ML25091A289
| ML25091A289 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/09/2025 |
| From: | Natreon Jordan NRC/NRR/DORL/LPL2-2 |
| To: | Coffey B Florida Power & Light Co |
| Jordan N, NRR/DORL/LPL2-2 | |
| References | |
| EPID L-2024-LLA-0162 | |
| Download: ML25091A289 (1) | |
Text
April 9, 2025 Bob Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company 700 Universe Blvd.
Mail Stop: EX/JB Juno Beach, FL 33408
SUBJECT:
ST. LUCIE PLANT, UNIT NO. 2 - REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUEST FOR LICENSING BASIS CHANGES IN SUPPORT OF ST. LUCIE UNIT 2 TRANSITION TO 24-MONTH FUEL CYCLES (EPID L-2024-LLA-0162)
Dear Bob Coffey:
By submittal dated November 26, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24331A249, Florida Power & Light (the licensee) requested an amendment to Renewed Facility Operating License NPF-16 for the St. Lucie Plant, Unit No. 2 (St. Lucie) facility. The proposed license amendment would revise St. Lucie, Unit 2 Technical Specification 5.5.16, Surveillance Frequency Control Program, to increase certain Surveillance Requirement Frequencies to support a 24-month fuel cycle.
The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit using a licensee-established electronic portal available to staff from approximately April 14, 2025, through August 18, 2025. Formal audit meetings using video and teleconferencing will be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.
If you have any questions, please contact me by telephone at 301-415-7410 or by email to Natreon.Jordan@nrc.gov.
Sincerely,
/RA/
Natreon J. Jordan, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-389
Enclosure:
Audit Plan cc: Listserv
- by email NRR-106 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LAiT*
NRR/DORL/LPL2-2/BC*
NAME NJordan CAdams (SL)
DWrona DATE 3/31/2025 4/3/2025 4/9/2025
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST FOR LICENSING BASIS CHANGES IN SUPPORT OF ST. LUCIE, UNIT 2 TRANSITION TO 24-MONTH FUEL CYCLES FLORIDA POWER & LIGHT COMPANY ST. LUCIE PLANT, UNIT 2 DOCKET NO. 50-389
1.0 BACKGROUND
By application dated November 26, 2024, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24331A249, Florida Power & Light Company (FPL, the licensee), requested changes to the technical specifications (TSs) for Saint Lucie Plant, Unit 2 (St. Lucie).
The proposed license amendment revises TS 5.5.16, Surveillance Frequency Control Program (SFCP), to increase certain Surveillance Requirement (SR) Frequencies to support a 24-month fuel cycle. In particular, the proposed changes would revise the St. Lucie licensing basis and make corresponding changes to the TSs to implement a 24-month operating cycle with a 25 percent grace period to permit up to 30 months to complete the SR. The proposed modification to the SFCP would permit affected SR Frequency increases in accordance with the U.S. Nuclear Regulatory Commission (NRC) Generic Letter 91-04 Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle (ML013100215).
Changes to some Reactor Protective System, Engineered Safety Features Actuation System, and Diesel Generator - Loss of Voltage Start Allowable Values and Trip Setpoints are required to support the change to a 24-month fuel cycle. Additionally, this change addresses an increase in the maximum boric acid concentration in the Refueling Water Tank and Safety Injection Tanks needed to support an increase in fuel cycle length. Lastly, a change to the reactor vessel surveillance capsule withdrawal schedule is requested to address the fluence changes associated with the 24-month operating cycle.
The NRC staff has initiated its review of the LAR in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, License Amendment Review Procedures (ML19248C539). The NRC staff has reviewed the licensees submittal in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures (ML19248C539), and determined that a regulatory audit of the information identified in the
Information Requests section below would assist in the timely completion of the subject LAR review process. The audit will be conducted in accordance with NRR LIC-111, Regulatory Audits, (Revision 2) with exceptions noted within this audit plan (ML24309A281). The NRC staff is continuing to review other aspects of the licensees submittal and may identify the need for additional audit subjects by separate correspondence.
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license, or regulation-related activity that includes the examination and evaluation of FPLs non-docketed information that provides the technical basis for the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision.
An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and record-keeping requirements, which although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information.
The NRC staff is requesting an initial set of internal licensee information to be audited by the staff using an online reference portal. Upon completion of this audit, the NRC staff expects to achieve the following.
- 1.
Confirm internal licensee information that supports statements made in the LAR.
- 2.
Determine whether the information included in the documents is necessary to be submitted to support a safety conclusion.
The audit information the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket.
The project manager from the Division of Operating Reactor Licensing - Plant Licensing Branch LPL II-2 will coordinate and facilitate execution of the audit plan.
3.0 SCOPE The audit team will view the documentation and calculations that provide the technical support for the LAR to:
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR, and confirm the NRC staffs understanding of the LAR; Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability of plant equipment to perform design-basis functions; and Identify questions and requests that may become formal requests for additional information (RAI) per NRR Office Instruction LIC-115, (Revision 1) Processing Requests for Additional Information (ML21141A238).
The LAR specifies that historical SR performance data and associated maintenance records were reviewed to evaluate the effect of these changes on safety. The failure analysis included non-calibration SRs, calibration SRs with setpoints (TS Allowable Values), and calibration SRs without setpoints (no TS Allowable Values). The scope of the NRC staffs audit will focus on the following subjects:
3.1 Proposed TS Changes -- Non-Calibration Changes The staff requests that applicable surveillance test reports and equipment failure reports pertaining to the previous five cycles for systems and components be available for review on the electronic portal.
The following Branches of NRR will participate in the Audit review and lead the focused review of the Surveillance Test History (successes and failures) for the proposed Non-Calibration changes to the TSs listed below:
Containment & Plant Systems Branch TS 3.6.3 Containment Isolation Valves TS 3.6.6 Containment Spray and Cooling Systems TS 3.6.7 Shield Building TS 3.6.9 Shield Building Ventilation System TS 3.7.2 Main Steam Isolation Valves TS 3.7.3 Main Feedwater Isolation Valves TS 3.7.4 Atmospheric Dump Valves TS 3.7.5 Auxiliary Feedwater System TS 3.7.7 Component Cooling Water System TS 3.7.8 Intake Cooling Water System TS 3.7.10 Control Room Emergency Ventilation System TS 3.7.12 Emergency Core Cooling System Area Ventilation System TS 3.9.3 Containment Penetrations Electrical Engineering Branch TS 3.8.1 AC Sources - Operating TS 3.8.4 DC Sources - Operating Instrumentation & Controls Branch/Long Term Ops and Modernization Branch TS 3.3.2 Reactor Protective System Logic and Trip Initiation TS 3.3.4 Engineered Safety Features Actuation System Logic and Manual Actuation Nuclear Systems Performance Branch TS 3.1.4 Control Element Assembly Alignment TS 3.1.6 Regulating Control Element Assembly Insertion Limits TS 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling Limits TS 3.4.9 Pressurizer TS 3.4.14 RCS Pressure Isolation Valve Leakage
TS 3.5.1 Safety Injection Tanks TS 3.5.2 ECCS - Operating TS 3.5.4 Refueling Water Tank TS 3.5.5 Trisodium Phosphate 3.2 Proposed TS Changes -- Calibration Changes The following Branches of NRR will participate in the Audit review and lead the focused review of the Surveillance Test History (successes and failures) for the proposed Calibration changes to the TSs listed below:
Containment & Plant Systems Branch TS 3.4.15 RCS Leakage Detection Instrumentation Instrumentation & Controls Branch and Long Term Ops and Modernization Branch TS 3.3.1 Reactor Protective System Instrumentation - Operating TS 3.3.3 Engineered Safety Features Actuation System Instrumentation TS 3.3.5 Diesel Generator - Loss of Voltage Start TS 3.3.6 Containment Isolation Instrumentation - Refueling TS 3.3.7 Control Room Isolation Signal TS 3.3.8 Fuel Pool Area Radiation Instrumentation TS 3.3.9 Post Accident Monitoring Instrumentation TS 3.3.10 Remote Shutdown System TS 3.3.11 Logarithmic Neutron Flux Monitoring TS 3.3.12, Reactor Protective System Instrumentation - Shutdown Nuclear Systems Performance Branch TS 3.4.12, Low Temperature Overpressure Protection System 3.3 Proposed TS Changes -- Programs Containment & Plant Systems Branch TS 5.5.2 Primary Coolant Sources Outside Containment TS 5.5.8 Ventilation Filter Testing Program 3.4 Risk Informed Review Containment & Plant Systems Branch Request that the Risk Profile for St. Lucie Unit 2 be posted on the e-portal (i.e., top 10 systems that contribute to CDF and LERF) to help the staff streamline its review of the surveillance test histories.
3.5 Capsule Removal Schedule - Review of The Fluence Methodology Vessels And Internals Branch Does not plan to participate in the Audit Nuclear Methods and Fuel Analysis Branch Request verification that the licensee is using their current licensing basis methodology to generate the fluence projections.
- i.
What methodology is FPL using?
ii.
Is the methodology approved by the NRC via a topical report (e.g., RAPTOR-M3G)?
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff will request information throughout the audit period. The NRC staff will identify the information to be audited (e.g., methodology, process information, and calculations) and the subjects of requested meetings.
The NRC staff requests that the licensee collect and have the information identified above available and accessible for the NRC staffs review via a web-based electronic portal either prior to or by the intended start date of the audit. The NRC staff requests the licensee to notify the review team when the audit item is added to its electronic portal by sending an email to the NRC licensing project manager.
5.0 AUDIT TEAM The following table identifies the NRC audit team members and their respective focus areas:
Name Email Review Area (Organization)
Natreon Jordan Natreon.Jordan@nrc.gov Plant Licensing Branch LPL II-2 David Nold David.Nold@nrc.gov Containment and Plant Systems Branch Nicholas Soliz Nicholas.Soliz@nrc.gov Containment and Plant Systems Branch David Rahn David.Rahn@nrc.gov Long Term Ops and Modernization Branch and Instrumentation & Controls Branch Gokul Vasudevamurthy Gokul.Vasudevamurthy@nrc.gov Nuclear Systems Performance Branch
Name Email Review Area (Organization)
Robert Beaton Robert.Beaton@nrc.gov Nuclear Systems Performance Branch Liliana Ramadan Liliana.Ramadan@nrc.gov Electrical Engineering Branch 6.0 LOGISTICS The audit will be conducted using a secure, online electronic portal, established by the licensee to present supporting documentation and calculations, by teleconferences with FPLs subject matter experts, virtually, and with in-person meetings, as necessary. The audit is scheduled to be conducted from April 14, 2025, through April 18, 2025. Audit meeting agenda and questions will be sent in advance of the audit teleconferences.
7.0 SPECIAL REQUESTS The following conditions associated with the online web-based electronic portal should be maintained while the NRC staff on the audit team who have access to the online portal:
The online electronic portal will be password-protected, and separate passwords will be assigned to each member of the audit team.
The online web-based electronic portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information from the web portal.
Conditions of use of the online electronic portal will be displayed on the login screen and will require acknowledgment by each user.
FPL is expected to provide username and password information directly to the NRC staff audit team, listed above. The NRC project manager will provide FPL the names and contact information if any NRC staff may need to be added to the audit team. All other communications should be coordinated with the NRC project manager. The NRCs project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the electronic portal.
No data accessed by the audit team members will be retained by the NRC following the conclusion of the audit.
8.0 DELIVERABLES The NRC team will develop an audit summary report to convey the results. The report will be placed in ADAMS within 90 days of the completion of the final audit session. The audit information the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket.