ML17132A382
Text
U. S. Nuclear Regulatory Commission Attn. Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 1 Docket No. 50-335 MAY 0 3 2017 Updated Final Safety Analysis Report Amendment No. 28, Amendment No. 27A and License Renewal 10 CFR 54.37(b) Report
References:
L-2017-074 10 CFR 50.71 10 CFR 54.37 1. St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 "Application for Renewed Operating Licenses Pursuant to 10 CFR 54.17 and 10 CFR 50.4(c)", FPL letter L-2001-058, dated November 29, 2001, Accession Number: ML013400473. 2. St. Lucie Unit 1 Docket No. 50-335 "Updated Final Safety Analysis Report Amendment No. 27, Amendment No. 26A and License Renewal 10 CFR 54.37(b) Report," FPL letter L-2015-220, dated October 22, 2015. 3. Generic Aging Lessons Learned (GALL) Report, NUREG-1801, Rev. 2, December 2010. Florida Power & Light Company (FPL) has completed its St. Lucie Unit 1 Cycle 27 (SLl-27) update of the Updated Final Safety Analysis Report (UFSAR) and its review of design activities to identify any new systems, structures, and components for potential impact on its license renewal aging management programs. This letter submits both the periodic update of the UFSAR (Amendment No. 28) with Amendment No. 27A changes dated January 2016 and the results of the license renewal review in accordance with the requirements of 10 CFR 50.71(e) and 10 CFR 54.37(b), respectively. The enclosed DVD reflects plant changes made since the previous update (Reference 2). This update incorporates changes for the period covering April 25, 2015 through November 9, 2016 and Amendment No. 27A changes dated January 2016. The enclosed information presents changes made since the previous submittal, necessary to reflect information and analyses submitted to the Commission, or prepared pursuant to Commission requirements. This amendment includes activities completed through November 9, 2016, minor changes introduced in January 2016 and the most recent revisions to Chapter 18 addressing License Renewal. The Unit 1 St. Lucie UFSAR is maintained as an electronic "living" document. Changes are made as they meet appropriate incorporation requirements enhancing our ability to maintain the St. Lucie licensing basis current. Revised UFSAR pages are annotated in the lower right hand corner with the amendment number and date, with revision bars in the right margin to identify changed portions. A single DVD containing this document is submitted in lieu qf hard copy. This UFSAR supersedes all previous copies of the document. It is labeled St. Lucie Unit 1 UFSAR Amendment 28. Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957 St. Lucie Unit 1 Docket No. 50-335 L-2017-074 Also enclosed is a second DVD which contains the drawings referenced in the UFSAR. This DVD is submitted for information only and is not part of the update required by 10 CPR 50.71(e) and it is labeled "St. Lucie Unit 1 Drawings Referenced in Amendment 28 UFSAR". The included drawings are a mixture of PDF Normal and Scanned Image PDF. There are three hundred ninety (390) drawing files plus an index. A brief description and summary of the 10 CPR 50.59 safety evaluations of changes, tests, and experiments reportable pursuant to 10 CPR 50.59 is being submitted under separate cover. License Renewal 10 CFR 54.37(b) Report 10 CPR 54.37(b) states that after the renewed license is -issued, a UFSAR update as required by 10 CPR 50.71(e) must include any newly identified systems, structures, and components (SSC's) that would have been subject to an aging management review or evaluation of time-limited aging analyses (TLAA) in accordance with§ 54.21. If newly identified SSC's are found, the UFSAR update must describe how the effects of aging will be managed such that the intended function(s) in§ 54.4(b) will be effectively maintained during the period of extended operation. The license renewal evaluation report submitted with the previous Unit 1 UFSAR 10 CPR 50.71(e) update submittal (Reference 2) addressed the requirements of 10 CPR 54.37(b) for the UFSAR update period April 30, 2001 through April 24, 2015. The purpose of the evaluation included herein is to review changes for the period April 25, 2015 thru November 9, 2016 and report any newly identified (SSC's) as required by 10CFR54.37 (b). This evaluation documents actions taken by St. Lucie Nuclear Plant (PSL) to meet the requirements of Section 54.37(b) of 10 CPR 54. Both evaluations included items noted in the NRC Regulatory Issue Summary (RIS) 2007-16, Revision 1, "Implementation of the Requirements of 10 CPR 54.37(b) for Holders of Renewed Licenses," as well as UFSAR revised text and plant changes/ modifications installed. The evaluation identified: EC 234768, PC/M 01079 Fire Detection NFPA Code Modifications includes newly identified SSCs required to be identified to the NRC under 54.37(b). EC 282743, NFPA-805 Transition for Technical Specification Amendment 231 includes newly identified SSCs required to be identified to the NRC under 54.37(b). Newly Identified SSCs EC 234768 PSL-1 UFSAR Amendment 19 and PSL-2 UFSAR Amendment 15 included changes associated with EC 234 7 68, Incipient Fire Detection (IFD) in the rooms which contain the Emergency Core Cooling System (ECCS) pumps. The systems utilize CPVC sensing lines in the rooms and transition to stainless steel prior to exiting the rooms. Page 2 of 5 St. Lucie Unit 1 Docket No. 50-335 L-2017-074 The Component / Commodity Group of Piping/Fittings in Table 3.3-6, Fire Protection, of the License Renewal Application (LAR) (Reference 1) did not include CPVC. The internal and external environments are the air in the ECCS pump rooms which is Indoor -not air conditioned. The incipient fire detection systems installed by EC 234768 meet the criteria of 10 CFR 54.37(b)(2), as the systems were installed in the plant at the time of the license renewal review and included in in the current licensing basis (CL:S) and should have been subjected to an aging management review. 10 CFR 54.21 (a)(l) Aging Management Review The intended function of the CPVC sensing lines is to maintain the ability to sample the air in the room. NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 2 (Reference 3), Chapter .VII Auxiliary Systems, J. Common Miscellaneous Material/Environment Combinations includes PVC in an Air -indoor uncontrolled environment. GALL identifies there is no Aging Effect/Mechanism, no Aging Management Program and no further evaluation is needed. The PSL use of CPVC piping is consistent with the material and the internal and external environments in NUREG-1801 Revision 2 (Reference 3) which identifies no AMP is required. As such, the CPVC piping used in the incipient fire detection systems will be capable of performing the intended function through the period of extended operation (PEO) without the need for an aging management program (AMP). Component Intended Commodity Function Group (Gall Rev. 2 Reference) Piping Pressure (VII.J.AP-Boundary 268) Piping Pressure (VII.J.AP-268) Boundarv EC 282743 LAR Table 3.3-6 FIRE PROTECTION Material Environment Internal Environment PVC/ Indoor -not air CPVC conditioned External Environment PVC/ Indoor -not air CPVC conditioned Aging Effects Program / Activity Requiring Management None None None None The Unit 1 Nuclear Safety Capability Analysis identifies two sources of makeup to the Unit 1 condensate storage tank (CST). These sources of makeup support natural circulation cooldown. One alignment uses the normally isolated common header (UFSAR section 9.2.5.2) of the makeup water system supply to the CST and connects the isolated common header to the fire water distribution system. The portion of the makeup Page 3 of 5 St. Lucie Unit 1 I)ocket:N"o. 50-335 L-2017-074 water system used for this alignment is not included in the scope of License Renewal. The other source is the Unit 2 CST using the crosstie which was included in the original license renewal application. As the CST makeup performs a function that demonstrates compliance with 10 CFR 50.48 the normally isolated common header portion of the makeup water system is within the scope of License Renewal. :N"o new commodity groups, materials or environments were identified. The materials and environments are identical to those in the License Renewal Application (LAR) (Reference 1) Table 3.4-3 Auxiliary Feedwater and Condensate. I)emineralized Makeup Water System (38) /Treated Water System/ Makeup Water Component Intended Material Environment Aging Effects Program/ Commodity Group Function Requiring Activity (Gall Reference) Management Internal Environment Valves Pressure Stainless Treated Water -other Loss of Chemistry Piping/ fittings Boundary Steel material Control Program :N"ote 1 External Environment Valves Pressure Stainless Outdoor :N"one :N"one Piping/ fittings Boundary Steel Indoor -not air Required conditioned :N"ote 2 1) Material and Environment are identical to those on LAR Table 3.3-3 I)emineralized Makeup Water (Unit 2 Ocln . 2) Material and Environment are identical to those on LAR Table 3.2-2 Containment Spray Page 4 of 5 J Please contact us should there be any questions regarding this information. St. Lucie Unit 1 Docket No. 50-335 L-2017-074 I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed on May-22.._, 2017. Sincerely, Daniel DeBoer Site Director St. Lucie Plant DD/lrb Enclosures (2) 1. DVD St. Lucie Unit 1 UFSAR Amendment 28 2. DVD St. Lucie Unit 1 Drawings Referenced in Amendment 28 UFSAR cc: USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Plant USNRC Senior Resident Inspector, St. Lucie Plant Page 5 of 5