ML26040A122
| ML26040A122 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/09/2026 |
| From: | Michele Sampson NRC/NRR/DNRL/NLRP |
| To: | Coffey R Florida Power & Light Co |
| References | |
| Download: ML26040A122 (0) | |
Text
Mr. Robert Coffey Executive Vice President, Nuclear Division, and Chief Nuclear Officer Florida Power & Light Company 700 Universe Boulevard Mail Stop: EX/JB Juno Beach, FL 33408
SUBJECT:
ST. LUCIE PLANT, UNITS 1 AND 2SUPPLEMENT TO REVISION 1 OF THE SAFETY EVALUATION FOR THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW RESULTING FROM THE FOURTH ANNUAL UPDATE
Dear Mr. Coffey:
By letter dated August 3, 2021 (Agencywide Documents Access and Management System 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), June 14, 2023 (ML23165A114), and July 13, 2023 (ML23194A211), Florida Power and Light Company (FPL, the applicant) submitted an application for subsequent license renewal (SLR) of Renewed Facility Operating License Nos. DPR-67 and NPF-16 for St. Lucie Plant, Units 1 and 2 (St. Lucie) to the U.S.
Nuclear Regulatory Commission (NRC). FPL submitted the subsequent license renewal application (SLRA) pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.
The NRC staff determined that the application was complete and acceptable for docketing, as communicated by letter dated September 24, 2021 (ML21246A091), and published in the Federal Register on September 29, 2021 (86 FR 53986). The NRC staff completed its safety review of the St. Lucie SLRA and issued the safety evaluation (SE) in September 2023 (ML23219A003).
By letter dated November 20, 2025, FPL submitted its fourth annual update (ML25324A217) for the St. Lucie SLRA in accordance with 10 CFR 54.21(b). In this update, FPL identified changes that materially affected the content of the St. Lucie SLRA and the corresponding sections of the NRC staffs SE. The NRC staff reviewed the submittal to determine whether the aging management review (AMR) items identified were either not applicable or consistent with the recommendations in NUREG-2191, Revision 1, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, dated July 2025. In addition, the NRC staff prepared new generic note AMR write-ups and updated applicable further evaluation sections, March 9, 2026
aging management program (AMP) sections, and the commitment table. The affected sections of the SE have been revised to reflect the information provided in the fourth annual update, as shown with the change bars in the enclosure.
If you have any questions regarding this matter, please contact the SLR project manager, Mr. Vaughn Thomas, by email to 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:
AMR Items: 3.2.1-72; 3.3.1-137; 3.3.1-139; 3.3.1-140; 3.4.1-62 & 3.4.1-67 New AMR Sections: 3.3.2.3.6 & 3.4.2.3.2 Further Evaluation Section: 3.3.2.2.7 AMP Sections: 3.0.3.1.8 & 3.0.3.3.11 Commitment 18 cc: GovDelivery Signed by Sampson, Michele on 03/09/26
SUBJECT:
ST. LUCIE PLANT, UNITS 1 AND 2 - SUPPLEMENT TO REVISION 1 OF THE SAFETY EVALUATION FOR THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW RESULTING FROM THE FOURTH ANNUAL UPDATE DATED: MARCH 9, 2026 DISTRIBUTION:
PUBLIC RidsNrrDnrl Resource RidsNrrPMStLucie Resource RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsNrrOd Resource VThomas, NRR/DNRL CHobbs, NRR/DNRL LRakovan, NMSS/REFS SKoenick, NMSS/REFS MSampson, NRR/DNRL RPenmetsa, NRR/DNRL EHerrera, NRR/DORL DWrona, NRR/DORL ANaber, OGC MWoods, OGC RSkokowski, OEDO DJohnson, OEDO SBurnell, HQ/OPA DMcIntyre, HQ/OPA LWilkins, OCA DGasperson, RII/OPA JPelchat, RII/FCO JBaptist, RII/DORS SRoberts, RII/DORS SSmith, RII/DORS Email:
Kenneth.Mack2@fpl.com Jerry.Phillabaum@fpl.com ADAMS Accession No.: Pkg: ML26070A144; Letter: ML26040A122
Enclosure Aging Management Review (AMR)
The following table 1 AMR items in the subsequent license renewal application (SLRA) have been reviewed and confirmed to be consistent with the recommendations in NUREG-2191, Revision 1, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR)
Report, dated July 2025. No additional safety evaluation input is required.
3.3.1-139 3.3.1-140 3.4.1-67 Section 3.2 3.2.2.1.1 AMR Results Identified as Not Applicable Table 1 AMR Item No.
SLRA Section 2 SLRA Section 3 Independent Source(s) 3.2.1-72 2.3.2 3.2 UFSAR [updated final safety analysis report]
Section 3.3 SLRA Table 1 AMR Item Not Used Alternative SLRA Table 1 AMR Item Used 3.3.1-137 3.3.1-139 3.3.2.3.6 Intake Cooling Water/Emergency Cooling CanalSummary of Aging Management Evaluation Internally Coated/Lined Carbon Steel Piping and Internally Coated/Lined Gray Cast Iron Valve Bodies Exposed to Raw Water. SLRA table 3.3.2-8 states that flow blockage for internally coated/lined carbon steel piping and internally coated/lined gray cast iron valve bodies exposed to raw water will be managed by the open-cycle cooling water system program. The AMR items cite generic note J, which states that [t]he material for this component is not explicitly listed in NUREG-2191 for this environment and aging effect; but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP. The staff finds the applicants proposal to manage flow blockage acceptable because, as noted in SRP-SLR Report item 3.3.1-37, steel piping and piping components (whether coated or uncoated) exposed to raw water are subject to this aging effect, which can be effectively managed using the open-cycle cooling water system program.
Section 3.4 3.4.2.1.1 AMR Results Identified as Not Applicable Table 1 AMR Item No.
SLRA Section 2 SLRA Section 3 Independent Source(s) 3.4.1-62 2.3.4 3.4 UFSAR 3.4.2.3.2 Auxiliary Feedwater and CondensateSummary of Aging Management Evaluation Internally Coated/Lined Carbon Steel Tanks Exposed to Gas. As amended by letter dated November 20, 2025 (ML25324A217), SLRA table 3.4.2-3 states that for internally coated/lined carbon steel tanks exposed to gas there is no aging effect and no AMP is proposed. The AMR item cites generic note G and plant-specific note 5, which states that [c]arbon steel does not have any aging effects when exposed to a gas environment (nitrogen). Therefore, carbon steel with internal coating/lining exposed to a gas environment (nitrogen) does not have aging effects that are expected to degrade the ability of the component to perform its intended function. The staff reviewed the associated item in the SLRA to confirm that aging effects are not applicable for this component, material, and environment combination. The staff finds the applicants proposal acceptable because, based on its review of the SRP-SLR and GALL-SLR Reports, aging effects are not expected in an inert environment for metallic materials (e.g., carbon steel) or polymeric materials (e.g., coatings).
Further Evaluation 3.3.2.2.7 Loss of Material Due to Recurring Internal Corrosion SLRA section 3.3.2.2.7 (as amended by letter dated November 20, 2025 (ML25324A217)) is associated with SLRA table 3.3-1, item 3.3-1, 127, and addresses loss of material due to recurring internal corrosion in metallic piping components exposed several water environments.
The SLRA states that plant-specific operating experience (OE) showed that carbon steel components exposed to raw water in the intake cooling water system have experienced recurring internal corrosion. The SLRA notes that the open-cycle cooling water system program, which manages the effects of aging for the intake cooling water system, is enhanced to manage loss of material due to recurring internal corrosion.
The staffs review of the enhancements to PSLs open-cycle cooling water system program is documented in SE section 3.0.3.2.11. The staff determined that the program enhancement to adjust the monitoring frequency of locations susceptible to ongoing degradation, based on trending of wall thickness measurements, meets the further evaluation criteria for managing recurring internal corrosion in SRP-SLR section 3.3.2.2.7. Therefore, the staff finds that PSLs proposed approach to manage recurring internal corrosion, using the enhanced open-cycle cooling water system program, is acceptable.
Aging Management Program (AMP) 3.0.3.1.8 Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks As amended by letter dated November 20, 2025 (ML25324A217), SLRA section B.2.3.28 describes the new internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks program as consistent with GALL-SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, as modified by SLR-ISG-2021-02-MECHANICAL (ML20181A434), Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance. The applicant amended this SLRA section by Subsequent License Renewal Application Revision 1 - Supplement 1|letter dated April 7, 2022]] (ML22097A202).
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 of the applicants program to the corresponding program elements of GALL-SLR Report AMP XI.M42, as modified by SLR-ISG-2021-02-MECHANICAL (ML20181A434).
For the detection of aging effects program element, the staff determined the need for additional information related to inspections for buried concrete-lined fire protection piping.
Specifically, the staff noted the following during the review:
GALL-SLR Report AMP XI.M42, as modified by SLR-ISG-2021-02-MECHANICAL (ML20181A434), states opportunistic inspections, in lieu of periodic inspections, are an acceptable alternative for buried internally lined/coated fire water system piping provided certain conditions are met. One of these conditions is that plant-specific OE is acceptable (i.e., no leaks due to age-related degradation of representative [emphasis added by staff] internal coatings/linings used in buried in-scope fire water system components).
SLRA section B.2.3.27, Buried and Underground Piping and Tanks, describes plant--
specific OE where intake cooling water system piping experienced through-wall degradation due to the damage to the cement liner.
Based on the OE noted above, the staff determined the need for additional information with respect to how the condition of concrete-lined piping in the intake cooling water system (where leaks occurred due to degradation of the cement liner) is not representative of the condition of concrete-lined piping in the fire protection system. The applicant provided a supplemental response (ML22097A202), which revised SLRA section B.2.3.28 to state the following:
The fire water system is supplied by the CWSTs [City Water Storage Tanks],
which are supplied by potable water from the Fort Pierce water supply line to the site. Although this is considered a raw water environment, it represents a significantly more benign environment for the aging effects of concern when compared with the other raw water source (brackish water at the intake structure) used at the PSL. Additionally, the flow rate through the fire water system is much lower than that through the intake cooling water system or the circulating water system. Because of the milder environment, lower flow rates, and because plant--specific OE does not show any leaks due to age-related degradation of the internally coated/lined portions of the fire water system, opportunistic inspections, in lieu of periodic inspections, will be performed for the buried concrete lined fire protection piping.
Based on the supplemental response, the staff finds that the OE noted by the staff is not representative of the condition of concrete-lined piping in the fire protection system. Therefore, the staffs concern associated with performing opportunistic inspections for buried concrete-lined fire protection piping is resolved.
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 by Subsequent License Renewal Application Revision 1 - Supplement 1|letter dated April 7, 2022]]), 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 are consistent with the corresponding program elements of GALL-SLR Report AMP XI.M42, as modified by SLR-ISG-2021-02-MECHANICAL (ML20181A434).
Operating Experience. SLRA section B.2.3.28 summarizes OE related to the internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks program.
The staff reviewed OE information in the application 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 and the supplemental information provided by the applicant, the staff finds that the conditions and OE at the plant are bounded by those for which the internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks program was evaluated.
UFSAR Supplement. As amended by letter dated November 20, 2025 (ML25324A217), SLRA appendix A1, section 19.2.2.28 and appendix A2, section 19.2.2.28 provide the UFSAR supplement for internal coatings/linings for in-scope piping, piping components, heat exchangers, 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. The staff also noted the applicant committed to the following: (a) implement the new internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks program no later than 6 months prior to the subsequent period of extended operation for managing the effects of aging for applicable components; (b) begin program inspections 10 years before the subsequent period of extended operation; and (c) complete baseline inspections 6 months prior to the subsequent period of extended operation 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 internal coatings/linings for in-scope piping, piping components, heat exchangers, 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 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 10 CFR 54.21(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 10 CFR 54.21(d).
3.0.3.3.11 Open-Cycle Cooling Water Systems As amended by letter dated November 20, 2025 (ML25324A217), SLRA section B.2.3.11 states that the open-cycle cooling water system program is an existing program with enhancements that will be consistent with the program elements in the GALL-SLR Report AMP XI.M20, Open--Cycle Cooling Water System. The applicant amended this SLRA section by Subsequent License Renewal Application Revision 1 - Supplement 1|letter dated April 07, 2022]] (ML22097A202).
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 AMP XI.M20.
The staff also reviewed the portions of the detection of aging effects, monitoring and trending, corrective actions, and operating experience program elements associated with enhancements to determine whether the program will be adequate to manage the aging effects for which it is credited. The staffs evaluation of these five enhancements is as follows.
Enhancement 1. SLRA section B.2.3.11 includes an enhancement to the detection of aging effects program element, which relates to ensuring that program tests and inspections follow site procedures that include requirements for items such as lighting, distance offset, surface coverage, presence of protective coatings, and cleaning processes. The staff reviewed these enhancements against the corresponding program elements in GALL-SLR Report AMP XI.M20 and finds them acceptable because, when they are implemented, the programs procedures will be consistent with the recommendations in the GALL-SLR Report.
Enhancement 2. SLRA section B.2.3.11 includes an enhancement to the monitoring and trending program element, which relates to ensuring that the primary program document, applicable procedures, and preventive maintenance activities include trending of wall-thickness measurements at locations susceptible to ongoing degradation due to specific aging mechanisms (e.g., MIC). The open-cycle cooling water system AMP will adjust the monitoring frequency based on the trending. The staff reviewed these enhancements against the corresponding program elements in GALL-SLR Report AMP XI.M20 and finds them acceptable because, when they are implemented, the programs procedures will be consistent with the recommendations in the GALL-SLR Report.
Enhancement 3. SLRA section B.2.3.11 includes an enhancement to the corrective actions program element, which relates to ensuring that the primary program document, applicable procedures, and preventive maintenance activities clarify that when components do not meet or are projected to not meet the next inspections minimum wall-thickness requirements, the program includes re-evaluation, repair, or replacement of such components. The staff reviewed this enhancement against the corresponding program element in GALL-SLR Report AMP XI.M20 and finds it acceptable because, when it is implemented, the programs procedures will be consistent with the recommendations in the GALL-SLR Report.
Enhancement 4. SLRA section B.2.3.11 includes an enhancement to the operating experience program element, which relates to ensuring that all above-ground, main-line and strainer-bypass line, safety-related intake cooling water (ICW) piping is replaced with AL6XN stainless-steel piping. During the audit review (ML22188A086) of the operating experience program element, the staff determined the need for the applicant to clarify the scope of the planned ICW piping replacement. Prior to the issuance of an RAI, the applicant provided a supplement (ML22097A202) that specified the scope to include all above-ground, main-line and strainer-bypass line, safety-related ICW piping, which was to be replaced with AL6XN stainless steel piping. Based on the supplemental response that clarified the scope of the planned ICW piping replacement, the staffs concern is resolved. The staff reviewed the enhancement against the corresponding program element in GALL-SLR Report AMP XI.M20 and finds it acceptable because, when implemented, the piping replacement will address an on-going recurring internal and external corrosion issue with above-ground, large-bore, safety-related ICW piping, which is consistent with the recommendations in the GALL-SLR Report.
Enhancement 5. SLRA section B.2.3.11 includes an enhancement to the operating experience program element, which relates to clarifying within the applicable procedures, specifications, and preventive maintenance activities that 100 percent of the internal inspections of the ICW header piping will be supplemented with localized volumetric examinations (ultrasonic examination [UT], radiography, etc.) as applicable for areas where visual inspection alone is not adequate or as needed to determine the extent of degradation. The staff reviewed this enhancement against the corresponding program element in GALL-SLR Report AMP XI.M20 and finds it acceptable because, when it is implemented, the programs procedures will be consistent with the recommendations in the GALL-SLR Report for systems that need to manage recurring internal corrosion.
The staff conducted an audit to verify the applicants claim of consistency with the GALL-SLR Report. Based on a review of the SLRA and amendments, 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.M20. In addition, the staff reviewed the enhancements associated with the detection of aging effects, monitoring and trending, corrective actions, and operating experience program elements and finds that, when implemented, they will make the AMP adequate to manage the applicable aging effects.
Operating Experience. SLRA section B.2.3.11 summarizes OE related to the open-cycle cooling water system AMP. The staff reviewed OE information in the application and during the audit.
As discussed in the audit report (ML22188A086), the staff reviewed search results of the plant OE information 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 beyond that incorporated during the development of the SLRA. Based on the audit and review of the application, the staff finds that the conditions and operating experience at the plant are bounded by those for which the open-cycle cooling water system program was evaluated.
UFSAR Supplement. SLRA appendix A1, section 19.2.2.11 and appendix A2, section 19.2.2.11 provide the UFSAR supplement for the open-cycle cooling water system AMP. 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. The staff also noted that the applicant committed to continue the existing open-cycle cooling water system AMP for managing the effects of aging for the applicable components during the subsequent period of extended operation and to implement the open-cycle cooling water system AMP enhancements no later than 6 months prior to the subsequent period of extended operation 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 open-cycle cooling water system AMP, 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 five enhancements and finds that, when 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 10 CFR 54.21(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 10 CFR 54.21(d).
Table A.1Commitment 18 Item No.
Program/Topic NUREG
-2192 Section Commitment Implementation Schedule Source 18 Fire Protection (19.2.2.15)
XI.M26 Continue the existing PSL Fire Protection AMP, including enhancement to:
a)
Enhance plant procedures to specify that penetration seals will be inspected for indications of increased hardness and loss of strength such as cracking, seal separation from walls and components, separation of layers of material, rupture, and puncture of seals. Inspections will be acceptable if there are no significant indications of cracking and loss of material that could result in the loss of the fire protection capability.
b)
Enhance plant procedures to specify that subliming, cementitious, and silicate materials used in fireproofing and fire barriers will be inspected for loss of material, separation, change in material properties, and cracking/delamination.
Inspections will be acceptable if there are no significant indications of cracking and loss of material that could result in the loss of the fire protection capability.
c)
Enhance plant procedures to specify that any loss of material (e.g., general, pitting, or crevice corrosion) to the fire damper housings is unacceptable.
d)
Enhance plant procedures to require projection of identified degradation to the next scheduled inspection for all monitored fire protection SSCs, where practical.
e)
Enhance plant procedures to require that projections are evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate of degradation.
f)
Enhance plant procedures to specify that:
Holes in fire doors should be filled with steel sheet metal screws or through-bolts.
Steel conduits which have been attached to fire door frames with proper fittings are considered acceptable provided the conduit does not pass completely through the frame.
Flexible steel conduit (with or without water resistant coatings) may be attached to fire door frames for security contacts and latches. They must be attached with steel hardware (sheet metal screws, through bolts, etc.).
No later than 6 months prior to the SPEO, i.e.:
PSL1: 09/01/2035 SLRA Rev. 1 ML21285A110 SLRA Supplement 1 ML22097A202 RAI Response Set 2 ML22192A078 Item No.
Program/Topic NUREG
-2192 Section Commitment Implementation Schedule Source Holes in one surface of fire doors or frames larger than that capable of being filled by sheet-metal screws and not larger than typical conduit penetrations may be covered by a 16-gauge steel plate which overlaps the hole on all sides. The plate should be attached with steel sheet-metal screws or may be welded.