ML18230B482

Report for the In-Office Regulatory Audit Regarding the Subsequent License Renewal Application Review

ML18230B482
Person / Time
Site:	Turkey Point
Issue date:	10/15/2018
From:	Lois James Division of Materials and License Renewal, NRC/NRR/DMLR/MRPB
To:	Nazar M Florida Power & Light Co
Lois James
References
EPID L-2018-RNW-0002
Download: ML18230B482 (101)

Text

October 15, 2018

.

Mr. Mano Nazaar President, Nuclear Division and Chief Nuclear Officer Florida Power and Light 700 Universe Blvd EX/JB Juno Beach, FL 33408

SUBJECT:

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

Dear Mr. Nazar:

By letters dated January 30, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18037A812), February 9, 2018 (ADAMS Accession No. ML18044A653), February 16, 2018 (ADAMS Accession No. ML18053A123), March 1, 2018 (ADAMS Accession No. ML18072A224), and April 10, 2018 (ADAMS Accession Nos. ML18102A521 and ML18113A132), Florida Power & Light Company (FPL) 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) to the U.S. Nuclear Regulatory Commission (NRC) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and part 54 of title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants.

The NRC staff completed its in-office regulatory audit from June 18, 2018 through July 23, 2018, in accordance with the in-office regulatory audit plan (ADAMS Accession No. ML18160A012).

The audit report is enclosed.

If you have any questions, please contact me 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

Enclosure:

Audit Report cc w/encl: Listserv

ML18230B482 OFFICE PM:MRPB:DMLR LA:MRPB:DMLR BC:MVIB:DMLR BC:MPHB:DMLR NAME LJames SLent* DAlley* SRuffin*

DATE 08/27/2018 08/27/2018 08/22/2018 08/06/2018 OFFICE BC:MCCB:DMLR BC: ESEB:DE BC:EENB:DE BC:ARCB:DRA NAME SBloom* BWittick* TMartinez-Navedo* KHsueh*

DATE 08/14/2018 08/14/2018 08/06/2018 08/09/2018 OFFICE BC:MRPB:DLR PM:MRPB:DMLR NAME EOesterle* LJames DATE 09/26/2018 10/15/2018

Audit Report In-Office Regulatory Audit Regarding the Turkey Point Nuclear Generating Unit Nos. 3 and 4, Subsequent License Renewal Application June 18 - July 23, 2018 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket Nos: 50-250 and 50-251 License No: DPR-31 and DPR-41 Licensee: Florida Power & Light Company Facility: Turkey Point Nuclear Generating Unit Nos. 3 and 4 Location: Rockville, Maryland Dates: June 18 - July 23, 2018 Reviewers: L. James, Senior Project Manager, Division of Materials and License Renewal (DMLR)

B, Allik, Materials Engineer, DMLR R. Beaton, Reactor Systems Engineer, Division of Safety Systems (DSS)

T. Brimfield, Reactor Systems Engineer, DSS A. Buford, Structural Engineer, Division of Engineering (DE)

A. Chereskin, Chemical Engineer, DMLR S. Cuadrado de Jesus, Structural Engineer, DE C. Fairbanks, Senior Materials Engineer, DMLR B. Fu, Materials Engineer, DMLR W. Gardner, Physical Scientist, DMLR J. Gavula, Mechanical Engineer, DMLR D. Hoang, Structural Engineer, DE K. Hoffman, Materials Engineer, DMLR W. Holston, Senior Mechanical Engineer, DMLR A. Huynh, Materials Engineer, DMLR N. Iqbal, Fire Protection Engineer, Division of Risk Assessment A. Johnson, Materials Engineer, DMLR R. Kalikian, Materials Engineer, DMLR B. Lehman, Structural Engineer, DE J. Lopez, Structural Engineer, DE D. Nguyen, Electrical Engineer, DE A. Prinaris, Structural Engineer, DE A. Rezai, Materials Engineer, DMLR F. Sacko, Electrical Engineer, DE M. Sadollah, Electrical Engineer, DE C. Sydnor, Materials Engineer, DMLR G. Thomas, Senior Structural Engineer, DE J. Tsao, Senior Materials Engineer, DMLR O. Yee, Materials Engineer, DMLR M. Yoder, Senior Chemical Engineer, DMLR

Approved By: Approved By: David Alley, Chief Vessels & Internals Branch Division of Materials and License Renewal Steve Bloom, Chief Chemical, Corrosion, & Steam Generator Branch Division of Materials and License Renewal Eric Oesterle, Chief License Renewal Projects Branch Division of Materials and License Renewal Steve Ruffin, Chief Piping & Head Penetration Branch Division of Materials and License Renewal Tania Martinez-Navedo, Chief Electrical Engineering, New Reactors, & License Renewal Branch Division of Engineering Brian Wittick, Chief Structural Engineering Branch Division of Engineering Kevin Hsueh, Chief Radiation Protection & Consequence Branch Division of Risk Assessment

Report for the In-Office Regulatory Audit Regarding the Turkey Point Nuclear Generating Unit Nos. 3 and 4, Subsequent License Renewal Application

1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an in-office audit of Florida Power & Light Companys (FPLs or the applicants) (1) methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR) (Scoping and Screening Portion), and (2) aging management programs (AMPs), AMR items, Time-Limited Aging Analyses (TLAA) and associated bases and documentation as applicable (AMP and TLAA Portion) for the 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).

The purpose of the Scoping and Screening Portion of the audit is to evaluate the scoping and screening process as documented in the license renewal application, implementing procedures, reports, and drawings, such that the NRC staff:

• Obtains an understanding of the process used to identify the SSCs within the scope of license renewal and to identify the structures and components subject to an aging management review.

• Has sufficient docketed information to allow it staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied.

The purpose of the AMP and TLAA Portion of the audit is to:

• Examine FPLs AMPs, AMR items, and TLAAs for Turkey Point;

• Verify FPLs claims of consistency with the corresponding NUREG-2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued in July 2017, AMPs, and AMR items; and

• Assess the adequacy of the TLAAs.

Enhancements and exceptions will be evaluated on a case-by-case basis. The NRC staffs review of enhancements and exceptions will be documented in the safety evaluation report.

NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, issued in July 2017 (SRP-SLR), provides staff guidance for reviewing a subsequent license renewal application. The SRP-SLR allows an applicant to reference in its license renewal application the AMPs described in GALL-SLR Report. By referencing the GALL-SLR Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL-SLR Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL-SLR Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL-SLR Report program. The applicant should document this determination in an auditable form and maintain the documentation onsite.

2. Audit Activities A regulatory audit is a planned, license-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain greater understanding of an application, to verify information, and/or to identify information that will require docketing to support the staffs conclusions that form the basis of the licensing or regulatory decision.

Licensing conclusions or staff findings should not be made in the audit reports since licensing and regulatory decisions cannot be made solely based on an audit. Therefore, items identified but not resolved within the scope of the audit will be followed using other NRC processes, such as requests for additional information, requests for confirmation of information, and public meetings. Licensing conclusions, staff findings, and resolution of audit items will be documented in the staffs safety evaluation report (SER).

The following sections discuss the subsequent license renewal application (SLRA) areas reviewed by the staff.

SLRA AMP B.2.2.1, Fatigue Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.2.1, Fatigue Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Fatigue Revision 1 070 Monitoring 0-ADM-651 Nuclear Chemistry Parameters Manual Revision 11 0-ADM-553 Maintaining Records for Design Cycles Revision 5 SIA Report No. Evaluation of Environmentally-Assisted Fatigue for Turkey Point Revision 5 - April 1700109.401P Units 3 and 4 for Subsequent License Renewal, April 2018 2018 During the audit, the staff verified that the preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, and parameters monitored or inspected, program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP.

In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing requests for additional information (RAIs). The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the Updated Final Safety Analysis Report (UFSAR) supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA AMP B.2.2.3, Concrete Containment Unbonded Tendon Prestress Summary of Information in the Application. The SLRA states that AMP B.2.2.3, Concrete Containment Unbonded Tendon Prestress, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP X.S1, Concrete Containment Unbonded Tendon Prestress. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

During the audit, the staff reviewed the enhancement associated with this AMP. The enhancement is evaluated in the SER.

Audit Activities. During its audit, the staff reviewed onsite documentation provided by the applicant.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- AMP Basis Document - Concrete Containment Unbonded Revision 1 101 Tendon Prestress FPLCORP020-REPT-Containment Structure and Internal Structural Components Revision 3 056 FPLCORP020-REPT- AMP Basis Document - ASME [American Society of Revision 1 103 Mechanical Engineers] Section XI, Subsection IWL Reactor Containment Building-Concrete Containment Inservice I2-ISI/IWL-PTN-3/4 Revision 1 Inspection Program

Document Title Revision / Date PTN-ENG-LRAM ASME Section XI, Subsection IWL Inservice Inspection Revision 3 0025 Program - License Renewal Program Basis Document 0-ADM-532 ASME Section XI Repair/Replacement Program Revision 1 PTN-BSFC-99-2005 Renewal and Subsequent License Renewal - Calculations Revision 2 During the audit, the staff verified that the preventive actions and parameters monitored or inspected program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the scope of program, detection of aging effects, monitoring and trending, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• Procedure I2-ISI/IWL-PTN-3/4 states that [f]or the 45th year inspection, calculation of prestress losses should also be performed based on the methodology of Regulatory Guide (RG) 1.35.1 for comparison. The scope of program program element of SLRA AMP B.2.2.3 is enhanced to account for its guidance, consistent with the GALL-SLR Report AMP X.S1. The Turkey Point SLRA commits implementation of RG 1.35.1, Determining Prestressing Forces for Inspection of Prestressed Concrete Containments, to be [n]o later than 6 months prior to the subsequent period of extended operation (SPEO). It is not clear to the staff whether the guidance of RG 1.35.1 was followed during the 45th year of IWL inspection and is part of the current licensing basis (CLB).

• Procedure I2-ISI/IWL-PTN-3/4 states that the common tendons for the 20th through the 45th year inspections of Units 3 and 4 were 51H18, 12V22, 3D8 and 62H82, 45V10, 3D20, respectively. However, a review of PTN-BSFC-99-2005 does not seem to support this. In accordance with IWL-2521, common or controlled tendons should be selected from the first year sample and kept unchanged unless detensioned per ASME Code,Section XI, Subsection IWL-2521 and IWL-3300. It is not clear how the applicant could develop a tendon prestress force history and correlate past observed data with those to be obtained from future inspections.

• SLRA AMP B.2.3.31, ASME Section XI, Subsection IWL, and its basis document FPLCORP020-REPT-103 state that the applicant plans to follow the frequency of tendon inspections consistent with IWL-2421 for sites with two units during the SPEO. When containments are twin containments, IWL-2421 allows modifications to inspection dates and examination requirements. However, the two Turkey Point units had concrete recast/replaced and tendons replaced and restressed in years following their original construction. It is not clear whether alterations made to the concrete containment(s) and its/their tendon prestress system(s) affected the twin containment claim for alternating the frequency of measurements of tendon lift-off forces.

During the audit of the operating experience program element, the staffs independent database search did not identify operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR.

However the staff noted that the statement in SLRA Section 17.2.1.3, Concrete Containment Unbonded Tendon Prestress, that states [t]he inspections are conducted every five years (i.e., 1, 3, 5, 10, 15, 20, 25, 30, 35, 40, 45th year, etc.) on alternating units, may need modification pending resolution of the applicability of IWL-2421. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

SLRA AMP B.2.2.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. The SLRA states that AMP B.2.2.4, Environmental Qualification of Electric Equipment is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.E1, Environmental Qualification of Electric Equipment. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancement associated with this AMP. The enhancement to the GALL-SLR Report AMP is evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed relevant documentation provided by the applicant.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP-020-REPT Aging Management Program Basis Document - Environmental 01/03/2018 109 Qualification of Electric Equipment FPLCORP-020-CALC- Turkey Point Unit 3 and 4 Environmental Qualification TLAA 06/23/2017 002 Evaluations - Calculations for TLAA FPLCORP-020-REPT Turkey Point Unit 3 and 4 Subsequent License Renewal 01/26/2018 120 Operating Experience Review Results - Aging Management Program Effectiveness PTN-ENG-LRTA Time Limited Aging Analysis and Exemptions 11/28/2000 044

Document Title Revision / Date 0-ADM-703 10 CFR [Code of Federal Regulation] 50.49 Environmental 06/15/2016 Qualifications 0-ADM-704 Environmental Qualifications Maintenance Index 04/02/2018 ER-AA-112 Environmental Qualifications Program Revision 0 PTN-ENG-LRAM Environmental Qualifications Program Revision 9 0003 2017 - Q4 Environmental Qualifications Program Health Report 12/11/2017 NEE-291-PI-005 Enercon Services Inc., Project Instructions for Confidential 04/21/2017 License Renewal Project - TLAAA Scoping and Exemptions identification and Evaluation Document EQ-DOC-PAC-1001 Turkey Point Unit 3 and 4 EQ Qualification Documentation 09/08/2014 Package 1001- EQ General Approach and Treatment of Issues DOC-PAC No. 1.0 Anaconda Wire and Cable Co. - Electric Cable 11/16/11 DOC-PAC No. 19.0 Okonite Co. - Electric Cable 01/24/2013 DOC-PAC No. 21.2 Raychem Corp. - Flametrol Electric Cable 01/16/2011 During the audit, the staff verified that the scope of program, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the preventive actions, parameters monitored or inspected, detection of aging effects, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observation:

• The staff reviewed the AMP basis document FPLCORP-020-REPT-109, and noted that preventive actions, parameters monitored or inspected, detection of aging effects, and corrective actions program elements do not mention Adverse Localized Environments (ALE). These corresponding elements in GALL-SLR AMP X.E1 include a discussion of ALE which is missing in the applicants basis document.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement section A.17.2.1.4. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The SLRA states that AMP B.2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD is an existing program that will be consistent with the program elements in GALL-SLR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant.

The table below lists documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - ASME Rev. 1 072 Section XI Inservice Inspection, Subsections IWB, IWC and 01/05/2018 IWD NDE 4.5 Non-Destructive Examination Procedure Rev. 4 03/28/2008 ENG/CSI-NDE-08-037 Strategic Plan for Stream Generator Integrity Rev.2 02/2016 PTN-LR-02-0027 License Renewal Screening Results Summary Report 03/11/2002 FPLCORP020-REPT- Aging Management Program Basis Document - Operating Rev. 0 120 Experience (OpE) Program Report FPLCORP120-REPT- Subsequent License Renewal Aging Management Review Rev. 0 028 Reactor Vessel FPLCORP020-REPT- Aging Management Program Basis Document - Reactor Rev. 1 032 Coolant System and Connected Piping AR 00459396 RPV [reactor pressure vessel] head BMV [bare metal visual] 03/26/2009 lessons learned AR 00467808 License Renewal Self-Assessment. 07/21/2009 AR 00054958 Dry boric acid found 09/23/2004

Document Title Revision / Date AR 00453123 Dry boric acid found 04/12/2008 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified that this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.2, Water Chemistry Summary of Information in the Application. The SLRA states that AMP B.2.3.2, Water Chemistry, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M2, Water Chemistry. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date 0-ADM-651 Nuclear Chemistry Parameters Manual Revision 12 0-NCOP-001 Primary Chemistry Control During Startup Revision 2 0-NCOP-041 Chemical Adjustments to the Reactor Coolant System and Revision 4B Pressurizer 0-NCSP-004 Schedule for Periodic Tests Revision 15 CY-TP-105-0009 Chemistry Documentation Revision 9 N/A Updated Final Safety Analysis Report 4/17/13 0-ADM-652 Chemistry Department QA/QC Program Revision 2

Document Title Revision / Date 0-ADM-653 Reporting Abnormal Chemistry Values Revision 0A QI-12-PTN-2 Control of Chemistry and Health Physics Measuring and Test Revision 1 Equipment During the audit, the staff verified that the scope of program, preventive actions, detection of aging effects, acceptance criteria, and corrective action program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the parameters monitored or inspected, and monitoring and trending, program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed the UFSAR report dated April 17, 2013, and noted that the water chemistry parameters for chlorides, fluorides, and sulfates appeared to differ from the values listed in 0-ADM-651, Nuclear Chemistry Parameters Manual, Revision 12.

• The staff also reviewed Section 5.7 of 0-ADM-651, Nuclear Chemistry Parameters Manual, Revision 12, and noted that the plant-specific action in response to Action Level 2 oxygen levels was not described in the procedure.

• The staff noted that 0-NCSP-004, Schedule for Periodic Tests, Revision 15, listed an item to conduct an Isotopic Analysis for the reactor coolant system, which the applicant stated includes an analysis of Cobalt-58, Cobalt-60, Manganese-54, Chromium-51, and Iron-59.

• The staff noted that in Section 5.3 of 0-ADM-651 formal technical reviews for prolonged abnormal water chemistry conditions are recommended, and not mandatory.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The SLRA states that AMP B.2.3.3, Reactor Head Closure Stud Bolting, is an existing program that will be consistent, with an exception and an

enhancement, with the program elements in GALL-SLR Report AMP XI.M3, Reactor Head Closure Stud Bolting. To verify this claim of consistency, the staff audited the SLRA AMP.

During the audit, the staff reviewed the exception and enhancement associated with this AMP.

The exception to the GALL-SLR Report AMP and the enhancement are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant.

The table below lists documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Reactor Head Rev. 1 075 Closure Stud Bolting 01/03/2018 FPLCORP020-REPT- Subsequent License Renewal Aging Management Review Rev. 0 028 Reactor Vessel 01/05/2018 AR 00467808 License Renewal Self-Assessment 07/21/2009 FPLCORP020-REPT- Aging Management Program Basis Document - Operating Rev. 0 120 Experience (OpE) Program Report 01/26/2018 0-GMM-043.17 Reactor Head Closure Stud Handling and Transport Rev. 6 01/05/2017 AR 02121743 Reactor Head Stud Tensioning 03/31/2016 AR 00459733 Discrepancy occurred during Reactor Vessel Head stud 04/05/2009 tensioning AR 01846875 Tensioner would not disengage from Stud #31 02/10/2013 AR 01770520 Reactor Head Closure Studs #35 and #37 original threads 05/25/2012 damaged During the audit, the staff verified that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified that aspects of the preventive actions program element not associated with the exception, are consistent with the corresponding element of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SRP Report.

SLRA AMP B.2.3.4, Boric Acid Corrosion Summary of Information in the Application. The SLRA states that AMP B.2.3.4, Boric Acid Corrosion, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M10, Boric Acid Corrosion. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The staff reviewed the enhancement associated with this AMP and will document its evaluation of the enhancement in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FLPCORP020-REPT- Aging Management Program Basis Document - Boric Acid Revision 1 074 Corrosion FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Revision 1 120 Report - Aging Management Program Effectiveness 0-ADM-537 Boric Acid Corrosion Control Program Revision 13 ER-AP-116 Boric Acid Corrosion Control Revision 2 ER-AP-116-1000 Boric Acid Corrosion Control Program Revision2 PTN-ENG-LRAM Boric Acid Wastage Surveillance Program - License Renewal Revision 4 0028 Basis Document During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. However, for the scope of program program element, sufficient information was not available for the staff to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience program element, the staff conducted an independent search of the Turkey Point operating experience database, as discussed in the Operating Experience (OpE) Audit Report. The staff did not identify any operating experience to indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The SLRA states that AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, is an existing program with enhancement that is consistent with the program elements in GALL-SLR Report AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (Pressurized Water Reactors (PWRs) Only). To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancement associated with this AMP. The enhancement to the GALL-SLR Report AMP is evaluated in the SER.

Audit Activities. During its audit, the staff reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Cracking of Rev. 1 076 Nickel-Alloy Components and Loss of Material due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components FPLCORP020-REPT- Aging Management Program Basis Document - ASME Section Rev. 1 072 XI Inservice Inspection, Subsections IWB, IWC, and IWD FPLCORP020-REPT- Subsequent License Renewal Aging Management Review Rev. 1 028 Reactor Vessel FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Rev. 1 120 Operating Experience Review Results - Aging Management Program Effectiveness AR 00535641 Turkey Point evaluated applicability of NRC Information Notice 2004 (IN) 2004-11 to Turkey Points pressurizer spray nozzles AR [Action Report] Turkey Point evaluated indications of staining/discoloration on 2012 / 2015 02088999 / surface of RV lower head on region of BMI nozzles (Code Case AR 01805464 N-722)

AR 01951665 / Turkey Point evaluated indications of boric acid residue on 2014 AR 01994996 / surface of RV upper head CRDM [control rod drive mechanism]

AR 01995321 nozzles (Code Case N-729 and N-722)

Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Boric Acid Rev. 1 074 Corrosion FPLCORP020-REPT- Aging Management Program Basis Document Water Chemistry Rev. 1 073 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit, the staff made the following additional observations:

• From review of FPLCORP020-REPT-076, the staff noted that Turkey Point Unit Nos. 3 and 4 have no Class 1 and 2 Inconnel piping welds.

• From review of FPLCORP020-REPT-072 and FPLCORP020-REPT-028, the staff noted that the aging effect of loss of material due to wear in the CRDM head penetrations is addressed in SLRA AMP B.2.3.1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD.

During the audit of the operating experience program element, the staff searched the applicants database using keywords: Nickel, Inconel, Alloy 600, Alloy 82/182, Dissimilar, PWSCC, SCC, Boric, Corrosion, BAC, BMI, Penetration, Nozzle, Sleeve, Thermal Sleeve, CRDM, Wear, and Crack. The staffs independent database search did not identify any operating experience that would indicate that the AMP B.2.3.5 may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the SRP-SLR.

B.2.3.6, Thermal Embrittlement of Cast Austenitic Stainless Steel AMP Summary of Information in the Application. SLRA states that AMP B.2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS). To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit only addresses the program basis documents and does not include implementing documents.

Audit Activities. During its audit, the staff reviewed the applicants onsite documents. The table below lists the documents that were reviewed and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Thermal Aging Revision 1 077 Embrittlement of Cast Austenitic Stainless Steel 01/03/2018 FPLCORP020-REPT- Subsequent License Renewal Aging Management Review Revision 1 032 Reactor Coolant System and Connected Piping 01/03/2018 FPLCORP020-REPT- Subsequent License Renewal Time-Limited Aging Analyses Revision 3 114 and Exemptions Based on Time-Limited Assumptions 04/12/2018 FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Revision 1 120 Report - Aging Management Program Effectiveness 01/26/2018 O-ADM-532 ASME Section XI Repair/Replacement Program Revision 1 08/06/2014 O-ADM-523 ASME Section XI Pressure Tests For Quality Group A,B,C Revision 3D Systems/Components 10/28/2016 During the audit the staff verified that the scope of the program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also audited the description of the SLRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.7, Reactor Vessel Internals Summary of Information in the Application. The SLRA states that AMP B.2.3.7, Reactor Vessel Internals, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M16A, PWR Vessel Internals. To verify this claim of consistency, the staff audited the SLRA AMP and the supporting information provided in SLRA Appendix C, MRP-227-A Gap Analysis. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date Turkey Point SLRA, MRP-227-A Gap Analysis January 2018 Appendix C

Document Title Revision / Date EPRI MRP 2017-038 Transmittal of Preliminary Results from MRP-191 Expert Panel 12/15/2017 Review in Support of Subsequent License Renewal at U.S.

PWR Plants (Reactor Vessel Internal Fluence Table for Westinghouse-Designed Plants, Provided in SLRA Enclosure 5, Attachment 11)

FPLCORP020-REPT- Aging Management Program Basis Document - Reactor Vessel Revision 1 078 Internals 4/13/2018 BMI-FTT-IP Bottom Mounted Instrumentation (BMI) Flux Thimble Tubing Revision 5 (FTT) Inspection Program (IP) for Turkey Point Units 3 and 4 0-ADM-563 Reactor Vessel Internals Aging Management Program Revision 2 11/17/2016 LTR-REA-17-168 Comparison of Turkey Point Units 3 and 4 Subsequent License Revision 0 Renewal Reactor Internals Fluence to Representative EPRI 2/2/2018

[Electric Power Research Institute] MRP-191 3-Loop Plant AR 2165558 MRP 2016-035 Reactor Vessel Internals - Control Rod Guide 10/26/2016 Tube (CRGT) Guide Cards Emergent Industry Issue Summary AR 2235785 Fleet Review of MRP 2017-024 Clevis Insert Bolt OpE 11/10/2017 AR 2170306 General Actions - RV Internals Program; 6/18/2018 AR 2262123 Perform Level 1 Assessment for Reactor Vessel Internals Program (Implementation of NEI 03-08 Elements)

AR 2255865 Engineering Evaluation Summary of Degradation at Reactor 3/23/2018 Vessel Core Support Barrel and Core Shroud Assembly (St.

AR 2256018 Lucie Unit 1)

AR 2253333 Fleet Review of MRP 2018-007, RVI Program, CRGT 4/24/2018 Inspection Requirements (Includes PWORG OG-18-46 per NSAL-17-1)

AR 2265723 Westinghouse 10 CFR Part 21 on Reactor Vessel Head 5/24/2018 Thermal Sleeve Flange Wear During the audit, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program and detection of aging effects program elements, sufficient information was not available to determine whether they are consistent with the corresponding program element of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program element of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the Safety Evaluation Report.

During the audit the staff made the following observations:

• The staff reviewed site action reports (ARs) addressing inspection of Turkey Point reactor vessel internal (RVI) components and evaluation of aging effects in accordance with industry guidance documents that are implemented under Nuclear Energy Institute (NEI) 03-08. Specifically, for Turkey Point Unit No. 4 baffle bolting inspections (AR 2231145) and Turkey Point Unit No. 4 guide card wear measurements (AR 2124311), the staff noted that the applicants inspection activities and evaluation of relevant indications for these components are consistent with the latest industry guidance documents that are implemented under the NEI 03-08 industry protocol, as recommended by GALL-SLR AMP XI.M16A. These are Turkey Point-specific ARs that were found based on the staffs corrective action program (CAP) document searches during the operating experience audit; therefore, the full citations of these ARs are listed in the operating experience audit report for this AMP.

• The staff reviewed AR 1953186 and AR 1953095 from 2014 addressing surface wear indications on Turkey Point Unit No. 3 lower radial support structure (LRSS) components: core barrel flange, core support ledge, radial support key, and clevis keyway. The staff noted that the applicant had adequately evaluated these surface indications to determine that there is no impact on the structural function for these LRSS components. The staff also noted that the applicants root cause evaluation determined that these indications were caused by abrasive wear from a foreign object during the 1990s and subsequent abrasive contact between LRSS surfaces during core support barrel movements. The staff verified that they are not related to active aging degradation. Full citations of these ARs are listed in the operating experience audit report for this AMP.

• For aging effects that were discovered at other plants that may be potentially applicable to Turkey Point, the staff reviewed additional CAP documents listed above that were provided by the applicant for the in-office audit. The staff noted that these documents include FPL fleet ARs for evaluation of industry operating experience and industry guidance for emergent RVI component aging issues. The staff verified that the applicant is evaluating the industry operating experience and implementing the associated industry guidance, as appropriate for addressing these emergent aging effects and their potential applicability to Turkey Point.

• The staff is reviewing the applicants AMP and SLRA Appendix C, MRP-227-A Gap Analysis to determine whether they are acceptable to support the applicants statement of consistency with GALL-SLR AMP XI.M16A. GALL-SLR AMP Element 1, Scope of Program, recommends that if the applicants AMP is based on MRP-227-A with a gap analysis, the scope of the program addresses the following:

a. Components that screen in for additional aging mechanisms when assessed for the 60-80 year SPEO.

b. Components that previously screened in for an aging mechanism and the severity of the aging mechanism could significantly increase for the 60-80 SPEO.

c. Changes to the existing MRP-227-A program characteristics or criteria, including, but not limited to, changes in inspection categories, inspection criteria, or primary-to-expansion criteria and relationships.

• With respect to Item a. of Element 1 of GALL-SLR AMP XI.M16A, the staff is reviewing the applicants SLRA Appendix C gap analysis for screening and evaluation of additional aging mechanisms for the 60-80 SPEO. The staff noted that consistent with the process used for the development of MRP-227-A, the gap analysis evaluates potential changes to RVI component screening results for the eight potential RVI degradation mechanisms for SPEO. The staff noted that the gap analysis determined that there are two time-dependent screening inputs - neutron fluence and cumulative usage factor (CUF) - that represent the potential to change the screening results for five of the eight degradation mechanisms for SPEO. For irradiation-assisted stress corrosion cracking (IASCC),

irradiation embrittlement, void swelling, and irradiation induced stress relaxation, the parameter which will change over time is neutron fluence. For fatigue, the parameter which will change over time is the CUF. The results of the staffs review of these changes will be addressed in the SER. Specific issues that may result in the issuance of RAIs for completion of the review include:

o Plant-specific applicability of the 80-year generic neutron fluence ranges for Westinghouse RVI components provided in SLRA Enclosure 5, Attachment 11.

o Description of the analytical methodology used for calculating the generic RVI neutron fluence ranges provided in SLRA Enclosure 5, Attachment 11.

o For Class 1 RVI components that received a TLAA evaluation in SLRA Section 4.3.1, there may be a need to assess whether the CUF screening threshold of 0.1 in the SLRA Appendix C gap analysis is adequate to address the potential for environmentally-assisted fatigue (EAF), based on the criteria of Action Item 8, item (5) in Section 3.5.1 of the staffs safety evaluation for MRP-227-A.

• With respect to Items b. and c. of Element 1 and Element 4, Detection of Aging Effects, of GALL-SLR AMP XI.M16A, the staff reviewed SLRA AMP B.2.3.7 and Appendix C gap analysis to determine whether the SLRA AMP addresses changes in failure likelihood for certain RVI components and incorporates industry guidance documents based upon emergent industry operating experience that was determined to be applicable to Turkey Point subsequent to its implementation of MRP-227-A. The staff noted that the emergent industry operating experience addressed in the SLRA includes the following:

o Baffle bolting degradation and interim inspection guidance per NEI 03-08; o Clevis insert bolting degradation and associated change in failure likelihood and inspection criteria; o Measurement and evaluation of CRGT guide card wear per WCAP-17451-P, Rev. 1 and NEI 03-08; and o Fuel alignment pin surface degradation.

For baffle-bolting degradation, clevis insert bolt degradation, and CRGT guide card wear, the staff noted that there are several discrepancies in the SLRA regarding the description of these AMP activities compared to the information that the staff reviewed in the CAP. These discrepancies will likely need to be addressed through an RAI.

During the audit of the operating experience program element, the staffs independent database search and review of additional CAP documents listed above did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects; however, discrepancies noted above regarding the description of certain AMP activities in the SLRA compared to information in the applicants CAP documents will need to be addressed for the staff to complete its evaluation. The staffs evaluation of the identified plant-specific operating experience and industry operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.8, Flow-Accelerated Corrosion Summary of Information in the Application. The SLRA states that AMP B.2.3.8, Flow-Accelerated Corrosion, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M17, Flow-Accelerated Corrosion. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The staff reviewed the enhancements associated with this AMP and will document its evaluation in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FLPCORP020- Aging Management Program Basis Document - Flow- Revision 1 REPT-079 Accelerated Corrosion FPLCORP020- Subsequent License Renewal Operating Experience Review Revision 1 REPT-120 Report - Aging Management Program Effectiveness ER-AA-111 Flow-Accelerated Corrosion Revision 1 ER-AA-111-1000 Flow-Accelerated Corrosion (FAC) Activities Revision 0 ER-AA-111-1001 Feedwater Heater Shell Inspection for Detection of Flow- Revision 0 Accelerated Corrosion ENG-CSI-FAC-100 Corporate Long Term Flow-Accelerated Corrosion Monitoring Revision 16 Program 0-ADM-530 Flow-Accelerated Corrosion (FAC) Inspection Implementation Revision 0D Program ENG-FAC 2.3-1 Identification of Susceptible Systems and Components Revision 9

Document Title Revision / Date ENG-FAC 2.3-5 Evaluation of Worn Components Revision 9 SPEC-M-006 Maintenance Specification for Evaluation and Acceptance of Revision 5 Pipe Surface Imperfections for St. Lucie Units 1 & 2 and Turkey Point Units 3 & 4 IM-AA-101 Software Quality Assurance Revision 12 IM-AA-202 Software Quality Assurance Process Revision 8 JIM-MIS-1178-EPRI EPRI CHECWORKS Steam/Feedwater Revision 1 PTN-4FSC-11-7005 Minimum Pipe Wall Thickness Calculation in Support of FAC Revision 0 Inspection Plan for Unit 4 Cycle 26 Outage During the audit, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. However, for the scope of program, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience program element, the staff conducted an independent search of the Turkey Point operating experience database, as discussed in the OpE Audit Report. The staff did not identify any operating experience to indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.9, Bolting Integrity Summary of Information in the Application. The SLRA states that AMP B.2.3.9, Bolting Integrity, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M18 Bolting Integrity. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging management Program Basis Document-Bolting Integrity Revision 1 080 FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 0 120 Operating Experience Review Results - Aging Management Program Effectiveness (Attachment 2.2)

PLCORP020-REPT- Subsequent License Renewal Aging Management Review - Revision 1 032 Reactor Coolant System and Connected Piping 0-ADM-564 Systems/Programs Monitoring Revision 3 0-GMP-102.23 Torque Methods and Guidelines Revision 2 0-GMP-102.2 Equipment Lubrication Guide Revision 66 SPEC-M-004 Maintenance Bolting Specification for St. Lucie Units 1 & 2 and Revision 15 Turkey Point Units 3 & 4 May 2011 0-ADM-532 ASME Section XI Repair/Replacement Program Revision 1 NDE 4.1 Visual Examination VT-1 Welds/Bolting/Bushings/Washers Revision 14 02/22/2014 NDE 4.2 Visual Examination VT-2 Conducted During System Pressure Revision 12 Tests 08/28/2015 NDE 4.3 Visual Examination VT-3 Revision 12 February 2014 5th Interval-ISI-PTN- Fifth Inservice Inspection Interval Program Plan for Turkey Point Revision 1 3/4-Program Plan Nuclear Power Plants Units 3 and 4 June 2016 During the audit, the staff verified that the scope of program, preventive actions, monitoring and trending and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding element(s) of the GALL-SLR Report AMP. In addition, the staff found that for the parameters monitored or inspected and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAI will be documented in the SER.

During the audit the staff made the following observation:

• SLRA Section B.2.3.9, Bolting Integrity, states that there is currently no high strength bolting within the scope of the Bolting Integrity Program. However, the staff noted that specification SPEC-M-004 lists bolting material of American Society for Testing and Materials (ASTM) No. SA/A540, Grade B23 C1.1 as acceptable for use at the site. The

applicants specification also states that this bolting has a yield strength equal to 150 kilograms per square inch (ksi) and a diameter of 3 inches or less. Based on this specification, the staff cannot confirm the applicants claim that high strength bolts are not being used in SSCs within the scope of the Bolting Integrity Program. The staff notes that the parameters monitored or inspected and detection of aging effects program elements in the GALL-SLR Report AMP XI.M18 recommend that high strength closure bolting (with a yield strength greater than or equal to 150 ksi and a diameter greater than 2 inches) should be monitored for indications of cracking due to stress corrosion cracking (SCC) and subject to volumetric examination in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 to detect stress corrosion cracking. Based on specification SPEC-M-004, it is not clear whether bolting material ASTM No. SA/A540, Grade B23 C1.1 can be installed as closure bolting.

If this material is used, the staff is concerned that the AMP may not adequately manage the aging effect of cracking due to SCC of the closure bolting. The staff may need additional information to determine whether there is high strength closure bolting (with a yield strength greater or equal to 150 ksi and a diameter greater than 2 inches) within the scope of the Bolting Integrity Program, and, if so, whether the applicant plans to manage cracking due to SCC consistent with the GALL-SLR Report AMP XI.M18 recommendations in the parameters monitored or inspected and detection of aging effects program elements.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.10, Steam Generators Summary of Information in the Application. The SLRA states that AMP B.2.3.10, Steam Generators, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M19, Steam Generators. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed an enhancement associated with this AMP. The enhancement will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Steam 07/30/2018 081 Generators

Document Title Revision / Date ENG/CSI-NDE-08-037 Strategic Plan for Steam Generator Integrity Revision 2 ENG/CSI-NDE-99-051 Steam Generator Secondary Side Integrity Plan Revision 14 ENG-CSI 2.2 Planning and Reporting Results of Steam Generator Tubing Revision 44 Examinations ER-AP-121 Steam Generator Integrity Revision 4 MA-AA-101-1000 Foreign Material Exclusion Procedure Revision 19 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.11, Open-Cycle Cooling Water System Summary of Information in the Application. The SLRA states that AMP B.2.3.11, Open-Cycle Cooling Water System is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System.

To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date SPEC-M-081 CCW Heat Exchanger Tube Integrity Inspection Revision 1

Document Title Revision / Date SPEC-M-086 Intake Cooling Water System Piping Inspection Revision 1 5614-M-3019 Intake Cooling Water System, Sheet 2 (P&ID) Revision 28 5610-019-DB-001 Intake Cooling Water System Design Basis Document 12/07/2015 5610-019-DB-002 Intake Cooling Water Component Design Requirements 10/25/2016 FPLCORP020-REPT- Aging Management Program Basis Document - Open-Cycle Revision 1 082 Cooling Water System During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP, the staff will consider issuing an RAI. The staffs evaluation of this potential RAI will be documented in the SER.

During the audit the staff made the following observation:

• The staff reviewed SPEC-M-086 and noted that the scope of inspections consists of piping with nominal diameters of 24 inches or larger. The staff also reviewed drawing 5614-M-3019 and noted that there appears to be piping with diameters less than 24 inches within the scope of the Open-Cycle Cooling Water System.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.12, Closed Treated Water Systems Summary of Information in the Application. The SLRA states that AMP B.2.3.12, Closed Treated Water Systems, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M21A, Closed Treated Water Systems. To verify this claim of consistency, the staff audited the SLRA AMP. The staff

reviewed the enhancements associated with this AMP and the exception to the GALL-SLR Report and will document its evaluation in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Closed Revision 1 083 Treated Water Systems FPLCORP020-REPT- Subsequent License Renewal Aging Management Review Revision 1 040 Component Cooling Water System FPLCORP020-REPT- Subsequent License Renewal Aging Management Review Revision1 033 Containment Ventilation FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Revision 1 120 Report - Aging Management Program Effectiveness PTN-ENG-LRAM License Renewal Aging Management Review - Component Revision 4 0138 Cooling Water System 0-ADM-651 Nuclear Chemistry Parameters Manual Revision 11 0-NCSP-004 Schedule for Periodic Tests Revision 11 EPRI 3002000590 Closed Cooling Water Chemistry Guideline Revision 2 V000060 Vendor Manual: Installation, Operation & Maintenance Revision 11 Instructions Emergency Containment Filter Equipment and Cooling V000968 Vendor Manual: Installation, Operation & Maintenance for Revision 2 Normal Containment Coolers During the audit, the staff verified that the scope of program, preventive actions, and parameters monitored or inspected program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified that the aspects of the detection of aging effects, monitoring and trending, and acceptance criteria program elements not associated with the exception identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.

During the audit, the staff reviewed the vendor manuals for the emergency and normal containment coolers. For the normal containment cooler, Vendor Manual V000968 contains a Coil Data Sheet by Aerofin with the tube material specified as 90/10 CuNi [copper nickel alloy].

In addition, it shows a fin type as helical L footed made from copper. Because this information differs from that shown for the heat exchanger tube AMR item in Table 3.3.2-10, the staff will consider issuing a separate RAI associated with the AMR item.

During the audit of the operating experience program element, the staff conducted an independent search of the Turkey Point operating experience database, as discussed in the OpE Audit Report. The staff did not identify any operating experience to indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The SLRA states that AMP B.2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Programs Basis Document - Inspection of Revision 1 084 Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 0 120 Operating Experience Review Results - Aging Management Program Effectiveness (Attachment 2.2) 0-ADM-564 Systems/Programs Monitoring Revision 3 0-ADM-717 Heavy Load Handling Revision 18A 0-PME-089.08 Turbine Crane Inspection Revision 0 0-PMM-009.05 Intake Area Gantry Crane Inspection and Preventive Revision 0 Maintenance 0-PMM-038.01 Manipulator Crane Inspection and Lubrication Revision 3 0-PMM-038.02 Spent Fuel Cask Handling Crane Inspection Revision 1

Document Title Revision / Date 0-PMM-089.2 Turbine Gantry Crane Inspection and Preventive Maintenance Revision 2 3-GMP-051.01 Reactor Polar Crane Inspection and Periodic Maintenance Revision 5 4-GMP-051.01 Reactor Polar Crane Inspection and Periodic Maintenance Revision 2 MA-AA-110-1000 Rigging Handbook and Inspection Procedure Revision 5 AR No. 02007672 NRC-Information Notice 2014-12 ISSUED 11/18/2014 During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the Safety Evaluation Report.

During the audit the staff made the following observation:

• In the AMPs program description (SLRA page B-130) the applicant states that the AMP does not manage aging effects for load handling components such as trolleys and rigging because such components are considered active components. The staff noted that depending on the size of the crane structural components, the trolleys and rigging may include structural girders and beams that are passive components that should be within the scope of this AMP. The staff noted that GALL-SLR Volume 1, page VII B-1, states that the primary components that this program (i.e., GALL-SLR Report AMP XI.M23) is concerned with are the structural girders and beams that make up the bridge and the trolley. The staff noted that although the SLRA states that these components will not be age managed, the SLRA has AMRs assigned to trolleys (e.g., trolley structures of the turbine gantry crane and polar crane, SLRA Tables 3.5.2-17 and 3.5.2-14) and rigging (e.g., intake cooling water (ICW) valve pit rigging beam, SLRA Table 3.5.2-11) of some cranes. It is not clear whether other cranes, trolleys and rigging may have similar passive components that should be included in the scope of program program element for this AMP. The staff may need additional information from the applicant to determine whether trolleys and rigging components of other cranes should be in scope of this AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.14, Compressed Air Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.3.14, Compressed Air Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M24, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP, which are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT-85 Aging Management Program Basis Document - Compressed Revision 1 Air Monitoring 0-ADM-215 Operations Surveillance Tracking Revision 27 0-OSP-200.1 Schedule of Plant Checks and Surveillances Revision 25 3-PMM-013.07 Instrumental Air Dryer Oil and Water Separator Prefilter Revision 2 Cleaning and Inspection 3-PMM-022.07 Emergency Diesel Generator 48 Month Preventive Revision 6 Maintenance 3-PMM-022.08 Emergency Diesel Generator 72 Month Preventive Revision 4 Maintenance During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective action program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit the staff made the following observation:

• The staff reviewed ADAMS Accession No. ML17348A266, response to Generic Letter (GL) 88-14, "Instrument Air Supply System Problems Affecting Safety-Related Equipment." The staff noted that the Compressed Air Monitoring program is based on the GL 88-14 response.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may

not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR.

SLRA AMP B.2.3.15, Fire Protection Summary of Information in the Application. The SLRA states that AMP B.2.3.15, Fire Protection, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M26, Fire Protection. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date 5610-016-DB-001 Fire Protection System NFPA [National Fire Protection Revision 0 Association] 805 Design Basis 0-ADM-016 Fire Protection Program 05/23/2017 FP-AA-104-1001 FP Maint., Testing, Impairment, and Compensatory Action Revision 0 FP-AA-104-1001 Fire Protection Performance and Trending Revision 2 0-SFP-016.1 Fire Barrier Penetration Seal Inspection Revision 3 FPL-CORP020-REPT- Aging Management Program Basis Document - Fire Protection Revision 1 086 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed 5610-016-DB-001 and confirmed that the applicant performed a fire hazards identification and nuclear safety capability assessment (Appendix F) as required by NFPA 805, Section 2.7.1.2. Contained in Appendix F, the applicants Fire Safety Analysis identifies each fire area, systems and features, engineering evaluations, and required systems.

• SLRA Table 3.5.2-10, Fire Rated Assemblies, cites drip shields over thermo-lag exposed to outdoor air. The staff reviewed 0-ADM-016 and FPL-CORP020-REPT-086 and noted that credited raceway protection located beneath the turbine/generator bearings is potentially exposed to leaking oil and that metal drip shields are installed to reduce direct impact effects of oil leaking onto the 1-hour fire rated barrier system. The staff also noted that the procedures do not address how the drip shields will be inspected such that they are managed for cracking and loss of material.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.16, Fire Water System Summary of Information in the Application. The SLRA states that AMP B.2.3.16, Fire Water System, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M27, Fire Water System. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP02-REPT- Aging Management Program Basis Document - Fire Water Revision 1 087 System FPLCORP02-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 120 Operating Experience Review Results Aging Management Program Effectiveness

Document Title Revision / Date 0-ADM-016 Fire Protection Program Revision 22A 0-SMM-016.1 Fire Suppression System Flush Revision 5 0-SMM-016.10 C-Bus Transformer Fire Suppression System 18 Month Revision 4 Functional Test 0-SMM-016.18 Open Head Spray/Sprinkler Three Year Air Flow Test Revision 1 0-SFP-016.5 Fire Protection Equipment Surveillance Revision 8 0-OSP-016.1 Electric Driven Fire Pump Annual Surveillance Test Revision 6B 0-OSP-016.2 Diesel Driven Fire Pump Annual Surveillance Test Revision 5 0-OSP-016.29 Fire Main Hydraulic Gradient Flow Test Revision 2A 0-OSP-016.30 Fire Main Post Indicator Valve (PIV) Leak/Flow Path Valve Revision 5 Surveillance Test and System Flush 0-OP-106.1 Fire Protection Water System Revision 24 3-SMM-016.02A Spray/Sprinkler System Insp. (EDG [emergency diesel Revision 1 generator] 3A Preaction Valve 3-10-847 Partial Flow Test, Zone 73 & 75) 3-SMM-016.02F Spray/Sprinkler System Insp. (Charging PMP [pump] Preaction Revision 0 Deluge VLV 3-10-841 Partial Flow Test, Zone 55) 3-SMM-016.07 Turbine Lube Oil Reservoir Fire Supply System 18 Month Revision 0 Functional Test 3-SMM-016.11 Auxiliary Transformer and Hydrogen Seal Oil Unit Fire Revision 3 Suppression System Functional Test 4-SMM-016.02A Spray/Sprinkler System Insp. (EDG 4A Preaction Deluge Revision 0 Valve 4-10-1112 Partial Flow Test, Zone 138) 4-SMM-016.02E Spray/Sprinkler System Insp. (CCW [closed cooling water] HX Revision 0A

[heat exchanger] Area Deluge Valve 4-10-835 Partial Flow Test, Zone 47B) 4-SMM-016.8 Main Turbine Fire Suppression System 18 Month Functional Revision 2 Test 4-SMM-016.9 Startup Transformer Fire Suppression System Functional Test Revision 2 FP-AA-1006 Implementation of the NFPA 805 [Performance-Based Standard Revision 0 for Fire Protection for Light Water Reactor Electric Generating Plants] Monitoring Program PIA-AA-104-1000 Condition Reporting Revision 15

Document Title Revision / Date PTN-TS-12208 Evaluate Leaking 2-inch Firewater Piping from the Entrance July 23, 2007 Building at the Building at Turkey Point Nuclear Plant Not Applicable Vendor Report: The Raw Water Tank #1 500,000 Gallon 12/30/2002 Groundlevel Welded Steel Not Applicable Vendor Report: The Raw Water Tank #2 750,000 Gallon 12/31/2002 Groundlevel Welded Steel 5610-C-1610 Sheet 1 Raw Water Storage Tank Foundation Plan and Pump Revision 3 Foundation Plan 5610-C-18-397 Sheet Raw Water Storage Tank I General Plan Revision 0 2

5610-C-18-394 Sheet Raw Water Storage Tank II General Plan Revision C 1

5610-C-18-394 Sheet RWST [raw water storage tank] II Anchor Bolt Setting Plan Revision 0 31 Work Order (WO) Spray Sprinkler Inspection Primary 1 of 2 September 2011 40066108-01 WO 40070811-01 Spray Sprinkler Inspection/18 MO [month] PM [preventive 12/11/2011 maintenance] 2 of 2 WO 40170479 T63B: Raw Water Storage Tank II Interior Inspection 2012 WO 40170490-01 T63A Raw Water Storage Tank Interior Inspection 2012 WO 40175699-01 X03 U4 Startup Transformer Deluge System 11/16/2012 WO 40175780-01 U4 Spray Sprinkler Inspection Primary 1 of 2 2013 WO 40178594-01 U4 Spray Sprinkler Inspection 2 of 2 07/12/2013 WO 40298783 U3 Spray Sprinkler Inspection 1 of 2 02/06/2015 WO 40308404-01 Spray Sprinkler Inspection Secondary 2 of 2 01/16/15 WO 40308385-01 X03 U4 Startup Transformer Deluge System 05/17/2017 WO 40401193-01 U3 Spray Sprinkler Inspection Secondary Part 2 of 2 09/01/2016 WO 40380758-01 U3 Fire Suppression System Flush Part 1 of 2 03/25/2016 WO 40380770-01 Fire Suppression System Flush 2 of 2 03/17/16 WO 40398574-01 U3 Spray Sprinkler Inspection Primary 1 of 2 07/21/2016

Document Title Revision / Date WO 40401193-03 U3 Spray Sprinkler Inspection Secondary Part 2 of 2 09/30/2016 WO 40407346-01 U4 Spray Sprinkler Primary 1 of 2 10/20/2016 WO 40412516-01 U4 Spray Sprinkler Inspection 18 Month PM 2 of 2 07/15/2016 WO 40431749-02 U3 X21 C Bus Transformer Deluge System 04/28/2017 WO 40469756-01 4T26 Lube Oil Tank Deluge System Functional Test 05/25/2017 During the audit, the staff verified that the scope of program, preventive actions, and parameters monitored or inspected, program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the Safety Evaluation Report.

During the audit the staff made the following observations:

• The staff reviewed 5610-C-1610 Sheet 1 and noted that the backfill under the raw water storage tank (RWST) consists of 3 inches of sand saturated with No. 3 or No. 5 fuel oil overtop of 6 inches of hard clean gravel. One inch of grout is installed between the tank bottom and the concrete foundation ring. The slope away from the tank is EL 16-feet 0-inches to 15-feet 7-inches.

• The staff reviewed 5610-C-18-394 Sheet 1 and 5610-C-18-397 Sheet 2 and noted that the RWST I and RWST II side to concrete foundations are not sealed or caulked.

• The staff reviewed WO 40066108-01, WO 40070811-01, WO 40175780-01, WO 40178594-01, WO 40298783, WO 40401193-01, WO 40398574-01, WO 40401193-03, WO 40407346-01, and WO 40412516-01, and noted that the sprinklers that were inspected had no evidence of loss of material from corrosion or spray pattern obstruction.

• The staff reviewed work orders for testing deluge valve systems and flush of sprinkler curtains and noted that:

o For WO 40175699-01, five spray heads were partially blocked, removed, cleaned, and restored.

o For WO 40308385-01, one spray head was clogged, cleaned, and reinstalled.

o For WO 40380758, one curtain sprinkler nozzle did not meet the acceptance criteria during the flush of the U3 emergency diesel generator intake water curtain sprinkler system flush, All sprinkler nozzles are clear and discharging approximately the same amount of water.

o For WO 40431749-02, one spray head was blocked, removed, cleaned, and reinstalled.

o For WO 40469756-01, two spray heads were blocked, cleaned, and restored.

• The staff reviewed 0-OSP-016.30 and noted that the procedure does not have a requirement to verify that the hydrants drain within 60 minutes.

During the audit of the operating experience program element, the staffs independent database search identified operating experience that would indicate that the AMP might not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.17, Outdoor and Large Atmospheric Metallic Storage Tanks Summary of Information in the Application. The SLRA states that AMP B.2.3.17, Outdoor and Large Atmospheric Metallic Storage Tanks, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document Outdoor and Revision 1 088 Large Atmospheric Storage Tanks FPLCORP02-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 120 Operating Experience Review Results Aging Management Program Effectiveness FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 019 Screening Results Waste Disposal System

Document Title Revision / Date 5610-030-DB-001 Design Basis Document Component Cooling Water System 12/03/2013 5613-M-3020 Primary Makeup Water System Sheet 2 Unit 3 Revision 35 5613-M-3030 Component Cooling Water System Sheet 1 Unit 3 Revision 35 5614-M-3020 Makeup Water System Sheet 2 Unit 4 Revision 30 5614-M-3030 Component Cooling Water System Sheet 1 Unit 3 Revision 30 5610-M-3074 Feedwater System Demineralized Storage and Deaeration Revision 40 Sheet 2 FPLCORP020-REPT- Subsequent License Renewal Aging Management Review Revision 1 043 Primary Makeup Water SPEC-C-047 Specification Field Erected Tanks Internal Inspection Turkey Revision 1 Point Units 3 and 4 5610-C-1333 Demin[eralized]. Water Storage {DWST] and Deaeration Revision 2 System Tank and Pump Foundations Plan, Section and Details 5610-C-375 Yard Tank & Misc. Equip. Foundation Details Revision 9 WO 39022011-01 Work Order: Perform Internal Tank Inspection RWST [Refueling 10/04/2010 Water Storage Tank]

WO 39022012-01 Work Order: Perform Internal Tank Inspection [RWST] 2011 WO 39022126 01 Perform Internal Tank Inspection [Condensate Storage Tank 2011 (CST)]

WO 40005208 01 T61 DWST Perform License Renewal Internal Inspection 2011 WO 40011000 01 3T8, Perform Tank Internal Inspection [CST] 2012 WO 40098121 U3 [Unit 3] RWST, Prep and Coat Interior 2012 During the audit, the staff verified that the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified that aspects of the preventive actions program element not associated with the staff-identified exception, which will be evaluated in the SER, are consistent with the corresponding program elements in the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary

to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed drawing 5610-C-1333 Section B, [no title], and noted that for the demineralized water storage tank, at the tank to concrete interface, there is a spacer ring that elevates that tank bottom above the concrete. In addition, Section E [no title],

shows that the tank to concrete interface is above ground elevation and the soil slopes away from the tank.

• The staff reviewed drawing 5610-C-375 Section A [no title] and noted that for the condensate storage tank: (a) there is a 1/8-inch layer of asphalt between the tank bottom and foundation; and (b) the concrete outside of the tank to concrete interface has a 1-inch slope away from the tank.

• The staff reviewed drawing 5610-C-375 Yard Tanks Foundation Schedule, General Plan, and Typical Section, [no title], and noted that for the diesel fuel storage tank (Unit 3), refueling water storage tank, and primary water storage tank, the concrete outside of the tank to concrete interface has a 1-inch slope away from the tank.

• The staff reviewed work order 39022011-01 and noted that paint chipping was detected on the floor and bubbling was detected.

• The staff reviewed work order 40005208-01 and noted that there was only one minor spot where there were signs of surface corrosion. This was located where the tank vent penetrates the roof.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified that, with the exception of potential RAIs associated with the scope of program program element, this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.18, Fuel Oil Chemistry Summary of Information in the Application. The SLRA states that AMP B.2.3.18, Fuel Oil Chemistry, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The exceptions to the GALL-SLR Report AMP and the enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Fuel Oil Revision 1 089 Chemistry 0-ADM-235 Technical Specification Surveillance Frequency Control Revision 6A Program 0-ADM-651 Nuclear Chemistry Parameters Manual Revision 11 0-NCSP-004 Schedule for Periodic Tests Revision 11 3-OSP-022.6 Unit 3 Diesel Fuel Oil Storage Tank Accumulated Water Revision 1 Removal 3-PMM-022.4 Diesel Oil Storage Tank Cleaning Revision 1B AR 40081697-01 3T23A: Perform Cleaning of 3A EDG Day Tank 11/02/2011 AR 40105924-01 3T23B: Perform Cleaning of 3B EDG Day Tank 11/02/2011 AR 40132809-01 4T260A: Perform Cleaning of 4A EDG Day Tank 08/17/2012 AR 40175731-01 4T260B: Perform Cleaning of 4B EDG Day Tank 09/21/2012 AR 39016000-01 3T36: EDG Diesel Oil Storage TNK 10 YR 09/28/2009 AR 40130415-01 4T259A: EDG Diesel Oil Storage TNK 10 YR 12/03/2012 AR 40130167-01 4T259B: EDG Diesel Oil Storage TNK 10 YR 08/08/2012 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective action program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified that aspects of the detection of aging effects program element not associated with the exception identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.

During the audit the staff made the following observations:

• The staff reviewed AR 40081697-01, AR 40105924-01, AR 40132809-01, and AR 40175731-01, and noted that minor corrosion was found in the 3T23B day tank.

• The staff reviewed AR 39016000-01, AR 40130415-01, and AR 40130167-01, and noted that localized corrosion was found on the 3T36: EDG Diesel Oil Storage Tank and was repaired.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA AMP B2.3.19, Reactor Vessel Material Surveillance Summary of Information in the Application. The SLRA states that AMP B2.3.19, Reactor Vessel Material Surveillance, is an existing program with no enhancements or exceptions that is consistent with the program elements in GALL-SLR Report AMP XI.M31, Reactor Vessel Surveillance. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date 0-ADM-527 Turkey Point Plant Administrative Procedure - Reactor Vessel Revision 1 Material Surveillance Program 0-ADM-565 Turkey Point Plant Administrative Procedure -Turkey Point Revision 0 Reactor Vessel Integrity Program FPLCORP020-REPT- Turkey Point Units 3 and 4 Aging Management Program Basis Revision 1 090 Document - Reactor Vessel Material Surveillance During the audit, the staff verified that the preventive actions, detection of aging effects, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, parameters monitored or inspected, and monitoring and trending, program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these

program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit, the staff discussed the surveillance capsule withdrawal schedule with the applicant. During review of AMP B2.3.19, the staff noted that the estimated neutron fluence for Capsule X4 at withdrawal will fall short of one to two times the projected peak RPV neutron fluence of interest at 80 years at the clad-to-base metal interface, thus is not consistent with the GALL-SLR guidance for the scope of program, parameters monitored or inspected, and monitoring and trending AMP elements.

The staff reviewed Turkey Point Unit Nos. 3 and 4 Aging Management Program Basis Document - Reactor Vessel Material Surveillance. This document indicates that the fluence of interest for the X4 capsule is the fluence at one-quarter wall thickness for the intermediate to lower shell weld. However, the staff notes that for PWRs, the neutron fluence at the clad-to-base metal interface or RPV inner diameter fluence is generally considered the fluence of interest since the Pressurized Thermal Shock (PTS) Rule, 10 CFR 50.61, requires evaluation of the PTS reference temperature (RTPTS) using the fluence at the clad-to-base metal interface, and PTS is a TLAA applicable to PWRs including Turkey Point Unit Nos. 3 and 4.

Since the discussion with the applicant and the document review did not resolve the question of whether the surveillance capsule withdrawal schedule is consistent with the GALL-SLR, the staff will consider issuing an RAI on this subject requesting a justification of how the capsule fluence at withdrawal is consistent with the GALL-SLR guidance of one to two times the RPV fluence of interest at 80 years.

The staff noted during its review of the AMP description in SLRA Section B2.3.19 and the Turkey Point Unit Nos. 3 and 4 Aging Management Program Basis Document - Reactor Vessel Material Surveillance that the AMP does not describe how neutron fluence will be monitored after Capsule X4 is withdrawn and tested. Therefore, the staff cannot determine whether the AMP is consistent with the Monitoring and Trending program element of AMP XI.M31, which states that if no in-vessel surveillance capsules are available, an alternative neutron fluence monitoring program uses alternative dosimetry, either from in-vessel capsules or ex-vessel capsules, to monitor neutron fluence during the subsequent period of extended operation, and that the methods used in this alternative neutron fluence monitoring program are consistent with RG 1.190, including appropriate benchmarking, as described in GALL-SLR Report AMP X.M2, Neutron Fluence Monitoring. This issue was not discussed during the breakout session for the Reactor Vessel Material Surveillance AMP, but the staff will consider issuing an RAI.

In summary, during the audit of AMP B2.3.19, Reactor Vessel Material Surveillance, the staff could not validate the applicants claim that its AMP is consistent with the GALL-SLR.

SLRA AMP B.2.3.20, One-Time Inspection Summary of Information in the Application. The SLRA states that AMP B.2.3.20, One-Time Inspection, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M32, One-Time Inspection. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the

program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - One - Time Revision 1 091 Inspection AR 01638881 FAC LOC. 98, Component I-CSA-E-2, Is Less That The 12/11/2012 Required During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed AR 01638881 and noted that the applicant has a long history of carbon steel piping corrosion in the Containment Spray (CS) system, as stated in AR 01638881. Additionally, AR 01638881 references another instance of corrosion of carbon steel in the CS System (in AR 01709832). AR 01709832 states that during the replacement of a carbon steel pipe, corrosion build-up was found in the CS header.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

SLRA AMP B.2.3.21, Selective Leaching Summary of Information in the Application. The SLRA states that AMP B.2.3.21, Selective Leaching, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date POD [Prompt Intake Cooling Water Piping Showing Graphitic Corrosion at 02/02/2018 Operability Penetration Determination] -

02247382 FPLCORP020-REPT- Aging Management Program Basis Document - Selective Revision 1 092 Leaching FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Aging Revision 1 062 Effects Operating Experience FPLCORP020-REPT- Subsequent License Renewal Aging Management Review Revision 1 036 Safety Injection and Accumulators Systems During the audit, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, detection of aging effects, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the Safety Evaluation Report.

During the audit the staff made the following observations:

• The staff reviewed AR 01735146 and noted that during the license renewal C auxiliary feedwater (AFW) lubricating oil cooler inspection, selective leaching was found on the gray cast iron bonnet end bells and divider plates. In addition, the staff noted that the AFW lubricating oil cooler uses demineralized water.

• The staff reviewed AR 01842355 and noted that during cleaning of a circulating water cooling spool piece, personnel identified what appeared to be a soft coating on the pipe.

A coating subject matter expert later concluded it was graphite caused by graphitic corrosion.

• The staff reviewed AR 02247382 and noted that a 30-inch intake cooling water piping at a penetration is showing external graphitic corrosion.

• The staff reviewed POD [Prompt Operability Determination] - 02247382 (regarding AR 02247382) and noted that (a) there did not appear to be graphitic corrosion on the exterior of the pipe, which would be expected since the pipe is not subjected to salt water on the exterior; and (b) the AR-02247382 originator was contacted and agreed that the exterior corrosion was not indicative of graphitic corrosion.

• The staff reviewed FPLCORP020-REPT-092, Section 4.4, Detection of Aging Effects, and noted that when inspections are conducted on piping, a 1-foot axial length section is considered one inspection.

During the audit of the operating experience program element, the staffs independent database search identified operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER. In light of the plant-specific operating experience, in order to obtain the information necessary to determine whether the applicants SLRA AMP can be adequate to manage the associated aging effects, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR.

SLRA AMP B.2.3.22, ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The SLRA states that AMP B.2.3.22, ASME Code Class 1 Small-Bore Piping, is an existing condition monitoring program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M35, ASME Code Class 1 Small-Bore Piping. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancement associated with this AMP.

The enhancement to the GALL-SLR Report AMP is evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - ASME Code Revision 1 093 Class 1 Small-Bore Piping

Document Title Revision / Date AR 00467808 License Renewal Self-Assessment. 07/21/2009 FPLCORP020-REPT- Aging Management Program Basis Document - Operating Revision. 0 120 Experience (OpE) Program Report PTN-ENG-LRAM Small-Bore Class 1 Piping Inspection License renewal Basis Revision. 3 039 Document PTN-ENG-SENS Turkey Point Units 3 and 4 ASME Code Class 1 Small-Bore Revision 1 062 Piping One-Time Inspection Plan AR 00406070 RCS Leak 08/07/2008 AR 02148592 Pinhole crack or leak 08/08/2016 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SRP Report.

SLRA AMP B.2.3.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The SLRA states that AMP B.2.3.23, External Surfaces Monitoring of Mechanical Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staffs evaluation of the enhancements will be documented in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - External Revision 1 094 Surfaces Monitoring of Mechanical Components

Document Title Revision / Date FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Revision 1 120 Report - Aging Management Program Effectiveness 0-ADM-564 Systems / Programs Monitoring Revision 5 PTN-ENG-LRAM Boric Acid Wastage Surveillance Program - License Renewal Revision4 0028 Basis Document 05000250/2017003 Turkey Point Nuclear Generating Station - Nuclear Regulatory 11/9/2017 Commission Integrated Inspection Report 05000250/2017004 Turkey Point Nuclear Generating Station - Nuclear Regulatory 2/8/2018 Commission Integrated Inspection Report 05000250/2017007 Turkey Point Nuclear Generating Station - NRC Design Bases 10/2/2017 Assurance Inspection (Team) Report During the audit, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. However, for the scope of program and detection of aging effects program elements, the staff did not have sufficient information to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience program element, the staff conducted an independent search the Turkey Point operating experience database as discussed in the OpE Audit Report along with other relevant operating experience information. The staff identified information indicating that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER. In light of the plant-specific operating experience, and in order to obtain the information necessary to determine whether the applicants AMP can adequately manage the associated aging effects, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.24, Flux Thimble Tube Inspection Summary of Information in the Application. The SLRA states that AMP B.2.3.24, Flux Thimble Tube Inspection is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M37, Flux Thimble Tube Inspection. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Flux Thimble Revision 1 095 Tube Inspection BMI-FTT-IP Bottom Mounted Instrumentation Flux Thimble Tube Inspection Revision 6 Program for Turkey Point Units 3 and 4 PTN-4FSM-08-002 Incore Flux Thimble Tubing Wear Eval. PT4-24 04/25/2008 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the detection of aging effects, and monitoring and trending, program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience program, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA AMP B.2.3.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The LRA states that AMP B.2.3.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Inspection of Revision 1 096 Internal Surfaces in Miscellaneous Piping and Ducting Components FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 062 Aging Effects Operating Experience During the audit, the staff verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit, the staff identified enhancements associated with the parameters monitored or inspected program element.

In addition, the staff found that for the parameters monitored or inspected program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observation:

• The staff reviewed FPLCORP020-REPT-096 and noted that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages loss of material, cracking, reduction of heat transfer due to fouling, hardening or loss of strength for elastomeric components, and flow blockage.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may

not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

SLRA AMP B.2.3.26, Lubricating Oil Analysis Summary of Information in the Application. The SLRA states that AMP B.2.3.26, Lubricating Oil Analysis, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FLPCORP020- Aging Management Program Basis Document - Lubricating Oil Revision 1 REPT-097 Analysis 0-GMP-102.2_R66 Equipment Lubricating Guide Revision 66 0-GMP-102.6_R10A Periodic Collection of Oil Samples from Plant Pumps, Motor, and Revision 10A Other Lubricating Components During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.27, Monitoring of Neutron-Absorbing Materials other than Boraflex Summary of Information in the Application. The SLRA states that AMP XI.M40, Monitoring of Neutron-Absorbing Materials other than Boraflex, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M40, Monitoring of Neutron-Absorbing Materials other than Boraflex. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP.

The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date 0-OSP-034.3_R1 Metamic Insert Surveillance Revision 1 0-ADM-550_R1A Spent Fuel Pool Rack Management Plan Revision 1A N/A Updated Final Safety Analysis Report 4/17/13 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the detection of aging effects, program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether this program elements is consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed the UFSAR dated April 17, 2013, and noted that it contained a detailed description of the neutron absorbing material monitoring program. During the breakout session for AMP XI.M40, Neutron-Absorbing Materials Other Than Boraflex, the staff asked how removal of a significant amount of detail from the UFSAR would impact the program. The applicant indicated that it would be preserved, and that the UFSAR supplement would be modified to reflect this.

• The staff also reviewed 0-OSP-034.3, Metamic Insert Surveillance, Revision 1, and noted that the inspection interval for Metamic insert surveillance was only scheduled for 30 years after installation.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.28, Buried and Underground Piping and Tanks Summary of Information in the Application. The SLRA states that AMP B.2.3.28, Buried and Underground Piping and Tanks, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020- Aging Management Program Basis Document - Buried and Revision 1 REPT-099 Underground Piping and Tanks FPLCORP020- Subsequent License Renewal Aging Management Review Waste Revision 2 REPT-045 Disposal EC 287426 Asset Management Plan Turkey Point Nuclear Station Revision 1 Underground Piping and Tank Integrity Program 5177-074-C034.1 Technical Specification for Placement and Control of Compacted Revision 10 Fill FPLCORP020- Aging Management Program Basis Document - Structures 01/08/2018 REPT-107 Monitoring FPLCORP020- Subsequent License Renewal Aging Management Review Intake Revision 1 REPT-039 Cooling Water System FPLCORP020- Turkey Point Units 3 and 4 Subsequent License Renewal Aging Revision 1 REPT-062 Effects Operating Experience FPLCORP020- Subsequent License Renewal Aging Management Review Safety Revision 1 REPT-036 Injection and Accumulators Systems

During the audit, the staff verified that the scope of program, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. During the audit, the staff identified an exception associated with the preventive actions program element. In addition, the staff found that for the preventive actions, parameters monitored or inspected, and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed AR 2066294 and noted that a leak in the service water system appeared to be similar to previously repaired leaking buried service water piping.

• The staff reviewed AR 2014369 and noted that (a) internal visual inspection of reinforced concrete piping in the ICW system found that the piping was in good condition with no staining, cracking, spalling, or concrete delamination; (b) internal inspections of the ICW systems found internal graphitization corrosion; and (c) the Asset Management Plan states that there was no original specification or requirement for underground piping coating systems.

• The staff reviewed AR 01940055 and noted that during excavation of a service water leak, implementation noticed that a buried service water valve was covered with asphalt.

• The staff reviewed AR 00462055 and noted that while performing a work order, corrosion was found on four areas of exposed buried service water piping. The most significant area was 1.5 to 2 inches wide and runs half the circumference of the pipe.

Ultrasonic thickness measurements performed on the pipe indicated a maximum corrosion depth of 0.125 inches.

• The staff reviewed AR 00464785 and noted that fire hydrant 10-HY-10 was excavated and a pinhole leak was located.

• The staff reviewed AR 00485197 and noted that the portion of the fire water supply header uncovered by excavation contained evidence of localized external corrosion.

One location was found to be below minimum wall thickness; however, there was no evidence of leakage.

• The staff reviewed AR 01955813 and noted that buried piping was measured for wall thickness using ultrasonic testing (UT). Results were satisfactory with measured wall thickness being 0.715 inches compared to a nominal wall thickness of 0.79 inches.

• The staff reviewed FPLCORP020-REPT-099 and noted the detection of aging effects program element states that the AMP is credited for managing the aging effects for steel, stainless steel, and cementitious materials exposed to soil.

• The staff reviewed EC 287426 and noted that (a) during excavation, it was noted that the liquid waste disposal line was encased in a concrete box, and in order to not disturb the

box, it was decided to inspect the concrete box itself to infer the health of the piping; (b) the box was found to be in excellent condition; (c) for the original buried piping at Turkey Point, the precise details of buried pipe coating from original construction are not well documented; (d) external buried piping inspections performed between 2011 and 2014 showed buried piping was coated and in good condition; and (d) ten soil corrosivity samples showed moisture content ranging from 5.55 to 8.64 percent with an average of 7.07 percent, soil resistivity ranged from 1,050 to 17,500 ohm-cm with an average of 11,671 ohm-cm, and average pH was 8.92 with all samples having a value of 7.5 or greater.

• The staff reviewed AR 00460508 and noted that corrosion of buried carbon steel piping is a known problem at the station, for example service water and fire protection systems.

• The staff reviewed AR 02055286 and noted that operating experience has previously identified multiple instances where uncoated stainless steel piping exposed to the salt laden environment present in either buried or embedded piping has failed due to corrosion.

• The staff reviewed 5177-074-C034.1 and noted that unless otherwise shown on drawings, underground piping shall be bedded with sand that meets the requirements ASTM C-33-86 for fine aggregates.

• The staff reviewed FPLCORP020-REPT-107 and noted that the groundwater/soil at Turkey Point is aggressive with chlorides greater than 500 pounds per minute, which indicates an aggressive groundwater/soil classification.

• The staff reviewed FPLCORP020-REPT-039, Table 4-2, ICW System External Aging Effects, and noted that corrosion of reinforcement is an applicable aging mechanism for concrete piping exposed to soil.

During the audit of the operating experience program element, the staffs independent database search identified operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER. In light of the plant-specific operating experience, in order to obtain the information necessary to determine whether the applicants SLRA AMP can be adequate to manage the associated aging effects, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

SLRA AMP B.2.3.29, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Summary of Information in the Application. The SLRA states that AMP B.2.3.29, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks. To verify this claim of consistency, the staff audited the SLRA AMP.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document and plant-specific inspection procedures. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Internal Revision 1 100 Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks FPLCORP02-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 120 Operating Experience Review Results Aging Management Program Effectiveness SPEC-C-004 Engineering Maintenance Specification Form Revision 14 0-ADM-732 Protective Coatings Revision 3 3-PMM-022.4 Unit 3 Diesel Fuel Oil Storage Tank Cleaning Revision 1B 4-PMM-022.4 Unit 4 Diesel Fuel Oil Storage Tank Cleaning Revision 2A ER-AA-109 Nuclear Fleet Protective Coatings Revision 3 40155017 04 Work Order (WO) 3P9B ICW: 3-50-321 Check Valve/Expansion September 2012 Joint Replacement [internal coatings]

2122945-01 Action Request (AR) 4B ICW [Intake Cooling Water] Discharge 04/04/2016 Header Crawl-Through Inspection 2124200 Inspection and Repair of Intake Cooling Water Piping Unknown SPEC-M-086 Specification Intake Cooling Water System Piping Inspections Revision 1 Turkey Point Units 3 and 4 40130415-01 4A EDG 4T259A Oil Storage Tank Cleaning/Inspect/Recoat 12/19/2012

Document Title Revision / Date 40130415-05 4A EDG 4T259A Oil Storage Tank Cleaning/Inspect/Recoat 12/13/2012 40130167-01 4T259B: 10 YR Tank Clean/Inspection 11/29/2012 39016000-01 3T36: EDG Diesel Oil Storage Tank 10 YR 10/01/2010 1831010 AR 4A EDG Fuel Oil Tank Degraded Coatings 12/08/2012 The staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed AR 2122945-01 and noted that there was one location of degraded coatings out of nine inspected where there was up to 0.180 inches of wall loss on a 6-inch by 3-inch area. There was a 4-inch by 4-inch area of bare steel exposure.

• The staff reviewed AR 2124200 and noted that the document states:

o [s]everal spots on the inner coating show degradation by the horizontal flange.

o [s]iphon OD [outside diameter] has a well adhered coating except for the lower section. The coating is degraded with lots of blisters. Scraping at the blisters reveals bare steel pipe. Performed abrasive blast and recoated the spool with Carboline Plasite 4550S on the OD and inside diameter (ID) per the requirements of SPEC C-004.

• The staff reviewed work order 40130415-01, fuel oil storage tank, and noted that the internal tank coatings failed the inspection. Action Report 01831010 was generated as a result of the inspection. This AR directed that the small and large blisters be repaired.

• The staff reviewed the pictures included in WO 40130415-05 and noted that there were many areas of small and large blisters in the coating and large areas of rust in the steel liner.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description

provided in the UFSAR supplement was an adequate description of the SLRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

SLRA AMP B.2.3.30, ASME Section XI, Subsection IWE Summary of Information in the Application. The SLRA states that AMP B.2.3.30, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X1.S1, ASME Section XI, Subsection IWE. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - ASME Section Revision 1, 102 XI, Subsection IWE 01/05/2018 ISI/IWE-PTN-4-PLAN The Turkey Point Unit 4 IWE Ten-Year Inspection Plan - Revision 4,

[Status: History] Containment Building Metallic Liner 08/31/2009 2nd Interval-IWE-PTN- Second IWE Inspection Interval Program Plan for Turkey Point Revision 1, 3/4-Program Plan Nuclear Power Plant 04/05/2016 ER-AA-118 ASME Section XI Inservice Inspection Program (Nuclear Fleet Revision 2, Program Description) 08/25/2016 0-ADM-532 ASME Section XI Repair/Replacement Program: Administrative Revision 1, Procedure 08/06/2014 NDE4.7 Visual Examination of the Reactor Building Containment Vessel Revision 4,

- General Visual / Detailed Visual (VT-1/VT-3, NDE Manual 11/19/2010 Examination Procedure FPLCORP020-REPT- Subsequent License Renewal Aging Management Review - Revision 3 056 (PBD Ref 9.2) Containment Structure and Internal Structural Components FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 120 (PBD Ref 9.15) Operating Experience Review Results - Aging Management Program Effectiveness, Appendix 1.20 XI.S1 ASME Section XI, Subsection IWE Drawing 5610-C-164 Containment Structure Floor Liner Plate Plan Revision 4

Document Title Revision / Date Drawing 5610-C-166 Containment Structure Floor Liner Plate Plan / Penetration Revision 1 Details Drawing 5610-C-166 Containment Structure Floor Liner Plate Repair Details Revision 1 Sheet 2 Drawing 5610-C-204 Containment Structure Reactor Fuel Transfer Tube Revision 6 Drawing 5610-M-475, Turkey Point Units 3 and 4, Fuel Transfer Tube Assembly Revision 9 Sheet 1 of 2 Drawing 5610-M-475, Containment Building Fuel Transfer Tube System Blind Flange Revision 1 Sheet 2 of 2 Davit Assembly Q4-2017 Program Health Report, PTN ISI-ISI None Q2-2016 Program Health Report, PTN ISI-ISI None Q4-2013 Program Health Report, PTN ISI-ISI None Q1-2012 Program Health Report, PTN ISI-ISI None During the audit, the staff verified that the scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the preventive actions, and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the Safety Evaluation Report. The staff notes that, with regard to the identified issue associated with the enhancement for preventive actions program element, during the audit breakout session, the applicant offered to voluntarily provide a revision to the enhancement without an RAI.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER. However, in light of the plant-specific configuration of a containment liner air chase system similar to the configuration described in NRC IN 2014-007, the staff will consider issuing an RAI in order to obtain the information necessary to determine whether the applicants SLRA AMP can be adequate to manage the associated aging effects. The staffs evaluation of the potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the SRP-SLR, subject to any conforming changes that may have to be made based on responses to the RAIs related to program consistency.

SLRA AMP B.2.3.31, ASME Section XI, Subsection IWL Summary of Information in the Application. The SLRA states that AMP B.2.3.31 ASME Section XI, Subsection IWL is an existing program with enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.S3, ASME Section XI, Subsection IWL. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancement associated with this AMP. The enhancement is evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - ASME Section Revision 1 103_R1_ISI_IWL_AMP XI, Subsection IWL 0-ADM-532 ASME Section XI Repair/Replacement Program Revision 1 3-OSP-051.17 Containment Building Visual Inspection Revision 3 I2-ISI-IWL-PTN-3-4_R1 ASME Section XI, Subsection IWL Interval 2 Concrete Revision 1 Containment Inservice Inspection Program PTN-ENG-LRAM ASME Section XI, Subsection IWL Inservice Inspection Revision 3 0025_R3_ISI_IWL Program - License Renewal Program Basis Document AR 2216534 Containment Cathodic Protection System Non Functional 09/19/2017 During the audit, the staff verified that the preventive actions, parameters monitored or inspected, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the scope of program, detection of aging effects, and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observation unique to the ASME Section XI, Subsection IWL AMP:

The staff reviewed several corrective actions reports associated with primary containment degradation and noted a number of instances of plant-specific operating experience related to concrete and tendon assembly degradation (e.g., grease leakage and spalling of cover concrete) and loss of prestress.

The staff made additional observations related to AMP X.S1 and TLAA 4.5 that relate to the ASME Section XI, Subsection IWL AMP. Those observations are documented in the appropriate audit report sections.

During the audit of the operating experience program element, the staffs independent database search identified operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects (see also Staff Review of AMR Item Details).

The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER. In light of the plant-specific operating experience, in order to obtain the information necessary to determine whether the applicants SLRA AMP can be adequate to manage the associated aging effects, the staff will consider issuing an RAI after an on-site audit. The staffs evaluation of the potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.32, ASME Section XI, Subsection IWF Summary of Information in the Application. The SLRA states that AMP B.2.3.32, ASME Section XI, Subsection IWF, is an existing program with an enhancements and exception that will be consistent with the program elements in GALL-SLR Report AMP XI.S3, ASME Section XI, Subsection IWF. To verify this claim of consistency, the staff audited the SLRA AMP.

Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The exception to the GALL-SLR Report AMP and the enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - ASME Section Revision 1 104 XI, Subsection IWF 5-INTERVAL-ISI- Fifth Inservice Inspection Interval Program Plan Revision 1 PLAN_001 Spec No. 2-24 Nuclear Engineering Drilled-In Expansion Type Anchors in Revision 13 Concrete Spec-M-004 Maintenance Bolting Specification for St. Lucie Units 1 & 2 and Revision 15 Turkey Point Units 3 & 4 During the audit, the staff verified that the acceptance criteria program element of the SLRA AMP is consistent with the corresponding element of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

SLRA AMP B.2.3.33, 10 CFR Part 50, Appendix J Summary of Information in the Application. The SLRA states that AMP B.2.3.33 10 CFR Part 50, Appendix J is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.S4, 10 CFR Part 50, Appendix J. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancement associated with this AMP. The enhancement to the GALL-SLR Report AMP is evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- AMP Basis Document - 10 CFR 50, Appendix J Revision 1 105 FPLCORP020-REPT- SLR, AMR Containment Structure and Internal Structural Revision 3 056 Components FPLCORP020-REPT- SLR, Containment Structure and Internal Structural Revision 1 024 Components Screening Results PTN-ENG-LRAM Aging Management Review Containment Structures and Revision 4 0055 Structural Components

Document Title Revision / Date FPLCORP020-REPT- SLR, OpE Review Report - AMP Effectiveness Revision 0 062 FPLCORP020-REPT- TP Units 3 and 4, SLR - OpE Review Report - AMP Revision 1 120 Effectiveness ENERCON- Turkey Point SLR Evaluation - Final Report 01/21/2016 CONFIDENTIAL 0-ADM-531 Containment leakage Rate Testing Program, Admin Procedure Revision 7 3-OSP-051.15 Valve Line-Up for ILRT Revision 8 4-OSP-051.15 Valve Line-Up for ILRT Revision 6A 3-OSP-051.16 Integrated Leakage Rate Test Revision 7A 4-OSP-051.16 Integrated Leakage Rate Test Revision 3B 3-OSP-051.17 Containment Building Visual Inspection Revision 3 4-OSP-051.17 Containment Building Visual Inspection Revision 2 4-OSP-051.3 Containment Personnel Air Lock Pressure Test Revision 4 3-OSP-051.3 Containment Personnel Air Lock Pressure Test Revision 5 4-OSP-051.4 Containment Emergency Air Lock Pressure Test Revision 4 3-OSP-051.4 Containment Emergency Air Lock Pressure Test Revision 6 4-OSP-051.5 Local Leak Rate Tests Revision 15 3-OSP-051.5 Local Leak Rate Tests Revision 21 ER-AA-114 Appendix J Testing Program - Nuclear Fleet, Nonsafety Revision 2 Related, Information Use 3-OSP-051.1 Containment Emergency Air Lock Seal Vacuum Test Revision 0 4-OSP-051.1 Containment Emergency Air Lock Seal Vacuum Test Revision 1A 3-OSP-051.2 Containment Personnel Air Lock Seal Vacuum Test Revision 2 4-OSP-051.2 Containment Personnel Air Lock Seal Vacuum Test Revision 2A During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, and monitoring and trending, program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the in-Office audit the staff reviewed Turkey Point SLRA Section B.2.3.33, and noted that its Program Description states that this is an existing AMP that was formerly the Turkey Point Containment Leak Rate Testing Program, although, it was not previously credited for license renewal. This is repeated in Appendix A, Updated Final Safety Analysis Report Supplement, for SLRA AMP 10 CFR Part 50, Appendix J (referenced as SLRA Section 17.2.2.33), and further repeated in FPLCORP020-REPT-024 and in other documents listed in Table titled Relevant Documents Reviewed above (e.g., Turkey Point SLR Evaluation - Final Report).

The staff considers this to be a new AMP with existing Operating Experience.

The staff also reviewed FPLCORP020-REPT-105 and other documents listed in Table titled Relevant Documents Reviewed above (e.g., ER-AA-114, 0-ADM-531) and noted that the applicant erroneously referenced in the application NEI 94-01, Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50 Appendix J, Nuclear Energy Institute, Washington D.C., October 2008, as the implementing document for the 10 CFR Part 50 Appendix J; it follows NEI 94-01, Revision 0, of the document.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

SLRA AMP B.2.3.34, Masonry Walls Summary of Information in the Application. The SLRA states that AMP B.2.3.34, Masonry Walls, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.S5, Masonry Walls. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancement associated with this AMP. The enhancement is evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed

Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Masonry Walls Revision 1 106 1/4/2018 0-ADM-561 Turkey Point Plant Administrative Procedure - Structures Revision 5 Monitoring Program 4/25/2016 PI-AA-104-1000 NextEra Energy Nuclear Fleet Administrative Procedure - Revision 15 Condition Reporting 11/10/2017 AR 01803016 NEI 12-07 Flooding Insp: Perimeter Flood Protection Barrier 11/12/2012 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience in the SLRA will be addressed in the SER. In light of the plant-specific operating experience, in order to obtain the information necessary to determine whether the applicants SLRA AMP can be adequate to manage the associated aging effects, the staff will consider issuing an RAI. The staffs evaluation of this potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.35, Structures Monitoring Summary of Information in the Application. The SLRA states that AMP XI.S6, Structures Monitoring, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The exception to the GALL-SLR Report AMP and the enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed

Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Structures Revision 1 107 Monitoring PTN UFSAR 429 Updated Final Safety Analysis Report Turkey Point Units 3 & 4 09/20/2016 0-ADM-561 Turkey Point Plant Structures Monitoring Program Revision 5 STD-C-007 General Civil Design Criteria for Turkey Point Units 3 & 4 Revision 3 SPEC-C-006 Purchase of Structural And Miscellaneous Steel for Turkey Revision 0 Point Units 3 & 4 and St. Lucie Units 1 & 2 SPEC-C-007 Erection of Structural And Miscellaneous Steel for Turkey Point Revision 3 Units 3 & 4 and St. Lucie Units 1 & 2 SPEC-M-004 Maintenance Specification Bolting for St. Lucie Units 1 & 2 and Revision 15 Turkey Point Units 3 & 4 ACAD 98-004 Guidelines for training and qualification of Engineering Revision 2 Personnel SSMP-WKDN-001A Structures Monitoring Program Walkdown Report, Unit 3, Revision 1A Baseline SSMP-WKDN-001B Structures Monitoring Program Walkdown Report, Unit 4, Revision 1B Baseline PTN-ENG-SECS 2017 PTN Structures Monitoring Program Report Revision 3 /

019 06/01/2018 AR 02239727 Major Gaps to Effectiveness - PTN Structures Monitoring 12/08/2017 Program AR 02213207 Structures Monitoring Long Term Action Monitoring Inspection 12/08/2017 Requirements Not Tracked AR 00479076 AR Evaluation 2007-12251- Concrete Falling From Turbine 04/23/2007 Deck to Mezzanine During the audit, the staff verified that the preventive actions program element of the SLRA AMP is consistent with the corresponding element of the GALL-SLR Report AMP. The staff also verified that aspects of the scope of program and acceptance criteria program elements not associated with the exception identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• The staff reviewed SSMP-WKDN-001A and SSMP-WKDN-001B and noted that several identified concrete degradations where based on qualitative criteria (e.g. very large spall, extensive spall, severe scaling).

• The staff reviewed corrective action report no. AR 02239727 and noted that the applicant self-identified gaps to the effective implementation of the Structures Monitoring Program. The applicant looked to address issues related, in part, to inspections not performed within 5-year inspection interval, and follow-up inspections not being tracked.

• The staff reviewed several corrective action reports associated with structural degradation and identified a notable amount of plant-specific operating experiences related to corrosion degradation for several structures and components at the site.

During the audit of the operating experience program element, the staffs independent database search identified operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER. In light of the plant-specific operating experience, in order to obtain the information necessary to determine whether the applicants SLRA AMP can be adequate to manage the associated aging effects, the staff will consider issuing an RAI after an on-site audit. The staffs evaluation of the potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.36, Inspection of Water Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The SLRA states that AMP XI.S7, Inspection of Water Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements, a portion of the Turkey Point Systems and Structures Monitoring Program that will be consistent with the program elements in GALL-SLR Report AMP XI.S7, Inspection of Water Control Structures Associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Inspection of Revision 1 068 Water Control Structures Associated with Nuclear Power Plants

Document Title Revision / Date 0-ADM-561 Turkey point Plant Structures Monitoring Program Revision 5 STD-C-007 General Civil Design Criteria for Turkey Point Units 3 & 4 Revision 3 SPEC-C-006 Purchase of Structural And Miscellaneous Steel for Turkey Revision 0 Point Units 3 & 4 and St. Lucie Units 1 & 2 SPEC-C-007 Erection of Structural And Miscellaneous Steel for Turkey Point Revision 3 Units 3 & 4 and St. Lucie Units 1 & 2 AR 01768157 Unit 3 Intake Structure degraded steel and concrete 07/13/2012 AR 02134432 Degradation of the structural support steel 10/27/2016 AR 02146030 Degradation of structural steel support plate 12/09/2016 AR 00403585 Significant grass event requiring unit down power 08/16/2008 0-ADM-116 Hurricane Season Readiness Revision 23A EP-SR-1002 Fleet support Hurricane Response procedure Revision 002 WD102008 PTN Hurricane Preparation Revision 15A 4015836101_000 Work Order: Spalled concrete in 3B2 intake well on west side 05/29/2012 strut beam 4020974603_000 Work Order: Coat U4 ICW support beams 4B1 bay 09/26/2016 4034593701_000 Work Order: Perform coating repairs in 4A2 well 09/30/2016 4034593704_000 Work Order: Perform coating repair in 4A2 well 09/04/2016 DWG-5610 C-1168 to Cooling canals system layout 10/15/1971 C-1078 TP.CCS.[cooling canal Turkey Point Consent Order OGC File No. 16-0241: Inspection 10/12/2016 system] Inspection of the Turkey Point Cooling Canal System periphery Report Soil Information USFAR Section 2.9.3 Local Geology, and Environmental Various Report SOLR Section 3.5.3, Soil During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identified any operating experience that would indicate that the AMP

may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER. In light of the plant-specific operating experience, in order to obtain the information necessary to determine whether the applicants SLRA AMP can be adequate to manage the associated aging effects, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.37, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The SLRA states that AMP B.2.3.37, Protective Coating Monitoring and Maintenance, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S8, Protective Coating Monitoring and Maintenance. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant.

The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Protective Revision 1 108 Coating Monitoring and Maintenance 0-ADM-732 Protective Coatings Revision 3 ER-AA-109 Nuclear Fleet Protective Coatings Revision 3 SPEC-C-034 Protective Coatings for Service Level I Applications Inside The Revision 9 Reactor Containment Building - PSL U1 and U2, PTN U3 and U4.

AR 02198767 As-left Coatings Walkdown 04/13/2017 AR 02232195 As-left Coatings Walkdown for the PT4-30 Refueling Outage 10/23/2017 During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Summary of Information in the Application. The SLRA states that AMP B.2.3.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program, formerly a portion of the Turkey Point Containment Cable Inspection Program, with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements to the GALL-SLR Report AMP are evaluated in the SER.

Audit Activities. During its audit, the staff reviewed documentation provided on by the applicant and held breakout sessions with the applicants staff for clarification. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020_REPT_ Aging Management Program Basis Document - Electrical Revision 1, 110_R1_XI_E1_AMP Insulation for Electrical Cables and Connections Not Subject to 1/3/2018 10 CFR 50.49 EQ Requirements FPLCORP020_REPT_ Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1, 001_R1_Electrical Electrical Screening Results 1/3/2018 Screening FPLCORP020_REPT_ Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1, 063_R1_Scoping Systems/Structure Scoping Report 1/4/2018 Report NEE_391_PI_001 Enercon Services, Inc., Project Instruction for Confidential Revision 0, Screening Project License Renewal Project Scoping Documents 4/21/2017 Instruction _ Approved FPLCORP020_REPT_ Turkey Point Units 3 and 4 Subsequent License Renewal Aging Revision 0, 062_R1_OE_Aging_Eff Effects Operating Experience 1/3/2018 ects_Report

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR SLRA AMP B.2.3.39, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements used in Instrumentation Circuits Summary of Information in the Application. The SLRA states that AMP B.2.3.39, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements used in Instrumentation Circuits, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E2, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits. To verify this claim of consistency, the staff audited the SLRA AMP.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff reviewed documentation provided by the applicant and held breakout sessions with the applicants staff for clarification. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020_REPT_ Aging Management Program Basis Document - Electrical Revision 1, 1/3/2018 111_R1_XI_E2_AMP Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements FPLCORP020_REPT_ Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1, 001_R1_Electrical Electrical Screening Results 1/3/2018 Screening FPLCORP020_REPT_ Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1, 063_R1_Scoping Systems/Structure Scoping Report 1/4/2018 Report NEE_391_PI_001 Enercon Services, Inc., Project Instruction for Confidential Revision 0, Screening Project License Renewal Project Scoping Documents 4/21/2017 Instruction _ Approved FPLCORP020_REPT_ Turkey Point Units 3 and 4 Subsequent License Renewal Aging Revision 0, 062_R1_OE_Aging_Eff Effects Operating Experience 1/3/2018 ects_Report

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

LRA AMP B.2.3.40, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 EQ Requirement Summary of Information in the Application. The SLRA states that AMP B.2.3.40, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 EQ Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3A, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed relevant documents provided by the applicant.The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Documents Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Electrical Rev. 1 112 Insulation for Inaccessible Medium-Voltage Power Cable Not Subject to 10 CFR 50.49 EQ Requirements FPLCORP020-REPT- Subsequent License Renewal Electrical Screening Rev. 1 001 FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Rev. 1 063 System/Structure Scoping Report FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Rev. 0 120 Report - Aging Management Program Effectiveness During the audit, the staff verified that scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptable criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

SLRA AMP B.2.3.41, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 EQ Requirement Summary of Information in the Application. The SLRA states that AMP B.2.3.41, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 EQ Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3B, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed relevant documents provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Electrical Revision 1 113 Insulation for Inaccessible Instrument and Control Cable Not Subject to 10 CFR 50.49 EQ Requirements FPLCORP020-REPT- Subsequent License Renewal Electrical Screening Revision. 1 001 FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 063 System/Structure Scoping Report FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Revision 0 120 Report - Aging Management Program Effectiveness During the audit, the staff verified that scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptable criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA AMP B.2.3.42, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 EQ Requirement Summary of Information in the Application. The SLRA states that AMP B.2.3.42, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 EQ Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3C, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed relevant document provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Electrical Revision 1 129 Insulation for Inaccessible Low-Voltage Power Cable Not Subject to 10 CFR 50.49 EQ Requirements FPLCORP020-REPT- Subsequent License Renewal Electrical Screening Revision 1 001 FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 063 System/Structure Scoping Report FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Revision 0 120 Report - Aging Management Program Effectiveness During the audit, the staff verified that scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptable criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA AMP B.2.3.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Requirements Summary of Information in the Application. The SLRA states that AMP B.2.3.43,Electrical Cable Connections Not Subject to 10 CFR 50.49 Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed relevant documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FLCORP 020-REPT- Aging Management Program Basis Document - Electrical Cable 01/02/2018 114 Connections Not Subject to 10 CFR 50.49 Requirements MA-AA-203-1000 Maintenance Testing - Nuclear Fleet Administration 11/03/2017 FLCORP 020-REPT- SLR Aging Management - Review of Electrical Commodities 04/13/2018 061 FLCORP 020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Aging 01/03/2018 062 Effects Operating Experience During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP XI.E6.

During the audit, the staff made the following observation regarding the monitoring and trending program element:

• The staff reviewed the applicants document FLCORP020-REPT-114 and noted that the monitoring and trending element of the applicants proposed program does not include trending for condition monitoring inspections and test results that are trendable. The staff will consider issuing an RAI in order to address this insufficiency. The staffs evaluation of the potential RAI will be documented in the SER.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR.

SLRA AMP B.2.3.44, High-Voltage Insulators Summary of Information in the Application. The SLRA states that AMP B.2.3.44, High-Voltage Insulators, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E7, High Voltage Insulators. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed relevant documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FLCORP 020-REPT- Aging Management Program Basis Document - High-Voltage 01/03/2018 117 Insulators FLCORP 020-REPT- SLR Aging Management - Review of Electrical Commodities 04/13/2018 061 FLCORP 020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Aging 01/03/2018 062 Effects Operating Experience Vendor Catalog - 011 NGK Locke Polymer Insulators, Inc. - Polymer Suspension N/A Insulators 69 kV to 765 kV During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP XI.E7.

During the audit the staff made the following observation:

• The staff reviewed document FLCORP020-REPT-117, as well as Vendor Catalog - 011 and noted that the basis document does not address polymer high-voltage insulators.

Polymer high-voltage insulators are mentioned in the SLRA AMP description, but the applicants basis document and SLRA Table 3.6.2-1 do not include these components.

The staff will consider issuing an RAI in order to address this insufficiency. The staffs evaluation of the potential RAI will be documented in the SER.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR.

SLRA AMP B.2.4.1, Pressurizer Surge Line Fatigue AMP Summary of Information in the Application. The SLRA states that AMP B.2.4.1, Pressurizer Surge Line Fatigue, AMP is an existing plant-specific aging management program. The staff audited the SLRA AMP to determine consistency with SRP-SLR Section A.1.2.3, Aging Management Program Elements.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documents provided by the applicant. The table below lists the documents that were reviewed and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Pressurizer Revision 1 069 Surge Line Fatigue 12/18/2017 FPLCORP20-REPT- Subsequent License Renewal Aging Management Review Revision 1 032 Reactor Coolant System and Connected Piping 01/03/2018 FPLCORP020-REPT- Subsequent License Renewal Operating Experience Review Revision 1 120 Report - Aging Management Program Effectiveness 01/26/2018 5th Interval-ISI-PTN- Fifth Inservice Inspection Interval Program Plan for Turkey Revision 1 3/4-Program Plan Point Nuclear Power Plants Units 3 and 4 06/22/2016 0-ADM-532 ASME Section XI Repair/Replacement Program Revision 1 08/06/2014 0-ADM-523 ASME Section XI Pressure Tests For Quality Group A,B,C Revision 3D Systems/Components 10/28/2016 During the audit the staff verified that the scope of the program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with SRP-SLR Section A.1.2.3.

During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate that the AMP may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in GALL-SLR Report.

SLRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses Summary of Information in the Application.

SLRA Section 4.1, Identification Of Time-Limited Aging Analyses, discusses the methodology for the identifying of TLAAs in the SLRA.

To verify the implementation of the applicants methodology to identify TLAAs, the staff performed an audit. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Subsequent License Renewal Time-Limited Aging Analyses Revision 3 115 and Exemptions Based on Time-Limited Assumptions During the audit, the staff verified that the applicants methodology supports identifying TLAAs in accordance with disposition of 10 CFR 54.21(c).

During the audit the staff made the following observations:

• The staff reviewed FPLCORP020-REPT-115 and confirmed that current licensing basis and design basis documentation were searched to identify potential TLAAs. The staff noted that specific key words were used during this search that would identify potential TLAAs.

• The staff reviewed FPLCORP020-REPT-115 and confirmed that each potential TLAA was reviewed against the six criteria of 10 CFR 54.3(a) and that those that met all six criteria were identified as TLAAs which require evaluation for the subsequent period of extended operation.

• The staff reviewed FPLCORP020-REPT-115 and confirmed that a search of docketed licensing correspondence, the operating license, and the UFSAR identified the active exemptions currently in effect pursuant to 10 CFR 50.12.

• The staff reviewed FPLCORP020-REPT-115 and confirmed that these exemptions were then reviewed to determine whether the exemption was based on a TLAA and that no 10 CFR 50.12 exemptions involve a TLAA as defined in 10 CFR 54.3.

SLRA TLAA Section 4.2, Neutron Embrittlement TLAAs Summary of Information in the Application. SLRA Section 4.2.2, Pressurized Thermal Shock, describes the applicants TLAA for pressurized thermal shock (PTS). The applicant dispositioned the PTS TLAA for the RPV beltline and extended beltline materials in accordance with 10 CFR 54.21(c)(1)(ii) to demonstrate that the analysis has been projected to the end of the period of extended operation.

SLRA, Section 4.2.3, Upper Shelf Energy, describes the applicants TLAA for upper shelf energy (USE). The applicant dispositioned the USE evaluation for the RPV beltline and extended beltline materials in accordance with 10 CFR 54.21(c)(1)(ii) to demonstrate that the effects of loss of fracture toughness on the intended functions have been projected to the end of the SPEO.

SLRA, Section 4.2.4, Adjusted Reference Temperatures, describes the applicants TLAA for Adjusted Reference Temperatures (ART). The applicant dispositioned the TLAA for the RPV beltline and extended beltline materials in accordance with 10 CFR 54.21(c)(1)(ii) to demonstrate that the analysis has been projected to the end of the period of extended operation. The applicant provided its calculations of the ART of all RPV beltline and extended beltline materials in Tables 4.2.4-1 (Turkey Point Unit No. 3) and 4.2.4-2 (Turkey Point Unit Nos. 4).

To verify that the applicant provided a basis to support its disposition of these TLAAs, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

In addition, the staff found that sufficient information was not available to support its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date

1. PTN-BFJS Turkey Point Units 3&4, 72 EFPY PTS, ART, and Revision 0 001, EC #290196 USE Calculation for 80 Year Subsequent License Renewal During the audit, the staff reviewed Calculation # PTN-BFJS-17-001, EC #290196 Rev. 0, Turkey Point Units 3&4, 72 EFPY PTS, ART, and USE Calculation for 80 Year Subsequent License Renewal - SLR. This calculation includes the references and the calculations for all the input values to the calculations of the pressurized thermal shock reference temperature (RTPTS), the ART, and the USE values that are reported in SLRA Section 4.2. The calculation also includes calculations of the best-fit chemistry factor (CF) for those reactor pressure vessel materials that have surveillance data. The staff notes that a technical report, BAW-2313, R7, B&W Fabricated Reactor Vessel Materials and Surveillance Data Information, PWR Owners

Group, September 2016, is referenced for the initial RTNDT values for several materials. During the breakout session, the applicant indicated that this is a generic report.

The staff reviewed the calculations and verified they are all done in accordance with the applicable methods from 10 CFR 50.61 (PTS) and RG 1.99, Rev. 2 (ART and USE). In the SLRA, RTPTS values were provided for several RPV materials based on surveillance data. The chemistry factor (CF) values for these materials are slightly different than the CFs in the previous analysis of record (Turkey Point Unit No. 3 and Turkey Point Unit No. 4 extended power uprate (EPU) licensing report, ADAMS Accession No. ML103560204).

During the breakout session, the NRC staff asked why these CFs changed relative to the EPU.

The applicant indicated that there were minor changes in the calculated capsule fluences which results in the small changes in the CFs compared to those that were approved as part of the EPU license amendment. The applicant also noted that the CF determined using surveillance data for the inner shell to lower shell welds for Turkey Point Unit No. 3 and Turkey Point Unit No. 4 is not used in the calculation of RTPTS or ART because these welds used the BAW-2308, Rev. 2-A, Initial RTNDT of Linde 80 Weld Materials, methodology of determining initial RTNDT.

As a condition of use of this methodology, the NRC safety evaluation requires the use of a minimum CF of 167, which is higher than the CF determined by surveillance data.

During the audit, the staff reviewed the calculations of the revised CFs. The specific calculations are in Tables 9 and 11 of # PTN-BFJS-17-001, for weld SA-1101/Heat 71249 and Lower Shell Forging Heat # 122SV80VA1. The staff verified that the calculations of the revised best-fit CFs for the surveillance methods have been performed in accordance with RG 1.99 (ADAMS Accession No. ML081270388).

For the USE, some of the unirradiated USE values in the calculation are different than the previous CLB values approved in the EPU license amendments. Specifically, for all the welds a generic initial USE of 64 ft-lbs was used. BAW-2313 R7 was referenced. This value was lower and thus more conservative than the previous values.

For certain materials, the RTNDT(u) and u values changed in the SLRA relative to the EPU license amendment. This question pertains to both the PTS TLAA (section 4.2.2) and the ART TLAA (Section 4.2.4). BAW-2313 R7 was referenced in Calculation PTN-BFJS-17-001 for many of the revised RTNDT(u) and u values. During the breakout session, the applicant identified the source of the revised values for each material. Most of the revised values were from BAW-2313 R7. Since this report has not been submitted to NRC, and the changes to the input values could result in significant changes to the RTPTS and ART values for the affected materials, the staff determined that an RAI may be necessary to obtain the information on the docket.

In summary, the staff found that sufficient information was not available to supports its review of the applicants basis that supports its TLAA disposition for Subsections 4.2.2 and 4.2.4. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

TLAA Section 4.3.1, Metal Fatigue of Class 1 Components Summary of Information in the Application. SLRA Section 4.3.1 Metal Fatigue of Class 1 Components, discusses the analyses for the ASME Boiler and Pressure Vessel Code,Section III, Class 1 fatigue calculations. This includes fatigue analyses for the reactor vessels, reactor vessel internals, pressurizers, steam generators, reactor coolant pumps, and pressurizer surge lines that have been designed in accordance with the requirements of the ASME Boiler and Pressure Vessel Code,Section III, Class 1. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date SIA Report No. Evaluation of Fatigue of ASME Section III, Class 1 Components Revision 4 1700109.402P for Turkey Point Units 3 and 4 for Subsequent License Renewal During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). In addition, the staff found that sufficient information was not available to supports its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience associated with the TLAA, the staffs independent database search did not identify any operating experience that would indicate that the TLAA may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA TLAA provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA TLAA. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

TLAA Section 4.3.2, Metal Fatigue of Piping Components Summary of Information in the Application. SLRA Section 4.3.2, Metal Fatigue of Piping Components, discusses the fatigue calculations for non-Class 1 piping components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-CALC- Screening of Class 1, 2 and 3 Piping for License Renewal Revision 0 003 TLAA Thermal Fatigue FPLCORP020-REPT- Subsequent License Renewal Time-Limited Aging Analyses Revision 3 115 and Exemptions Based on Time-Limited Assumptions During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). In addition, the staff found that sufficient information was not available to supports its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience associated with the TLAA, the staffs independent database search did not identify any operating experience that would indicate that the TLAA may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA TLAA provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA TLAA. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

TLAA Section 4.3.3, Environmentally Assisted Fatigue Summary of Information in the Application. SLRA Section 4.3.3, Environmentally Assisted Fatigue, discusses the analyses that address environmentally assisted fatigue for reactor coolant pressure boundary components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date SIA Report No. Evaluation of Fatigue of ASME Section III, Class 1 Components Revision 4 1700109.402P for Turkey Point Units 3 and 4 for Subsequent License Renewal SIA Report No. Evaluation of Environmentally-Assisted Fatigue for Turkey Point Revision 5 1700109.401P Units 3 and 4 for Subsequent License Renewal SIA Calculation No. 3-D Finite Element Model of Pressurizer Bottom Head, Skirt Revision 0 1700804.316P Assembly and Heater Wells SIA Calculation No. Pressurizer Spray Nozzle Loads Revision 2 1700804.313P SIA Calculation No. Pressurizer Spray Nozzle Finite Element Model and Stress Revision 1 1700804.314P Analyses SIA Calculation No. Pressurizer Spray Nozzle Fatigue Analysis Revision 2 1700804.315P LTR-SDA-II-17-13-P Environmentally Assisted Fatigue Evaluation of the Turkey Revision 2 Point Unit 3 and Unit 4 Pressurizer Upper Head and Shell and Reactor Vessel Core Support Blocks LTR-CECO-17-025-P Environmentally Assisted Fatigue Evaluation of the Turkey Revision 1 Point Unit 3 and Unit 4 Replacement Steam Generators Areva Calculation No. Turkey Point 3 & 4 CRDM Nozzle to Adapter Weld Connection Revision 1 32-9279174 EAF Evaluation Areva Calculation No. Turkey Point 3 & 4 Replacement RVCH CRDM Nozzle EAF Revision 1 32-9279212 Analysis Areva Calculation No. TP CRDM Latch Housing Environmentally Assisted Fatigue Revision 1 32-9279367 Areva Calculation No. TP Vent Nozzle Environmentally Assisted Fatigue Revision 1 32-9279362 Areva Calculation No. Turkey Point SLR EAF Analysis for Reactor Vessel Flange Revision 1 32-9279161 Areva Calculation No. TP CRDM Lower Joint Environmentally Assisted Fatigue Revision 1 32-9280202 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). In addition, the staff found that sufficient information was not available to supports its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience associated with the TLAA, the staffs independent database search did not identify any operating experience that would indicate that the TLAA may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA TLAA provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.4, Reactor Vessel Underclad Cracking Summary of Information in the Application. SLRA Section 4.3.4, Reactor Vessel Underclad Cracking, discusses the analysis for postulated underclad cracks in the reactor pressure vessels (RPVs). The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this audit report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date PWROG-17031-NP Update for Subsequent License Renewal: WCAP-15338-A Revision 0 (provided in SLRA Enclosure 4, Attachment 9) August 2017 WCAP-15338-A A Review of Cracking Associated with Weld Deposited October 2002 Cladding in Operating PWR Plants (includes NRC SE and RAI correspondence)

NRC Letter, Turkey Point Units 3 and 4 - Issuance of Amendments 06/15/2012 Amendment No. 249, Regarding Extended Power Uprate Amendment No. 245, NRC SE During the audit of the TLAA, the staff verified that the applicant provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). In addition, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• To support its 10 CFR 54.21(c)(1)(ii) disposition of the TLAA, the SLRA included PWR Owners Group (PWROG) Report PWROG-17031-NP, Revision 0, in Enclosure 4 of the SLRA. The PWROG-17031-NP report provides a generic methodology for analysis of underclad cracks in Westinghouse RPVs, applicable to 80-years of plant operation.

• The staff noted that the PWROG-17031-NP report is not approved by the NRC for generic use in SLR applications. Therefore, the staff is reviewing PWROG-17031-NP, as included in the SLRA, to determine whether this supports the applicants TLAA disposition of 10 CFR 54.21(c)(1)(ii) for acceptance of RPV underclad cracks.

• The SLRA states that while no RPV underclad cracking has been detected at Turkey Point, the generic underclad cracking analysis is part of the CLB and thus requires evaluation for the SPEO. Accordingly, the applicants TLAA considers a postulated underclad crack based on the bounding underclad crack size reported in the industry operating experience described in PWROG-17031-NP.

• With the exception of the cumulative fatigue crack growth (FCG) projections, the staff verified that the analytical methods in PWROG-17031-NP are the same as those in the NRC-approved 60-year methodology of WCAP-15338-A, October 2002 (ADAMS Accession No. ML083530289). Both reports use the linear elastic fracture mechanics (LEFM) methods and FCG rate curves of the ASME Code,Section XI, IWB-3600 and Non-Mandatory Appendix A for analyzing postulated underclad cracks in RPVs.

• PWROG-17031-NP shows that the Code-allowable flaw sizes for normal/upset/test and emergency/faulted loading conditions per IWB-3600 remain unchanged for 80 years.

This is based on consideration of the same governing transients for 3-Loop plants, which is the Turkey Point design, as well as continued use of time-invariant upper shelf fracture toughness of 200 ksiin for all transient analyses. The SLRA indicates that the governing transients are unchanged with the implementation of the EPU license amendment in 2012 (ADAMS Accession No. ML11293A359). The staff verified that the 2012 EPU license amendment would not affect the transient loadings on the RPV for determining Code-allowable flaw sizes.

• The staff noted that PWROG-17031-NP projects the generic cumulative FCG for 80-years by applying a multiplication factor of two to the original 40-year design transient cycles for normal, upset, and test conditions. The staff verified that this is consistent with the 60-year WCAP-15338-A FCG methodology, which used a multiplication factor of 1.5 for the original 40-year design cycles.

• The staff compared the applicants 80-year projected and analyzed transient cycles in SLRA Tables 4.3-2 and 4.3-3 with the generic 80-year cycle assumption used for the FCG projections in PWROG-17031-NP. The staff verified that the plant-specific transient cycles for the Turkey Point Unit No. 3 and No. 4 RPVs are well bounded by the generic 80-year transient cycle assumption (twice the 40-year design cycles) of PWROG-17031-NP.

• The staff noted that analysis results for the Large Steamline Break transient show a slightly more limiting allowable flaw size for a circumferential flaw compared to the axial flaw. This is inconsistent with RPV shell tensile stress due to internal pressure. This issue may potentially result in an RAI.

During the audit of the operating experience associated with the TLAA, the staffs independent database search did not identify any operating experience that would indicate that the TLAA may not be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA TLAA provided in the FSAR supplement.

The staff found that this description is consistent with the discussion of these analyses in SLRA Section 4.3.4.

SLRA TLAA Section 4.4 Environmental Qualification (EQ) of Electric Equipment Summary of Information in the Application. SLRA Section 4.4, Environmental Qualification (EQ) of Electric Equipment, discusses the thermal, radiation, and cyclical aging analysis of the plant electrical and instrumentation components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed relevant documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP-020-REPT- Subsequent License Renewal Time Limited Aging Analysis and 04/12/2018 115 Exceptions based on Time Limited Assumptions FPLCORP-020-REPT- Aging Management Program Basis Document - Environmental 01/03/2018 109 Qualification of Electric Equipment FPLCORP-020-CALC- Turkey Point Unit 3 and 4 Environmental Qualification TLAA 06/23/2017 002 Evaluations - Calculations for TLAA PTN-ENG-LRTA Time Limited Aging Analysis and Exemptions 11/28/2000 044 During the audit of the TLAA, the staff verified that the applicant has provided basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).

During the audit of the operating experience associated with the TLAA, the staffs independent database search did not identify any operating experience that would indicate that the TLAA may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA TLAA provided in the UFSAR supplement Section A.17.3.4. The staff verified this description is consistent with the description provided in the SRP-SLR.

TLAA Section 4.5, Concrete Containment Tendon Prestress

Summary of Information in the Application. SLRA Section 4.5, Concrete Containment Tendon Prestress, discusses the tendon prestress analysis for the concrete containment. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date AMP Basis Document - Concrete Containment Unbonded FPLCORP020-REPT-101 Revision 1 Tendon Prestress FPLCORP020-REPT-056 Containment Structure and Internal Structural Components Revision 3 FPLCORP020-REPT-103 AMP Basis Document - ASME Section XI, Subsection IWL Revision 1 Reactor Containment Building-Concrete Containment Inservice I2-ISI/IWL-PTN-3/4 Revision 1 Inspection Program PTN-ENG-LRAM ASME Section XI, Subsection IWL Inservice Inspection Revision 3 0025 Program - License Renewal Program Basis Document 0-ADM-532 ASME Section XI Repair/Replacement Program Revision 1 PTN-BSFC-99-2005 Renewal and Subsequent License Renewal - Calculations Revision 2 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). In addition, the staff found that sufficient information was not available to support its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit the staff made the following observations:

• SLRA Section 4.5, Concrete Containment Tendon Prestress, discusses the TLAA for tendon prestress and predicted lower limit (PLL). Although tendon trending is dispositioned as 10 CFR 54.21(c)(1)(iii), the staff noted that there is no discussion regarding the regulatory dispositioning of the PLL. The staff reviewed SLRA Section 4.5 and noted that it is not clear whether the PLL is dispositioned as 10 CFR 54.21(c)(1)(i),

(ii), or (iii).

• Calculations in PTN-BSFC-99-2005 and SLRA Section 4.5, Concrete Containment Tendon Prestress, indicate that lift-off force data included a greater number of tendons

for certain group of tendons than those required for examination by ASME Code Section XI, Subsection IWL in Table IWL-2521-1/IWL-3221.

• Calculations in PTN-BSFC-99-2005 and SLRA Section 4.5, Concrete Containment Tendon Prestress, state that certain plotted data (e.g., 45th year surveillance of Unit No 3, vertical tendons) exhibits considerable tendon lift-off force variation. Assuming proportional loading vs displacement either at seating or during inspections, tendon measured elongations/stresses are limited by ASME Code,Section III (CC-4464),

Section XI (IWL-2522, IWL-3221.1), and RG 1.35.1. It is not clear how these criteria are met.

• Calculations in PTN-BSFC-99-2005 and SLRA Section 4.5, Concrete Containment Tendon Prestress, state that tendon prestressing forces are referred to either as effective or normalized. In addition, both documents show a predicted tendon force (PTF) line, a predicted upper limit (PUL) line, and PLL line. Attachment 4, Subsequent License Renewal - TLAA, of Calculations PTN-BSFC-99-2005 also states the following:

Tendon lift-off data analyzed and presented in the TLAA for License Renewal (surveillance years 1-25) is a normalized lift-off force, and the data in the 40th and 45th years surveillance reports (Refs 1.2.3 and 1.2.4) is only given as an average lift-off force. The 40th and 45th years tendon selection and predicted force reports (Refs. 1.2.7 and 1.2.8) are used to convert the average lift-off force data to normalized lift-off force data.

Attachment 5, Updated Tendon Data, Subsequent License Renewal - TLAA, of PTN-BSFC-99-2005 further discusses baseline predicted forces (BPF). It is not clear whether the data points in Figures 4.5-1 through 4.5-6 of the SLRA represent normalized or effective tendon lift off forces or a mix of both. Also the SLRA does not provide an explanation as to why normalized tendon lift-off forces, effective tendon lift off forces, BPF, PTF, PUL, and PLL lines are needed and if so how are they defined and what is their role in safety evaluation of the TLAA. The staff noted that reportable data for regression analyses for trending of tendon prestress force and safety evaluation of the containment tendon prestress should be limited to the prestress minimum required value (MRV) and PLL lines.

• SLRA Section 4.5, Concrete Containment Tendon Prestress, states:

[f]igures 4.5-1 through 4.5-6 contain the reanalyzed regression analyses for each tendon group at PTN [Turkey Point]. Extended trend lines have been developed for both the group control tendons, as well as for all tendons within the respective group, including the control tendons, and plotted with the MRVs over the 80-year period.

However, the staff noted that SLRA Figures 4.5-1 through 4.5-6, have omitted the inclusion of regression analyses trend lines which are necessary to statistically predict each groups (hoop, vertical, dome) tendon prestress forces (and hence loss of tendon prestress force) with respect to time.

During the audit of the operating experience associated with the TLAA, the staffs independent database search identified operating experience that would indicate that the TLAA may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-

specific operating experience will be addressed in the SER. In light of the plant-specific operating experience, in order to obtain the information necessary to determine whether the applicants SLRA TLAA can be adequate to manage the associated aging effects, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

The staff also audited the description of the SLRA TLAA provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA TLAA. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI. The staffs evaluation of the potential RAI will be documented in the SER.

TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis Summary of Information in the Application. SLRA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue, discusses the analysis for the containment liner plate and penetrations. The applicant dispositioned the TLAA in accordance with 10 CFR Section 54.21(c)(1)(i). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date PTN UFSAR 429 Updated Final Safety Analysis Report Turkey Point Units 3 & 4 09/20/2016 V000243 Operation and Maintenance Manual for Personnel Lock, Revision 4 /

Escape Locks and Equipment Doors 02/24/2011 5610-C-166 SH1/SH2 Containment Structure Liner Plate / Penetrations Details Revision 1 5610-C-167 Containment Structure Liner Plate Details Revision 13 5610-C-164 Containment Structure Floor Liner Plate Plan Revision 14 5610-C-204 Containment Structure Reactor Fuel Transfer Tube Revision 6 AR 02090843 IWE Liner Exam - Various Areas of Degradation Identified 11/12/2015 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). In addition, the staff found that sufficient information was not available to support its review of the applicants basis for its TLAA

disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience associated with the TLAA, the staffs independent database search did not identify any operating experience that would indicate that the TLAA may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA TLAA provided in UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

TLAA Section 4.7.1, Bottom-Mounted Instrumentation Thimble Tube Wear Summary of Information in the Application. SLRA Section 4.7.1, Bottom-Mounted Instrumentation Thimble Tube Wear, discusses the analysis for the projected wear to flux thimble tubes that is used to establish subsequent inspections. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Aging Management Program Basis Document - Flux Thimble Revision 1 095 Tube Inspection BMI-FTT-IP Bottom Mounted Instrumentation Flux Thimble Tube Inspection Revision 6 Program for Turkey Point Units 3 and 4 PTN-4FSM-08-002 Incore Flux Thimble Tubing Wear Eval. PT4-24 4/25/2008 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).

In addition, the staff found that sufficient information was not available to supports its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

During the audit of the operating experience associated with the TLAA, the staffs independent database search did not identify any operating experience that would indicate that the TLAA

may not be adequate to manage the associated aging effects. The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.

The staff also audited the description of the SLRA TLAA provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the SRP-SLR.

TLAA Section 4.7.2, Emergency Containment Cooler Tube Wear Summary of Information in the Application. SLRA Section 4.7.2, Emergency Containment Cooler Tube Wear, discusses the analysis for the emergency containment cooler heat exchanger tubes. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii) by noting that the One-Time Inspection program described in SLRA Section B.2.3.20 will ensure that the emergency containment cooler tube wear will be adequately managed for the subsequent period of extended operation.

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The table below lists the documents that were reviewed by the staff and were found relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date FPLCORP020-REPT- Subsequent License Renewal Time-Limited Aging Analyses Revision 3 115 and Exemptions Based on Time-Limited Assumptions PTN-ENG-LRAM Emergency Containment Coolers Inspection - License Revision 3 0065 Renewal Basis Document V000060 Vendor Manual: Installation, Operation & Maintenance Revision 11 Instructions Emergency Containment Filter Equipment and Cooling During the audit, the staff reviewed the bases provided by the applicant to support dispositioning the TLAA in accordance with 10 CFR 54.21(c)(1)(iii). However, the staff did not find sufficient information to complete its review of the TLAA disposition. In order to obtain the information, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

The staff also audited the UFSAR supplement description of the TLAA provided in SLRA Section 17.3.7.2. The staff verified that this description is sufficiently comprehensive, as prescribed in the SRP-SLR.

SLRA TLAA Section 4.7.3 Leak-Before-Break Analysis for Reactor Coolant System Piping Summary of Information in the Application. SLRA Section 4.7.3, Leak-Before-Break Analysis for Reactor Coolant System Piping, discusses the leak before break (LBB) analyses for the reactor coolant system piping. The applicant dispositioned the TLAA in accordance with 10 CFR Section 54.21(c)(1)(ii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff reviewed the documentation provided by the applicant in its portal. The staff conducted an independent search of the applicants operating experience database using keywords: stress corrosion cracking, fatigue, leak before break, water hammer, wall thinning, and creep. The staff reviewed the following documents and found them relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date AR 01610224 This condition report discusses errors in pipe stress software 1/19/2011 AR 00473275 This condition report discusses the impact of topical report 2/15/2017 MRP-192 on the thermal fatigue cracking of piping AR 02238624 This condition report discusses thermal cycles in hot leg B 12/1/2017 During the audit of the TLAA, the staff verified that the applicant has provided its basis that the LBB analysis of reactor coolant piping supports its disposition of 10 CFR 54.21(c)(1)(ii).

During the audit, the staff made the following additional observations:

• The staff will consider issuing an RAI to ask the applicant whether errors in pipe stress software as discussed in AR 01610224 will affect the LBB analysis of reactor coolant piping.

• The staff noted that with regard to AR00473275, EPRI topical report MRP-192 is related to the thermal fatigue of smaller size pipe that is connected to the large reactor coolant loop piping. The staff will consider issuing an RAI to ask the applicant the impact of MRP-192 on the LBB analysis of reactor coolant piping.

• The staff noted that the thermal cycles as discussed in AR 02238624 have been addressed in the design cycles used in the fatigue crack growth calculations in the LBB analysis of reactor coolant piping. The staff will review the fatigue crack growth calculations further during the review of Section 4.7.3.

During the audit of the operating experience associated with the TLAA, the staffs independent database search identified operating experience that may be relevant to the TLAA to manage the associated aging effects. However, the staff found that sufficient information was not available to support its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that

supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

The staff also audited the description of the UFSAR supplement Section 17.3.7.3 provided in SLRA Appendix A. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.7.4, Leak-Before-Break Analysis for Class 1 Auxiliary Piping Summary of Information in the Application. SLRA Section 4.7.4, Leak-Before-Break Analysis for Class 1 Auxiliary Piping, discusses the LBB analyses for the reactor coolant system auxiliary piping. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff reviewed the documentation provided by the applicant in its portal. The staff conducted an independent search of the applicants operating experience database using keywords: stress corrosion cracking, fatigue, leak before break, water hammer, wall thinning, and creep. The staff reviewed the following documents and found them relevant to the audit.

Relevant Documents Reviewed Document Title Revision / Date AR 00473275 This condition report discusses the impact of topical report 2/15/2017 MRP-192 on the thermal fatigue cracking of piping AR 02198941 This condition report discusses possible calculation error 4/14/2017 identified from EPU project in LBB AR 02238624 This condition report discusses thermal cycles in hot leg B 12/1/2017 AR 01610224 This condition report discusses errors in pipe stress software 1/19/2011 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).

During the audit, the staff made the following additional observations:

• The staff noted that with regard to AR00473275, EPRI topical report MRP-192 is related to the thermal fatigue of smaller size pipe that is connected to the reactor coolant loop piping. The staff will consider issuing RAI to ask the applicant the impact of MRP-192 on the LBB analysis of Class 1 auxiliary piping.

• The staff noted that the applicant has addressed the calculation error identified in AR 02198941 by performing an additional analysis as shown in SIA report,

0901350.304, Rev. 0, Fatigue Crack Growth Evaluation, September 18, 2017. This report is associated with (SIA) Report No. 0901350.401, Revision 3, Leak-Before-Break Evaluation - Accumulator, Pressurizer Surge, and Residual Heat Removal Lines, Turkey Point Units 3 and 4, September 2017. Both of these reports are included in SLRA. The staff will review both reports further in detail as part of reviewing Section 4.7.4.

• The staff notes that the thermal cycles as discussed in AR 02238624 have been addressed in the design cycles used in the fatigue crack growth calculations in the LBB analysis of Class 1 auxiliary piping. The staff will review the fatigue crack growth calculations further as part of reviewing Section 4.7.4.

• The staff will consider issuing an RAI to ask the applicant whether errors in pipe stress software as discussed in AR 01610224 will affect the LBB analysis of Class 1 auxiliary piping.

The staff found that sufficient information was not available to support its review of the applicants basis that supports its TLAA disposition. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

The staff also audited the description of the UFSAR supplement, Section 17.3.7.4, in SLRA, Appendix A. During the audit, the staff questioned the accuracy of the information in Section 17.3.7.4. The applicant confirmed the presence of an error in Section 17.3.7.4 and stated that it will revise SLRA, Appendix A, Section 17.3.7.4. In order to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

SLRA TLAA Section 4.7.5 Code Case N-481 Reactor Coolant Pump Integrity Analysis Summary of Information in the Application. SLRA Section 4.7.5, Code Case N-481 Reactor Coolant Pump Integrity Analysis, discusses the analysis for the reactor coolant pump (RCP) casing to demonstrate that casing integrity remains valid for the SPEO and verified that the effects of aging on the intended function of the RCP casing will be adequately managed for the SPEO. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff reviewed the documentation provided by the applicant in its portal. The staff conducted an independent search of the applicants operating experience database using keywords: stress corrosion cracking, fatigue, pump, and pump inspection.

The staff reviewed the applicants operating experience but did not find any relevant documents.

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).

During the audit of the operating experience associated with the TLAA, the staff searched the applicants database. The staff did not identify any operating experience that is relevant to the

TLAA. The staff found that sufficient information was not available to support its review of the applicants basis that supports its TLAA disposition in the SLRA. In order to obtain the necessary information to review the acceptability of the applicants basis that supports its TLAA disposition, the staff will consider issuing RAIs. The staffs evaluation of these potential RAIs will be documented in the SER.

The staff also audited the description of the SLRA TLAA Sections 17.3.7.5 provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

Staff Review of AMR Item Details Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:

• SLRA Table 3.5.2-11, Intake Structures, cites component type intake structures cranes and ICW valve pit rigging beam exposed to air-outdoor.

• SLRA Table 3.5.2-12, Main Steam and Feedwater, cites component type main steam platform rails exposed to air-outdoor.

• SLRA Table 3.5.2-1, Containment Structure and Internal Structural Components, cites:

o anchorage components (post tensioning system) exposed to air - indoor uncontrolled, air - outdoor; o reinforced concrete containment structure (accessible and inaccessible) exposed to air - indoor uncontrolled, air - outdoor/groundwater; and o tendons (post-tensioning system) exposed to air - indoor uncontrolled

• SLRA Table 3.5.2-1: Containment Structure and Internal Structural Components, cites pressure retaining boundary/bolting exposed to air - indoor uncontrolled/air - outdoor.

• SLRA Table 3.6.2 item corresponding to LRA Table 3.6.1-4, transmission conductors composed of aluminum, steel exposed to air-outdoor

• SLRA Table 3.6.2 item corresponding to LRA Table 3.6.1-5, transmission connectors composed of aluminum, steel exposed to air-outdoor

• SLRA Table 3.6.2 item corresponding to LRA Table 3.6.1-6, switchyard bus and connections composed of aluminum, copper, bronze, stainless steel, galvanized steel exposed to air-outdoor

• SLRA Table 3.6.2 item corresponding to LRA Table 3.6.1-7, transmission conductors composed of aluminum, steel exposed to air-outdoor

• SLRA Table 3.6.2 item corresponding to LRA Table 3.6.1-21, transmission conductors composed of aluminum exposed to air - outdoor

• SLRA Section 3.5.2.2.2.2 (AMR 3.5-1, 048) addresses the further evaluation for the aging effect of reduction of strength and modulus due to elevated temperature in concrete of Groups 1-5 concrete structures.

• SLRA Table 3.5.2-1: Containment Structure and Internal Structural Components, cites carbon steel tendons exposed to air-indoor uncontrolled for loss of prestress.

The table below lists the documents that were reviewed by the staff and were found relevant to the review of these items. These documents were provided by the applicant.

Relevant Documents Reviewed Document Title Revision / Date 0-PMM-009.05 Intake Area Gantry Crane Inspection and Preventive Revision 0 Maintenance AR 01607315 Steam Erosion Identified in PWO 4000023 Has Progressed 01/10/2011 AR 01630764 Spalled Concrete Around the U4 Escape Hatch 08/30/2011 AR 01751146 Horizontal Tendon Unable To Be Stressed to 80% Overstress 04/05/2012 AR 01767026 Unit 3 Containment - Vertical Tendon Gallery Degraded 07/02/2012 Concrete AR 01767040 Unit 3 Containment - Vertical Tendon Gallery Degraded 05/14/2012 Concrete AR 1959317 Unusual Stains - U3 Northeast Containment Building Tendon 07/30/2014 Caps AR 437888 Tendon Grease/Oil Seeping From The Non-Structural 02/16/2007 AR 445083 Indications Noted During Performance of 3-OSP-051 09/22/2007 AR 437147 Buttonheads Missing From Tendon Number 13H31 01/30/2007 FPLCORP020-REPT- TP Units 3 and 4, SLR - OpE Review Report - AMR Revision 1 062 Effectiveness AR 02010647 CV-4-956A Type B/C LLRT NOT Performed Following Repairs 12/03/2014 FPLCORP020-REPT- Subsequent License Renewal - Aging Management Review of Revision 2 061 Electrical Commodities FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Revision 1 001 Electrical Screening Results

Document Title Revision / Date FPLCORP020-REPT- Turkey Point Units 3 and 4 Subsequent License Renewal Aging 01/03/2018 062 Effects Operating Experience 5610-E-1-SH1- Turkey Point Nuclear Unit 3 Main Single Line Revision 46 FPLCORP020 5610-E-1-SH2- Turkey Point Nuclear Unit 4 Main Single Line Revision 18 FPLCORP020 PTN-BSFC-99-2005 Renewal and Subsequent License Renewal - Calculations Revision 2 During the audit the staff made the following observations:

• During its review of document 0-PMM-009.05, Intake Area Gantry Crane Inspection and Preventive Maintenance, Revision 0, the staff noted that this document states that structural bolting of the intake crane must be visually inspected for signs of defect. The staff noted that GALL-SLR Report AMR 3.3-1, 199 recommends that crane structural bolting be managed under the GALL-SLR Report AMP XI.M23 for the aging effects for loss of preload, loss of material, and cracking. The staff also noted that SLRA AMP B.2.3.13 is enhanced to account for aging effects of bolted connections. However, SLRA Table 3.5.2-11, Intake Structures, component types intake structures cranes and ICW valve pit rigging beam; and SLRA Table 3.5.2-12, Main Steam and Feedwater, component type main steam platform rails do not have AMRs for structural bolting of cranes components. The staff noted that that these crane components may have bolting that should be age managed for these aging effects as recommended in GALL-SLR AMR 3.3-1, 199. During a breakout session on July 13, 2018, the applicant stated that AMRs for the structural bolts of these cranes should have been included in the SLRA and that they will revise SLRA Tables 3.5.2-11 and 3.5.2-12 to include the AMRs for the crane bolts consistent with the GALL-SLR AMR 3.3-1, 199. Pending voluntary submittal by the applicant to revise the associated SLRA AMRs, the staff may consider issuing an RAI clarifying whether these cranes have bolting, and if so how the relevant aging effects will be managed.

• The staff reviewed the noted ARs and noted several instances of containment degradation. The staff will perform an onsite audit to verify that containment degradation will be adequately managed through the subsequent period of operation. This input will be used in the SER.

• The staff reviewed AR 02010647 and noted that the applicant failed to perform an as-found local leak rate test (LLRT) proposing to replace the required leakage rate testing with visual inspection and documenting the deviating process in ADM-0531. This input may be used in SER Section 3.

• The SLRA states that process piping carrying hot fluid (pipe temperature greater than 200 degrees Fahrenheit (°F)) through penetrations in the concrete walls by design does not result in local temperatures exceeding 200 °F on the concrete surface because the penetration configuration includes guard pipes and insulation of the process piping to minimize heat transfer to the exterior environment that surrounds the process piping.

Therefore, the applicant concluded that the aging effect of reduction of strength and

modulus due to elevated temperature is not applicable for Group 1-5 structures at Turkey Point. The GALL-SLR Report AMR item 3.4-1, 064 recommends that non-metallic thermal insulation be age managed for the aging effect of reduced thermal insulation. The staff noted that the SLRA states that AMR item 3.4-1, 064 is not applicable because there is no thermal insulation in the scope of SLR. During a breakout session held on July 9, 2018, the applicant stated that it did not consider thermal insulation to be an intended function. It is not clear whether a degradation of the thermal insulation could result in concrete being exposed to a local temperature exceeding 200 °F, and if so it is not clear how the aging effect of reduction of strength and modulus due to elevated temperature is not applicable. The staff may request the applicant to provide additional information regarding its basis for not managing the aging effects of (1) thermal insulation for the process piping, and (2) the reduction of strength and modulus due to elevated temperature for concrete.

• The staff reviewed PTN-BSFC-99-2005 and noted that calculations in PTN-BSFC 2005 include tendon prestress force trend lines. Certain groups calculated and plotted over time tendon prestress force trend lines, however, are ascending rather than descending. It is not clear how ascending tendon prestress force trend lines are possible. The staff noted that this ascending trend implies that the tendon prestress force trend line could not cross the PLL/MRV lines during foreseeable IWL inspections (i.e., during the SPEO). The staff noted that such ascending tendon prestress force trend lines may provide a false impression that the prestress concrete containment during the SPEO may have an increasing pressure retaining capacity and the excessive force could adversely affect tendon anchorages.

3. Applicant Personnel Contacted During Audit Name Affiliation Glenn Alexander Florida Power & Light (FPL)

Donna Slivon FPL Maribel Valdez FPL William Rigby FPL Scott Walker FPL Garth Dolderer FPL Denise Pennicooke Mcfarlane FPL Bill Maher FPL Paul Jacobs FPL Terry Mccool FPL Brian Messitt FPL Mark Joseph FPL Rick Orthen FPL Steve Franzone FPL Stephen Hale ENERCON J R (Jack) Hoffman ENERCON Jeffrey Head ENERCON Aaron Halstrom ENERCON

Kathryn West ENERCON Tony Ploplis ENERCON Andy Cianek ENERCON Caleb Trainor ENERCON Mark Winsor ENERCON Troy Skillen ENERCON James Wicks ENERCON Mitch McFarland ENERCON John Ahearn Westinghouse Electric Company (WEC)

Amy Freed WEC John McFadden WEC Mike Semmler WEC Tom Zalewski WEC Alan Stalker FRAMATOME Pavan Thallapragada FRAMATOME Davis Cofflin FRAMATOME Brian Haibach FRAMATOME Dave Gerber Structural Integrity Associates (SIA)

Terry Herrmann SIA DJ Shim SIA

4. Exit Meeting An exit meeting was held with the applicant on July 23, 2018, to discuss the results of the operating experience audit. The staff is considering the issuance of RAIs and requests for confirmation of information to support the completion of the staffs SLRA review.

5. Acronyms AFW auxiliary feedwater ALE adverse localized environments AMPs aging management programs AMR aging management review AR action report ART adjusted reference temperatures ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials BMI bottom mounted instrumentation BMV bare metal visual BPF baseline predicted forces CAP corrective action program CASS cast austenitic stainless steel

CCS cooling canal system CCW closed cooling water CF chemistry factor CFR Code of Federal Regulations CLB current licensing basis CRDM control rod drive mechanism CRGT control rod guide tube CS containment spray CST condensate storage tank CUF cumulative usage factor DWST demineralized water storage EAF environmentally-assisted fatigue EDG emergency diesel generator EPRI Electric Power Research Institute EPU extended power uprate EQ environmental qualification FAC flow-accelerated corrosion FPL Florida Power & Light Company FTT flux thimble tubing GALL-SLR NUREG 2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued in July 2017 GL generic letter HX heat exchanger IASCC irradiation-assisted stress corrosion cracking ICW intake cooling water ID inside diameter IN Information Notice LBB leak before break LLRT local leak rate test NEI Nuclear Energy Institute NFPA National Fire Protection Association NRC U.S. Nuclear Regulatory Commission OD outside diameter OpE operating experience PIV post indicator valve PLL predicted lower limit PM preventive maintenance POD prompt operability determination PTF predicted tendon force PTS pressurized thermal shock PUL predicted upper lim PWRs Pressurized Water Reactors RAIs requests for additional information RCP reactor coolant pump

RG regulatory guide RPV reactor pressure vessel RT reference temperature RVI reactor vessel internal RWST raw water storage tank SER safety evaluation report SIA Structural Integrity Associates SLRA subsequent license renewal application SPEO subsequent period of extended operation SRP-SLR NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, July 2017 SSCs systems, structures and components TLAA time limited aging analyses UFSAR updated final safety analysis report USE upper shelf energy UT ultrasonic testing WEC Westinghouse Electric Company