ML18080A168

Summary of Pre-Application Meeting Between the NRC and FPL to Discuss AMP XI.M16A, PWR Vessel Internals Associated with the Turkey Point Units 3 and 4, Subsequent License Renewal Application

ML18080A168
Person / Time
Site:	Turkey Point
Issue date:	12/21/2017
From:	Lois James Division of Materials and License Renewal
To:	Florida Power & Light Co
Lois M. James, 301-415-3306
References
L-2018-RNW-0002
Download: ML18080A168 (6)

Text

OFFICIAL USE ONLY - PROPRIETARY INFORMATION December 21, 2017 LICENSEE:

Florida Power & Light Company FACILITY:

Turkey Point Nuclear Generating, Unit Nos. 3 and 4

SUMMARY

OF PRE-APPLICATION MEETING HELD ON SEPTEMBER 6, 2017, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND FLORIDA POWER & LIGHT COMPANY REPRESENTATIVES TO DISCUSS AMP XI.M16A, "PWR VESSEL INTERNALS" ASSOCIATED WITH THE TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4, SUBSEQUENT LICENSE RENEWAL APPLICATION On September 6, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff met with members of Florida Power & Light Company (the applicant) in a closed door meeting to discuss the license renewal application for the Turkey Point Nuclear Generating Unit Nos. 3 and 4. The meeting agenda can be found at the NRCs Agencywide Documents and Access Management System Accession No. ML17230A025, a list of attendees is provided in Enclosure 1, and a summary of the meeting is provided in Enclosure 2.

Sincerely,

/RA/

Lois M. James, Senior Poject Manager License Renewal Project Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket Nos.: 50-250 and 50-251

Enclosures:

1.

Attendance List 2.

Meeting Summary cc w/encls: Listserv OFFICIAL USE ONLY - PROPRIETARY INFORMATION FPL submitted the Subsequent License Renewal Application on January 30, 2018 (ADAMS Package Accession No. ML18037A812) therefore, it is no longer necessary to withhold as proprietary.

ML17348B319

• concurrence via e-mail OFFICE PM:MRPB:DMLR LA:DLP:PBMB BC:MVIB:DML R

BC: MRPB:DMLR NAME LJames SLent SRuffin (A)

EOesterle DATE 12/20/17 12/19/17 12/21/17 12/21/17/

OFFICE PM:MRPB:DMLR NAME LJames DATE 12/21/17

OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION CLOSED MEETING BETWEEN THE NRC STAFF AND FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 SUBSEQUENT LICENSE RENEWAL APPLICATION - REACTOR VESSEL INTERNALS ROCKVILLE, MARYLAND MEETING ATTENDANCE LIST SEPTEMBER 6, 2017 PARTICIPANTS AFFILIATIONS Lois James U.S. Nuclear Regulatory Commission (NRC)

James Medoff NRC Bennett Brady NRC Joseph Donoghue NRC Seung Min NRC Theresa Buchanan NRC Allen Hiser NRC Dave Rudland NRC Jeff Poehler NRC Steve Ruffin NRC Heather Jones NRC Albert Wong NRC Mark Joseph Florida Power & Light Company (FPL)

Stephan Franzone FPL Bill Maher FPL Maribel Valdez FPL Richard Orthen FPL William Maher FPL Paul Jacobs FPL Steve Scroggs FPL Sara Mechtensimer FPL

OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION PARTICIPANTS AFFILIATIONS James V. Wick Enercon Stephen Hail Enercon Jack Hoffman Enercon Tom Slavonic Enercon Mary Hoganson Enercon Randall Lantz Enercon Susanna Scott Enercon Mike Margolis Enercon

OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION CLOSED MEETING BETWEEN THE NRC STAFF AND FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 SUBSEQUENT LICENSE RENEWAL APPLICATION - REACTOR VESSEL INTERNALS ROCKVILLE, MARYLAND MEETING

SUMMARY

SEPTEMBER 6, 2017 On May 17, 2017, Florida Power & Light Company (FPL, the licensee) submitted a Notice of Intent (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML17142A036 (non-public, proprietary) and ML17139D442 (public, non-proprietary)) to submit a supplemental license renewal application (SLRA) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). This Notice of Intent was submitted as proprietary information. On May 25, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff issued its approval of FPLs request for withholding information from public disclosure (ADAMS Accession Nos. ML17096A477 (non-public, proprietary) and ML17139D441 (public, non-proprietary)).

On September 6, 2017, the NRC staff participated in a pre-application, closed door meeting at NRC Headquarters with FPL to discuss Turkey Points plant specific program to implement MRP-227, Materials Reliability Program: Pressurized Water Reactor [PWR] Internals Inspection and Evaluation Guidelines. The proprietary meeting notice was issued on August 28, 2017 (ADAMS Accession No. ML17248A007, non-public), and was supplemented with additional topics to be discussed on September 5, 2017 (ADAMS Accession No. ML17248A007, non-public).

As a starting point, FPL stated that Turkey Points initial license renewal application (LRA) was submitted prior to the staffs issuance of NUREG-1801, Generic Aging Lessons Learned (GALL) Report, in July 2001. The licensee further stated that it submitted a letter of intent to Adopt Materials Reliability Program (MRP) Report MRP-227, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines" and Revision of Commitments, in May 2011 (ADAMS Accession No. ML11152A068), and affirmed that Turkey Points License Renewal Reactor Vessel Internals (RVI) Aging Management Program (AMP) meets all criteria specified in the NRC staffs safety evaluation for MRP-227 (MRP-227-A).

The NRC staff cautioned FPL that Action Item 8, Subpart 5 of the staffs safety evaluation of MRP-227, Rev. 0, may not have previously applied and FPL should address this action item in Turkey Points SLRA. The NRC staff also requested that FPL address whether all three criteria for plant-specific applicability of MRP-227-A were met throughout the plant life in the Turkey Points SLRA.

Following the meeting, the NRC staff found that on December 14, 2012, FPL submitted the Turkey Point License Renewal RVI Commitment Implementation Report and Inspection Plan (ADAMS Accession No. ML12363A103), and on December 18, 2015, the NRC staff issued it assessment of the licensee's submittal (ADAMS Accession No. ML15336A046) and addressed the applicant/licensee action items specified in MRP-227-A that are applicable to Turkey Point.

The staff concluded that the submittal was acceptable because it was consistent with the inspection and evaluation guidelines of MRP-227-A and because the licensee further explained

OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION that, in the development of the SLRA, no changes were made in the RVI component list or aging effects.

For the SLRA RVI AMP, MRP-175, Revision 0, Material Reliability Program: PWR Internals Aging Degradation Mechanism Screening and Threshold Values, is being used as the source of the screening criteria. The MRP-191, Materials Reliability Program: Screening, Categorization and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design, will be used to develop the fluence input parameters.

The NRC staff cautioned that these fluence values were not meant to be bounding, but are representative values based on expert panel elicitation, and the use of MRP-191 parameters and a scaling factor should be fully explained in the Turkey Point SLRA.

The staff identified additional areas of concern that should be addressed in the SLRA:

1. Evaluation of RVI component fatigue

2. Clear distinction between ASME Code Section XI items and MRP-227 items

3. Robust gap analysis (e.g., provide inputs and details of the analysis), not just results The NRC staff ended the closed meeting by stressing that the staff will strive for an 18 months schedule, assuming the SLRA is thorough, is sufficiently detailed, addresses previous requests for additional information, and considers peer review comments.