pipes Location where sea turtles are typically released back to the ocean Beach locations of sea turtle nesting surveys All 3.
Radwaste tour Liquid radwaste system - discharge locations Gaseous radwaste system - discharge locations LLW Storage Area (Radwaste Building)
Leah Parks Virtual Meetings Please be prepared to participate in breakout meetings with the appropriate subject matter expert(s) and/or contractor(s) concerning the following topics. Those in attendance should be prepared to discuss the corresponding questions as described in the Information Needs and Document Requests section below. The staff intends to use these breakout meetings, as needed, to resolve or clarify any outstanding data needs or questions arising from the environmental audit.
NRC intends to leverage virtual breakouts to the extent possible. Any in-person breakouts will be specified at a later date.
9 General Topics Ecological Resources (Aquatic, Terrestrial, Federally Protected)
Geologic Environment Greenhouse Gas Emissions and Climate Change Groundwater and Surface Water Resources Human Health (virtual with any necessary follow-up onsite)
Land Use and Visual Resources Meteorology, Air Quality, and Noise Replacement Power Alternatives Socioeconomics Spent Nuclear Fuel Terrestrial Resources Waste Management (including Termination of Operations & Decommissioning)
Information Needs and Document Requests Information needs and document requests are identified below by resource area.
General (All)
The following request is generic to more than one environmental review area.
GEN-1 In its January 2025 environmental report (ER) supplement (ML25034A029), Florida Power & Light Co. (FPL) stated that it was not aware of any significant new information that has arisen since FPLs St. Lucie Nuclear Plant, Units 1 and 2, Subsequent License Renewal Application - Environmental Audit Requests For Confirmation of Information (RCI)/ Requests for Additional Information Response, dated June 14, 2022 (Agencywide Documents Access and Management System (ADAMS) ML22165A180),
that could affect the NRCs assessment of Category 1 environmental issues. Please discuss the methodology applied to identify and evaluate new and significant information, including the process for determining how new information was determined to not be significant.
Topic-specific The following requests are specific to a single environmental review area. If a topic is not provided below, the discussions held in response to the generic requests above are expected to fully cover that topic.
Air Quality and Noise (Nancy Martinez)
Audit Needs AQN-1 Section 3.3.3 of the ER (ML21215A319) states that beginning in 2020, annual air emission reports are no longer required by Florida Department of Environmental Protection (FDEP) for St. Lucie. Table 3.3-10 of the ER presented annual air emissions for the 2015-2019 period. Does FPL have estimated annual air emissions for 2020-2024? If so, please provide.
AQN-2 Has FPL received any notices of violation or non-compliance associated with St.
Lucies air permit since 2019? If so, please provide.
10 AQN-3 Has FPL conducted field tests concerning ozone and nitrogen oxide emissions generated by St. Lucies in-scope transmission lines? If so, please provide.
AQN-4 Has FPL received any noise complaints with respect to St. Lucie operation since June 14, 2022? If so, please provide.
AQN-5 Section 3.4 of the ER (ML21215A319) states that FPL conducted an ambient noise study that was performed as part of the St. Lucie site certification application for the power uprate project.
a.
Has FPL conducted or commissioned any noise surveys been since 2007 at or in the vicinity of St. Lucie? If so, please provide a copy.
- b. Please provide a copy of the September 2007 noise study.
c.
Please identify the primary offsite noise sources in the immediate vicinity of St.
Lucie.
Document Needs None Aquatic Resources (Briana Arlene)
Audit Needs None at this time Document Needs AQ-1 Please provide copies of the following references cited in FPLs January 2025 ER Supplement (ML25034A029):
a.
FDEP. 2024a. Notice of Draft Permit No. FL0002208. Accessed via OCULUS Document Management System. Retrieved from
<https://depedms.dep.state.fl.us/Oculus/servlet/login> (accessed January 14, 2025).
b.
FPLs April 16, 2021, National Pollutant Discharge Elimination System (NPDES) permit renewal application Cumulative Impacts (Peyton Doub)
Audit Needs None at this time Document Needs None at this time
11 Federally Protected Ecological Resources (Mitchell Dehmer and Shannon Healy)
Audit Needs FPE-1 FPLs January 2025 ER Supplement (ML25034A029) does not specifically discuss whether FPL has new information concerning the federally protected species and critical habitats previously analyzed in the August 2021 ER (ML21215A314). Please provide any new occurrence data, ecological survey information, or other new information on the federally listed species and critical habitats analyzed in Sections 3.7.8 and 4.6.6 of the 2021 ER of federally protected species under the Endangered Species Act in or near the project area. If no such information exists, please confirm that there are no updates.
FPE-2 Is FPL aware of milkweed (Asclepias spp.) occurring on the St. Lucie site? If so, does milkweed occur in areas that FPL would manage with herbicides, pesticides, mowing, or other management techniques during the subsequent license renewal (LR)? Has FPL implemented any specific mitigation or measures that would be protective of the monarch butterfly with respect to landscape maintenance practices?
FPE-3 Section 3.7.8.1.2 of the 2021 ER states that American alligators (Alligator mississippiensis) have been observed on the St. Lucie site in ponds and in the intake canal and have been documented in the Smithsonians Indian River Lagoon inventory.
Does FPL implement any specific mitigation measures to avoid or minimize potential impacts to this species?
FPE-4 Section 3.7.8.1.4 of the 2021 ER states that five West Indian manatees (Trichechus manatus) have entered the intake canal since St. Lucie began operations. The 27 December 2006, Unusual or Important Environmental Event - Manatee report (ML070090495), states that there were seven West Indian manatees that have entered the intake canal since operations began at St. Lucie. The most recent removal of a manatee from the intake canal was in June 2024 (ML24192A215). Please clarify the total number of manatees collected at St. Lucie and the dates they were collected.
Please provide a list of mitigation measures that FPL implements to avoid or minimize potential impacts to manatees.
Document Needs FPE-5 Please provide copies of correspondence between FPL or its contractors and the U.S.
Fish and Wildlife Service (FWS) that has transpired since the submittal of the August 2021 ER.
Geologic Environment (Gerry Stirewalt)
Audit Needs GE-1 Geologic resources were not mentioned in the ER or the ER supplement. Section 3.4 (Geologic Environment) of Regulatory Guide 4.2, Supplement 1, Preparation of Environmental Reports for Nuclear Power Plant License Renewal Applications, Revision 1, June 2013, suggests that geologic resources should be addressed in an ER. Please confirm that no geologic resources that could be considered assets occur at or adjoining the site, including sand and gravel deposits.
12 Document Needs None at this time Greenhouse Gases/Climate Change (Nancy Martinez)
Audit Needs GG-1 Section 4.0 of the ER Supplement (ML25034A029), states that FPL conducted a new and significant information review for Category 1 issues, which included greenhouse gas emissions impacts on climate change. The ER Supplement further states that FPL did not identify any new and significant information regarding Category 1 issues. Table 3.3-10 of the ER (ML21215A319) presents annual greenhouse gas emissions for the 2015-2019 period.
a.
Please provide updated annual greenhouse gas emissions (direct and indirect emissions) for the 2020-2024 period.
b.
Does FPL use sulfur hexafluoride (SF6) at St. Lucie? If so, please identify the equipment that use SF6 and include Green House Gas (GHG) emissions for the 2020-2024 period under part a. above. Additionally, if fluorinated gases are used, identify and discuss procedures implemented to manage the handling of fluorinated gases.
c.
If available, please provide fugitive GHG emissions from refrigerant equipment at St. Lucie for the 2020-2024 period.
GG-2 Section 5.13.2.3 of the ER Supplement (ML25034A029) discussed climate change impacts on water resources. Section 3.6.1.2.6 of the ER (ML21215A319) states that cooling water intake water temperatures for each unit are measured and averaged for each month. Figure 3.6-4 of the ER (ML21215A319) provides water intake temperatures for the 2015-2020 period. Please provide a time series figure of the annual average intake cooling water temperatures available for the long-term period of record. Additionally, provide a discussion and any relevant information as to whether a warming trend has been observed.
GG-3 Section 5.13.2.3 of the ER Supplement (ML25034A029) states: Using a GWL 2°C scenario, the surface water temperature on the coastline of Florida is expected to increase by 3.6°F. (USGCRP 2023).
a.
Please identify the chapter, section, or figure in the Fifth National Assessment Report (USGCRP 2023) that supports this statement.
b.
Has FPL conducted thermal discharge studies that account for increases water temperature in the Atlantic Ocean due to climate change? If so, please provide a copy.
Document Needs None
13 Groundwater Resources (Gerry Stirewalt)
Audit Needs GW-1 Please discuss groundwater flow paths along which tritium migrates including discharges of groundwater to the intake canal where it is used in the cooling water system, then transferred to the discharge canal and ultimately into the Atlantic.
GW-2 FPLs 2025 ER Supplement reports tritium concentrations of 541pCi/L in the 10 groundwater wells. Are data available for 2024 that show similar concentrations?
GW-3 Please confirm that FPL did not identify new and significant information related to concentrations of radionuclides in groundwater since the previous environmental audit.
Document Needs GW-4 Please provide a map with groundwater monitoring well locations, including the 10 wells sampled by the Florida Department of Health on a quarterly basis.
Historic and Cultural Resources (Jeff Rikhoff)
Audit Needs None at this time Document Needs None at this time Human Health (Leah Parks)
Audit Needs HH-1 Section 5.11.1.4 of the February 3, 2025, Supplement to Subsequent License Renewal Application Environmental Report states that all in-scope transmission lines at St. Lucie meet or exceed the applicable National Electric Safety Code (NESC) standards.
In-scope transmissions lines at St. Lucie include one overhead 230-kV line connecting Units 1 and 2 to the regional electric power grid, and one overhead 230-kV line. These provide power from the grid to feed the plant during outages, as discussed in St. Lucie subsequent license renewal ER Section 2.2.5.1. All in-scope transmission lines are located completely within the St. Lucie site boundary, as shown in Figure 2.2-4 of the St. Lucie SLR ER. No modifications to the in-scope transmission lines have been made since the submittal of the St. Lucie SLR ER. All in-scope transmission lines at St.
Lucie meet or exceed the applicable NESC standards [emphasis added]. To maintain this status, FPL monitors and reviews all changes to existing NESC design standards to determine if these changes would be applicable to St. Lucie. FPL maintains electrical safety procedures, including procedure for working on or near exposed energized parts, procedure for proper personal protective equipment and tool
14 selection, and grounding for the protection of employees.
Please be prepared to discuss how the in-scope transmission lines at St. Lucie Nuclear Plant satisfy NESC standards.
HH-2 Please have St. Lucie subject matter experts available to discuss the electrical safety program along with related Occupational Safety and Health Administration regulations as implemented at the site.
Document Needs HH-3 As discussed in ER Section 3.10.2., Electric Shock Hazards, please provide copies of fleet electrical safety program procedures, including those addressing: proper clearances; grounding of vehicles, equipment, and structures; and the workplace hazards identification process. Include FPLs Rigging and Material Handling Procedure MA-AA-212-1000 which addresses the precautions when working around overhead energized lines on the St. Lucie site and St. Lucie Switchyard Access/Work Control Procedure ADM-16.01 controls activities using cranes and vehicle clearances within the switchyard and perimeter.
Land Use and Visual Resources (Caroline Hsu)
Audit Needs LU-1 Section 2.0 in the 2025 supplement lists several changes to plant structures, systems or operations that have been undertaken or planned for future implementation since the preparation of the ER. Please provide more information about item 2, item 3, and item 4.
a) Item 2, Removal of West Test Facility and Quality Control Building with concrete pads remaining. Was this removal already undertaken or is it planned for the future? Why was the building removed, and will a new building be constructed elsewhere onsite? Will the concrete pad ever be removed and the site restored?
b) Item 3, Addition of second switchyard southeast of existing switchyard in a site previously occupied by the site's ballfield. Was this addition of a second switchyard already undertaken or is planned for the future? What is the area of the second switchyard? What was the land use/ land cover of the ballfield and what is the land use/land cover of the new second switchyard?
c)
Item 4, Dune renourishment seaward of the seawall project. Please describe this project and provide any plans or reports on the dune renourishment. What is the area/square footage of the project?
VR-1 Please provide any new and significant information regarding visual resources/
aesthetics since the ER. For example, changes in lighting, new tall structures.
Document Needs None at this time
15 Meteorology (Nancy Martinez)
Audit Needs MC-1 Tables 3.3-2, 3.3-4, and 3.3-5 of the ER (ML21215A319) provide wind conditions, temperature, and precipitation measurements from St. Lucies meteorological monitoring program for the 2013-2020 period. Please update these tables to include measurements through 2024.
Document Needs None Postulated Accidents/SAMA (William Rautzen)
Audit Needs None at this time Document Needs None at this time Replacement Power Alternatives (Peyton Doub)
Audit Needs ALT-1 What information sources did FPL consider when identifying the replacement power alternatives presented in Section 7.2 of the original (2021) ER?
ALT-2 Please indicate whether there is any new and significant information or other relevant updated information regarding the analysis of replacement power alternatives in Section 7.2 of the original (2021) ER.
Document Needs None at this time Socioeconomics (Caroline Hsu)
Audit Needs SOC-1 Please provide annual property tax paid by FPL for the years 2020, 2021, 2022, 2023, and 2024 (if available). Please provide FY Total St. Lucie County Property Tax Revenues for 2020, 2021, 2022, 2023, and 2024 (if available).
16 Year Annual Property Tax Paid by FPL FY Total St. Lucie County Property Tax Revenues 2020
$43,866,726.19 2021
$42,525,898.26 2022 2023 2024 SOC-2 Please describe other sizeable annual support payments such as emergency preparedness fees, one-time payments, non-tax compensation to local organizations, communities, jurisdictions, school districts, on behalf of St. Lucie in addition to the annual emergency preparedness support to St. Lucie County, Martin County, Palm Beach County, Indian River County, Brevard County, Florida Department of Emergency Management, and the Florida Department of Health.
SOC-3 Table 2.5-1 in the ER shows St. Lucie Permanent Employee Residence Information from October 2020. Have there been any changes to this table up to the county level since October 2020? What percentage of permanent full-time employees reside in Martin and St. Lucie counties as of 2025? Please update Table 2.5-1 to the county level.
SOC-4 Section 2.5 in the ER states that the nonoutage workforce at St. Lucie consists of 804 employees, including 508 FPL workers and 296 supplemental staff and that overall plant staffing levels have been reduced over time due to increased efficiencies. As of 2025, what is the nonoutage workforce at St. Lucie including FPL workers and supplemental staff?
Document Needs None at this time Spent Nuclear Fuel (Leah Parks)
Audit Needs SNF-1 As stated in 2021 ER Section 3.1.4, the possible need to expand the ISFSI and scope of any such expansion cannot be determined at this time, as such expansion would depend on the status of the U.S. Department of Energys (DOEs) future performance of its obligation to accept spent nuclear fuel (SNF) or the availability of other interim storage options. Consequently, the possibility of such expansion is currently speculative, and not reasonably foreseeable. The ISFSI is sized to accommodate all SNF generated through the first period of extended operation, and the spent fuel pools could presumably accommodate another 20 years of SNF.
The February 3, 2025, Supplement to Subsequent License Renewal Application Environmental Report states, As discussed in Section 4.12 of the St. Lucie SLR ER, expansion of the St. Lucie ISFSI for the proposed SLR operating term is not reasonably foreseeable. The FPL response to RCI LU-3 confirmed that if an ISFSI expansion occurs during the subsequent period of extended operation, there exists sufficient land on the St. Lucie site to accommodate the construction and operation of the ISFSI expansion (FPL 2022b).
17 Please confirm whether the current ISFSI, along with the space available in the spent fuel pools, has the capacity to accommodate the spent nuclear fuel generated during the subsequent period of operation. Also, if an ISFSI expansion occurs during the subsequent license renewal period, please confirm there exists sufficient previously disturbed land on the site to accommodate the construction and operation of the ISFSI expansion and that the expansion would not be expected to have any significant environmental impacts.
Document Needs None at this time Surface Water Resources (Lloyd Desotell)
Audit Needs SW-1 Since the ER was written, has St. Lucie received any notices of violation or non-compliances associated with wastewater discharges to receiving surface waters? If so, please provide a description of the violation and associated corrective actions.
SW-2 The Annual Radiological Environmental Operating Reports state that samples are collected and analyzed by the State of Florida, Department of Health (DOH). Please describe the arrangement/agreement St. Lucie has with the DOH and provide a copy of the agreement for NRC staff review.
SW-3 The ER refers to the salinity of groundwater and the Indian River Lagoon near the St.
Lucie site (see pages 3-76 and 3-145). Please provide any relevant salinity data collected near the St. Lucie site.
SW-4 Section 3.1.4 of the ER discusses a pilot project which installed a submerged reef ball breakwater under permit 0314668-001-JC (see Table 9.1-1 of the ER). Please describe the plans, if any, to construct additional concrete reef ball breakwaters.
SW-5 On February 6, 2025, FDEP issued an Intent to Issue letter regarding wastewater permit FL0002208. Please provide an update regarding the status of this permit and describe any differences in the permit conditions (e.g. outfalls, target analytes, sample frequency) from those described in the ER.
SW-6 Section 3.6.4.1 of the ER discusses water bodies near St. Lucie that have been identified as impaired by FDEP in 2020. Section 3.6.4.1 also states that St. Lucie does not contribute to these impairments. Please confirm that the discussion in Section 3.6.4.1 continues to be valid when considering the latest FDEP listing of impaired waters or provide a revised discussion as appropriate.
SW-7 ER Tables 3.6-3a and 3.6-3b present annual and monthly surface water withdrawals, from 2016 to 2020. Please update these tables to provide data from 2021 to the present.
SW-8 What is the Atlantic Ocean surface water intake nearest to St. Lucie? What category of use does that intake serve?
18 SW-9 ER Section 3.6.3.1 discusses withdraws by St. Lucie County from the intake canal for seasonal flushing of the mangrove impoundment between the intake and discharge canals to enhance growth of mangroves and assist in mosquito control. Please provide addition available information on these withdrawals including any related agreements with St. Lucie County.
SW-10 ER Section 3.6.1.2.2 discusses staff compliance evaluations that provide an overall assessment of the conditions at the facility that potentially impact stormwater quality and the effectiveness of the current stormwater pollution prevention plan (SWPPP).
Provide copies of these evaluations for last 5 years.
SW-11 Over the last 5 years, has St. Lucie reduced power to meet thermal discharge limits? If so, please briefly summarize these instances.
SW-12 ER Table 3.6-1 lists outfall I-009 as an emergency discharge location during extreme storm events. Has this outfall been used in the last 5 years? If so, please briefly summarize these instances.
SW-13 ER Section 4.12.4.3 states St. Lucie operates in compliance with its permits for water withdrawals and discharges. What is the regulatory/permitting basis that authorizes St.
Lucies use of Atlantic Ocean surface water? Please provide a copy of the authorization documents.
SW-14 Review of the last 5 years of Annual Radioactive Effluent Release Reports indicates that batch releases of water from the South Settling Basin to the Intake Canal occur to lower the basin water level from periods of higher-than-normal rainfall. Please provide the criteria and site procedure for this action.
SW-15 The site area map and environmental sampling locations figure in the Annual Radiological Environmental Operating Reports are somewhat unclear, please provide a figure indicating the location of radiological environmental monitoring program surface water sampling stations H-15, H13 and H36.
SW-16 The Annual Radiological Environmental Operating Reports list multiple tritium results above detection levels for surface water sampling location H36. The result for April 2021 exceeded 22,000 pCi/L. The result for January 2023 was 11,820 pCi/L and noted that the sample was taken during release. Please provide a description of the source of tritium detected at H36 and summarize the basis for its intermittent detection at this location.
SW-17 ER Section 3.1.4 states future projects may include dredging of intake and discharge canals. Please provide an update on this project, as applicable.
Document Needs SW-18 Current spill prevention, control, and countermeasure plan.
SW-19 Best Management Practices Plan SW-20 Current SWPPP (if not included with best management practices plan)
19 SW-21 Maintenance dredging permit SAJ-1993-01803 SW-22 Stormwater discharge permits 56-00848-S and 85-142 SW-23 Discharge monitoring reports for the last 5 years SW-24 Joint coastal permit 0314668-001-JC SW-25 Thermal discharge study referenced in ER 2.2.3.5 Termination of Operations and Decommissioning (Leah Parks)
Audit Needs None at this time Document Needs None at this time Terrestrial Resources (Caroline Hsu)
Audit Needs TR-1 Please provide lighting regime (color of light, steady or blinking) for all tall structures (greater than 100 ft) onsite.
TR-2 Section 3.7.8.5 of the ER discusses FPLs migratory bird special purpose utility permit (SPUT). During the previous audit, FPL provided a copy of the SPUT which expired March 31, 2024 but which has been administratively continued as of January 2025.
Has FWS issued a renewed permit? Please provide a copy of the current permit.
TR-3 Section 3.7.8.5 of the ER states that as part of the SPUT, FPL submits a yearly report to USFS on injured or dead birds. Please provide these yearly reports for the last 10 years.
TR-4 Have any surveys or studies on State-protected species, or species protected under the Migratory Bird Treaty Act or Bald and Golden Eagle Protect Act been conducted since 2001 by either FPL or by another entity? Please provide any known avian or terrestrial ecology studies performed in the last 10 years.
Document Needs TR-5 Avian Protection Plan TR-6 Invasive species management plan TR-7 BMPs or management plans for pollinators TR-8 Vegetation and herbicide management plans
20 Uranium Fuel Cycle (Leah Parks)
Audit Needs None at this time Document Needs None at this time Waste Management (Leah Parks)
Audit Needs WM-1 If there have been any reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement since the previous audit took place in February 2022 (besides what are documented in the effluent release reports), please provide a description of the releases. Please be prepared to discuss your plan to handle unplanned releases of radioactive materials.
WM-2 If there have been any reportable inadvertent nonradioactive releases that would be classified as an incidental spill which would trigger a notification requirement since the previous audit took place in February 2022, please provide a description of spills/releases. Please be prepared to discuss your plan to handle inadvertent nonradioactive releases.
WM-3 St. Lucie is subject to the reporting provisions of Title 40 of the Code of Federal Regulations Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Any discharges of oil in such quantities that may be harmful to the public health or welfare, or the environment must be reported to Environmental Protection Agencys National Response Center. In section 9.5.3.7 of the ER, the applicant discusses reportable spills and states that for the 5-year period of 2016-2020, there were no reportable spills/no releases. In response to the audit requests for confirmatory information dated June 14, 2022, the license confirmed that there were no reportable spills of this nature since the ER was written. If there have been any reportable spills/releases which would trigger this notification requirement since June 14, 2022, please provide a description of any spills/releases.
WM-4 St. Lucie is subject to the reporting provision under Florida Administrative Code 62-780 and under the site conditions of certification. This reporting provision requires that any spills of materials having potential to significantly pollute surface or groundwaters and which are not confined to a building or similar containment structure be reported to the FDEP Office of Emergency Response by telephone immediately after discovery of such spill, followed by a detailed written report. Please confirm whether there have been reportable spills since June 14, 2022, that would trigger this notification.
WM-5 Please confirm if there are any proposed changes or upgrades to the hazardous and mixed waste management program being considered during the
21 license renewal term.
WM-6 Please confirm whether there are any proposed changes or upgrades to the low-level radioactive waste program being considered during the license renewal term.
Document Needs None
22 St. Lucie Nuclear Plant, Units 1 and 2 Environmental Audit Schedule Tuesday, April 22, 2025 START END ACTIVITY 9:00 am ET 9:30 am ET Entrance meeting between U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Co. (FPL) 9:30 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC and FPL subject matter experts (SMEs)
Wednesday, April 23, 2025 START END ACTIVITY 9:00 am ET 4:00 pm ET Virtual tours/virtual meetings between NRC and FPL SMEs Thursday, April 24, 2025 START END ACTIVITY 9:00 am ET 11:00 am ET Virtual tours/virtual meetings between NRC and FPL SMEs 11:00 am ET 11:30 am ET Virtual audit exit meeting between NRC and FPL