L-2011-385, License Renewal Commitment Change Summary
| ML11285A309 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/28/2011 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2011-385 | |
| Download: ML11285A309 (2) | |
Text
POWERING TODAY.
L-2011-385 EMPOWERING TOMORROW.0 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-00001 Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Renewal Commitment Change Summary The purpose of this letter is to summarize a commitment change related to the method utilized in performing the license renewal one-time visual inspections of the field erected tanks at Turkey Point station.
Background:
Florida Power and Light Company (FPL) has a license renewal commitment for Turkey Point Units 3 and 4 to perform one-time visual inspection of the following five field erected tanks prior to the end of the initial operating license term to determine the extent of any internal corrosion of the tank steel:
o Condensate Storage Tanks (CSTs) for Turkey Units 3 and 4 o
Demineralized Water Storage Tank (DWST) common tank for Turkey Point Units 3 and 4 o
Refueling Water Storage Tanks (RWSTs) for Turkey Points Units 3 and 4.
The description of the visual inspection is explicitly credited in the Nuclear Regulatory Commission Safety Evaluation Report (SER), NUREG-1759, Section 3.8.4.2 Staff Evaluation, and Page 3-194.
Specifically, FPL stated (in response to NRC's Open Item 3.8.4-1 dated November 2001) that although the internal tank inspection will not be an ASME Section XI inspection, the lighting and resolution requirements will be the same as those specified for a VT-3 inspection, which are described in IWA-2210 of ASME Section XI.
Commitment Revision:
Original Commitment, as stated in the Turkey Point License Renewal SER, NUREG-1759, Page 3-194:
"_..the internal tank inspection will not be an ASME Section XI inspection, the lighting and resolution requirements will be the same as those specified for a VT-3 inspection, which is described in IWA-2210 of ASME Section XI."
Revised Commitment as being implemented (added text is bolded and underlined):
"_the internal tank inspection will not be an ASME Section XI inspection, the lighting and resolution requirements will be normal lighting for coating inspections and if degradation/deterioration of the coatings is observed or if bare metal of the tanks is exposed, the liihting and resolution requirements for the tank steel inspection will be the same as those specified for a VT-3 inspection, which is described in IWA-22 10 of ASME Section XI."
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L-2011-385 Page 2 The commitment change evaluation determined that the use of normal lighting is sufficient to observe degradation of the coatings, since evidence of flaking, blistering, peeling, discoloration, pitting is identified easily without the need of enhanced lighting and resolution. However, if during these initial coating inspections, degradation or deterioration of the coatings is observed, or if bare metal is exposed, additional visual inspections are necessary to determine the extent of any internal corrosion of the tank steel. The illumination and resolution for the additional visual inspections of the tank steel surfaces would be performed in accordance to VT-3 illumination and resolution requirements as indicated in IWA-2210, Visual Examinations.
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Conclusion:==
The revised method to perform the one-time visual inspections of the field erected tanks is considered adequate for detecting flaking, blistering, peeling, discoloration, pitting or excessive corrosion and as such effective in determining degradation of the internal tank surfaces.
Should there be any questions, please contact Robert J. Tomonto, Turkey Point Licensing Manager at 305-246-7327.
Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant SM cc:
Regional Administrator, USNRC Region II USNRC Senior Resident Inspector - Turkey Point Plant