L-2025-168, Subsequent License Renewal Commitments 20 and 21 Revisions
| ML25295A251 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/21/2025 |
| From: | Mack K Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-2025-168 | |
| Download: ML25295A251 (1) | |
Text
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE: Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 October 21, 2025 L-2025-168 Turkey Point Subsequent License Renewal Commitments 20 and 21 Revisions
References:
- 1. Safety Evaluation Report, "Related to the Subsequent License Renewal of Turkey Point Generating Units 3 and 4," July 2019 (ADAMS Accession No. ML19191A057)
- 2. Florida Power and Light letter L-2018-152, "Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 1 Responses," dated August 31, 2018 (ADAMS Accession No. ML18248A257)
- 3. Florida Power and Light letter L-2018-175, "Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 5 Responses," dated October 17, 2018 (ADAMS Accession No. ML18292A642)
- 4. NUREG-2191, Volume 2, "Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report August 2016 (ADAMS Accession No. ML17187A204)
Florida Power and Light Company (FPL) hereby submits this notification of two (2) regulatory commitment changes for Turkey Point Units 3 and 4. Reference 1 documents the NRC review of FPL's Fire Water System and Outdoor and Large Atmospheric Metallic Storage Tanks programs and concludes the program elements have demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the current licensing basis (CLB) for the subsequent period of extended operation (SPEO), as required by 1 O CFR 54.21 (a)(3).
Turkey Point Commitments 20.e and 21.b state that a new procedure will be developed that performs tank bottom thickness inspections using the low frequency electromagnetic testing (LFET) technique and, as necessary, follow-up ultrasonic examinations. The Turkey Point commitment to utilize the LFET technique for tank bottom inspections was documented in the response to RAls B.2.3.16-3 and B.2.3.17-3, which are included in Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2025-168 Page 2 of 3 Reference 2 and 3, respectively. During the evaluation of the Turkey Point response to RAls B.2.3.16-3 and B.2.3.17-3, the staff noted that the LFET method of conducting tank bottom thickness measurements is an acceptable method cited in footnote 3 of GALL-SLR Table XI.M29-1 (Reference 4). The staff also noted Turkey Point's response and proposed procedure to conduct tank bottom thickness measurements as acceptable because the test methods and periodicity will be consistent with GALL-SLR Report AMP XI. M29.
To provide additional flexibility in performing the SLR tank bottom inspections, Turkey Point also proposes utilizing either phased array ultrasonic testing (PAUT) or guided wave phased array (GWPA) techniques.
PAUT is a non-destructive testing (NDT) method that uses a multi-element ultrasonic transducer to generate and receive sound waves, allowing for electronic control to steer, focus, and sweep beams in ways impossible with single-probe conventional methods. By individually controlling the timing of pulses to each element in the array, PAUT creates and shapes ultrasonic beams, resulting in faster scanning, more accurate flaw detection, and detailed imaging of a component's internal structure.
GWPA testing is an advanced ultrasonic inspection technique that uses an array of transducers to electronically steer and sweep guided waves around a stationary probe to rapidly screen large structures like pipelines and tank shells for flaws. By phasing the individual elements of the array, the system creates a steered ultrasonic beam that can scan 360 degrees, creating high-resolution, radar-like images of the structure's interior and exterior from a single probe position. This allows for rapid detection and localization of various defects, such as corrosion, cracks, and wall thickness changes. GWPA will scan all accessible portions of the tank bottom and identify critical areas that require additional targeted UT examination.
Regardless of which testing method is used to assess the Turkey Point outdoor tank bottoms in the scope of SLR (PAUT or GWPA), the examination packages for each tank will include documentation demonstrating that the testing method effectively detects aging effects that require management (AERM). Additionally, the documentation will confirm that a sufficient portion of the tank's bottom surface is examined to provide reasonable assurance that localized aging effects are identified. This requirement is consistent with footnote 3 of GALL-SLR Table XI.M29-1.
An additional editorial change is made to Commitments 20.e and 21.b to delete reference to the development of a new procedure, as vendor procedures will be used to perform the tank bottom inspections.
Should you have any questions regarding this submittal, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 21 day of October 2025.
Sincerely, <'z~~
Kenneth A. M~
,/
Director, Licensing and Regulatory Compliance Florida Power and Light Company Attachment (1) cc: USN RC Regional Administrator, Region II USN RC Project Manager, Turkey Point Nuclear Plant USN RC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. Clark Eldredge, Florida Department of Health L-2025-168 Page 3 of 3
Attachment Turkey Point Units 3 and 4 UFSAR Table 17.4-1 Changes NOTE Bold is the new information.
Strikethrough is information deleted Commitment No. 20 Continue the existing PTN Fire Water System AMP, including enhancement to:
a) Replace sprinklers before they reach 50 years of service or test a representative sample of sprinklers from one or more sample areas using the guidance of NFPA 25; b) Perform volumetric wall thickness inspections on the portions of the water-based FPS components periodically subjected to flow but normally dry; c) Perform additional volumetric wall thickness inspections after surface irregularities, indicative of corrosion or erosion, are visually detected; d) Perform testing and visual inspections in accordance with the methods and intervals from Table XI.M27-1 from NUREG-2191, (based on NFPA 25, 2011 Ed.) and perform external visual inspections on a refueling outage interval. These inspections and tests include inspection parameters for items such as lighting, distance offset, presence of protective coatings, and cleaning processes.
e) Perform volumetric inspections from the inside surface of the raw water tanks (T63A/B) in accordance with NUREG-2191, Table XI.M29-1. These inspections are required to be performed for each 10-year period starting 1 O years prior to the SPEO. The new procedure performs tTank bottom thickness inspections will be performed using either; 1) the low-frequency electromagnetic testing (LFET) technique and, as necessary, followup ultrasonic examinations, 2) the phased array ultrasonic testing (PAUT) technique, or 3) the guided wave phased array (GWPA) technique and, as necessary, followup ultrasonic examinations.
Regardless which testing method is used to assess the raw water tanks, the examination packages for each tank will include documentation demonstrating that the testing method effectively detects aging effects that require management (AERM). Additionally, the documentation will confirm that a sufficient portion of the tank's bottom surface is examined to provide reasonable assurance that localized aging effects are identified.
Commitment No. 21 Continue the existing PTN Outdoor and Large Atmospheric Metallic Storage Tanks AMP, including enhancement to:
a) Add the U3 EDG FOST and the Unit 3 and 4 PWSTs and associated acceptance criteria to the scope of the AMP; b) Convert one-time inspections for original license renewal to the following periodic inspections, with the associated frequencies and acceptance criteria -
Visual examination of tank internal surfaces Develop a new* procedure to perform the tTank bottom thickness inspections will be performed using either; 1) the low-frequency electromagnetic testing (LFET) technique and, as necessary, followup ultrasonic examinations, 2) the phased array ultrasonic testing (PAUT) technique, or
- 3) the guided wave phased array (GWPA) technique and, as necessary, followup ultrasonic examinations. Regardless which testing method is used to assess the tanks, the examination packages for each tank will include documentation demonstrating that the testing method effectively detects aging effects that require management (AERM).
Additionally, the documentation will confirm that a sufficient portion of the tank's bottom surface is examined to provide reasonable assurance that localized aging effects are identified.
Note: These additional inspections will be conducted each 10-year interval starting 1 O years prior to entering the SPEO.
c) Clarify that increased inspections address each tank in a material environment combination in the same inspection interval, including tanks from both units, IF only one tank is inspected and does not meet acceptance criteria, which requires corrective action.