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{{#Wiki_filter:St. Lucie SLRA: Breakout Questions SLRA Section 4.3.3, Environmentally-Assisted Fatigue TRP: 143.3
{{#Wiki_filter:Page 1 of 7 St. Lucie SLRA: Breakout Questions SLRA Section 4.3.3, Environmentally-Assisted Fatigue TRP: 143.3 Note: Breakout Questions are provided to the applicant and will be incorporated into the publicly-available audit report.
Technical Reviewer Seung Min 12/7/2021 Technical Branch Chief Matt Mitchell 12/21/2021 Breakout Session Date/Time To be filled in by PM Applicant Staff NRC staff To be filled out by PM during breakout Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)
Discussion Question / Request Outcome of Discussion 1
4.3.3 4.3-21 SLRA Section 4.3.3 addresses the environmentally-assisted fatigue (EAF) analysis for the reactor coolant system.
As part of the EAF analysis, Tables 3-1 and 3-2 of Westinghouse LTR-SDA-II 31-NP, Revision 2 report provide the leading EAF locations (also called sentinel locations) for the equipment components and piping components, respectively.
In comparison, NUREG/CR-6260 identifies the charging system nozzle location as one of the EAF leading locations for Combustion-Engineering-designed plants. However, Tables 3-1
: 1. Provide justification for not identifying the charging system nozzle in the sentinel location list of LTR-SDA-II-20-31-NP, Revision 2 even though the component is identified as a leading EAF location for Combustion Engineering designed plants in NUREG-6260. If the charging system nozzle is bounded by another location in terms of environmental cumulative usage factor (CUFen),


Note: Breakout Questions are provided to the applicant and will be incorporated into the publicly-available audit report.
Page 2 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)
Discussion Question / Request Outcome of Discussion and 3-2 of Westinghouse LTR-SDA-II 31-NP, Revision 2 does not clearly discuss the EAF analysis results for the charging system nozzle.
identify the bounding location and provide the environmental fatigue correction factor (Fen) and CUFen values of the bounding location and charging system nozzle location to demonstrate the bounding nature of the other leading location.
2 4.3.3 4.3-21 SLRA Section 4.3.3 addresses the environmentally-assisted fatigue (EAF) analysis for the reactor coolant system.
In addition, Westinghouse LTR-SDA-II-20-31-NP, Revision 2 describes the applicants approach for determining the EAF leading locations.
The SLRA does not clearly address how the determination of the leading EAF locations evaluates the piping systems or zones that are exposed to different thermal and pressure transients.
: 1. Clarify how the applicants determination of the leading EAF locations evaluates the piping systems or zones that are exposed to different thermal and pressure transients. As part of the response, clarify whether the leading EAF locations are determined based on the environmental cumulative usage factors in each piping system or zone that is exposed to essentially the same thermal and pressure transients.  


Technical Reviewer Seung Min 12/ 7 /2021 Technical Branch Chief Matt Mitchell 12/21/ 2021 Breakout Session Date/Time To be filled in by PM
Page 3 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)
 
Discussion Question / Request Outcome of Discussion 3
Applicant Staff NRC staff To be filled out by PM during breakout
4.3.3 4.3-21 The following BWXT report discusses the environmentally-assisted fatigue (EAF) analysis for St. Lucie Unit 1 replacement steam generators (
 
Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed)
 
1 4.3.3 4.3-21 SLRA Section 4.3.3 addresses the 1. Provide justification for not environmentally-assisted fatigue (EAF) identifying the charging analysis for the reactor coolant system. system nozzle in the As part of the EAF analysis, Tables 3-1 sentinel location list of LTR -
and 3-2 of Westinghouse LTR -SDA-II-20-SDA-II 31-NP, Revision 31-NP, Revision 2 report provide the 2 even though the leading EAF locations (also called component is identified as a sentinel locations) for the equipment leading EAF location for components and piping components, Combustion Engineering respectively. designed plants in NUREG-In comparison, NUREG/CR -6260 6260. If the charging identifies the charging system nozzle system nozzle is bounded location as one of the EAF leading by another location in terms locations for Combustion-Engineering-of environmental cumulative designed plants. However, Tables 3-1 usage factor (CUFen),
 
Page 1 of 7
 
Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed) and 3-2 of Westinghouse LTR-SDA-II identify the bounding 31-NP, Revision 2 does not clearly location and provide the discuss the EAF analysis results for the environmental fatigue charging system nozzle. correction factor (Fen) and CUFen values of the bounding location and charging system nozzle location to demonstrate the bounding nature of the other leading location.
 
2 4.3.3 4.3-21 SLRA Section 4.3.3 addresses the 1. Clarify how the applicants environmentally-assisted fatigue (EAF) determination of the analysis for the reactor coolant system. leading EAF locations In addition, Westinghouse LTR-SDA-II-evaluates the piping 20- 31-NP, Revision 2 describes the systems or zones that are applicants approach for determining the exposed to different EAF leading locations. thermal and pressure The SLRA does not clearly address how transients. As part of the the determination of the leading EAF response, clarify whether locations evaluates the piping systems or the leading EAF locations zones that are exposed to different are determined based on thermal and pressure transients. the environmental cumulative usage factors in each piping system or zone that is exposed to essentially the same thermal and pressure transients.
 
Page 2 of 7
 
Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed) 3 4.3.3 4.3-21 The following BWXT report discusses the 1. Provide justification for environmentally-assisted fatigue (EAF) excluding the plant analysis for St. Lucie Unit 1 replacement loading/unloading, 10 steam generators (


==Reference:==
==Reference:==
BWXT percent step load Report MSLEF-SR-01-NP, Revision 0, St. increase/decrease, and Lucie Unit 1 Replacement Steam normal plant vibration Generator Environmentally Assisted transients from fatigue Fatigue Report). Table 2 of the BWXT monitoring even though report lists the design transients analyzed these transients and in the EAF analysis. associated cycles are used SLRA Section 4.3.1 and Table 4.3.1-2 in the EAF analysis for Unit indicate that some of the transients, 2 steam generators. As which are used for the CUFen calculations part of the response, in the BWXT report, will not be monitored explain how the applicant in the Fatigue Monitoring Program for can ensure that the actual subsequent period of extended operation. cycles of these transients The transients, which the applicant do not exceed the cycles proposed not to monitor, are the analyzed in the CUFen following: (1) plant loading/unloading calculations of the BWXT transient; (2) 10 percent step load report.
BWXT Report MSLEF-SR-01-NP, Revision 0, St.
increase/decrease transient; and (3) normal plant vibration transient.
Lucie Unit 1 Replacement Steam Generator Environmentally Assisted Fatigue Report). Table 2 of the BWXT report lists the design transients analyzed in the EAF analysis.
SLRA Section 4.3.1 and Table 4.3.1-2 indicate that some of the transients, which are used for the CUFen calculations in the BWXT report, will not be monitored in the Fatigue Monitoring Program for subsequent period of extended operation.
The transients, which the applicant proposed not to monitor, are the following: (1) plant loading/unloading transient; (2) 10 percent step load increase/decrease transient; and (3) normal plant vibration transient.
The analyzed cycles of the plant loading/unloading, 10 percent step load increase/decrease, and normal plant vibration transients in the EAF analysis of the BWXT report are 2077, 2000 and 1000000 cycles, respectively. The staff found a need to confirm the adequacy of excluding these transients from fatigue monitoring.
The analyzed cycles of the plant loading/unloading, 10 percent step load increase/decrease, and normal plant vibration transients in the EAF analysis of the BWXT report are 2077, 2000 and 1000000 cycles, respectively. The staff found a need to confirm the adequacy of excluding these transients from fatigue monitoring.
: 1. Provide justification for excluding the plant loading/unloading, 10 percent step load increase/decrease, and normal plant vibration transients from fatigue monitoring even though these transients and associated cycles are used in the EAF analysis for Unit 2 steam generators. As part of the response, explain how the applicant can ensure that the actual cycles of these transients do not exceed the cycles analyzed in the CUFen calculations of the BWXT report.


Page 3 of 7
Page 4 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)
 
Discussion Question / Request Outcome of Discussion 4
Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed)
4.3.3 4.3-21 The following BWXT report discusses the environmentally-assisted fatigue (EAF) analysis for the St. Lucie Unit 1 replacement steam generators
 
4 4.3.3 4.3-21 The following BWXT report discusses the 1. Explain why transient pair environmentally-assisted fatigue (EAF) number 4 involves a analysis for the St. Lucie Unit 1 significantly greater Fen replacement steam generators value compared to the
(
(


==Reference:==
==Reference:==
BWXT Report MSLEF-SR-other transient pairs. As 01-NP, Revision 0, St. Lucie Unit 1 part of the response, Replacement Steam Generator compare the temperature, Environmentally Assisted Fatigue strain rate, coolants Report). Table 5 of the BWXT report dissolve oxygen and steel summarizes the EAF analysis results for sulfur content values used steam generator tubesheet solid rim near in the Fen calculations the tubesheet dome. The tubesheet solid between transient pair 4 rim is fabricated of low alloy steel. and the other transient Table 5 of the BWXT report also indicates pairs.
BWXT Report MSLEF-SR-01-NP, Revision 0, St. Lucie Unit 1 Replacement Steam Generator Environmentally Assisted Fatigue Report). Table 5 of the BWXT report summarizes the EAF analysis results for steam generator tubesheet solid rim near the tubesheet dome. The tubesheet solid rim is fabricated of low alloy steel.
that the environmental fatigue correction factor (Fen) for transient pair number 4 is 2. Clarify the following items:
Table 5 of the BWXT report also indicates that the environmental fatigue correction factor (Fen) for transient pair number 4 is greater than the Fen values for the other transient pairs by a factor of 6.7 approximately. The staff found a need to clarify why transient pair number 4 involves a significantly greater Fen value compared to the other transient pairs.
greater than the Fen values for the other (1) which cycles are used transient pairs by a factor of 6.7 in the Fen calculations approximately. The staff found a need to between the design cycles clarify why transient pair number 4 and 80- year allowable involves a significantly greater F en value cycles listed in Table 5 of compared to the other transient pairs. the BWXT report; and (2)
In addition, Table 5 of the BWXT report lists both the design transient cycles and the 80-year allowable cycles. The staff needs to clarify the following items: (1) which cycles are used in the environmental cumulative usage factor (Fen) calculations between the design cycles and the allowable cycles for the transient pairs; and (2) whether the allowable cycles are based on the
In addition, Table 5 of the BWXT report whether the allowable lists both the design transient cycles and cycles for the transient the 80-year allowable cycles. The staff pairs in Table 5 of the needs to clarify the following items: (1) BWXT report are based on which cycles are used in the the acceptable 80-year environmental cumulative usage factor projected cycles of the (Fen) calculations between the design transients described in cycles and the allowable cycles for the Table 2 of the BWXT transient pairs; and (2) whether the report.
: 1. Explain why transient pair number 4 involves a significantly greater Fen value compared to the other transient pairs. As part of the response, compare the temperature, strain rate, coolants dissolve oxygen and steel sulfur content values used in the Fen calculations between transient pair 4 and the other transient pairs.
allowable cycles are based on the
: 2. Clarify the following items:
 
(1) which cycles are used in the Fen calculations between the design cycles and 80-year allowable cycles listed in Table 5 of the BWXT report; and (2) whether the allowable cycles for the transient pairs in Table 5 of the BWXT report are based on the acceptable 80-year projected cycles of the transients described in Table 2 of the BWXT report.  
Page 4 of 7
 
Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed) acceptable 80-year projected cycles of the transients described in Table 2 of the BWXT report.


5 4.3.3 4.3-21 The Framatome 86 -9329644- 001 report 1. Provide justification for summarizes the environmentally-assisted excluding the plant fatigue (EAF) analysis for St. Lucie Unit 2 loading/unloading, 10 replacement steam generators, Unit 1 and percent step load 2 replacement reactor vessel closure increase/decrease, and heads, Unit 2 pressurizer repairs, Unit 2 cold feedwater following weld overlays and Unit 2 auxiliary spray hot standby transients line reducer (
Page 5 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)
Discussion Question / Request Outcome of Discussion acceptable 80-year projected cycles of the transients described in Table 2 of the BWXT report.
5 4.3.3 4.3-21 The Framatome 86-9329644-001 report summarizes the environmentally-assisted fatigue (EAF) analysis for St. Lucie Unit 2 replacement steam generators, Unit 1 and 2 replacement reactor vessel closure heads, Unit 2 pressurizer repairs, Unit 2 weld overlays and Unit 2 auxiliary spray line reducer (


==Reference:==
==Reference:==
Framatome from fatigue monitoring Document Number 86-9329644- 001, St. even though these Lucie SLR CUFen Evaluations Summary, transients and associated July 15, 2021). reduced cycles are used in Table 5-2 of the Framatome report the EAF analysis of the specifies the reduced cycles of the Framatome report.
Framatome Document Number 86-9329644-001, St.
transients that are used in the environmental cumulative usage factor 2. Clarify whether the (CUFen) calculations, as reduced from the primary coolant pump design cycles. Some of these transients, starting/stopping transient which involve limited ( reduced) cyclesof St. Lucie Unit 2 will be compared to design cycles, will not be monitored in the Fatigue monitored in the Fatigue Monitoring Monitoring program. If not, program, as indicated in SLRA Section provide justification for 4.3.1. excluding the transient The transients, which are used for the from fatigue monitoring.
Lucie SLR CUFen Evaluations Summary, July 15, 2021).
CUFen calculations in the Framatome report and will not be monitored in the 3. Clarify whether the spray Fatigue Monitoring program, are the nozzle, main spray following: (1) plant loading/unloading initiation, auxiliary spray transient; (2) 10 percent step load at power 1, auxiliary increase/decrease transient; and (3)
Table 5-2 of the Framatome report specifies the reduced cycles of the transients that are used in the environmental cumulative usage factor (CUFen) calculations, as reduced from the design cycles. Some of these transients, which involve limited (reduced) cycles compared to design cycles, will not be monitored in the Fatigue Monitoring program, as indicated in SLRA Section 4.3.1.
 
The transients, which are used for the CUFen calculations in the Framatome report and will not be monitored in the Fatigue Monitoring program, are the following: (1) plant loading/unloading transient; (2) 10 percent step load increase/decrease transient; and (3)
Page 5 of 7
: 1. Provide justification for excluding the plant loading/unloading, 10 percent step load increase/decrease, and cold feedwater following hot standby transients from fatigue monitoring even though these transients and associated reduced cycles are used in the EAF analysis of the Framatome report.
 
: 2. Clarify whether the primary coolant pump starting/stopping transient of St. Lucie Unit 2 will be monitored in the Fatigue Monitoring program. If not, provide justification for excluding the transient from fatigue monitoring.
Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed) cold feedwater following hot standby spray at power 2, and transient. Given that these transients and main spray term in their reduced cycles are used for the cooldown transients will CUFen calculations in the Framatome be monitored in the report, the staff found a need to confirm Fatigue Monitoring the adequacy of excluding these program to ensure that the transients form fatigue monitoring. actual transient cycles do The staff also noted that the primary not exceed the cycles coolant pump starting/stopping transient projected and analyzed in (also designated as the DP transient) is the EAF analysis o f the used in the EAF analysis for the Unit 2 Framatome report. If not, steam generator tube-to-tubesheet weld. provide justification for However, SLRA Section 4.3.1 and excluding these transients Framatome report do not clearly address from fatigue monitoring.
: 3. Clarify whether the spray nozzle, main spray initiation, auxiliary spray at power 1, auxiliary  
whether the pump transient for St. Lucie Unit 2 will be monitored in the Fatigue Monitoring program.
In addition, SLRA Section 4.3.1 and Framatome report Tables 5-2 and 5-3 (addressing pressurizer spray nozzle transients) do not clearly address whether the following transients related to Unit 2 pressurizers, which involve reduced cycles in the CUFen calculations, will be monitored in the Fatigue Monitoring program: (1) spray nozzle transient ( also called the spray nozzle transient 17A/B/C); (2) main spray initiation transient; (3) auxiliary spray at power 1 and auxiliary spray at power 2 transients; and (4) main spray term in cooldown transient.
 
Page 6 of 7
 
Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed)


6
Page 6 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)
Discussion Question / Request Outcome of Discussion cold feedwater following hot standby transient. Given that these transients and their reduced cycles are used for the CUFen calculations in the Framatome report, the staff found a need to confirm the adequacy of excluding these transients form fatigue monitoring.
The staff also noted that the primary coolant pump starting/stopping transient (also designated as the DP transient) is used in the EAF analysis for the Unit 2 steam generator tube-to-tubesheet weld.
However, SLRA Section 4.3.1 and Framatome report do not clearly address whether the pump transient for St. Lucie Unit 2 will be monitored in the Fatigue Monitoring program.
In addition, SLRA Section 4.3.1 and Framatome report Tables 5-2 and 5-3 (addressing pressurizer spray nozzle transients) do not clearly address whether the following transients related to Unit 2 pressurizers, which involve reduced cycles in the CUFen calculations, will be monitored in the Fatigue Monitoring program: (1) spray nozzle transient (also called the spray nozzle transient 17A/B/C); (2) main spray initiation transient; (3) auxiliary spray at power 1 and auxiliary spray at power 2 transients; and (4) main spray term in cooldown transient.
spray at power 2, and main spray term in cooldown transients will be monitored in the Fatigue Monitoring program to ensure that the actual transient cycles do not exceed the cycles projected and analyzed in the EAF analysis of the Framatome report. If not, provide justification for excluding these transients from fatigue monitoring.


Page 7 of 7}}
Page 7 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)
Discussion Question / Request Outcome of Discussion 6}}

Latest revision as of 19:11, 27 November 2024

Trp 143.3 St Lucie SLRA - Breakout Questions EAF
ML22013A304
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 12/21/2021
From:
Office of Nuclear Reactor Regulation
To:
Rodriguez-Luccioni H
References
EPID L-2021-SLR-0002, L-2021-SLR-0002
Download: ML22013A304 (7)


Text

Page 1 of 7 St. Lucie SLRA: Breakout Questions SLRA Section 4.3.3, Environmentally-Assisted Fatigue TRP: 143.3 Note: Breakout Questions are provided to the applicant and will be incorporated into the publicly-available audit report.

Technical Reviewer Seung Min 12/7/2021 Technical Branch Chief Matt Mitchell 12/21/2021 Breakout Session Date/Time To be filled in by PM Applicant Staff NRC staff To be filled out by PM during breakout Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)

Discussion Question / Request Outcome of Discussion 1

4.3.3 4.3-21 SLRA Section 4.3.3 addresses the environmentally-assisted fatigue (EAF) analysis for the reactor coolant system.

As part of the EAF analysis, Tables 3-1 and 3-2 of Westinghouse LTR-SDA-II 31-NP, Revision 2 report provide the leading EAF locations (also called sentinel locations) for the equipment components and piping components, respectively.

In comparison, NUREG/CR-6260 identifies the charging system nozzle location as one of the EAF leading locations for Combustion-Engineering-designed plants. However, Tables 3-1

1. Provide justification for not identifying the charging system nozzle in the sentinel location list of LTR-SDA-II-20-31-NP, Revision 2 even though the component is identified as a leading EAF location for Combustion Engineering designed plants in NUREG-6260. If the charging system nozzle is bounded by another location in terms of environmental cumulative usage factor (CUFen),

Page 2 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)

Discussion Question / Request Outcome of Discussion and 3-2 of Westinghouse LTR-SDA-II 31-NP, Revision 2 does not clearly discuss the EAF analysis results for the charging system nozzle.

identify the bounding location and provide the environmental fatigue correction factor (Fen) and CUFen values of the bounding location and charging system nozzle location to demonstrate the bounding nature of the other leading location.

2 4.3.3 4.3-21 SLRA Section 4.3.3 addresses the environmentally-assisted fatigue (EAF) analysis for the reactor coolant system.

In addition, Westinghouse LTR-SDA-II-20-31-NP, Revision 2 describes the applicants approach for determining the EAF leading locations.

The SLRA does not clearly address how the determination of the leading EAF locations evaluates the piping systems or zones that are exposed to different thermal and pressure transients.

1. Clarify how the applicants determination of the leading EAF locations evaluates the piping systems or zones that are exposed to different thermal and pressure transients. As part of the response, clarify whether the leading EAF locations are determined based on the environmental cumulative usage factors in each piping system or zone that is exposed to essentially the same thermal and pressure transients.

Page 3 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)

Discussion Question / Request Outcome of Discussion 3

4.3.3 4.3-21 The following BWXT report discusses the environmentally-assisted fatigue (EAF) analysis for St. Lucie Unit 1 replacement steam generators (

Reference:

BWXT Report MSLEF-SR-01-NP, Revision 0, St.

Lucie Unit 1 Replacement Steam Generator Environmentally Assisted Fatigue Report). Table 2 of the BWXT report lists the design transients analyzed in the EAF analysis.

SLRA Section 4.3.1 and Table 4.3.1-2 indicate that some of the transients, which are used for the CUFen calculations in the BWXT report, will not be monitored in the Fatigue Monitoring Program for subsequent period of extended operation.

The transients, which the applicant proposed not to monitor, are the following: (1) plant loading/unloading transient; (2) 10 percent step load increase/decrease transient; and (3) normal plant vibration transient.

The analyzed cycles of the plant loading/unloading, 10 percent step load increase/decrease, and normal plant vibration transients in the EAF analysis of the BWXT report are 2077, 2000 and 1000000 cycles, respectively. The staff found a need to confirm the adequacy of excluding these transients from fatigue monitoring.

1. Provide justification for excluding the plant loading/unloading, 10 percent step load increase/decrease, and normal plant vibration transients from fatigue monitoring even though these transients and associated cycles are used in the EAF analysis for Unit 2 steam generators. As part of the response, explain how the applicant can ensure that the actual cycles of these transients do not exceed the cycles analyzed in the CUFen calculations of the BWXT report.

Page 4 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)

Discussion Question / Request Outcome of Discussion 4

4.3.3 4.3-21 The following BWXT report discusses the environmentally-assisted fatigue (EAF) analysis for the St. Lucie Unit 1 replacement steam generators

(

Reference:

BWXT Report MSLEF-SR-01-NP, Revision 0, St. Lucie Unit 1 Replacement Steam Generator Environmentally Assisted Fatigue Report). Table 5 of the BWXT report summarizes the EAF analysis results for steam generator tubesheet solid rim near the tubesheet dome. The tubesheet solid rim is fabricated of low alloy steel.

Table 5 of the BWXT report also indicates that the environmental fatigue correction factor (Fen) for transient pair number 4 is greater than the Fen values for the other transient pairs by a factor of 6.7 approximately. The staff found a need to clarify why transient pair number 4 involves a significantly greater Fen value compared to the other transient pairs.

In addition, Table 5 of the BWXT report lists both the design transient cycles and the 80-year allowable cycles. The staff needs to clarify the following items: (1) which cycles are used in the environmental cumulative usage factor (Fen) calculations between the design cycles and the allowable cycles for the transient pairs; and (2) whether the allowable cycles are based on the

1. Explain why transient pair number 4 involves a significantly greater Fen value compared to the other transient pairs. As part of the response, compare the temperature, strain rate, coolants dissolve oxygen and steel sulfur content values used in the Fen calculations between transient pair 4 and the other transient pairs.
2. Clarify the following items:

(1) which cycles are used in the Fen calculations between the design cycles and 80-year allowable cycles listed in Table 5 of the BWXT report; and (2) whether the allowable cycles for the transient pairs in Table 5 of the BWXT report are based on the acceptable 80-year projected cycles of the transients described in Table 2 of the BWXT report.

Page 5 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)

Discussion Question / Request Outcome of Discussion acceptable 80-year projected cycles of the transients described in Table 2 of the BWXT report.

5 4.3.3 4.3-21 The Framatome 86-9329644-001 report summarizes the environmentally-assisted fatigue (EAF) analysis for St. Lucie Unit 2 replacement steam generators, Unit 1 and 2 replacement reactor vessel closure heads, Unit 2 pressurizer repairs, Unit 2 weld overlays and Unit 2 auxiliary spray line reducer (

Reference:

Framatome Document Number 86-9329644-001, St.

Lucie SLR CUFen Evaluations Summary, July 15, 2021).

Table 5-2 of the Framatome report specifies the reduced cycles of the transients that are used in the environmental cumulative usage factor (CUFen) calculations, as reduced from the design cycles. Some of these transients, which involve limited (reduced) cycles compared to design cycles, will not be monitored in the Fatigue Monitoring program, as indicated in SLRA Section 4.3.1.

The transients, which are used for the CUFen calculations in the Framatome report and will not be monitored in the Fatigue Monitoring program, are the following: (1) plant loading/unloading transient; (2) 10 percent step load increase/decrease transient; and (3)

1. Provide justification for excluding the plant loading/unloading, 10 percent step load increase/decrease, and cold feedwater following hot standby transients from fatigue monitoring even though these transients and associated reduced cycles are used in the EAF analysis of the Framatome report.
2. Clarify whether the primary coolant pump starting/stopping transient of St. Lucie Unit 2 will be monitored in the Fatigue Monitoring program. If not, provide justification for excluding the transient from fatigue monitoring.
3. Clarify whether the spray nozzle, main spray initiation, auxiliary spray at power 1, auxiliary

Page 6 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)

Discussion Question / Request Outcome of Discussion cold feedwater following hot standby transient. Given that these transients and their reduced cycles are used for the CUFen calculations in the Framatome report, the staff found a need to confirm the adequacy of excluding these transients form fatigue monitoring.

The staff also noted that the primary coolant pump starting/stopping transient (also designated as the DP transient) is used in the EAF analysis for the Unit 2 steam generator tube-to-tubesheet weld.

However, SLRA Section 4.3.1 and Framatome report do not clearly address whether the pump transient for St. Lucie Unit 2 will be monitored in the Fatigue Monitoring program.

In addition, SLRA Section 4.3.1 and Framatome report Tables 5-2 and 5-3 (addressing pressurizer spray nozzle transients) do not clearly address whether the following transients related to Unit 2 pressurizers, which involve reduced cycles in the CUFen calculations, will be monitored in the Fatigue Monitoring program: (1) spray nozzle transient (also called the spray nozzle transient 17A/B/C); (2) main spray initiation transient; (3) auxiliary spray at power 1 and auxiliary spray at power 2 transients; and (4) main spray term in cooldown transient.

spray at power 2, and main spray term in cooldown transients will be monitored in the Fatigue Monitoring program to ensure that the actual transient cycles do not exceed the cycles projected and analyzed in the EAF analysis of the Framatome report. If not, provide justification for excluding these transients from fatigue monitoring.

Page 7 of 7 Question Number SLRA Section SLRA Page Background / Issue (As applicable/needed)

Discussion Question / Request Outcome of Discussion 6