ML25251A079
| ML25251A079 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/16/2025 |
| From: | Natreon Jordan Plant Licensing Branch II |
| To: | Coffey R Florida Power & Light Co |
| Jordan N | |
| References | |
| EPID L-2024-LLA-0124 | |
| Download: ML25251A079 (6) | |
Text
September 16, 2025 Mr. Robert Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company 700 Universe Blvd.
Mail Stop: EX/JB Juno Beach, FL 33408
SUBJECT:
ST. LUCIE PLANT, UNIT NO. 2 - AUDIT
SUMMARY
FOR LICENSE AMENDMENT REQUEST FOR FUEL METHODOLOGY CHANGES IN SUPPORT OF TRANSITION TO 24-MONTH FUEL CYCLES (EPID L-2024-LLA-0124)
Dear Mr. Coffey:
By letter dated September 11, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24255A118), Florida Power and Light (FPL, the licensee),
submitted a license amendment request (LAR) for St. Lucie Plant (St. Lucie), Unit No. 2, to the U.S. Nuclear Regulatory Commission (NRC). Specifically, the proposed LAR would revise the St. Lucie, Unit 2, Technical Specification 5.6.3, Core Operating Limits Report, by updating the listing of NRC-approved analytical methods used to determine the core operating limits. This is to support the proposed transition to 24-month fuel cycles at St. Lucie, Unit No. 2.
To support its review, on February 4, 2025 (ML25041A239), the NRC staff notified the licensee that they would conduct a regulatory audit through an online portal (also known as electronic portal, ePortal, electronic reading room) established by the licensee and provided the audit plan.
The regulatory audit summary is enclosed with this letter.
If you have any questions, please contact me at (301) 415-7410, or by e-mail at Natreon.Jordan@nrc.gov.
Sincerely,
/RA/
Natreon J. Jordan, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-389
Enclosure:
Regulatory Audit Summary cc: Listserv
Enclosure REGULATORY AUDIT
SUMMARY
REGARDING LICENSE AMENDMENT REQUEST RELATED TO FUEL METHODOLOGY CHANGES IN SUPPORT OF TRANSITION TO 24-MONTH FUEL CYCLES ST. LUCIE PLANT, UNIT NO. 2 DOCKET NO. 50-389 FLORIDA POWER AND LIGHT
1.0 BACKGROUND
By application dated September 11, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24255A118), Florida Power and Light (FPL, the licensee),
submitted a license amendment request (LAR) for St. Lucie Plant (St. Lucie), Unit No. 2, to the U.S. Nuclear Regulatory Commission (NRC). Specifically, the proposed LAR would revise the St. Lucie, Unit 2, Technical Specification (TS) 5.6.3, Core Operating Limits Report, by updating the listing of NRC-approved analytical methods used to determine the core operating limits.
The NRC staff performed a preliminary review of the LAR and determined that a regulatory audit would assist in the timely completion of the review. An audit plan was provided to the licensee on February 4, 2025 (ML25041A239), which provided details pertaining to the audit. The purpose of the audit was to gain an understanding of the information needed to support the NRC staffs licensing decision regarding the LAR and to develop requests for additional information (RAIs), if necessary. The information submitted in support of the LAR is under final review, and any additional information needed to support the LAR review will be formally requested by the NRC staff using the RAI process in accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, Revision 6, License Amendment Review Procedures (ML19248C539).
The regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information, that will require docketing to support the basis of a licensing or regulatory decision.
Performing a regulatory audit of the licensees information is expected to assist the NRC staff in efficiently conducting its review or gaining insights into the licensees processes or procedures.
Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, the NRC staff may review supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) section 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which, although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information.
2.0 SCOPE On February 4, 2025, the NRC staff issued an audit plan. To support discussions, the NRC staff provided audit questions with items for FPL to clarify. FPL posted answers to these questions to the online portal. The NRC staff held clarification discussions with the FPL staff via Microsoft Teams. All audit questions were discussed. Technical discussions were primarily focused on information provided by the licensee to support the methodology used in the licensees criticality analysis.
3.0 AUDIT TEAM The NRC audit team included the following:
Natreon Jordan, Plant Licensing Branch II-2 (LPL2-2)
Robert Beaton, Nuclear Systems Performance Branch (SNSB)
Kevin Heller, Nuclear Methods and Fuels Branch (SFNB)
Richard Fu, Nuclear Methods and Fuels Branch (SFNB)
Logan Gaul, Nuclear Systems Performance Branch (SNSB) 4.0 DOCUMENT AND FILES REVIEWED The NRC staff requested that the following information be added to the online reference portal for staff review as part of the audit:
- 1.
Calculations performed for the small-break loss-of-coolant accident (SBLOCA) and the realistic large-break loss-of-coolant accident (RLBLOCA) evaluations.
- 2.
Documentation supporting the disposition of Chapter 15 Non-LOCA events as described in Section 4.0 of ANP-4105P, St. Lucie Unit 2 24-Month Non-LOCA Summary Report, Revision 2, September 2024.
- 3.
Calculations performed for the Chapter 15 Non-LOCA events.
Additionally, the licensee responses to NRC staff audit questions were also included on the portal for NRC staff review.
The audit covered several areas where the NRC staff sought confirmation and clarification.
Those areas involved general discussions on the SBLOCA, LBLOCA and non-LOCA transient analysis, disposition of all Chapter 15 events, and details on how the licensee met certain limitations and conditions for the ARITA methodology. FPL provided the following documents for NRC staff review:
Framatome calculation FS1-0060594, Rev. 1, St. Lucie Unit 2 24-Month Cycle SBLOCA Time in Cycle Study, October 26, 2023.
Framatome calculation FS1-0060587, Rev. 1, St. Lucie Unit 2 24-Month Cycle Transient Analysis for SBLOCA, October 26, 2023.
Framatome calculation FS1-0060592, Rev. 1, St Lucie Unit 2 Cycle 29 RLBLOCA Uncertainty Analysis, October 10, 2023.
Framatome calculation FS1-0066561, Rev. 4, St. Lucie Unit 2 24 Month Fuel Cycle Non-LOCA Safety Analysis Disposition of Events, June 4, 2024.
Framatome calculation FS1-0068915, Rev. 1, St. Lucie Unit 2 24-Month Cycle Transition - Loss of Load to One SG [steam generator] (Single MSIV [main steam isolation valve] Closure) ARITA Analysis, August 26, 2024.
Framatome calculation FS1-0065652, Rev. 3, St. Lucie U2 24-months: ARITA S-RELAP5 Base Model Steady-State and Null Transients, January 15, 2024.
Framatome calculation FS1-0068916, Rev. 1, St. Lucie Unit 2 24-Month Fuel Cycle -
Uncontrolled CEA Bank Withdrawal from a Subcritical or Low Power Startup Condition ARITA Analysis, October 15, 2024.
Framatome calculation FS1-0068911, Rev. 2, St. Lucie Unit 2 24-Month Cycle -
Feedwater System Malfunctions that Result in an Increase in Feedwater Flow ARITA Analysis, January 30, 2025.
Framatome calculation FS1-0070806, Rev. 2, ARITA MB-2 MSLB [main steamline break] Benchmark, March 26, 2024.
Framatome calculation FS1-0072149, Rev. 2, Response to ARITA L&C 2, October 22, 2024.
Framatome calculation FS1-0063044, Rev. 4, St. Lucie Unit 2 24-Month Cycle:
Representative Equilibrium Core Design, March 6, 2023.
Framatome calculation FS1-0064639, Rev. 2, SLU2 24 Month Cycle: Neutronic Inputs to Safety for DOE, September 21, 2023.
Framatome calculation FS1-0064412, Rev. 1, GALILEO PWR Normal Operation Analysis for SLU2 24-Month Transition, January 10, 2023.
Framatome calculation FS1-0068039, Rev. 1, SLU2 24m Cycle - UFSAR 15.4 Non-LOCA Analytical Input Summary, May 7, 2024.
Framatome calculation FS1-0069580, Rev. 1, SLU2 24m Cycle - UFSAR 15.2 Non-LOCA Analytical Input Summary, May 3, 2024.
Framatome calculation FS1-0066759, Rev. 3, SLU2 24m Cycle - UFSAR 15.1 Non-LOCA Analytical Input Summary - ARITA, April 18, 2024.
Framatome calculation FS1-0067117, Rev. 2, St. Lucie 2, 24 Month Project (SLU2) -
UFSAR 15 Analytical Input Summary, Generic Input Parameters for ARITA, March 18, 2024.
5.0 RESULTS OF THE AUDIT As a result of the audit, the NRC staff gained a better understanding of the licensees analyses and calculations that provide the technical support for the LAR. Several RAIs were issued to the licensee on April 27, 2025 (ML25119A284). The licensee provided a response to the RAIs on May 29, 2025 (ML25150A005).
- via eConcurrence OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DSS/SFNB/BC NAME NJordan ABaxter SKrepel DATE 9/3/2025 9/9/2025 9/9/2025 OFFICE NRR/DRNL/NVIB/BC NRR/DSS/STSB/BC NRR/DSS/SNSB/BC NAME ABuford SMehta NDifrancesco DATE 9/9/2025 9/10/2025 9/10/2025 OFFICE NRR/DSS/SCPB/BC NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME MValentin DWrona NJordan DATE 9/9/2025 9/11/2025 9/16/2025