ML25188A245
| ML25188A245 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/02/2025 |
| From: | Natreon Jordan NRC/NRR/DORL/LPL2-2 |
| To: | |
| Shared Package | |
| ML25188A243 | List: |
| References | |
| EPID L-2024-LLA-0162 | |
| Download: ML25188A245 (1) | |
Text
1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ST. LUCIE UNIT 2 - LICENSING BASES CHANGES FOR 24-MONTH FUEL CYCLES FLORIDA POWER & LIGHT COMPANY SAINT LUCIE, UNIT 2 DOCKET NO. 05000389 ISSUE DATE: N/A Regulatory Basis:
10 CFR 50.36, Technical Specifications [TS], defines the content required in TS. Specifically, 10 CFR 50.36(c)(3) requires that the TS include Surveillance Requirements (SRs) relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
Request for Confirmation #1 Follow-up to Audit Question AQ-SCPB-2
Background:
By letter dated November 26, 2024, Florida Power & Light Company (FPL, the licensee) submitted License Amendment Request L-2024-185, Licensing Basis Changes in Support of St.
Lucie Unit 2 Transition to 24-Month Fuel Cycles (ADAMs Accession # ML24331A255 Proprietary ). During the audit, held from April 14 through 21, 2025, based on the approved Audit Plan (ADAMs Accession # ML25091A289), the NRC staff requested further clarification of the following issue:
Issue:
LAR Enclosure 2 (Page 65 of 73) pertaining to 3.4.15 RCS Leakage Detection Instrumentation surveillance SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required reactor cavity sump inlet flow monitor reads, in part: A review of the SR test history identified no functional failures that would have been detected solely by performance of this SR.
During the review of historical performance for SR 3.4.15.3, as reflected in Evaluation PLL-ENG_SEMS-23-006 Rev. 0, Attachment 1-9 List of Work Orders Reviewed for Calibration SRs on the Certrec E-Portal, the NRC staff requested clarification pertaining to the Failure Analysis contained therein. In particular, the staff inquired about the need to clean the weir box and level sensor displacer during the performance of this surveillance in the year 2017, and whether this cleaning activity happens on a fixed frequency. During the audit, the licensee responded that task PMRQ 36689-2 addresses cleaning of the sump weir box and the LS-07-12 displacer on a 1R frequency. The licensee also specified that a similar issue requiring weir box/displacer cleaning was noted in 2023 (AR 2450289). The licensee concluded that since these two cleanings transpired six years apart, that the frequency 1R of task PMRQ 36689-2 is sufficient to act in concert with both the current performance frequency and the proposed decreased performance frequency of SR 3.4.15.3.
The NRC staff requests that the licensee confirm, for occurrences where the frequency of performance of SR 3.4.15.3 is decreased from once per eighteen months to once per twenty-
2 four months to accommodate a 24-month fuel cycle, that the frequency of conducting task PMRQ 36689-2 performance will remain at 1R and be pro-actively managed by the licensee to prevent future operability concerns by requiring performance of task PMRQ 36689-2 each at least once per refueling outage, which is at a significantly greater frequency than once every six years as implied by the data summarized above.
Request for Confirmation #2 Follow-up to Audit Question AQ-SCPB-3
Background:
During the audit, held from April 14 through 21, 2025, based on the approved Audit Plan (ADAMs Accession # ML25091A289),the NRC staff requested further clarification of the following issue(s):
Issue:
LAR Enclosure 2 (Page 56 of 73) pertaining to TS 5.5.2 Primary Coolant Sources Outside Containment reads, in part:
The program shall include the following:
- 1. Preventive maintenance and periodic visual inspection requirements and
- 2. Integrated leak test requirements for each system at a Frequency in accordance with the Surveillance Frequency Control Program.
This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. and A review of the SR test history identified no functional failures that would have been detected solely by performance of this SR.
During the review of TS 5.5.2.b historical performance data as reflected in Evaluation PLL-ENG_SEMS-23-006 Rev. 0, Attachment 1-6 List of Work Orders Reviewed for Non - Calibration SRs, as provided during the audit, the NRC staff requested clarification pertaining to apparent repetitive boric acid leaks on the subject systems. The systems included: Low Pressure Safety Injection; High Pressure Safety Injection; Containment Spray; and Reactor Coolant Sampling.
The NRC staff identified that for the 50-plus line-item comments contained under the column heading Failure Analysis as reflected in Attachment 1-6 for TS 5.5.2.b that no failed surveillances were documented for the four subject systems. Equally significant is the staffs observation that no failed surveillances were attributed to the boric acid leaks delineated in the 15-line items that contained comments under the column labeled Failure Analysis.
However, during the audit, the NRC staff inquired about apparent prima facie repetitive boric acid leakage issues originating from:
the mechanical seal of the Containment Spray Pump CS Pp 2A [Action Request (AR) 2153065] and Valve V07173 (drain valve on "A" containment sump suction piping to "A" train ECCS pumps) [AR 2184068].
During the audit the licensee provided additional information in response to Audit Question No:
AQ-SCPB-3 that clarified that these two apparent repetitive leakage issues were in fact only one
3 singular leakage instance for each bulleted issue above (i.e., One Condition Report for each issue with a multiple work order resolution). Furthermore, the licensee provided information demonstrating that both leakage issues were managed through the Boric Acid Control Program and/or work order completions tracked via a Condition Report. For these subject instances of Failure Analysis, the AR number became the Condition Report number.
The NRC staff requests that the licensee confirm, for occurrences where the frequency of performance of the TS 5.5.2 program requirements for components CS Pp 2A and V07173 is decreased from once per eighteen months to once per twenty-four months to accommodate a 24-month fuel cycle, that past boric acid leakage issues such as documented in Evaluation PLL-ENG_SEMS-23-006 Rev. 0, Attachment 1-6 will still be adequately managed.
Request for Additional Information #1, Request for Revision to Reactor Vessel Surveillance Capsule Removal Schedule, contains revised values for capsule neutron fluence, lead factor, and capsule withdrawal effective full power years (EFPY) for the surveillance capsule at the 277° vessel location.
Appendix H to 10 CFR 50, Reactor Vessel Material Surveillance Program Requirements, describes requirements associated with the capsule withdrawal schedule, including discussion of relevant ASTM E standards indicating an approved fluence methodology must be used. The current licensing basis for St. Lucie, Unit 2, (UFSAR Section 4.3.3.3 Reactor Vessel Fluence Calculation Model) describes the neutron fluence methodology and indicates consistency with Regulatory Guide 1.190 (CALCULATIONAL AND DOSIMETRY METHODS FOR DETERMINING PRESSURE VESSEL NEUTRON FLUENCE) and the use of an "NRC-approved methodology framework."
For the revised neutron fluence values in Enclosure 5, identify the neutron fluence methodology used to determine the values, whether that methodology is NRC-approved, and justification for using the methodology (e.g. addressing any applicable limitations and conditions). If not NRC-approved, provide a technical basis for the methodology used to determine the revised neutron fluence values.