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| | U. S. Nuclear Regulatory Commission APR 3 0 2020 L-2 020-061 10 CFR 50.90 Attn: Document Control Desk Washington D C 20555-0001 RE: St. Lucie Unit 2 Docket No. 50-389 Renewed Facility Operating Licenses NPF-16 Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements |
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| | ==References:== |
| | : 1. Florida Power & Light Company letter, L-2019-091, License Amendment Request to Modify the Reactor Coolant Pump CRCP) Flywheel Inspection Program Requirements, October 9, 2019 (ADAMS Accession No. ML19282D338) |
| | : 2. NRC electronic memorandum, RAls for LAR to Revise Technical Specifications 6.8.4.o, "Reactor Coolant Pump Flywheel Inspection Program", March 31, 2020 In Reference 1, Florida Power & Light Company (FPL) requested an amendment to Renewed Facility Operating License NPF-16 for St. Lucie Nuclear Plant Unit 2. The proposed license amendment modifies the St. Lucie Unit 2 Technical Specifications (TS) by revising the Reactor Coolant Pump Flywheel Inspection Program requirements consistent with the conclusions and limitations specified in NRC safety evaluation (SE) , Acceptance for Referencing of Topical Report SIR-94-080, "Relaxation of Reactor Coolant Pump Flywheel Inspection Requirements", dated May 21 , 1997. |
| | In Reference 2, the NRC requested additional information determined necessary to complete its review. |
| | The enclosure to this letter provides FPL's response to the NRC's request for additional information (RAI). |
| | The RAI response provides supplemental information that clarifies the application, does not expand the scope of the application as originally noticed, and does not alter the conclusion in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92 and there are no significant environmental impacts associated with the changes. |
| | This letter contains no new or revised regulatory commitments. |
| | Should you have any questions regarding this submittal, please contact Mr. Wyatt Gades, St. Lucie Licensing Manager, at (772) 467-7435. |
| | I declare under penalty of perjury that the foregoing is true and correct. |
| | Executed on APR *3 0 2020 Sincerely, Daniel DeBoer Site Director - St. Lucie Nuclear Plant Florida Power & Light Company Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957 |
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| | St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Page 2 of 2 |
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| | ==Enclosure:== |
| | FPL Response to Request for Additional Information cc: USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Plant, Units 1 and 2 USNRC Senior Resident Inspector, St. Lucie Nuclear Plant, Units 1 and 2 |
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| | St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclos ure Page 1 of 4 ENCLOSURE St. Lucie Unit 2 Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements |
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| | St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclos ure Page 2 of 4 In Reference 1, Florida Power & Light Company (FPL) requested an amendment to modify the St. Lucie Unit 2 Technical Specifications (TS) by revising the Reactor Coolant Pump RCP) Flywheel Inspection Program requirements consistent with the conclusions and limitations specified in NRC safety evaluation (SE), Acceptance for Referencing of Topical Report SIR-94-080, "Relaxation of Reactor Coolant Pump Flywheel Inspection Requirements" (Reference 2). In Reference 3, the NRC staff requested additional information (RAI) determined necessary to complete its review, as indicated below. FPL's response follows: |
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| | ===Background=== |
| | By letter dated October 9, 2019 (ADAMS Accession No. ML19282D338), Florida Power & Light Company (FPL, the licensee), submitted to the United States Nuclear Regulatory Commission (NRC) , a license amendment request (LAR) to revise Technical Specification (TS) 6.8.4.o "Reactor Coolant Pump Flywheel Inspection Program" of the St. Lucie Nuclear Plant, Unit 2 (St. Lucie, Unit 2), pursuant to Title 10 of the Code of Federal Regulations (10 CFR) , Part 50, Paragraph 50.90. Specifically, the licensee proposed to modify the St. Lucie, Unit 2 Reactor Coolant Pump (RCP) Flywheel Inspection Program requirements to be consistent with the conclusions and limitations specified in the NRC's safety evaluation (SE) of topical report SIR-94-080, Revision 1 (ADAMS Legacy Accession Nos. 9706230099 and 9706240192). |
| | Regulatory Basis General design criterion (GDC) 4 of Appendix A to 10 CFR 50 states that structures, systems, or components (SSCs) important to safety be designed to accommodate the effects of and be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. GDC 4 further states that SSCs shall be appropriately protected against dynamic effects, which include the effects of missiles, pipe whipping , and discharging fluids , that may result from equipment failures. The RCP flywheel is a large solid metallic disk and is part of the RCP motor to provide rotational inertia when the RCP motors are turned off to ensure slow decrease in reactor coolant flow. If the RCP flywheel fails during normal operation , it has sufficient kinetic energy to produce high-energy missiles that could damage SSCs important to safety in the reactor coolant system. |
| | Structural integrity of the RCP flywheels thus must be maintained in order to meet the design criterion of GDC 4. Therefore, NRC staff (the staff) determined that the following requests for additional information (RAls) pertaining to the structural integrity of St. Lucie, Unit 2 RCP flywheels is needed to complete the review of the LAR. |
| | The staff noted that conclusion (1) in Section 4 of the staff's SE of SIR-94-080, Revision 1 specifies that licensees meeting the first condition stated in the SE should either conduct a volumetric examination through a "qualified in-place [ultrasonic testing (UT)] examination" or surface examination . In the markup of St. Lucie, Unit 2 TS 6.8.4.o in the licensee's LAR, however, the licensee stated that the RCP flywheel be inspected "100% volumetric inspection" but did not state the type of volumetric inspection to be a "qualified in-place UT examination ," as specified in the staff's SE of SIR-94-080, Revision 1. |
| | Request: State the type of volumetric inspection for the St. Lucie Unit 2 RCP flywheels proposed in the LAR. If the stated volumetric inspection is not" a "qualified in-place UT examination, " as specified in the staff's SE of SI R-94-080, Revision 1, justify how the stated volumetric inspection is equivalent to a "qualified in-place UT examination ." |
| | FPL Response: |
| | The term "qualified in place" refers the process of calibrating the search unit on the component at a known location. FPL employs qualified volumetric procedure NDE 5.15, "Ultrasonic Examination of Reactor Coolant Pump Flywheels" for examining the RCP flywheels . The procedure calls for calibration of the complete ultrasonic examination system by placing the search unit transducer on |
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| | St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclos ure Page 3 of 4 the flywheel peripheral edge with the sound beam aimed at the bore hole and maximizing the signal response from a keyway to set the search unit sensitivity level. Any change in search units, ultrasonic instruments, cables, wedges, or Level 111111 personnel is cause for a calibration check. |
| | NOE 5.15 requires peripheral scanning of the flywheels 360 degrees in two directions using a 25-degree longitudinal, 2.25 MHz, 1/2" x 1" transducer with a 40-inch screen distance. |
| | RAI- -2 In Section 3.5 of the enclosure to the submittal, the licensee calculated fracture toughness (Kie) using empirical formulas and stated that the resulting Kie values "are of greater toughness than the lower bound ASME Kie vs. T-RTNoT curve. " The staff noted that this conclusion is inconsistent with the licensee's calculation of Kie in Section 3.4 of the enclosure to the submittal using equation A-4000 of ASME Code, Section XI. This is based on the fact that all the Ki e values using the empirical formulas were less than the ASME Code Kie value. |
| | Request: Explain the inconsistency between the statement in Section 3.5 of the enclosure to the submittal that the Kie using the empirical formulas "are of greater toughness than the lower bound ASME Kie vs. T-RTNOT curve" and the ASME Code Kie calculation in Section 3.4 of the enclosure to the submittal. |
| | FPL Response: |
| | The statement in question is technically accurate but requires clarification. The values obtained by the empirical correlations exceed the ASME XI Appendix A curve at the temperatures used for the correlations (room temperature and 110°F.) It would be inappropriate to compare these values to those from section 3.4, which calculates Kie using the derived RTNOT of-50°F. The result of applying the correlation temperatures to the ASME Curve is summarized by the table below. |
| | Result for PSL Unit 2 (ksiv'in) |
| | Correlation Name Equation CVN at Room CVN at Temp. (-72°F) +110°F Carten and Sailors 15.5 (CVN) 0 *5 139.5 147.0 Roberts and Newton 9.35(CVN) 063 149.0 159.2 ASME XI , Appendix A 33.2 + 20.734 exp[0.02(T - RTNoT)] 69.5 50 While not a direct comparison to the Kie calculated in 3.4, the correlations do result in values that exceed both the 90 ksiv'in at +100°F required by the SIA topical report (Reference 2), and ASME XI Appendix A values for similar temperatures. |
| | Note 1 - Section 3.4 of the LAR reported a Kie of 449 ksiv'in . However, the ASME Kie vs. T-RT NOT curve is truncated above 200 ksiv'in , and 200 ksiv'in is considered the maximum attainable Kie using the ASME XI, Appendix A, curve. |
| | Note 2 -A similar justification was accepted by the NRC for Millstone Nuclear Power Station, Unit 2 (Reference 4), albeit with a higher RTNOT (+40°F versus -50°F for St. Lucie Unit 2) , which correlates to lower toughness. |
| | |
| | St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclosure Page 4 of 4 |
| | |
| | ==References:== |
| | : 1. Florida Power & Light Company letter, L-2019-091 , License Amendment Request to Modify the Reactor Coolant Pump CRCP) Flywheel Inspection Program Requirements, October 9, 2019 (ADAMS Accession No. ML19282D338) |
| | : 2. NRC letter to Director, Nuclear Safety Division , Entergy Operations, Inc., Acceptance for Referencing of Topical Report SIR-94-080, Relaxation of Reactor Coolant Pump Flywheel Inspection Requirements, May 21 , 1997 (ADAMS Legacy Accession Nos. 9706230099 and 9706240192) . |
| | : 3. NRC electronic memorandum, RAls for LAR to Revise Technical Specifications 6.8.4.o, "Reactor Coolant Pump Flywheel Inspection Program", March 31 2020 |
| | : 4. NRC letter to Dominion Nuclear Connecticut, Inc. Millstone Nuclear Power Station , Unit No. 2 - |
| | Issuance of Amendment RE: Reactor Coolant Pump Flywheel Inspection; February 1, 2002 (ADAMS Accession No. ML013370406)}} |
Letter Sequence Response to RAI |
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EPID:L-2019-LLA-0227, License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements (Approved, Closed) |
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Category:Letter type:L
MONTHYEARL-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) L-2024-004, Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) Extension of Inspection Interval for Reactor Pressure Vessel Welds from 10 to 20 Years2024-01-18018 January 2024 Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) Extension of Inspection Interval for Reactor Pressure Vessel Welds from 10 to 20 Years L-2024-002, Withdrawal of Proposed Alternative to American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump2024-01-0808 January 2024 Withdrawal of Proposed Alternative to American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-179, Unusual or Important Environmental Event - 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Aging Management Requests for Additional Information Set 42023-03-27027 March 2023 Subsequent License Renewal Application - Aging Management Requests for Additional Information Set 4 L-2023-028, and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications2023-03-27027 March 2023 and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications L-2023-025, Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-12023-03-15015 March 2023 Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-1 L-2023-029, and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3)2023-03-10010 March 2023 and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3) L-2023-039, Cycle 27 Core Operating Limits Report2023-03-0707 March 2023 Cycle 27 Core Operating Limits Report L-2023-032, 2022 Annual Radioactive Effluent Release Report2023-02-28028 February 2023 2022 Annual Radioactive Effluent Release Report L-2023-038, 2022 Annual Operating Report2023-02-28028 February 2023 2022 Annual Operating Report L-2023-016, Radiological Emergency Plan - Revision 74 Report of Changes to Emergency Plan2023-02-15015 February 2023 Radiological Emergency Plan - Revision 74 Report of Changes to Emergency Plan L-2023-019, Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 20222023-02-15015 February 2023 Annual Summary of Commitment Changes Implemented Without Prior NRC Notification for Calendar Year 2022 L-2023-009, Owner'S Activity Report2023-01-31031 January 2023 Owner'S Activity Report L-2022-188, Unusual or Important Environmental Event - Turtle Mortality2022-12-19019 December 2022 Unusual or Important Environmental Event - Turtle Mortality L-2022-185, Turkey Points, Units 3 & 4; Seabrook Station; and Point Beach, Units 1 and 2 - Supplement to License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22022-12-0909 December 2022 Turkey Points, Units 3 & 4; Seabrook Station; and Point Beach, Units 1 and 2 - Supplement to License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 L-2022-175, Application to Adopt 10 CPR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2022-12-0202 December 2022 Application to Adopt 10 CPR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors L-2022-180, CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2022-11-0909 November 2022 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums L-2022-165, Subsequent License Renewal Application - Aging Management Request for Additional Information (RAI) 4.3.1-1a(second Round) - Class 1 Fatigue Response2022-10-26026 October 2022 Subsequent License Renewal Application - Aging Management Request for Additional Information (RAI) 4.3.1-1a(second Round) - Class 1 Fatigue Response L-2022-160, Station,, Point Beach Units 1 and 2, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22022-10-0404 October 2022 Station,, Point Beach Units 1 and 2, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 2024-01-08
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARL-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, L-2023-162, Response to 50.69 2nd Round of Rals2023-11-21021 November 2023 Response to 50.69 2nd Round of Rals L-2023-118, Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-09-11011 September 2023 Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 L-2023-059, Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 4 Supplemental Response2023-04-21021 April 2023 Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 4 Supplemental Response L-2023-026, Subsequent License Renewal Application - Aging Management Requests for Additional Information Set 42023-03-27027 March 2023 Subsequent License Renewal Application - Aging Management Requests for Additional Information Set 4 ML23013A2032023-01-13013 January 2023 RAI Set 4 Draft Response L-2022-165, Subsequent License Renewal Application - Aging Management Request for Additional Information (RAI) 4.3.1-1a(second Round) - Class 1 Fatigue Response2022-10-26026 October 2022 Subsequent License Renewal Application - Aging Management Request for Additional Information (RAI) 4.3.1-1a(second Round) - Class 1 Fatigue Response L-2022-156, Correction to Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 1a Response2022-09-19019 September 2022 Correction to Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 1a Response L-2022-143, Subsequent License Renewal Application - Aging Management Requests for Additional Information Set 1A Response2022-09-0808 September 2022 Subsequent License Renewal Application - Aging Management Requests for Additional Information Set 1A Response L-2022-115, Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 3 Response and Submittal of Superseded Response for One Set 2 RAI and One Supplement 1 Attachment2022-08-0909 August 2022 Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 3 Response and Submittal of Superseded Response for One Set 2 RAI and One Supplement 1 Attachment L-2022-108, Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 2 Response2022-07-11011 July 2022 Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 2 Response L-2022-075, Subsequent License Renewal Application-Aging Management Requests for Additional Information (RAI) Set 1A Response and Request for Confirmation of Information (RCI) Set 1 Response2022-06-13013 June 2022 Subsequent License Renewal Application-Aging Management Requests for Additional Information (RAI) Set 1A Response and Request for Confirmation of Information (RCI) Set 1 Response L-2022-000, License Amendment Request for the Technical Specifications Conversion to NUREG- 1432 Revision 5 - Request for Supplemental Information (Rsi) Response2022-01-19019 January 2022 License Amendment Request for the Technical Specifications Conversion to NUREG- 1432 Revision 5 - Request for Supplemental Information (Rsi) Response L-2021-105, Response to Request for Additional Information for St. Lucie License Amendment Request to Allow Risk Informed Completion Times (RICT) for the 120-Volt AC Instrument Bus Requirements2021-05-12012 May 2021 Response to Request for Additional Information for St. Lucie License Amendment Request to Allow Risk Informed Completion Times (RICT) for the 120-Volt AC Instrument Bus Requirements L-2021-065, Response to Request for Additional Information. Relief Request Number RR 15, Extension of St. Lucie Unit 2 RPV Welds from 10 to 20 Years2021-04-0101 April 2021 Response to Request for Additional Information. Relief Request Number RR 15, Extension of St. Lucie Unit 2 RPV Welds from 10 to 20 Years L-2020-165, Supplement to Updated Final Response to NRC Generic Letter 2004-022020-12-0404 December 2020 Supplement to Updated Final Response to NRC Generic Letter 2004-02 L-2020-094, Supplemental Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements2020-06-26026 June 2020 Supplemental Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements L-2020-061, Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements2020-04-30030 April 2020 Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements ML20015A0282020-01-14014 January 2020 NMFS to NRC, Concurrence with Interim Response to Requests for Additional Information for St. Lucie Endangered Species Act Section 7 Consultation L-2019-164, Response to Request for Additional Information Regarding License Amendment Request to Relocate the MOV Thermal Overload Protection Bypass Devices Requirements to Licensee Control2019-09-11011 September 2019 Response to Request for Additional Information Regarding License Amendment Request to Relocate the MOV Thermal Overload Protection Bypass Devices Requirements to Licensee Control L-2019-166, Refueling Outage SL2-24 Steam Generator Tube Inspection Report RAI Response2019-08-21021 August 2019 Refueling Outage SL2-24 Steam Generator Tube Inspection Report RAI Response L-2019-153, Exigent Technical Specification Amendment Request Supplemental RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG2019-07-25025 July 2019 Exigent Technical Specification Amendment Request Supplemental RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG L-2019-149, Exigent Technical Specification Amendment Request RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG2019-07-24024 July 2019 Exigent Technical Specification Amendment Request RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG L-2019-118, Response to Request for Additional Information Regarding License Amendment Request to Allow Performance of Selected Emergency Diesel Generator (EDG) Surveillance Requirements (Srs) During Power Operation2019-06-28028 June 2019 Response to Request for Additional Information Regarding License Amendment Request to Allow Performance of Selected Emergency Diesel Generator (EDG) Surveillance Requirements (Srs) During Power Operation L-2019-107, License Amendment Request - Iodine Removal System Elimination2019-05-17017 May 2019 License Amendment Request - Iodine Removal System Elimination L-2019-056, Inservice Inspection Plan RAI Reply, Fifth Ten-Year Interval Unit 1 Relief Request2019-03-0707 March 2019 Inservice Inspection Plan RAI Reply, Fifth Ten-Year Interval Unit 1 Relief Request L-2018-205, Response to Request for Additional Information Regarding License Amendment Request to Reduce the Number of Control Element Assemblies2018-11-15015 November 2018 Response to Request for Additional Information Regarding License Amendment Request to Reduce the Number of Control Element Assemblies L-2018-153, Supplemental Information for License Amendment Request to Reduce the Number of Control Element Assemblies2018-08-17017 August 2018 Supplemental Information for License Amendment Request to Reduce the Number of Control Element Assemblies L-16-001, Units. 3 and 4, Response to Request for Supplemental Information Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools.2018-05-24024 May 2018 Units. 3 and 4, Response to Request for Supplemental Information Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools. L-2018-068, Florida Power and Light Co. - Response to Request for Additional Information Re Decommissioning Funding Plan Updates for Independent Spent Fuel Storage Installations2018-04-0303 April 2018 Florida Power and Light Co. - Response to Request for Additional Information Re Decommissioning Funding Plan Updates for Independent Spent Fuel Storage Installations L-77-291, Attachment a to L-77-291 Response to NRC Questions of May 24, 19772018-03-29029 March 2018 Attachment a to L-77-291 Response to NRC Questions of May 24, 1977 L-2018-040, Response to Request for Additional Information Regarding License Amendment Request to Add New Required Actions for an Inoperable Auxiliary Feedwater Pump Steam Supply2018-02-14014 February 2018 Response to Request for Additional Information Regarding License Amendment Request to Add New Required Actions for an Inoperable Auxiliary Feedwater Pump Steam Supply L-2018-006, Third Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Risk Informed Extended Completion Times - RITSTF Initiative 4b2018-02-0101 February 2018 Third Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Risk Informed Extended Completion Times - RITSTF Initiative 4b L-2017-210, Updated Final Response to NRC Generic Letter 2004-022017-12-20020 December 2017 Updated Final Response to NRC Generic Letter 2004-02 L-2017-216, License Renewal Commitments: Reactor Vessel Internals Aging Management Plan, Clarification of Responses to RAI 1 and RAI 62017-12-19019 December 2017 License Renewal Commitments: Reactor Vessel Internals Aging Management Plan, Clarification of Responses to RAI 1 and RAI 6 L-2017-209, Response to Request for Additional Information Regarding Fifth 10-Year Inservice Testing (IST) Program Interval Relief Request PR-012017-11-30030 November 2017 Response to Request for Additional Information Regarding Fifth 10-Year Inservice Testing (IST) Program Interval Relief Request PR-01 L-2017-159, Response to Request for Additional Information Regarding Inservice Inspection Plan, Fifth Ten-Year Interval Unit 1 Relief Request No. 3, Revision 02017-09-13013 September 2017 Response to Request for Additional Information Regarding Inservice Inspection Plan, Fifth Ten-Year Interval Unit 1 Relief Request No. 3, Revision 0 L-2017-116, Response to Request for Additional Information Regarding License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instrumentation and Add New TS 3.0.52017-07-0303 July 2017 Response to Request for Additional Information Regarding License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instrumentation and Add New TS 3.0.5 L-2016-220, License Amendment Request EDG Day Tank Fuel Volume Change2016-12-0505 December 2016 License Amendment Request EDG Day Tank Fuel Volume Change L-2016-188, Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools, Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)2016-11-0303 November 2016 Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools, Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) L-2016-153, Response to Request for Additional Information Regarding License Amendment Request for Biological Opinion License Changes2016-08-11011 August 2016 Response to Request for Additional Information Regarding License Amendment Request for Biological Opinion License Changes L-2016-135, Second Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B2016-07-22022 July 2016 Second Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B L-2016-143, Response to Request for Additional Information for the Proposed Technical Specification Change to Remove the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank and Relocate to Licensee-Controlled Documents2016-07-15015 July 2016 Response to Request for Additional Information for the Proposed Technical Specification Change to Remove the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank and Relocate to Licensee-Controlled Documents L-2016-114, Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 48.2016-07-0808 July 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 48. L-2016-102, RAI Reply - License Amendment Request, Containment Vacuum Gothic Analyses and Conforming Changes2016-05-0606 May 2016 RAI Reply - License Amendment Request, Containment Vacuum Gothic Analyses and Conforming Changes L-2016-104, RAI Reply - Application for Technical Specification Change Regarding Moderator Temperature Coefficient (Mtc) Surveillance Test Elimination at the End of Cycle2016-05-0606 May 2016 RAI Reply - Application for Technical Specification Change Regarding Moderator Temperature Coefficient (Mtc) Surveillance Test Elimination at the End of Cycle L-2016-096, Inservice Inspection Plan, RAI Reply for Fourth Ten-Year Interval Relief Request No. 10, Revision 02016-04-21021 April 2016 Inservice Inspection Plan, RAI Reply for Fourth Ten-Year Interval Relief Request No. 10, Revision 0 L-2016-084, Response to Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-422, Revision 2, Change in Technical Specifications End States.2016-04-20020 April 2016 Response to Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-422, Revision 2, Change in Technical Specifications End States. L-2016-040, License Renewal Commitments, Reactor Vessel Internals Aging Management Plan, Response to Request for Additional Information2016-02-26026 February 2016 License Renewal Commitments, Reactor Vessel Internals Aging Management Plan, Response to Request for Additional Information 2023-09-11
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U. S. Nuclear Regulatory Commission APR 3 0 2020 L-2 020-061 10 CFR 50.90 Attn: Document Control Desk Washington D C 20555-0001 RE: St. Lucie Unit 2 Docket No. 50-389 Renewed Facility Operating Licenses NPF-16 Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements
References:
- 1. Florida Power & Light Company letter, L-2019-091, License Amendment Request to Modify the Reactor Coolant Pump CRCP) Flywheel Inspection Program Requirements, October 9, 2019 (ADAMS Accession No. ML19282D338)
- 2. NRC electronic memorandum, RAls for LAR to Revise Technical Specifications 6.8.4.o, "Reactor Coolant Pump Flywheel Inspection Program", March 31, 2020 In Reference 1, Florida Power & Light Company (FPL) requested an amendment to Renewed Facility Operating License NPF-16 for St. Lucie Nuclear Plant Unit 2. The proposed license amendment modifies the St. Lucie Unit 2 Technical Specifications (TS) by revising the Reactor Coolant Pump Flywheel Inspection Program requirements consistent with the conclusions and limitations specified in NRC safety evaluation (SE) , Acceptance for Referencing of Topical Report SIR-94-080, "Relaxation of Reactor Coolant Pump Flywheel Inspection Requirements", dated May 21 , 1997.
In Reference 2, the NRC requested additional information determined necessary to complete its review.
The enclosure to this letter provides FPL's response to the NRC's request for additional information (RAI).
The RAI response provides supplemental information that clarifies the application, does not expand the scope of the application as originally noticed, and does not alter the conclusion in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92 and there are no significant environmental impacts associated with the changes.
This letter contains no new or revised regulatory commitments.
Should you have any questions regarding this submittal, please contact Mr. Wyatt Gades, St. Lucie Licensing Manager, at (772) 467-7435.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on APR *3 0 2020 Sincerely, Daniel DeBoer Site Director - St. Lucie Nuclear Plant Florida Power & Light Company Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Page 2 of 2
Enclosure:
FPL Response to Request for Additional Information cc: USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Plant, Units 1 and 2 USNRC Senior Resident Inspector, St. Lucie Nuclear Plant, Units 1 and 2
St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclos ure Page 1 of 4 ENCLOSURE St. Lucie Unit 2 Response to Request for Additional Information Regarding License Amendment Request to Modify the Reactor Coolant Pump (RCP) Flywheel Inspection Program Requirements
St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclos ure Page 2 of 4 In Reference 1, Florida Power & Light Company (FPL) requested an amendment to modify the St. Lucie Unit 2 Technical Specifications (TS) by revising the Reactor Coolant Pump RCP) Flywheel Inspection Program requirements consistent with the conclusions and limitations specified in NRC safety evaluation (SE), Acceptance for Referencing of Topical Report SIR-94-080, "Relaxation of Reactor Coolant Pump Flywheel Inspection Requirements" (Reference 2). In Reference 3, the NRC staff requested additional information (RAI) determined necessary to complete its review, as indicated below. FPL's response follows:
Background
By letter dated October 9, 2019 (ADAMS Accession No. ML19282D338), Florida Power & Light Company (FPL, the licensee), submitted to the United States Nuclear Regulatory Commission (NRC) , a license amendment request (LAR) to revise Technical Specification (TS) 6.8.4.o "Reactor Coolant Pump Flywheel Inspection Program" of the St. Lucie Nuclear Plant, Unit 2 (St. Lucie, Unit 2), pursuant to Title 10 of the Code of Federal Regulations (10 CFR) , Part 50, Paragraph 50.90. Specifically, the licensee proposed to modify the St. Lucie, Unit 2 Reactor Coolant Pump (RCP) Flywheel Inspection Program requirements to be consistent with the conclusions and limitations specified in the NRC's safety evaluation (SE) of topical report SIR-94-080, Revision 1 (ADAMS Legacy Accession Nos. 9706230099 and 9706240192).
Regulatory Basis General design criterion (GDC) 4 of Appendix A to 10 CFR 50 states that structures, systems, or components (SSCs) important to safety be designed to accommodate the effects of and be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. GDC 4 further states that SSCs shall be appropriately protected against dynamic effects, which include the effects of missiles, pipe whipping , and discharging fluids , that may result from equipment failures. The RCP flywheel is a large solid metallic disk and is part of the RCP motor to provide rotational inertia when the RCP motors are turned off to ensure slow decrease in reactor coolant flow. If the RCP flywheel fails during normal operation , it has sufficient kinetic energy to produce high-energy missiles that could damage SSCs important to safety in the reactor coolant system.
Structural integrity of the RCP flywheels thus must be maintained in order to meet the design criterion of GDC 4. Therefore, NRC staff (the staff) determined that the following requests for additional information (RAls) pertaining to the structural integrity of St. Lucie, Unit 2 RCP flywheels is needed to complete the review of the LAR.
The staff noted that conclusion (1) in Section 4 of the staff's SE of SIR-94-080, Revision 1 specifies that licensees meeting the first condition stated in the SE should either conduct a volumetric examination through a "qualified in-place [ultrasonic testing (UT)] examination" or surface examination . In the markup of St. Lucie, Unit 2 TS 6.8.4.o in the licensee's LAR, however, the licensee stated that the RCP flywheel be inspected "100% volumetric inspection" but did not state the type of volumetric inspection to be a "qualified in-place UT examination ," as specified in the staff's SE of SIR-94-080, Revision 1.
Request: State the type of volumetric inspection for the St. Lucie Unit 2 RCP flywheels proposed in the LAR. If the stated volumetric inspection is not" a "qualified in-place UT examination, " as specified in the staff's SE of SI R-94-080, Revision 1, justify how the stated volumetric inspection is equivalent to a "qualified in-place UT examination ."
FPL Response:
The term "qualified in place" refers the process of calibrating the search unit on the component at a known location. FPL employs qualified volumetric procedure NDE 5.15, "Ultrasonic Examination of Reactor Coolant Pump Flywheels" for examining the RCP flywheels . The procedure calls for calibration of the complete ultrasonic examination system by placing the search unit transducer on
St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclos ure Page 3 of 4 the flywheel peripheral edge with the sound beam aimed at the bore hole and maximizing the signal response from a keyway to set the search unit sensitivity level. Any change in search units, ultrasonic instruments, cables, wedges, or Level 111111 personnel is cause for a calibration check.
NOE 5.15 requires peripheral scanning of the flywheels 360 degrees in two directions using a 25-degree longitudinal, 2.25 MHz, 1/2" x 1" transducer with a 40-inch screen distance.
RAI- -2 In Section 3.5 of the enclosure to the submittal, the licensee calculated fracture toughness (Kie) using empirical formulas and stated that the resulting Kie values "are of greater toughness than the lower bound ASME Kie vs. T-RTNoT curve. " The staff noted that this conclusion is inconsistent with the licensee's calculation of Kie in Section 3.4 of the enclosure to the submittal using equation A-4000 of ASME Code,Section XI. This is based on the fact that all the Ki e values using the empirical formulas were less than the ASME Code Kie value.
Request: Explain the inconsistency between the statement in Section 3.5 of the enclosure to the submittal that the Kie using the empirical formulas "are of greater toughness than the lower bound ASME Kie vs. T-RTNOT curve" and the ASME Code Kie calculation in Section 3.4 of the enclosure to the submittal.
FPL Response:
The statement in question is technically accurate but requires clarification. The values obtained by the empirical correlations exceed the ASME XI Appendix A curve at the temperatures used for the correlations (room temperature and 110°F.) It would be inappropriate to compare these values to those from section 3.4, which calculates Kie using the derived RTNOT of-50°F. The result of applying the correlation temperatures to the ASME Curve is summarized by the table below.
Result for PSL Unit 2 (ksiv'in)
Correlation Name Equation CVN at Room CVN at Temp. (-72°F) +110°F Carten and Sailors 15.5 (CVN) 0 *5 139.5 147.0 Roberts and Newton 9.35(CVN) 063 149.0 159.2 ASME XI , Appendix A 33.2 + 20.734 exp[0.02(T - RTNoT)] 69.5 50 While not a direct comparison to the Kie calculated in 3.4, the correlations do result in values that exceed both the 90 ksiv'in at +100°F required by the SIA topical report (Reference 2), and ASME XI Appendix A values for similar temperatures.
Note 1 - Section 3.4 of the LAR reported a Kie of 449 ksiv'in . However, the ASME Kie vs. T-RT NOT curve is truncated above 200 ksiv'in , and 200 ksiv'in is considered the maximum attainable Kie using the ASME XI, Appendix A, curve.
Note 2 -A similar justification was accepted by the NRC for Millstone Nuclear Power Station, Unit 2 (Reference 4), albeit with a higher RTNOT (+40°F versus -50°F for St. Lucie Unit 2) , which correlates to lower toughness.
St. Lucie Unit 2 L-2020-061 Docket No. 50-389 Enclosure Page 4 of 4
References:
- 1. Florida Power & Light Company letter, L-2019-091 , License Amendment Request to Modify the Reactor Coolant Pump CRCP) Flywheel Inspection Program Requirements, October 9, 2019 (ADAMS Accession No. ML19282D338)
- 2. NRC letter to Director, Nuclear Safety Division , Entergy Operations, Inc., Acceptance for Referencing of Topical Report SIR-94-080, Relaxation of Reactor Coolant Pump Flywheel Inspection Requirements, May 21 , 1997 (ADAMS Legacy Accession Nos. 9706230099 and 9706240192) .
- 3. NRC electronic memorandum, RAls for LAR to Revise Technical Specifications 6.8.4.o, "Reactor Coolant Pump Flywheel Inspection Program", March 31 2020
- 4. NRC letter to Dominion Nuclear Connecticut, Inc. Millstone Nuclear Power Station , Unit No. 2 -
Issuance of Amendment RE: Reactor Coolant Pump Flywheel Inspection; February 1, 2002 (ADAMS Accession No. ML013370406)