IR 05000250/2012009
| ML12362A401 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/21/2012 |
| From: | Vias S NRC/RGN-II/DRS/EB3 |
| To: | Nazar M Florida Power & Light Co |
| References | |
| IR-12-009 | |
| Download: ML12362A401 (14) | |
Text
UNITED STATES ber 21, 2012
SUBJECT:
TURKEY POINT NUCLEAR PLANT - NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT 05000250/2012009 AND 05000251/2012009
Dear Mr. Nazar:
On November 16, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Post-Approval Site Inspection for License Renewal at your Turkey Point Nuclear Plant, Units 3 and 4.
The enclosed report documents the inspection results, which were discussed on November 16, 2012, with members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings were identified. The inspectors determined that the overall implementation of Aging Management Program activities reviewed during the Unit 4 refueling outage was consistent with the License Renewal commitments In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Steven J. Vias, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-250, 50-251 License Nos. DPR-31, DPR-41
Enclosure:
Inspection Report 05000250/2012009 and 05000251/2012009 w/Attachment: Supplemental Information
REGION II==
Docket Nos: 50-250, 50-251 License Nos: DPR-31, DPR-41 Report No: 05000250/2012009, 05000251/2012009 Licensee: Florida Power & Light Company (FPL)
Facility: Turkey Point Nuclear Plant, Units 3 and 4 Location: 9760 S. W. 344th Street Homestead, FL 33035 Dates: November 12 - November 16, 2012 Inspectors: Robert Williams Jr., Reactor Inspector Approved by: Steven J. Vias, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000250,-251/2012009; November 12, 2012 - November 16, 2012; Turkey Point Nuclear
Plant, Units 3 and 4; Post Approval Site Inspection for License Renewal.
The report covers an inspection conducted by a regional inspector in accordance with NRC Manual Chapter 2515 and NRC Inspection Procedure 71003, Post-Approval Site Inspection for License Renewal.
Based on the sample selected for review, the inspector determined that commitments, license conditions, and regulatory requirements associated with the renewed facility operating license were either being met or, where commitment actions had not been completed, the licensee had administrative controls in place to ensure completion before the period of extended operation.
The inspector identified one performance deficiency during this inspection associated with the implementation of license renewal commitment changes and changes to the description of aging management programs described in the UFSAR supplement.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings None
Licensee-Identified Violations
None
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Other Activities: Post-Approval Site Inspection for License Renewal (Phase 1)
.1 Implementation of License Conditions and Commitments, including Aging Management
Programs
a. Inspection Scope
The inspector reviewed a sample of license renewal activities scheduled for the Unit 4 Fall 2012 refueling outage, which was the last outage before the beginning of the period of extended operation (PEO). Additionally, the inspector reviewed two observations that remained open following the Phase 2 implementation of NRC inspection procedure 71003. The inspections objective was to maximize observations of the actual implementation of license renewal activities before the beginning of the PEO (April 10, 2013), and verify that the licensee completed the necessary actions to:
- (a) comply with the conditions stipulated in the renewed facility operating license;
- (b) meet the license renewal commitments described in NRC Memorandum dated March 6, 2007 (ADAMS Accession Number ML070640041), and
- (c) meet the future inspection activities described in the Updated Final Safety Analysis Report (UFSAR) supplement submitted pursuant to 10 CFR 54.21(d). The previous Phase 2 implementation of NRC inspection procedure 71003 was completed on June 8, 2012 and is publicly available on ADAMS under accession number ML12195A272. The license renewal application (LRA) for Turkey Point Nuclear Plant, Units 3 & 4 and the corresponding NRC Safety Evaluation Report (SER) documented in NUREG-1759 are publicly available on ADAMS under accession numbers ML003764392 and ML021280541, respectively.
The inspectors reviewed supporting documents; conducted interviews with licensee staff; observed in-process outage activities; and performed visual inspection of structures, systems, and components (SSCs) including those not accessible during power operation. The specific inspection activities conducted for each aging management program (AMP) are also described below. Specific documents reviewed are listed in the report attachment.
Reactor Vessel Internals Inspection Program (UFSAR Section 16.1.6 and Commitment No. 6 in NRC Memorandum): This commitment specified that prior to the period of extended operation, the licensee would implement a program for managing aging effects of the reactor vessel internals consisting of visual and ultrasonic examinations. The licensee also committed to submit a report to the NRC, summarizing the understanding of aging effects applicable to the reactor vessel internals. The report would be submitted prior to the period of extended operation of Unit 3 and would include an inspection plan, including the methods for detection and sizing of cracks and acceptance criteria.
On December, 22, 2011, the licensee submitted a letter to the NRC formally revising the original license renewal commitment to implement a program in accordance with the guidance in recently approved Material Reliability Program (MRP)-227-A, Electric Power Research Institute Reactor Vessel Internals Program; however, the licensee requested additional time for the implementation of the plant specific MRP-227-A program as approved by the NRC. The licensee requested to extend the due date for the submittal of the Unit 3 inspection plan until December 31, 2012, and prior to the period of extended operation for Unit 4 (April 10, 2013). The licensee also informed the NRC of their plans to revise the original license renewal commitment under the controls of 10 CFR 50.59.
During the Phase 2 implementation of NRC inspection procedure 71003, an observation was made that the licensee had not completely developed the Reactor Vessel Internals Inspection Program as described in the latest correspondence submitted to the NRC, revising the original license renewal commitment to adopt the guidelines in MRP-227-A and was still working on several tasks associated with the plant specific actions necessary to meet the guidelines in MRP-227-A.
On December 14, 2012, the licensee submitted letter L-2012-438 that detailed the inspection plan for the plant-specific implementation of MRP-227-A. The inspectors reviewed the licensing basis, program documents and document submission timelines to verify that this program was implemented in accordance with the revised commitment as described in the letter submitted to the NRC in December 2011. The inspectors also interviewed plant and corporate personnel to assess the implementation of the Reactor Vessel Internals Inspection Program.
Small Bore Class 1 Piping Inspection (UFSAR Section 16.1.7 and Commitment No. 7 in NRC Memorandum): This commitment specified that prior to the end of the initial operating license term, a volumetric inspection of a sample of small bore Class 1 piping and nozzles would be performed to determine if cracking is an aging effect requiring management during the period of extended operation. This one-time inspection would address Class 1 piping less than 4 inches in diameter.
During the Phase 2 implementation of NRC inspection procedure 71003, an observation was made that, inconsistently with the intent of the program, the licensee selected five socket welds within a single pipe segment approximately one foot long. The inspectors were concerned that the selected location did not constitute a representative sample on which to base a determination that no aging effects were present in general. The licensee had entered this issue into the CAP as AR 01770267 for Unit 3 and AR 01629607-08-14 for the planned Unit 4 inspections. For the current inspection, the inspectors reviewed the sample selection of welds to be destructively tested from Unit 4 and noted that unlike Unit 3, the samples chosen were all from different welds that were exposed to various pressure-temperature environments and consistent with the intent of the program.
Systems and Structures Monitoring Program (UFSAR Section 16.2.15 and Commitment No. 15 in NRC Memorandum): Commitment Item 15 in the NRC Memorandum dated March 6, 2007, specified that the Systems and Structures Monitoring Program will be enhanced by restructuring it to address inspection requirements to manage certain aging effects in accordance with 10 CFR 54, modifying the scope of specific inspections and improving documentation requirements. NUREG-1759 and the UFSAR supplement for license renewal described the planned inspections, scope changes and enhancements for this program.
The examination of the structures and systems within the scope of the Systems and Structures Monitoring Program consists of visual examinations (VT-1 and VT-3)performed in accordance Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. This program was credited to manage loss of material, cracking, fouling, loss of seal and change in materials properties for the systems, structures and components within its scope. Aging management of structural components that are inaccessible for inspection was accomplished by inspecting accessible structural components with similar materials and environments for aging effects that may be indicative of aging effects for the inaccessible structural components.
The inspector reviewed the licensing basis, implementing procedures, engineering evaluations, personnel qualifications, and non-destructive examination plans to verify that the Systems and Structures Monitoring examinations performed during the Unit 4 fall 2012 outage were implemented as stated in the commitment. Additionally, the inspector directly observed the VT-3 examination of the 14 level of containment (which included all accessible structures and containment surfaces) to verify that essential attributes such as calibration and disposition of indications were performed in accordance with the license renewal commitment.
b. Findings and Observations
No findings were identified.
Based on the review of licensee actions completed at the time of this inspection, the timeliness of those actions, and the administrative controls in place to track pending tasks, the inspectors determined that there was reasonable assurance that the licensee:
- had established the required program to manage aging effects of small bore piping to maintain their intended function(s) through the period of extended operation of Units 3 and 4,
- would adequately manage the aging effects associated with the Systems and Structures Monitoring Program and continue it during the PEO, and
- had established the required program to manage aging effects of the Reactor Vessel Internals to maintain their intended function(s) through the period of extended operation of Units 3 and 4.
.2 License Renewal Commitment Changes
a. Inspection Scope
As part of the review of license renewal commitments described in section 4OA5.1.a of this report, the inspectors reviewed license renewal commitment change documents to verify the licensee followed the guidance in NEI 99-04, Guidelines for Managing NRC Commitment Changes, for any change to the commitments, including their elimination.
The inspectors verified that the licensee properly evaluated, reported, and approved where necessary, changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.
The inspectors also reviewed the licensees procedures for commitment revision to obtain reasonable assurance that future changes to (or elimination of) license commitments would follow the guidance in NEI 99-04, and would properly evaluate, report, and approve changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.
b. Findings and Observations
No findings were identified With the exception of one observation described below, the inspectors determined that the licensee followed the established plant procedures to modify license renewal commitments, which referenced the guidance in NEI 99-04. Commitment changes where implemented against the guidance in NEI 99-04 and formal notification was submitted to the NRC where applicable. For changes to AMP descriptions in the UFSAR supplement, the licensee implemented such changes under the controls of 10 CFR 50.59. Additionally, for changes affecting the plant Technical Specifications, the licensee submitted a license amendment to the NRC for review and approval.
- (1) Observation for the Small Bore Class 1 Piping Inspection Program - The inspectors noted that in implementing the commitment change to the Small Bore Class 1 Piping Inspection Program to follow the guidance provided in the Generic Aging Lessons Learned (GALL) Report, NUREG-1801, Rev. 2, Section AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping, the licensee failed to perform adequate 50.59 Screenings in accordance with their commitment change program described in EN-AA-204-1100-F01, Rev. 0, Document Change Request. 10 CFR 50, Appendix B, Criterion V states, in part, that, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, the licensee failed to perform a 50.59 screening for Engineering Change 273274, Turkey Point Units 3 and 4 ASME Code Class 1 Small-Bore Piping One-Time Inspection Plan, Rev. 0. The licensee entered this issue into their correction action program as AR 01792178 and subsequently performed the 50.59 screening.
Additionally, the 50.59 screening of Engineering Change 274618, Issue Revision 3 to PTN-ENG-LRAM-00-0039, Rev. 0, to update the Small Bore Class 1 Piping AMP incorrectly stated that the change did not involve a change to the UFSAR Section 16.1.7 and that the UFSAR remained unaffected by the proposed changes. The technical justification used to support that statement referenced UFSAR content that was not present in the current version of the UFSAR at the time and that would not be reviewed, approved or implemented until five months later. The licensee entered this issue into their correction action program as AR 01824085. The UFSAR section has since been updated to reflect the implemented changes to the AMP.
Since neither of these failures to perform adequate 50.59 screenings resulted in elevated 50.59 evaluations nor missed notifications to the NRC, this performance deficiency was dispositioned as a minor violation of 10 CFR 50, Appendix B, Criterion V in accordance with the guidance contained in NRC Inspection Manual Chapter 0612, Appendix B, Issue Screening. .
.3 Newly Identified Structures, Systems and Components
The review of newly identified SSCs pursuant 10 CFR 54.37(b) was completed during the Phase 2 implementation of NRC inspection procedure 71003.
.4 Description of Aging Management Programs in the UFSAR Supplement
The review of the description of AMPs and time-limited aging analyses in the UFSAR supplement submitted pursuant 10 CFR 54.21(d) was completed during the Phase 2 implementation of NRC inspection procedure 71003.
4OA6 Management Meetings
Exit Meeting Summary
On November 16, 2012, the inspector presented the inspection results to Mr. Mike Kiley, Site Vice President, and other members of the licensee staff. The licensee acknowledged the inspection results. The inspector confirmed that all proprietary information reviewed during the inspection was returned to the licensee and that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Patel, License Renewal Team (Contractor)
- K. Mohindral, FPL License Renewal Manager
- R. Tomonto, Licensing Manager
- S. Mihalakea, Licensing Engineer
- T. Satyan, License Renewal Team (Contractor)
LIST OF REPORT ITEMS
Opened
None
Closed
None
Discussed
None