ML18086A705

Plan for the Operating Experience Review Audit Regarding the Subsequent License Renewal Application Review

ML18086A705
Person / Time
Site:	Turkey Point
Issue date:	04/26/2018
From:	Lois James NRC/NRR/DMLR/MRPB
To:	Nazar M Florida Power & Light Co
James L, NRR-DMLR 415-3306
References
EPID L-2018-RNW-0002
Download: ML18086A705 (10)

Text

April 26, 2018

.

Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division Florida Power & Light Company Mail Stop EX/JB 700 Universe Blvd Juno Beach, FL 33408

SUBJECT:

TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 - PLAN FOR THE OPERATING EXPERIENCE AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2018-RNW-0002)

Dear Mr. Nazar:

By letter dated Januay 30, 2018 (Agencywide DocumentsAccess and Management System Package Accession No. ML18037A812), as supplemented and revised, Florida Power & Light Company (FPL or the applicant) submitted an application for subsequent license renewal of Renewed Facility Operating License Nos. DPR-31 and DPR-41 for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point), respectively. FPL requested renewal of the Turkey Point operating licenses for an additional 20 years beyond the current renewed 60-year current license terms, which expire on July 19, 2032, for Unit 3 and April 10, 2033, for Unit 4.

The U.S. Nuclear Regulatory Commission staff plans to conduct this audit at the EXCEL Services Corporation offices in Rockville, Maryland, from May 7 - 18, 2018, in accordance with the enclosed operating experience audit plan and audit needs list. If you have any questions, please contact me by telephone at 301-415-3306 or by e-mail at Lois.James@nrc.gov.

Sincerely,

/RA/

Lois M. James, Senior Project 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. Audit Plan

2. Audit Needs List cc w/encl: Listserv

ML18086A705 OFFICE PM:MRPB:DMLR LA:MRPB:DMLR PM:MRPB:DMLR BC:MRPB:DMLR NAME LJames YEdmonds BRogers EOesterle DATE 4/20/2018 4/20/2018 4/20/2018 4/23/2018 OFFICE OGC (NLO)* PM:MRPB:DMLR NAME STurk LJames DATE 4/21/2018 4/26/2018

Audit Plan Operating Experience Review Audit Regarding the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Subsequent License Renewal Application May 7 - 18, 2018 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure 1

Operating Experience Audit Regarding the Turkey Point Nuclear Generating Unit Nos. 3 and 4, Subsequent License Renewal Application Audit Plan

1. Background By letters dated January 30, 2018, (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18037A812), February 9, 2018 (ADAMS Accession No. ML18044A653), February 16, 2018 (ADAMS Package Accession No. ML18053A123),

March 1, 2018 (ADAMS Package Accession No. ML18072A224), and April 10, 2018 (ADAMS Accession Nos. ML18102A521 and ML18113A132), Florida Power & Light Company (FPL or the applicant) submitted an application for subsequent renewal of Operating Licenses Nos.

DPR-31 and DPR-41 for the Turkey Point Nuclear Generating Units 3 and 4 (Turkey Point),

respectively. FPL requested renewal of the Turkey Point operating licenses for an additional 20 years beyond the current renewed 60-year current license terms, which expire on July 19, 2032, for Unit 3 and April 10, 2033, for Unit 4. The staff of the U.S. Nuclear Regulatory Commission (NRC) performs an independent review of plant specific operating experience to identify examples of age related degradation, as documented in the applicants corrective action program database.

2. Regulatory Audit Bases License renewal requirements are specified in Title 10 of the Code of Federal Regulations (10 CFR), Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

Guidance is provided in NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), dated July 2017, and NUREG-2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, dated July 2017.

3. Regulatory Audit Scope The scope of this subsequent license renewal regulatory audit of Turkey Point is the NRC staffs independent review of plant specific operating experience. The review is performed to identify pertinent examples of age related degradation, as documented in the applicants corrective action program database. The results of the audit will be used to support the NRC staffs further review of aging management programs (AMPs), time limited aging analyses (TLAAs) and aging management review (AMR) items to provide a basis for the NRC staffs conclusions on the ability of the applicants proposed AMRs, AMPs and TLAAs to manage the effects of aging in the period of extended operation.

The NRC staff will use risk insights to focus the breadth and depth of its review of plant specific operating experience. However, the NRC staffs review is not limited to risk significant systems and components because 10 CFR Part 54 is a deterministic rule. The NRC staff must conclude that there is reasonable assurance that activities will continue to be conducted in accordance with the current licensing basis and the effects of aging will be managed during the period of extended operation for all structures and components within the scope of 10 CFR Part 54.

4. Information and Other Material Necessary for the Regulatory Audit As described in the Audit Needs List in Enclosure 2.

5. Team Assignments Area of Review Assigned Auditors (include, but not limited to)

Documentation of plant specific operating Allik, Brian experience as described in the Turkey Point Beaton, Robert Nuclear Generating Unit Nos. 3 and 4 Buford, Angela corrective action program database. Chereskin, Alexander Disciplines include mechanical, materials, Cuadrado de Jesus, Samuel structural, electrical and systems. Fairbanks, Carolyn Fu, Bart Gardner, William Gavula, James Holston, William Huynh, Alan Iqbal, Naeem James, Lois Johnson, Andrew Jones, Steve Kalikian, Roger Lopez, Juan Nguyen, Duc Nold, David Prinaris, Andrew Render, Diane Rezai, Ali Rogers, Bill Sacko, Fanta Sadollah, Mohammad Sydnor, Christopher Thomas, George Tsao, John Wong, Albert Yee, On Yoder, Matthew

6. Logistics The audit will be conducted on location at the EXCEL Services Corporation offices in Rockville, Maryland, from May 7 - 18, 2018. Entrance and exit briefings will be held at the beginning and end of this audit, respectively.

7. Special Requests The NRC staff requests that FPL provide electronic access to Turkey Point information, as discussed in the Audit Needs List in Enclosure 2. The NRC staff requests a suitable facility for the audit team to caucus during the audit and to hold meetings between NRC staff and FPL personnel.

8. Deliverables An audit report should be issued to FPL within 90 days from the end of the audit.

Operating Experience Audit Regarding the Turkey Point Nuclear Generating Unit Nos. 3 and 4, Subsequent License Renewal Application Audit Needs List

1. Corrective Action Program Database The U.S. Nuclear Regulatory Commission (NRC) staff requests electronic access, using Florida Power & Lights (FPLs) equipment, to FPLs corrective action program (CAP) database to perform independent searches of the database.

2. License Renewal Portal The staff requests electronic access, using FPLs equipment, to the license renewal portal.

3. Prepared Operating Experience Keyword Review Results The NRC staff requests that 10 years of plant-specific CAP entries be compiled into an excel workbook, organized by keywords. The data entered would be all CAP entries (e.g., issue reports, condition reports) that cite one of the keywords in the table below. This spreadsheet will be used by the staff during the Operating Experience (OpE) Audit. The parameters for the database should be as follows.

• The CAP entries should be compiled with an individual datasheet for each term. Some CAP entries could appear in multiple datasheets due to the use of multiple search terms when the CAP entry was initiated.

• At a minimum, each entry should include the CAP entry number, date of initiation, and the title of the CAP entry or a brief summary. The efficiency of the staffs screening review is increased with more details in the excel spreadsheet. For example, a simple title might result in the CAP entry appearing to be an applicable age-related issue; however, when the full entry is reviewed, it may be noted that the degradation was not age related (e.g., damage during excavating buried pipe, damage to internal coatings as a result of scaffold installation).

• For efficiency, it would be helpful to the staff if the CAP entries include the plant system number. This is not required, but it can improve the efficiency of the staffs review process. Specifically, generic search terms such as corros, indication, pit, etc.,

provide a large number of entries and the staffs search time can be significantly reduced if the plant system is identified.

The staff requests electronic access, using FPL equipment, to the results of the operating keyword list query of FPLs corrective action database. The results are expected to be in an excel workbook, organized by keywords.

Enclosure 2

LIST OF KEYWORDS FOR OPERATING EXPERIENCE AUDIT 89-13 EPR NEUTRON FLUX DETECTOR AGE1 EQ NEUTRON-ABSORB AGED1 EQ AUDIT NICKEL-ALLOY AGING EQ INSPECTION NOBLE ALUMINUM EQ REANALYSIS NODUL ARC EQ SELF ASSESSMENT OIL ANALYSIS ARCING EROSI ORGANIC BAC ETHYLENE PROPYLENE OXIDATION RUBBER BIOFOUL EXCAVAT OXYGEN BIOLOGICAL EXCORE PARTIAL DISCHARGE BLISTER FAC PEEL BLOCK FAIL PERFORAT BOLT FATIGUE PIPING BORAL FEEDWATER NOZZLE PIT BORIC FIRE BARRIER POLYMER BREAK FLAK POLYMER HV INSULATORS BRITTLE FLAW PRELOAD BRITTLE CABLE FLOW ACCELERATED PWSCC BRITTLE INSULATION FLOW ACCELERATED Q LIST CORROSION BRONZE FLOW RESTRICT QUALIFICATION BRYOZOA FLOW RESTRICTOR RADIATION MONITORING BURIED FLOW-ACCELERATED RECUR BUS FLOW-ASSIST REDU CABLE FLUORIDE RESIDUE CABLE BURNED FOUL RETURN LINE NOZZLE CABLE BUS FRACTURE RUPTURE CABLE BUS - EXTERNAL FUEL HANDLING BUILDING RUST SURFACE - CORROSION - RADIATION MONITOR PITTING CABLE BUS - REDUCED FUEL OIL SCALE ELECTRICAL INSULATION CABLE CONTAMINATION FUSE HOLDER SCALING 1

For terms enclosed in quotation marks, the intent is that when compiling the database, only CAP entries where the term is used independently are included. For example, for age, CAP entries would not be included where age was used in package or signage.

LIST OF KEYWORDS FOR OPERATING EXPERIENCE AUDIT CABLE DEGRADATION GALVANIC SCC CABLE DISCOLORED GROUT SEDIMENT CABLE INSULATION HALON SEEP CABLE REPLACED HANGER SERVICE WATER CABLE RESIDUE HARDEN SHELL CABLE TESTING HEAT EXCH SILICONE RUBBER CARBON DIOXIDE HEAT SINK SILT CAST HEAT TRANS SIR CAVITAT HIGH RANGE SPALL CONTAINMENT AREA MONITOR CHECWORK HIGH RANGE RADIATION SPRAY MONITOR CHLORIDE HIGH VOLTAGE SPRINKLER INSULATOR CLAM HIGH VOLTAGE STEEL INSULATOR - CRACKS -

FOREIGN DEBRIS CLEVIS HIGH VOLTAGE STRESS INSULATOR -

MECHANICAL WEAR-CORROSION CLOG HIGH VOLTAGE STRESS CORROSION INSULATOR - REDUCED CRACKING ELECTRICAL INSULATION CLOSURE STUD HIGH VOLTAGE STRUCTURAL SUPPORT INSULATOR - SALT - DUST

- COOLING TOWER PLUME

- CONTAMINATION CMU HOLE STUCK CO2 HOLIDAY SUBMERGED CABLE COAT HWC SULFATE COMPONENT COOLING HYDROGEN WATER SUMP WATER RADIATION CHEMISTRY MONITOR CONCRETE IMPINGE SUMP PUMP CONDUCTIVITY INDICATION SWITCHYARD CONNECTION INFRARED INSPECTION TAN DELTA CONTAMINATED CABLE INSTRUMENT AIR TANK COOLER INSULATION TERMINATION COPPER INSULATION RESISTANCE THERMAL CORONA CAMERA INSULATOR THERMOGRAPHY

LIST OF KEYWORDS FOR OPERATING EXPERIENCE AUDIT CORRO INTERG THREAD CORROS INTERMITTENT THROUGH WALL CRACK IRON TRACKING CRACKED CABLE JACKET TRANSGRA CRANE LEACH TRANSIENT MONITORING CREVICE LEAK TRANSMISSION CONDUCTOR - LOSS OF STRENGTH - CORROSION CYCL LINED TRANSMISSION CONNECTORS -

OXIDATION - LOSS OF PRELOAD DAMAGE LINING TRANSMISSION LINE DAMPER LITHIUM UNDERGROUND DEALLOY LOSS OF MATERIAL VAULT DEALUM MAIN CONTROL ROOM VESSEL INTERNALS RADIATION MONITO DEGRAD MANHOLE VIBRATION DEGRADED CABLE MASONRY VOLTAGE DEGRAPH MEB WALL LOSS DELAMIN MEDIUM VOLTAGE CABLE WALL THICK DEPOSITS METAL ENCLOSED BUS WALL THIN DETECTION MIC WASTAGE DETERIORATED CABLE MICROBIOLOGIC WASTED DEZINC MIN WALL WATER INTRUSION DISSOLVED OXYGEN MOLLUSK WEAR DRAINAGE MOLY WELD DRIP MORTAR WORN DROP NEUTRON ABSORB WRAP DUG NEUTRON FLUX ZINC It would be helpful to the staff to have one datasheet which incorporates all of the entries associated with the OpE key word terms. This datasheet would be used by staff to search for CAP entries that might not be associated with a specific OpE search term, but is of interest due to data reviewed by accessing the search terms.