L-2019-071, Response to Request for Additional Information (RAI) Set 10 Subsequent License Renewal Application Safety Review Requests
| ML19102A065 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/10/2019 |
| From: | Maher W Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2019-071 | |
| Download: ML19102A065 (22) | |
Text
April 10, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Florida Power & Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2019-071 10 CFR 54.17 Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI} Set 10 Response
References:
- 1. FPL Letter L-2018-004 to NRC dated January 30, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application (ADAMS Accession No. ML18037A812)
- 2. FPL Letter L-2018-082 to NRC dated April 10, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application - Revision 1 (ADAMS Accession No. ML18113A134)
- 3. NRC RAI E-Mail to FPL dated March 28, 2019 - Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application -Set 10 (EPID No. L-2018-RNW-0002) (ADAMS Accession Nos. ML19087A209 and ML19087A211)
- 4. FPL Letter L-2019-037 to NRC dated March 6, 2019, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 9 Responses (ADAMS Accession No. ML19070A113)
Florida Power & Light Company (FPL) submitted a subsequent license renewal application (SLRA) for Turkey Point Units 3 and 4 to the NRC on January 30, 2018 (Reference 1) and SLRA Revision 1 on April 10, 2018 (Reference 2).
The purpose of this letter is to provide, as attachments to this letter, the response to the safety review Set 10 RAI No. 8.2.3.28-1 issued by the NRC on March 28, 2019 (Reference 3), and a supplemental response for the Open-Cycle Cooling Water (OCCW) Aging Management Program (AMP). The Set 10 RAI response augments the response submitted by FPL on March 6, 2019 (Attachment 1 of Reference 4). The attachments identify revisions amending the SLRA.
If you have any questions, or need additional information, please contact me at 561-
. 691-2294.
Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2019-071 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 10, 2019.
William Maher Senior Licensing Director Florida Power & Light Company WDM/RFO
- Attachments:
Senior Resident Inspector, USNRC, Turkey Point Nuclear Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Nuclear Plant Project Manager, USNRC, SLRA Plant Project Manager, USNRC, SLRA Environmental Ms. Cindy Becker, Florida Department of Health
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.3.28-1 b L-2019-071 Attachment 1 Page 1 of 8 NRC RAI Letter Nos. ML19087A209 and ML19087A211 Dated March 28, 2019
Section 54.21 (a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the subsequent period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis (CLB). As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21 (a)(3) by referencing the NUREG-2191, Rev. 0, "Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report," dated July 2017. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.
Background:
By letter dated February 6, 2019, (ADAMS Accession No. ML19037A398) the staff issued follow-up RAI B.2.3.28-1 a requesting that a basis be provided for why Preventive Action Category F is appropriate for buried steel piping during the 10-year period prior to the subsequent period of extended operation (SPEO). The basis for issuing this RAI was that:
(a) operating experience (OE) at Turkey Point has indicated several instances of leaks/significant degradation of buried steel piping; and (b) Preventive Action Category F is limited to instances where plant-specific OE identifies only a few (i.e., as opposed to several) instances of leaks/significant degradation. The staff's assertion that there have been several instances of leaks/significant degradation of buried steel piping due to external corrosion is based on the following:
SLRA Section B.2.3.28, "Buried and Underground Piping and Tanks," states:
Turkey Point has experienced a number of pipe leaks and/or breaks in buried piping. Most of these pipe breaks have been in the piping for the fire water and service water systems. These breaks have been documented in the corrective action program (CAP). A review of the documentation in the CAP indicates that typically they have been caused by localized corrosion.
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 8.2.3.28-1 b L-2019-071 Attachment 1 Page 2 of 8 During the audit the staff noted that: (a) several leaks and locations of localized external corrosion have occurred in buried service water and fire water system piping; (b) an action report (AR) from 2008 documents that corrosion of buried carbon steel piping is a known problem at the station; and (c) the Structures Monitoring program basis report documents that groundwater/soil at Turkey Point is aggressive with chlorides greater than 500 parts per million (ppm), which indicates an aggressive groundwater/soil classification.
Follow-up RAI B.2.3.28-1 was responded to by Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 9 Responses|letter dated March 6, 2019]], (ADAMS Accession No. ML19070A113). Each of the ARs that were cited by the staff in the OE audit report (ADAMS Accession No. ML18183A445) were addressed. For several of the ARs which identified leaks, the response states that the buried piping is not within the scope of subsequent license renewal (SLR) and is therefore not related to the Buried and Underground Piping and Tanks program. The overall conclusion stated in the response was that: (a) there has not been significant degradation and only one minor leak was identified; and (b) no additional inspections beyond those currently planned are required for buried steel piping during the 10-year period prior to the SPEO.
The response to follow-up RAI B.2.3.28-1 a focused on addressing each of the ARs that were cited by the staff in the OE audit report. The staff has two issues with the response:
- 1. The staff does not agree with the claim that leaks/degradation in out-of-scope buried piping are not relevant to the Buried and Underground Piping and Tanks program. In-scope piping would be just as susceptible to degradation as out-of-scope piping unless a technical justification is provided for why the two are not.
representative of each other (e.g., similar material composition, degradation mechanisms, coatings, environmental conditions, age of installation, operational history of cathodic protection if installed). GALL-SLR Report Aging Management Report (AMP) XI.M41 states:
If cathodic protection is not provided for any reason, the applicant reviews the most recent 10 years of plant-specific operating experience (OE) to determine if degraded conditions that would not have met the acceptance criteria of this AMP have occurred. This search includes components that are not in-scope for license renewal if, when compared to in-scope piping, they are similar materials and coating systems and are buried in a similar soil environment.
Although cathodic protection will be installed at least 7 years prior to the SPEO, AMP XI.M41 clearly establishes the purpose of using plant-specific operating experience related to buried components that are not in-scope.
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.3.28-1 b L-2019-071 Attachment 1 Page 3 of 8
- 2. The response addressed each of the ARs listed in the OE audit report; however, this listing of ARs was not intended to be an exhaustive list documenting all instances of buried piping leaks/degradation at Turkey Point. The staff's review of operating experience spans approximately 10 years, not the entire life of the plant. The staff also notes that corrosion of buried carbon steel piping was known to be an issue in 2008 (approximately 10 years ago). Therefore, there could be examples of buried steel piping leaks/degradation that were not included in the OE audit report.
Request:
State the basis for why additional inspections, beyond those recommended for Preventive Action Category F, are not appropriate for buried steel piping during the 10-year period prior to the SPEO.
FPL Response:
This response augments the response in Attachment 1 of Ref. 4. The number of inspections planned during the 10-year period prior to the SPEO conforms to the*
guidance for Preventive Action Category F in NUREG-2191, Table XI.M41-2. This initial plan for SLR is justified by consideration of current LR programs, a more in-depth (holistic) review of operating experience, and documented soil conditions. Each consideration is further discussed below.
Current LR and SLR Program Inspection Plans The buried steel piping systems included in the scope of the PTN Buried and Underground Piping and Tanks AMP for SLR are intake cooling water (ICW), fire protection (FP) and plant air (PA). Per the piping design specifications, the buried piping materials for these systems are as follows:
ICW - Cast iron piping, cement lined (double thickness), coated FP - Cast iron piping, some small bore carbon steel piping, wrapped and coated PA-Carbon steel, galvanized, wrapped and coated For current license renewal, aging management for these systems is performed by the Intake Cooling Water Inspection Program, the Fire Protection Program, and the Systems and Structures Monitoring Program, respectively. To address NEI 09-014, Rev. 4 (Ref.
1 ), PTN more recently implemented the Turkey Point Nuclear Station Underground Piping and Tank Integrity Program, which includes periodic external inspections of buried piping.
Activities under these programs will continue to be performed throughout the balance of the current period of extended operation (PEO) in conjunction with the pre-SPEO inspections for SLR described below.
The PTN plan for SLR is to follow the guidance in NUREG-2191, Table XI.M41-2, Preventive Action Category F, and perform 11 buried steel piping inspections of a combination of ICW, FP and PA. These inspections will begin no earlier than 10 years and no later than six months prior to the SPEO. Consistent with the requirements of
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.3.28-1 b L-2019-071 Attachment 1 Page 4 of 8 XI.M41, piping inspection locations will be selected based on risk (i.e., susceptibility to degradation and consequences of failure). Plant specific OE can also be used as an input for selecting inspection locations. PTN is also committed to installing a cathodic protection system at least seven years prior to the SPEO, which will ultimately reduce the number of required inspections (Ref. 2). However, the cathodic protection system is not credited in establishing the number of steel piping inspections to be performed prior to the SPEO. There are also provisions in element 7, Corrective Actions, of the PTN Buried and Underground Piping and Tanks AMP to expand the number of inspections based on the extent of degradation found consistent with XI.M41 requirements.
Therefore, based on current inspection plans, there is reasonable assurance that systems within the scope of the PTN Buried and Underground Piping and Tanks AMP will continue to perform their intended functions.
Review of OE To ensure a thorough assessment of OE as it relates to buried piping, a more in-depth (holistic) review of OE has been performed, including the OE summarized by the NRC in the OE audit report (Ref. 3), and the OE assessed by FPL in support of the SLRA including over 200 ARs, seven buried piping inspection self-assessments, and twenty-four buried piping system health reports.
This review included the Turkey Point Nuclear Station Underground Piping and Tank Integrity Program (available on the ePortal), which identifies the internal and external piping inspection history from 2004 to 2016 and future inspection plans.
Based on the above, 15 ARs of relevance were identified. These are further discussed below:
Four ARs (01931234, 02066294, 02071661, 02105634) were for service (domestic) water piping leaks located outside the plant protected area. These four ARs were reporting leakage from the same -15 foot section of service water piping located in a paved area between the nuclear entrance building and the FPL fitness center. The ARs did not document any coating or wrap on the piping. This OE is not directly comparable to the buried piping in the scope of the PTN Buried and Underground Piping and Tanks AMP for the following reasons:
o With exception to a limited amount of small bore carbon steel piping in the fire water system, the carbon steel service water piping is a different material than the steel piping (e.g., cast iron, galvanized carbon steel) in the scope of the PTN Buried and Underground Piping and Tanks AMP.
o The design and installation of piping outside of the protected area are not covered by the design and installation specifications for piping installed on the main plant island (power block) for Units 3 and 4.
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.3.28-1 b L-2019-071 Attachment 1 Page 5 of 8 o
The PTN specifications for fill indicate that all areas containing foundations for the main plant island (power block) for Units 3 and 4 are compacted to 95 percent or greater meaning smaller rock size and a better environment for buried piping. Fill for tanks, plant and access roads within the protected area are compacted to 85 percent or less. There are no specific criteria for fill for areas outside the protected area, so compaction would be expected to be much less than that for the main plant island (power block).
o There are no specific license renewal commitments to manage aging of the buried portions of the service water system. Thus, the system is not monitored or inspected on a regular basis.
One AR (00529702) was associated with fire protection piping for PTN fossil Units 1 and 2, which are no longer in operation and outside of the protected area. The design and installation of piping for the fossil units are not covered by and typically less rigorous than the design and installation specifications for piping installed on the nuclear units, and the pipe material, presence of coatings, and fill conditions are unknown.
Five ARs (ARs in parentheses) were not related to aging and/or buried piping as follows:
o A fire main break caused by construction excavation activities (00461305).
o A service water leak in the stairwell of the central storage facility (02053141 ).
o A drawing issue associated with a valve installed in a section of buried service water piping (01940055).
o A question raised regarding coating requirements on new stainless steel piping that was planned to be encased in concrete (02055286).
o A leak in a service water valve supplying administrative buildings on the South side of the plant site (00460508).
Five ARs (ARs in parentheses) represented applicable OE to the PTN Buried and Underground Piping and Tanks AMP as follows:
o Two for external inspections of buried ICW piping indicating it was in good condition (01955813, 02014369).
o One for corrosion of fire protection piping (00485197).
o One for a pin-hole leak on a fire hydrant (00464785).
o Although not in the scope of SLR, one for corrosion of service water piping located near the plant cafeteria (00462055).
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.3.28-1 b L-2019-071 Attachment 1 Page 6 of 8 The review of these five ARs indicates there are three ARs that are related to corrosion of buried piping. These ARs, which were discussed in Ref. 4, are summarized below for convenience:
In January 2009 (AR 00485197), fire protection piping was found corroded during excavation for a construction activity. Although the external surface of the piping was corroded, the lowest wall thickness measurement was still well above the minimum wall thickness required for the service conditions. The cause was attributed to damage to the protective pipe wrap either due to past excavations or limited fill cover
(<18"). The piping was cleaned, coated and backfilled.
In October 2009 (AR 00464785), a pin-hole leak on a cast iron fire hydrant lower barrel (extension casing) was discovered after excavation to address bubbling paint above ground and at the air/ground interface. The functionality assessment indicated that although there was reduced margin, the fire hydrant was considered "Functional".
The pin-hole leak was due to a localized corrosion cell. The leak location was repaired, coated and backfilled.
In January 2009 (AR 00462055), external corrosion was found on four areas of buried service water piping between the cafeteria and the nuclear entrance building within the PA. Although the external surface of the piping was corroded, the lowest wall thickness measurement was greater than that required to maintain pressure integrity.
The piping was cleaned, coated and backfilled.
SLRA, Section B.2.3.28, Buried and Underground Piping and Tanks, page B-233, makes the following statement:
"In addition, PTN has experienced a number of pipe leaks and/or breaks* in buried piping. Most of these pipe breaks have been in the piping for the fire water and service water systems. These breaks have been documented in the CAP. A review of the documentation in the CAP indicates that typically they have been caused by localized corrosion. These breaks have been repaired and the piping returned to service.'1 Based on the OE review summarized above, this statement is revised. There has only been one pipe break, and that was due to construction excavation activities. Additionally, only one minor (pin-hole) leak has occur~ed that is directly applicable to external corrosion of buried piping within the scope of SLR. Accordingly, the statement in SLRA Section B.2.3.28 is revised as noted below in the SLRA associated changes.
Buried Piping Soil Classification The RAI above indicates that per the Structures Monitoring AMP the groundwater/soil at PTN meets an aggressive classification. However, this is for groundwater/soil below
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRG RAI No. 8.2.3.28-1 b L-2019-071 Attachment 1 Page 7 of 8 groundwater level and none of the piping within the scope of the PTN Buried and Underground Piping and Tanks AMP is installed below groundwater level. Additionally, soil resistivity and pH testing performed per the Turkey Point Nuclear Station Underground Piping and Tank Integrity Program, with average values of 11,671 ohm-cm and 8.92 respectively, concluded that the soil condition above groundwater at PTN is moderately corrosive to non-corrosive.
==
Conclusion:==
Therefore, plant specific OE (one instance of a leak in the fire water system (AR 00464785) and no significant degradation of buried piping in the scope of SLR (see ICW
. and other inspection results above)) supports the applicability of Preventative Action Category F in Table XI.M41-2 of NUREG-2191. Accordingly, PTN's current plan to perform 11 buried steel piping inspections (determined using the guidance of Table XI.M41-2, Preventive Action Category F) prior to the SPEO, in conjunction with other inspections being performed for current LR, are appropriate and justified.
References:
- 1. NEI 09-14, Rev. 4, Guideline for the Management of Underground Piping and Tank Integrity, December 2014
- 2. FPL Letter L-2018-166 to NRG dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application, Safety Review Requests for Additional Information (RAI) Set 3 Responses (ADAMS Accession No. ML18296A024)
- 3. NRG letter dated July 23, 2018 entitled, Turkey Point Nuclear Generating Units 3 and 4 - Report for the Operating Experience Review Audit Regarding the Subsequent License Renewal Application Review (EPID No. L-2018-RNW-0002), transmitting "Audit Report Operating Experience Review Audit Regarding the Turkey Point Nuclear Generating Units 3 and 4, Subsequent License Renewal Application" (ADAMS Accession No. ML18183A445)
- 4. FPL Letter L-2019-037 to NRG dated March 6, 2019 Turkey Point Units 3 and 4 Subsequent License Renewal Application, Safety Review Requests for Additional Information (RAI) Set 9 Responses (ADAMS Accession No. ML19070A113).
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.3.28-1 b L-2019-071 Attachment 1 Page 8 of 8 Associated SLRA Revisions:
SLRA Section B.2.3.28 is amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions.
Revise SLRA Section B.2.3.28 on page B-223 as follows:
In addition, PTN has experienced a number of pipe leaks and/or breaks in buried piping.
Most of these pipe breaks have been in the piping for the fire water and service \\Nater systems. These breaks have been documented in the CAP. A reviev: of the documentation in the CAP indicates that typically they have been Only one minor (pin-hole) leak has occurred on buried piping in the scope of SLR. This pin-hole leak
~
caused by! localized corrosion cell. These breaks have been The leak was repaired and the piping returned to service.
Associated
Enclosures:
None
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 1 of 12 Open Cycle Cooling Water (OCCW) System, GALL AMP XI.M20
- Issue:
Turkey Point's SLRA states that the Open-Cycle Cooling Water (OCCW) System AMP will be used to manage loss of coating integrity for internal coatings of intake cooling water (ICW) system piping. NUREG-2191 AMP XI.M20, "Open-Cycle Cooling Water System" states that if the OCCW system program manages loss of coating integrity for internal coatings or linings, the prog-ram includes the guidance provided in the 'scope of program' program element in NUREG-2191 AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks." This program element identifies three criteria for when an applicant elects to manage the aging effects for internal coatings/linings in an alternative AMP that is specific to the component or system in which the coatings/linings are installed. The staff identified inconsistencies with the first and third recommendations, which state that the recommendations of this AMP (XI.M42) are incorporated into the alternative program (OCCW) and that the FSAR supplement for this AMP (XI.M42) is included in the application with a reference to the alternative AMP (OCCW).
Regarding the first recommendation, Section B.2.3.11 of the SLRA includes enhancements to meet the recommendations of AMP XI.M42. However, the staff identified inconsistencies with several items. For example, for the 'detection of aging effects' program element, the inspection interval is specified to not exceed five years, while Table XI.M42-1 defines Inspection Categories A and B to be 6 and 4 years, respectively, based on the criteria listed in the table. It also appears that the recommendations of the 'monitoring and trending' and 'corrective actions' program elements of AMP XI.M42 are not addressed.
Regarding the third recommendation, SLRA Section 17.2.2.29 does not appear to include a reference to the OCCW System AMP.
Request:
The staff needs additional information to confirm that the portion of the applicant's OCCW System program used to manage loss of coating integrity is consistent with the recommendations in AMP XI.M20 and AMP XI.M42.
FPL Response:
FPL inadvertently omitted the necessary enhancements to Elements 4, 5 and 7 of the PTN Open-Cycle Cooling Water (OCCW) System AMP in SLRA Section B.2.3.11 and Commitment 15 of SLRA Table 17-3 required to manage loss of coating integrity of ICW system piping consistent with the requirements of NUREG-2191 AMP XI.M42. In addition, the UFSAR update included in SLRA Section 17.2.2.29 (Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks) inadvertently omitted a reference to the OCCW AMP.
PTN SLRA Sections 17.2.2.29 and B.2.3.11 and Commitment 15 of Table 17-3 are updated to address these inconsistencies in the PTN Open-Cycle Cooling Water
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 2 of 12 System and Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMPs.
This supplemental response also supersedes the response to Request #2 of RAI 8.2.3.29-2 and the associated SLRA markups_ for Section B.2.3.11 and Commitment 15 of Table 17-3 which is provided in Attachment 7 of Reference 1.
References:
- 1. FPL Letter L-2018-152 to NRC dated August 31, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 1 Responses (ADAMS Accession Number ML18248A257)
Associated SLRA Revisions:
SLRA Sections 17.2.2.29 and B.2.3.11 and Table 17-3 are amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions.
Revise the first paragraph of SLRA Section 17.2.2.29 as follows:
The PTN Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP is a new AMP, although some of its activities and inspections were formerly a portion of the PTN Periodic Surveillance and Preventative Maintenance Program, the PTN Intake Cooling Water Inspection Program, the PTN Field Erected Tanks Internal Inspection Program, and other site-specific programs. This AMP is a condition monitoring program that manages degradation of internal coatings/linings exposed to raw water, treated water, treated borated water, waste water, lubricating oil or fuel oil that can lead to loss of material of base materials and downstream effects such as reduction in flow, reduction in pressure or reduction of heat transfer when coatings/linings become debris. Note that the applicable elements of this AMP are included in the Open-Cycle Cooling Water (OCCW) System AMP (Section 17.2.2.11) to manage loss of coating integrity for internal coatings of intake cooling water (ICW) system piping.
Update the Enhancements table of SLRA Section B.2.3.11 to revise Element 4 and add new Elements 5 and 7 as follows:
Element Affected
- 4. Detection of Aging Effects Enhancement ICW piping internal inspections are based on an evaluation of the effect of a coating/lining failure on the in-scope component's intended function otential roblems identified durin rior
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 3 of 12 Element Affected Enhancement inseections1 and known service life histo!l'.. lnseection intervals are established bl£ a coating seecialist gualified in accordance with RG 1.54 [Reference B.3.20]. However1 inseection intervals should not exceed those seecified in GALL SLR Table XI.M42-1.
The extent of the ICW eieing internal inseection is not an)£ less than the following for each coating/lining material and environment combination. The coating/lining environment includes both the environment inside the eieing and the metal to which the coating/lining is attached. Since PTN is a two-unit site1 a reeresentative samele of fiftv-five {55} 1-foot axial length circumferential segments of eieing are inseected eer unit. The inseection surface includes the entire inside surface of the 1-foot segment. If geometric limitations imeede the inseection of the entire circumferential segment1 the number of inseection segments is increased in order to cover an eguivalent of fif!l£-five {55} 1-foot axial length circumferential segments.
Where documentation exists that manufacturer recommendations and indust!l'. consensus documents {i.e.1 those recommended in RG 1.541 or earlier versions of those standards} were comelied with during installation 1 the extent of eieing inseections ma)£ be reduced to nineteen {19} 1-foot axial length circumferential segments of eieing of each coating/lining material and environment combination at each unit. Reduction of the number of reguired ICW eieing internal inseections is acceetable for PTN Units 3 and 4 as the ICW S)lstems on each unit are essentiall)l identical {Section 2.3.3.1 }.
Similar ICW S)lstem oeerating conditions {flowrate1 eressure1 temeerature1 cooling water source1 etc.} for PTN Unit 3 and 4 will continue to erovide reeresentative inseection results for each unit.
Coating/lining surfaces caetured between interlocking surfaces
{e.g.1 flange faces} are not reguired to be inseected unless the joint has been disassembled to allow access for an internal coating/lining inseection or other reasons. For areas not readil)l accessible for direct inseection1 consideration is given to the use of remote or robotic inseection tools.
For cementitious ICW piping coatings within the scope of the program, inspectors should have a minimum of five years of experience inspecting or testing concrete structures or cementitious coatings/linings, or a degree in the civil/structural discipline and a minimum of one year of experience.
- 5. Monitoring and Trending A ere-inseection review of the erevious two ICW giging inseections is conducted 1 when available1 that includes reviewing the results of the insgections and anl£ subseguent regair activities. A coatings seecialist ereeares the eost-insgection regort to include: a list and location of areas evidencing deterioration1 a grioritization of the regair areas into areas that must be regaired before returning the S)lstem to service and areas where regair can be eosteoned to the next refueling outage1 and where eossible1 ghotograghic documentation indexed to insnection locations.
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 4 of 12 Element Affected Enhancement Where (!ractical, degradation is (!rejected until the next scheduled ins(!ection. Results are evaluated against the acce(!tance criteria to confirm that the sam(!ling bases will maintain the com(!onent's intended functions throughout the SPEO based on the (!rejected rate and extent of degradation.
- 7. Corrective Actions ICW (!i(!ing coatings/linings that do not meet acce(!tance criteria are re(!aired, re(!laced 1 or removed. Ph~sical testing is (!erformed where
(!h~sicall~ (!Ossible {i.e., sufficient room to conduct testing} or examination is conducted to ensure that the extent of re(!aired or re(!laced coatings/linings encom(!asses sound coating/lining material.
As an alternative, internal coatings exhibiting indications of (!eeling and delamination ma~ be returned to service if: {a} (!h~sical testing is conducted to ensure that the remaining coating is tightl~ bonded to the base metalj {bl the (!Otential for further degradation of the coating is minimized, {i.e., an~ loose coating is removed, the edge of the remaining coating is feathered}; {c} adhesion testing using ASTM International standards endorsed in RG 1.54 {e.g., (!LIii-off testing, knife adhesion testing} is conducted at a minimum of 3 sam(!le (!Oints adjacent to the defective areaj {d} an evaluation is conducted of the (!Otential im(!act on the s~stem, including degraded (!erformance of downstream com(!onents due to flow blockage and loss of material or cracking of the coated com(!onentj and {e} follow-LI(! visual ins(!ections of the degraded coating are conducted within 2 ~ears from detection of the degraded condition, with a reins(!ection within an additional 2 ~ears, or until the degraded coating is re(!aired or re(!laced.
If the ICW (!i(!ing base metal has been ex(!osed or it is beneath a blister, the com(!onent's base material in the vicinitv of the degraded coating/lining is examined to determine if the minimum wall thickness is met and will be met until the next ins(!ection.
When a blister does not meet the acce(!tance criteria, and it is not re(!aired 1 (!h~sical testing is conducted to ensure that the blister is com(!letel~ surrounded b~ sound coating/lining bonded to the surface. Ph~sical testing consists of adhesion testing using ASTM International standards endorsed in RG 1.54. Where adhesion testing is not (!Ossible due to (!h~sical constraints, another means of determining that the remaining coating/lining is tightl~ bonded to the base metal is conducted such as lightl~ ta(!(!ing the coating/lining. Acce(!tance of a blister to remain in service should be based both on the (!Otential effects of flow blockage and degradation of the base material beneath the blister.
Additional ins(!ections are conducted if one of the ins(!ections does not meet acce(!tance criteria due to current or (!rejected degradation {i.e., trending}. The number of increased ins(!ections is determined in accordance with the site's corrective action (!rocess; however, there are no fewer than five additional ins(!ections for each insoection that did not meet acceotance criteria. The timina of
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 5 of 12 Element Affected Enhancement the additional inseections is based on the severit~ of the degradation identified and is commensurate with the eotential for loss of intended function. However1 in all cases1 the additional inseections are comeleted within the interval in which the original inseection was conducted 1 or if identified in the latter half of the current inseection interval1 within the next refueling outage interval.
These additional inseections conducted in the next inseection interval cannot also be credited towards the number of inseections in the latter interval. If subseguent inseections do not meet acceetance criteria1 an extent of condition and extent of cause anal~sis is conducted to determine the further extent of inseections. Additional sameles are inseected for an~ recurring degradation to erovide reasonable assurance that corrective actions aeeroeriatel~ address the associated causes. The additional inseections include inseections at both PTN units with the same eieing material1 environment1 and aging effect combination.
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 6 of 12 Update the Commitment 15 of SLRA Table 17-3 as follows:
Aging Management Program NUREG-2191 No.
or Activity (Section)
Section Commitment 15 Open-Cycle Cooling Water XI.M20 Continue the existing PTN Open-Cycle Cooling Water System (17.2.2.11)
System AMP, including enhancement to:
a)
Delineate within the pertinent testing specification the descriptions of the specific aging mechanisms associated with coatings/linings (blistering, cracking, flaking, peeling, delamination, and rusting);
b) eA6blFe tl=!at tl=!e iAs13eGtieA ffeEfbl9ASY feF IGlJIJ 13i13iA§ iAternal iAs13estieAs EleliAeateEI iA tl=!e 13eFtiAeAt testiA§ s13esifisatieA sl=!e1c1IEI Aet exseeEI 5 yeaFs.. Pending seating insf!estien Fesults, Sf!esifis lesatiens may Fe!iJUiFe seatings ins(!estiens e*JeF\\' feuF veaFS in asseFdanse with NblRiG 2191 Sestien XI.M42 +able XI.M42 1. IA aEIElitieA, sl=laA§es te 13i13iA§ iAternal iAs13estieA iAteFVals aFe te ee estaelisl=!eEI ey a seatiA§ s13esialist EfblalifieEI iA asseFElaAse witl=! aA A~+M IAternatieAal staAElaFEI eAEleFseEI iA NRG RG 1.54.
ICW RiRing internal insRections are based on an evaluation of the effect of a coating/lining failure on the in-scoRe comRonent's intended function, ROtential Rroblems identified during Rrior insRections 1 and known service life histo!)l.
lnsRection intervals are established bl£ a coating SRecialist gualified in accordance with RG 1.54
[Reference B.3.20}. However, insRection intervals should not exceed those SRecified in GALL SLR Table XI.M42-1.
The extent of the ICW RiRing internal insRections is not an)! less than the following for each coating/lining material and environment combination. The coating/lining environment includes both the environment inside the oioina Implementation Schedule No later than 6 months prior to the SPEO, i.e.:
PTN3: 1/19/2032 PTN4: 10/10/2032
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 7 of 12 Aging Management Program NUREG-2191 No.
or Activity (Section)
Section Commitment Implementation Schedule and the metal to which the coating/lining is attached. Since PTN is a two-unit site1 a reQresentative samQle of fiftv-five (55} 1-foot axial length circumferential segments of QiQing are insQected Qer unit. The insQection surface includes the entire inside surface of the 1-foot segment. If geometric limitations imQede the insQection of the entire circumferential segment1 the number of insQection segments is increased in order to cover an eguivalent of fiftv-five (55} 1-foot axial length circumferential segments.
Where documentation exists that manufacturer recommendations and industrv consensus documents (i.e. 1 those recommended in RG 1.541 or earlier versions of those standards} were comQlied with during installation1 the extent of QiQing insQections ma~ be reduced to nineteen (19} 1-foot axial length circumferential segments of QiQing of each coating/lining material and environment combination at each unit. Reduction of the number of reguired ICW QiQing internal insQections is acceQtable for PTN Units 3 and 4 as the ICW s~stems on each unit are essential!~
identical (Section 2.3.3.1}. ICW s~stem OQerating conditions (flowrate1 Qressure1 temQerature1 cooling water source1 etc.} for PTN Unit 3 and 4 will continue to Qrovide reQresentative insQection results for each unit.
Coating/lining surfaces caQtured between interlocking surfaces (e.g.1 flange faces} are not reguired to be insQected unless the joint has been disassembled to allow access for an internal coating/lining insQection or other reasons. For
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 8 of 12 Aging Management Program NUREG-2191 No.
or Activity (Section)
Section Commitment Implementation Schedule areas not readill£ accessible for direct inspection 1 consideration is given to the use of remote or robotic inspection tools.
For cementitious ICW piping coatings within the scope of the program, inspectors should have a minimum of 5 years of experience inspecting or testing concrete structures or cementitious coatings/linings or a degree in the civil/structural discipline and a minimum of 1 year of experience.
c)
A pre-inspection review of the previous two ICW piping inspections is conducted 1 when available1 that includes reviewing the results of the inspections and any: subseguent repair activities.
A coatings specialist prepares the post-inspection report to include: a list and location of areas evidencing deterioration 1 a prioritization of the repair areas into areas that must be repaired before returning the sy:stem to service and areas where repair can be postponed to the next refueling outage1 and where possible1 photographic documentation indexed to inspection locations.
Where practical1 degradation is projected until the next scheduled inspection. Results are evaluated against the acceptance criteria to confirm that the sampling bases will maintain the component's intended functions throughout the SPEO based on the projected rate and extent of degradation.
$.fi Ensure the pertinent testing specification coating acceptance criteria include the following:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 9 of 12 Aging Management Program NUREG-2191 No.
or Activity (Section)
Section fil Commitment Implementation Schedule
- There are no indications of peeling or delamination.
- Blisters are evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size or frequency should not be increasing between inspections (e.g., ASTM D714-02, "Standard Test Method for Evaluating Degree of Blistering of Paints").
- Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard.
- Minor cracking and spalling of cementitious coatings/ linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
- As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
- Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in site-specific design requirements specific to the coating/lining and substrate.
Ensure ICW eieing coatings/linings that do not meet acceetance criteria are regaired 1 reelaced1 or removed. Ph3tsical testing is eerformed where gh3tsical!l£ eossible (i.e.1 sufficient room to conduct testina\\ or examination is conducted to ensure that
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 10 of 12 Aging Management Program NUREG-2191 No.
or Activity (Section)
Section Commitment Implementation Schedule the extent of reQaired or reQlaced coatings/linings encomQasses sound coating/lining material.
As an alternative1 internal coatings exhibiting indications of Qeeling and delamination ma~ be returned to service if: (a) Qh~sical testing is conducted to ensure that the remaining coating is tight!~ bonded to the base metal; (b) the QOtential for further d~radation of the coating is minimized1 (i.e.1 an~ loose coating is removed1 the edge of the remaining coating is feathered); (c) adhesion testing using ASTM International standards endorsed in RG 1.54 (e.g.1 QUll-offtesting1 knife adhesion testing) is conducted at a minimum of 3 samQle QQints adjacent to the defective area; (d) an evaluation is conducted of the Qotential imQact on the s~stem1 including degraded Qerformance of downstream comQonents due to flow blockage and loss of material or cracking of the coated comQonent; and (e) follow-uQ visual insQections of the d~raded coating are conducted within 2 ~ears from detection of the d~raded condition1 with a reinsQection within an additional 2 ~ears1 or until the d~raded coating is reQaired or reQlaced.
If the ICW QiQing base metal has been e!Qosed or it is beneath a blister1 the comoonent's base material in the vicini~ of the d~raded coating/lining is examined to determine if the minimum wall thickness is met and will be met until the next insQection. When a blister does not meet the acceQtance criteria1 and it is not reQaired 1 Qh~sical testing is conducted to ensure that the blister is comQletel~ surrounded b~ sound coating/lining bonded to the surface. Ph~sical testing consists of adhesion testing using ASTM
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 11 of 12 Aging Management Program NUREG-2191 No.
or Activity (Section)
Section Commitment Implementation Schedule International standards endorsed in RG 1.54.
Where adhesion testing is not gossible due to gh)lsical constraints, another means of detennining that the remaining coating/lining is tightlll bonded to the base metal is conducted such as lightll£ tagging the coating/lining.
Accegtance of a blister to remain in service should be based both on the ootential effects of flow blockage and d!!9radation of the base material beneath the blister.
Additional insgections are conducted if one of the insgections does not meet accegtance criteria due to current or grojected d!!9radation {i.e., trending}.
The number of increased insgections is detennined in accordance with the site's corrective action grocessj however, there are no fewer than five additional insgections for each ins1;2ection that did not meet accegtance criteria. The timing of the additional insgections is based on the seve!FL of the d!!9radation identified and is commensurate with the gotential for loss of intended function.
However, in all cases, the additional insgections are comgleted within the interval in which the original insgection was conducted, or if identified in the latter half of the current insgection interval, within the next refueling outage interval. These additional ins~ctions conducted in the next insgection interval cannot also be credited towards the number of insgections in the latter interval. If subs!!9uent insgections do not meet accegtance criteria, an extent of condition and extent of cause anal)lsis is conducted to detennine the further extent of insgections. Additional samgles are insgected for anl£ recurring d!!9radation to grovide
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251
. FPL Supplemental Response for OCCW AMP L-2019-071 Attachment 2 Page 12 of 12 Aging Management Program NUREG-2191 No.
or Activity (Section)
Section Associated
Enclosures:
None Commitment Implementation Schedule reasonable assurance that corrective actions am;!ro12riatel~ address the associated causes. The additional ins(!ections include ins(!ections at both PTN units with the same 12i12ing material1 environment1 and aging effect combination.