ML18269A228

Request for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 6 (EPID No. L-2018-RNW-0002) - Enclosure

ML18269A228
Person / Time
Site:	Turkey Point
Issue date:	10/04/2018
From:	Lois James NRC/NRR/DMLR/MRPB
To:	Nazar M Florida Power & Light Co, NextEra Energy
Lois James
Shared Package
ML18269A226	List: ML18269A227 ML18269A228
References
EPID L-2018-RNW-0002
Download: ML18269A228 (31)

Text

TURKEY POINT NUCLEAR GENERATING UNITS 3 AND 4 (TURKEY POINT)

SUBSEQUENT LICENSE RENEWAL APPLICATION (SLRA)

REQUESTS FOR ADDITIONAL INFORMATION (RAIS)

SAFETY - SET 6

1. Reactor Pressure Vessel Underclad Cracking, TLAA 4.3.4 Regulatory Basis:

Pursuant to 10 CFR 54.21(c), the SLRA shall include an evaluation of time-limited aging analyses (TLAAs). The applicant shall demonstrate that (i) the analyses remain valid for the period of extended operation; (ii) the analyses have been projected to the end of the period of extended operation; or (iii) the effects of aging on the intended function(s) will be adequately managed for the period of extended operation. In accordance with 10 CFR 54.21(c)(1)(ii), the applicant has proposed to disposition the SLRA Section 4.3.4 TLAA for RPV underclad cracking in accordance with 10 CFR 54.21(c)(1)(ii) to demonstrate that the analyses have been projected to the end of the subsequent period of extended operation (SPEO).

Background:

To support its 10 CFR 54.21(c)(1)(ii) disposition of the RPV underclad cracking 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. PWROG-17031-NP is not generically approved by the NRC staff for use SLR applications. Therefore, the staff is reviewing the PWROG-17031-NP report, as included in the SLRA, to determine whether this supports the applicants TLAA disposition of 10 CFR 54.21(c)(1)(ii).

RAI 4.3.4-1 Issue:

PWROG-17031-NP shows that the Code-allowable flaw sizes for normal/upset/test and emergency/faulted loading conditions per IWB-3600 remain the same for 80 year applications as those in the 2002 version of this methodology, WCAP-15338-A, which is NRC-approved for 60 years. This is based on consideration of the same governing transient intensities for 3-Loop plants, as well as the continued use of time-invariant upper shelf fracture toughness (KIC) of 200 ksiin for all transient analyses.

In order for an assumed KIC fracture toughness of 200 ksiin to remain valid for the SPEO, the Level B, C, and D transient temperatures shall exceed the limiting adjusting RTNDT values for the analyzed flaw depths by at least 104.25 °F; this is based on the KIC curve provided in the ASME Code,Section XI, Appendix A.

Request:

Considering the projected state of RPV beltline neutron embrittlement through the end of the SPEO, as analyzed in SLRA Section 4.2, and the limiting temperatures for the governing transients evaluated in PWROG-17031-NP, please justify the continued use of 200 ksiin as the RPV material fracture toughness for determining the allowable flaw sizes in Section 5.5 (normal, upset, and test) and Section 5.7 (emergency and faulted conditions) of PWROG-17031-NP.

RAI 4.3.4-2 Issue:

The staff noted that analysis results for the Large Steamline Break transient in Section 5.7 of PWROG-17031-NP and in Appendix A-5 of WCAP-15338-A (2002) show a slightly more limiting allowable flaw depth for the continuous circumferential flaw (2.21 inches) compared to the allowable flaw depth for the continuous axial flaw (2.50 in.). Considering its reliance on the assumed KIC fracture toughness of 200 ksiin for the upper shelf temperature regime, this analysis result is inconsistent with RPV beltline shell tensile stress due to internal pressure.

Request:

Considering the RPV shell axial stress versus RPV shell hoop stress due to internal pressure and a fixed KIC value of 200 ksiin, please explain how the IWB-3600 analysis of Large Streamline Break transient can result in the more limiting allowable flaw depth (2.21 in.) for the continuous circumferential flaw compared to the 2.50 in. allowable flaw depth for the continuous axial flaw. If this is a typographical error, please correct it in both the WCAP-15338-A and PWROG-17031-NP reports.

2. Steam Generators, GALL AMP XI.M19 Regulatory Basis:

Section 54.21(a)(3) of 10 CFR requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. As described in the SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

RAI B.2.3.10-1

Background:

SRP-SLR Section 3.1.2.2.11, Cracking Due to Primary Water Stress Corrosion Cracking, recommends actions to manage aging of divider plate assemblies depending on the material of the divider plate assemblies and whether industry analyses (EPRI 3002002850, Steam Generator Management Program: Investigation of Crack Initiation and Propagation in the Steam Generator Channel Head Assembly, October 2014) are bounding for the applicants unit(s).

Since the divider plate assemblies in the applicants SGs are fabricated of Alloy 600 material and the applicants evaluation of EPRI TR-3002002850 is not yet complete, the following recommendations from SRP-SLR are potentially applicable at Turkey Point:

For units with divider plate assemblies fabricated of Alloy 600 or Alloy 600 type weld materials, if the analyses performed by the industry (EPRI [Electric Power Research Institute] 3002002850) are applicable and bounding for the unit, a plant-specific AMP is not necessary.

For units with divider plate assemblies fabricated of Alloy 600 or Alloy 600 type weld materials, if the industry analyses (EPRI 3002002850) are not bounding for the applicants unit, a plant-specific AMP is necessary or a rationale is necessary for why such a program is not needed. A plant-specific AMP (one beyond the primary water chemistry and the steam generator programs) may include a one-time inspection that is capable of detecting cracking to verify the effectiveness of the water chemistry and steam generator programs and the absence of PWSCC in the divider plate assemblies.

Issue:

SLRA Section 3.1.2.2.11, Cracking due to Primary Water Stress Corrosion Cracking, states, in part:

Turkey Point has an Alloy 600 divider plate and the EPRI analysis is applicable. FPL is evaluating the industry analysis (EPRI TR-3002002850) as part of the existing Steam Generators AMP for the current PEO to determine whether it is bounding for Turkey Point. This evaluation is scheduled for completion by the end of 2018.

Until the applicant has completes its evaluation to determine whether the industry analyses are bounding, the NRC staff cannot complete its review.

Request:

Please provide the results of FPLs evaluation regarding EPRI 3002002850 and whether the relevant industry analyses are bounding for the units.

3. Scoping and Screening Results: Electrical and Instrumentation and Controls, SLRA 2.5 Regulatory Basis:

The scoping criteria in 10 CFR 54.4(a)(3) require, in part, an applicant to consider all systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for station blackout (SBO) (10 CFR 50.63).

As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.4(a)(3) by ensuring that its methodology includes SSCs relied upon during the coping duration and recovery phase of an SBO event. In addition, because 10 CFR 50.63(c)(1)(ii) and its associated guidance in RG 1.155 include procedures to recover from an SBO that include offsite and onsite power, the offsite power system that is used to connect the plant to the offsite power source should also be included within the scope of the rule.

SRP-SLR, Section 2.5.2.1.1, Components Within the Scope of SBO (10 CFR 50.63), states in part, that both the offsite and onsite power systems are relied upon to meet the requirements of the SBO Rule and include equipment that is required to cope with an SBO (e.g., alternate ac power sources), and the plant system portion of the offsite power system that is used to connect the plant to the offsite power source meeting the requirements under 10 CFR 54.4(a)(3).

RAI 2.5-1

Background:

SLRA section 2.1.3.4.5 states that Turkey Point's design satisfies the SBO Rule by providing for a unit cross-tie at the 4.16 kV level. It further states that resolution of the SBO issue for the Turkey Point nuclear units is by use of an alternate safety-related, Class 1E, seismic Class/Category I, power source with the ability to align the source to the SBO unit within 10 minutes of confirmation of a station blackout condition. However, the highlighted electrical drawing the applicant supplied does not include the cross-tie and the alternate safety-related power source.

Issue:

1. It is not clear to the NRC staff whether the cross-tie and alternate AC power source are within the scope of license renewal.

2. The applicants SLRA and electrical drawing identifying the SBO recovery path do not state the specific type of structures, cabling, and connections (e.g., bus duct, cable bus, metal enclosed bus, iso-phase bus, etc.) used in the SBO recovery path from alternate AC source via the unit 3 and 4 cross-tie.

Request:

1. Clarify whether the cross-tie and alternate AC power source (part of the SBO recovery path), are safety-related and are considered in-scope for license renewal.

2. Provide information regarding methods, and type of components and structures used for the unit 3 and 4 cross-tie connection.

4. ASME Section XI Inservice Insepction, Subsections IWB, IWC, AND IWD, GALL AMP XI.M1 Regulatory Basis:

Title 10 of the Code of Federal Regulations (10 CFR) 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to the managing the effects of aging during the subsequent period of extended operation (SPEO) on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the subsequent renewed license will continue to be conducted in accordance with the CLB. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL SLR Report. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

Pursuant to 10 CFR 54.4(a)(1), safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions -- (i) The integrity of the reactor coolant pressure boundary; (ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1),

§ 50.67(b)(2), or § 100.11 of this chapter, as applicable Pursuant to 10 CFR 54.4(a)(2), all nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (ii), or (iii) of 54.4.

Background:

Sections 3.1.2.2.10.1 and 3.1.2.2.10.2 of the Turkey Point subsequent license renewal application (SLRA) provide discussions on the reactor pressure vessel head penetration control rod drive mechanisms (CRDM) thermal sleeve wear. Specifically, 3.1.2.2.10.2 states the thermal sleeves do not perform a subsequent license renewal intended function.

Notes for Table 2.3.1-2 of the Turkey Point SLRA, in part, states, the thermal sleeves are considered to support the pressure boundary component intended function.

In a teleconference public meeting dated September 10, 2018, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18262A078)), the applicant asserted that:

• The stainless steel (SS) thermal sleeves of the CRDM were not scoped into the Turkey Point SLRA because they were determined to be not part of the reactor coolant pressure boundary and not safety-related components, and their failure could not affect satisfactory accomplishment of any of the functions identified under 10 CFR 54.4(a)(1);

• Reference to SS thermal sleeve in both Table 2.3.1-2 and notes for Table 2.3.1-2 was intended for the pressurizers thermal sleeves and not for the thermal sleeves of the CRDMs.

• The enhancements discussed in Section 3.1.2.2.10 include the aging management of loss of material due to wear at the centering tab location and at the bottom of the nickel alloy CRDM nozzle tubes which were scoped into Turkey Point SLRA, but not at the SS thermal sleeves of CRDMs which were not scoped into Turkey Point SLRA.

Issue:

Given the recent operating experience documented in Westinghouse letters, LTR-NRC-18-34 Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21 dated May 23, 2018 (ML18143B678), LTR-NRC-18-53 NSAL-18-1 Revision 0, Thermal Sleeve Flange Wear Leads to Stuck Control Rod dated July 17, 2018 (ML18198A275), and NRC Information Notice 2018-10 Thermal Sleeve Flange Wear Leads to Stuck Control Rod at Foreign Nuclear Plant dated August 29, 2018 (ML18214A710), the staff requests the following additional information.

RAI B.2.3.1-1 Provide the basis for not scoping the SS thermal sleeves of CRDMs into Turkey Point SLRA, and justify why the control rod functionality could not be impacted if the thermal sleeve flange failed due to wear.

RAI B.2.3.1-2 Discuss the aging management of loss of material due to wear at the SS thermal sleeve flange location, and at the bottom of the CRDM tube location.

5. Non-GALL AMR, Structural Components Regulatory Basis:

10 CFR 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under § 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis (CLB). As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

RAI 3.5.2-9-1

Background:

SLRA Table 3.5.2-9 (SLRA page 3.5-149) states that the Unit 4 carbon steel diesel oil storage tank (DOST) liner embedded in concrete has no aging effect requiring management for the external surface exposed to the concrete.

GALL-SLR Item VII.J.AP-282 addresses carbon steel piping embedded in concrete and lists no aging effect and no AMP but does recommend further evaluation. The associated SRP-SLR Table 3.3-1 ID 112 also recommends further evaluation. The further evaluation section (SRP-SLR 3.3.2.2.9) notes that no aging effect is applicable for steel embedded in concrete if: (a) the concrete was constructed in accordance with ACI 318 or 349 (low water-to-cement ratio, low permeability, adequate air entrainment);

(b) plant-specific operating experience indicates no degradation of the concrete that could lead to penetration of water to the metal surface; and (c) the piping is not potentially exposed to groundwater.

Issue:

Although the GALL-SLR lists no aging effect for steel embedded in concrete, this is only applicable if the above conditions are met. SLRA Section 3.3.2.2.9 states that a review of operating experience indicates there are occurrences of concrete degradation that could lead to the penetration of water to the metallic surfaces of the tank.

Request:

Based on the operating experience described in Section 3.3.2.2.9 of the SLRA, explain why aging management is unnecessary for the external metallic surface of the Unit 4

DOST tank embedded in concrete. If sealants are relied upon to keep water off the external metallic surfaces of the tank, explain how the sealants are age-managed.

6. ASME Section XI, Subsection IWE, GALL AMP XI.S1 Regulatory Basis:

Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report and when evaluation of the matter in the GALL-SLR Report applies to the plant.

RAI B.2.3.30-1

Background:

The detection of aging effects program element of GALL-SLR AMP XI.S1 states, in part:

The requirements of ASME Code Section XI, Subsection IWE and 10 CFR 50.55a are further supplemented to require a one-time volumetric examination of metal shell or liner surfaces that are inaccessible from one side, only if triggered by plant-specific OE

[operating experience]. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell or liner corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environment. Any identified degradation is addressed in accordance with the applicable provisions of the AMP. The sample size, locations, and any needed scope expansion (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 10 percent loss of nominal thickness. Guidance provided in EPRI TR-107514 may be used for sampling considerations. (emphasis added)

SLRA Section B.2.3.30 states that the Turkey Point ASME Section XI, Subsection IWE AMP, with enhancements, will be consistent with the 10 elements of NUREG-2191 AMP XI.S1.

Further, in SLRA Section B.2.3.30, the enhancement to the detection of aging effects program element states:

If site-specific OE identified after the approval of the SLRA triggers the requirement to implement a one-time supplemental volumetric examination, then perform this inspection

by sampling randomly-selected, as well as focused, liner locations susceptible to corrosion that are inaccessible from one side. The trigger for this one-time examination is site-specific occurrence or recurrence of liner corrosion that is determined to originate from the inaccessible (concrete) side. Any such instance would be identified through code inspections performed since June 6, 2002. (emphasis added)

Issue:

The staff is unable to determine that the detection of aging effects program element, with the stated enhancement, will be consistent with that in GALL-SLR AMP XI.S1 because of the following issues identified with regard to the enhancement.

1. Contrary to the GALL-SLR specification that the one-time volumetric examination would be triggered by plant-specific OE identified since the date of issuance of the first renewed license (i.e., June 6, 2002 for Turkey Point U3 and U4), the enhancement states the trigger to be site-specific OE identified after the approval of the SLRA.

2. The trigger specified in the GALL-SLR is the site-specific occurrence or recurrence of the stated plant-specific OE without regard to the method by which (how) it is identified.

Contrary to this, the SLRA enhancement states that the triggering OE would be specific to that identified through code inspections.

3. The enhancement does not include the sampling specifications in the GALL-SLR program element that the sample size, locations and any needed scope expansion for this one-time volumetric examination shall demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 10 percent loss of nominal thickness.

4. Based on information provided in the SLRA and on the electronic portal, the staff is unable to positively determine whether or not there has been operating experience of containment liner corrosion initiated on the inaccessible (concrete) side of Turkey Point Unit 3 or Unit 4 identified since the June 6, 2002, issuance of first renewed license.

Request:

1) Provide a revised enhancement to the detection of aging effects program element in SLRA Section B.2.3.30, that addresses the issues identified in 1 through 3 above and would make the Turkey Point AMP program element consistent with that in GALL-SLR AMP XI.S1, or explain why a revised enhancement is unnecessary.

2) State if there has been operating experience of containment liner corrosion initiated on the inaccessible (concrete) side identified at Turkey Point Unit 3 or Unit 4 since the June 6, 2002, issuance of the first renewed license.

3) If the response to Request 2 is yes, then (i) describe the operating experience and how it was addressed in the corrective action program; and (ii) explain how the conduct of the

triggered supplemental volumetric examination, including schedule, is sufficiently captured in the revised enhancement in response to Request 1.

RAI B.2.3.30-2

Background:

The operating experience program element of GALL-SLR AMP XI.S1 includes industry operating experience described in NRC Information Notice (IN) 2014-07 concerning degradation of inaccessible areas of containment liner due to moisture intrusion into leak-chase channel systems through degraded interfaces at the containment floor level from lack of inspection of these interface components that serve a moisture barrier function.

The staffs review of Drawing 5610-C-164, Revision 4, Containment Structure Floor Liner Plate Plan, indicates the existence of an air chase system along the circumference as well as at inner locations of the containment floor for Turkey Point Unit 3 and Unit 4. The typical air test connection shown in Details 2, 3 and 9 and Typical Air Test Connection details on the drawing appear to indicate that these connections provide pathways, at the containment floor-level interface, for potential intrusion of moisture into inaccessible areas of the liner plate.

Issue:

Based on review of the Program Basis Document for the IWE AMP and the Second IWE Inspection Interval Program Plan, it is not clear if barriers (e.g., pipe cap, pipe plug, etc.)

associated with the air chase system test connections at containment floor-level interfaces, intended to prevent moisture intrusion, are being inspected under IWE program as discussed in NRC IN 2014-07.

Request:

Discuss whether or not the air chase test connection components at the containment floor-level interfaces, that serve a function to prevent moisture intrusion into inaccessible areas of the liner, are examined in the IWE Program as discussed in NRC IN 2014-07. If not, justify the adequacy of the Turkey Point ASME Section XI, Subsection IWE to manage liner degradation in inaccessible areas related to operating experience described in NRC IN 2014-07.

7. Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analyses, TLAA 4.6 Regulatory Basis:

Section 54.21(c)(1) of 10 CFR requires the applicant to evaluate time limited aging analyses (TLAA). Section 54.21(a)(3) of 10 CFR requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with

10 CFR 54.21(a)(3) by referencing the GALL-SLR Report and when evaluation of the matter in the GALL-SLR Report applies to the plant.

RAI 3.5.1.9-1

Background:

Section 4.6 of the SRP-SLR states that containment metal liner plates, metal containments and penetrations (including personnel airlocks, equipment hatches, sleeves, dissimilar metal welds, and bellows), may be designed in accordance with requirements of Section III of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). The SRP-SLR also states that if a plants code of record requires a fatigue parameter evaluation (fatigue analysis or fatigue waiver), then this analysis may be a time limited aging analyses (TLAA) and must be evaluated in accordance with 10 CFR 54.21(c)(1) for the subsequent period of extended operation.

SRP-SLR Table 3.5-1, item 009, associated with the further evaluation section 3.5.2.2.1.5, recommends that metal liner, metal plates, and penetrations (including personnel airlocks, equipment hatches, penetration sleeves, bellows, vent lines, etc.) be managed for cumulative fatigue damage due to cyclic loading using the TLAA disposition from SRP-SLR Section 4.6, if a current licensing basis (CLB) fatigue analysis exists. Otherwise, if a CLB fatigue analysis does not exist for these components, SRP-SLR Table 3.5-1, item 027, recommends these components to be managed for cracking due to cyclic loading using the GALL-SLR Report AMP XI.S1, "ASME Section XI, Subsection IWE," and AMP XI.S4, 10 CFR Part 50, Appendix J aging management programs (AMPs).

Turkey Point subsequent license renewal application (SLRA) Table 3.5-1, item 3.5-1, 009, states that the containment liner plate fatigue analysis is addressed in SLRA Section 4.6 and that the further evaluation is documented in SLRA Section 3.5.2.2.1.5. The SLRA further evaluation for Cumulative Fatigue Damage states that liner and connections to penetration sleeves and hatches for the containment structures is addressed in SLRA Section 4.6. SLRA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue, addresses a TLAA for containment liner plate and piping penetrations. Additionally, SLRA Table 3.5-1, item 3.5-1, 027, states that this item is not applicable.

Also, SLRA Section B.2.3.30 ASME Section XI, Subsection IWE AMP states: PTN [Turkey Point] has no pressure-retaining components subject to cyclic loading without CLB fatigue analysis. Further, there are no enhancements proposed in the SLRA AMP to perform recommended supplemental surface examination or other applicable technique capable of detecting fine cracking; and no Appendix J leak rate tests are credited Issues:

Based on the information provided in the SLRA, it is not clear if a fatigue analysis or fatigue waiver exists for containment penetrations other than piping penetrations (e.g. personnel airlocks, equipment hatch and/or personnel hatch, electrical penetrations, etc.), or how the aging effect of cracking due to cyclic loading will be adequately managed, in accordance with 10 CFR 54.21(a)(3), for these components.

The staff notes that the SLRA does not clearly state if a CLB fatigue analysis exists for the components described above, or how these components were designed for cyclic loading. If a CLB fatigue analysis or fatigue waiver exists for these components, it is not clear how these analyses were dispositioned in SLRA Section 4.6, or why Table 3.5-1, item 3.5-1, 009, its associated Table 2 items, and Section 3.5.2.2.1.5 of the SLRA does not address these components to demonstrate that the aging effect of cumulative fatigue damage due to cyclic loading will be adequately managed during the subsequent period of extended operation.

Likewise, if a CLB fatigue analysis or fatigue waiver does not exist for these components, it is not clear how cracking due to cyclic loading will be adequately managed for these components during the subsequent period of extended operation since SLRA Table 3.5-1, item 3.5-1, 027, states that this item is not applicable.

Requests:

1. Clarify if a fatigue analysis or fatigue waiver exists for containment penetrations other than piping penetrations (i.e. personnel airlocks, equipment hatch, personnel hatch, electrical penetrations, etc.)

2. If a fatigue analysis or fatigue waiver exists, address with supporting justification the disposition under 10 CFR 54.21(c)(1) of each containment penetration fatigue analysis or fatigue waiver, and describe the following for each analyzed component:

a. the name of the transients considered in each analysis,

b. the design cycle limits of each transient,

c. the projected cycles to 80-years of operation for each transient, and

d. the review of the calculated cumulative usage factor (CUF), if applicable.

Otherwise, pursuant to 10 CFR 54.21(a)(3), if fatigue analysis or fatigue waiver does not exist, clarify how containment penetrations other than piping penetrations will be adequately managed for cracking due to cyclic loading during the subsequent period of extended operation (i.e. SRP-SLR Table 3.5-1, item 027, with GALL-SLR Report recommendation for supplemental surface examinations using AMP XI.S1, "ASME Section XI, Subsection IWE" or identifying and crediting appropriately justified Appendix J leak rate tests).

RAI 3.5.1.9-2

Background:

Section 4.6 of the SRP-SLR states that dissimilar metal welds are used to connect the piping penetrations to the bellows or stainless steel (SS) plates to provide a leak-tight penetration, and high energy piping penetrations and the fuel transfer tubes in some plants are equipped with SS bellow assemblies. The SRP-SLR also states that these components may be designed in accordance with the requirements of Section III of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), and if a plants code of record requires a fatigue parameter evaluation (fatigue analysis or fatigue waiver), then this analysis

may be a time limited aging analyses (TLAA) and must be evaluated in accordance with 10 CFR 54.21(c)(1) for the subsequent period of extended operation.

GALL-SLR Report item II.A3.C-13, associated with SRP-SLR Table 3.5-1, item 009, addresses, in part, the cumulative fatigue damage due to fatigue for penetrations with dissimilar metal welds and penetration bellows when a current licensing basis (CLB) fatigue analysis exists.

Likewise, SLR-GALL Report item II.A3.CP-37, associated with SRP-SLR Table 3.5-1, item 027, addresses, in part, cracking due to cyclic loading for penetrations with dissimilar metal welds and penetration bellows when a CLB fatigue analysis does not exist.

Subsequent license renewal application (SLRA) Section 3.5.2.2.1.6 states that stainless steel piping from high-temperature piping systems that penetrates the containment uses dissimilar metal welds between the flued head of the steel penetration assembly and the outside of the pipe. SLRA Table 3.5-1, item 3.5-1, 009, and the associated further evaluation in SLRA Section 3.5.2.2.1.5, addresses only the disposition of carbon steel penetration sleeves and containment liner plate. SLRA Table 3.5-1, item 3.5-1, 027, states that this item is not applicable.

During the in-office audit, the staff reviewed drawing no. 5610-C-204, "Containment Structure Reactor Fuel Transfer Tube, and noted that the fuel transfer tube has two expansion joints as part of its design.

Issues:

Based on the information provided in the SLRA, it is not clear if (1) a fatigue analysis or fatigue waiver analysis exists for penetrations with dissimilar metal welds and for penetration bellows which may require an evaluation in accordance with 10 CFR 54.21(c)(1), and (2) how the aging effect of cracking due to cyclic loading will be adequately managed, in accordance with 10 CFR 54.21(a)(3), for these components during the subsequent period of extended operation.

The staff noted that the SLRA does not clearly state if a CLB fatigue analysis exists for the penetrations with dissimilar metal welds and the expansion joints described in the background section (above), or how these components where evaluated for cumulative fatigue damage due to fatigue. If a CLB fatigue analysis or fatigue waiver exists for these components, it is not clear how these analyses were dispositioned in SLRA Section 4.6, or why Table 3.5-1, item 3.5-1, 009, its associated Table 2 items, and Section 3.5.2.2.1.5 of the SLRA do not address these components to demonstrate that the associated aging effect will be adequately managed during the subsequent period of extended operation. Likewise, if a CLB fatigue analysis or fatigue waiver does not exist for these components, it is not clear how cracking due to cyclic loading will be adequately managed for these components during the subsequent period of extended operation since SLRA Table 3.5-1, item 27, states that this item is not applicable.

Also, SLRA Section B.2.3.30 ASME Section XI, Subsection IWE AMP states: PTN [Turkey Point] has no pressure-retaining components subject to cyclic loading without CLB fatigue analysis. Further, there are no enhancements proposed in the SLRA AMP to perform recommended supplemental surface examination or other applicable technique capable of detecting fine cracking; and no Appendix J leak rate tests are credited.

Requests:

1. Clarify if a fatigue analysis or fatigue waiver analysis exists for dissimilar the piping penetrations with dissimilar metal welds (including the welds) described in SLRA Section 3.5.2.2.1.6.

2. Clarify if a fatigue analysis or fatigue waiver exists for the expansion joints illustrated in drawing 5610-C-204, "Containment Structure Reactor Fuel Transfer Tube,

3. If a fatigue analysis or fatigue waiver exists for any on the components discussed above, address with supporting justification the disposition under 10 CFR 54.21(c)(1) of each the fatigue analysis or fatigue waiver, and describe the following for each analyzed component:

• the name of the transients considered in each analysis,

• the design cycle limits of each transient,

• the projected cycles to 80-years of operation for each transient, and

• the review of the calculated cumulative usage factor (CUF), if applicable.

Otherwise, pursuant to 10 CFR 54.21(a)(3), if fatigue analysis or fatigue waiver does not exists, clarify how these components will be adequately managed for cracking due to cyclic loading during the subsequent period of extended operation (i.e. SLRA Table 3.5-1, item 3.5-1, 027, with GALL-SLR Report recommendation for supplemental surface examinations using AMP XI.S1, "ASME Section XI, Subsection IWE" or identifying and crediting appropriately justified Appendix J leak rate tests).

8. Reactor Coolant Pump Integrity Analysis, GALL TLAA 4.7 Regulatory Basis:

Section 54.21 (c) of 10 CFR requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) for the subsequent period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to the managing the effects of aging during the subsequent period of extended operation (SPEO) on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the subsequent renewed license will continue to be conducted in accordance with the CLB. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

Background:

The regulation in 10 CFR 54.21(c)(1)(ii) states that, for a specific time limited aging analyses (TLAA) that is dispositioned in accordance with this regulation, the applicant must demonstrate that the analysis has been projected to the end of the SPEO. Subsequent license renewal application (SLRA) Section 4.7.5, Code Case N-481 Reactor Coolant Pump Integrity Analysis, identifies the examination reactor coolant pump (RCP) casing in the current licensing basis as a TLAA item.

In 2000, the applicant submitted for NRC review and approval the 60-year license renewal application. As part of that application, the applicant performed a reactor coolant pump (RCP) integrity analysis for Turkey Point Units 3 and 4 as documented in Westinghouse topical reports, WCAP-13045 and WCAP-15355. To demonstrate continued compliance during SPEO, the Pressurized Water Reactor Owners Group (PWROG) re-evaluated WCAP-13045 associated with the application of Code Case N-481 to the RCP casing during the SPEO as documented in PWROG-17033, Revision 0. The applicant submitted the topical report PWROG-17033, Revision 0 as part of the SLRA.

RAI 4.7.5-9 Issue:

Section 2.2 of PWROG-17033 discusses fracture toughness calculation based on NUREG/CR-4513, Revision 2. The NRC staff notes that Aging Management Program XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel, in Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) report, NUREG-2191, Volume 2, discusses fracture toughness values based on the prediction method in NUREG/CR-4513, Revision 1. The GALL-SLR report does not reference Revision 2 of NUREG/CR-4513.

Request:

Discuss whether the saturated fracture toughness value used in the crack stability analysis of pump casing at Turkey Point would still be limiting and bounding if the method of predicting fracture toughness in accordance with NUREG/CR-4513, Revision 1 was used. That is, regardless whether the method in revision 1 or revision 2 of NUREG/CR-4513 was used, the fracture toughness value used in the crack stability analysis at Turkey Point would still be limiting.

RAI 4.7.5-10 Issue:

The applicant stated that the JIC, Jmax, and Tmat values in Table 1 of PWROG-17033-P are bounding and were used to demonstrate the crack stability of pump casing. However, the JIC, Jmax and Tmat values used in Tables 11-2 and 11-3 of WCAP-13045 to demonstrate the crack stability of flaw 5-93 were higher than the JIC, Jmax, and Tmat values listed in Table 1 of PWROG-17033, respectively. If the lower JIC, Jmax and Tmat values in Table 1 of PWROG-17033 were used to analyze flaw 5-93, crack stability may not be demonstrated for flaw 5-93. It appears that

various fracture toughness value criteria are needed to qualify various flaws to demonstrate crack stability, not a single set of fracture toughness value as specified in Table 1 of PWROG-17033-P. Table 5-1 of WCAP-13045 does provide 4 sets of fracture toughness values as end of service life criteria. Therefore, it seems that the fracture toughness values in Table 5-1 of WCAP-13045 should be compared to the fracture toughness values predicted based on the method in NUREG/CR-4513, Revision 1.

Request:

Discuss whether the 4 sets of fracture toughness values in Table 5-1 of WCAP-13045 satisfy the fracture toughness values as predicted using the method in NUREG/CR-4513 Revision 1. If not please justify.

9. Structures Monitoring Program, GALL AMP XI.S6 Regulatory Basis:

Section 54.21(a)(3) of 10 CFR requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report and when evaluation of the matter in the GALL-SLR Report applies to the plant.

RAI B.2.3.35-1

Background:

The detection of aging effects program element of GALL-SLR Report AMP XI.S6, Structures Monitoring, recommends inspectors to be qualified consistent with industry guidelines and standards and guidelines for implementing the requirements of 10 CFR 50.65. The GALL-SLR Report states that qualifications of inspection and evaluation personnel specified in ACI 349.3R are acceptable for inspection of concrete structures.

The subsequent license renewal application (SLRA), Section B.2.3.35, Structures Monitoring, states that inspections are performed and evaluated by qualified personnel. The SLRA also states that the aging management program (AMP), with exception and enhancements, will be consistent with the 10 elements of NUREG-2191,Section XI.S6, Structures Monitoring.

During the audit, the staff reviewed procedure 0-ADM-561, Structures Monitoring Program, and report no. FPLCORP020-REPT-107, Aging Management Program Basis Document -

Structures Monitoring, and noted that inspectors and lead reviewers are qualified in accordance with the Engineering Training Program (ETP) or ACI 349.3R, and by having proficiency in detecting structural deficiencies. The staff also noted that the Fleet ETP (i.e. TR-AA-110) and Guideline ACAD 98-004, Guidelines for Training and Qualification of Engineering Personnel,

does not specify qualification requirements for inspectors or lead reviewers performing inspections or evaluations under the Structures Monitoring Program.

Issue:

The Structures Monitoring Program allows an inspector or a lead reviewer to be qualified by only meeting the Engineering Training Program requirements, which does not provide specific personnel qualification requirements that is consistent with industry guidelines and standards (e.g. ACI 349.3R) for concrete. Therefore, it is not clear how the Turkey Point Structures Monitoring Program will ensure consistency with the GALL-SLR Report recommendation for inspector qualifications, or what criteria is used by Turkey Point to determine that an inspector or a lead reviewer is qualified. Additionally, it is not clear how by having proficiency in detecting structural deficiencies, as stated in the program procedure, supports the qualification program or what criteria is used to establish and maintain proficiency.

Request:

Clarify how Turkey Point Structures Monitoring Program will be consistent with the GALL-SLR Report recommendation for inspectors to be qualified consistent with industry guidelines and standards (e.g. ACI 349.3R for concrete); otherwise, provide adequate justification if an exception is taken to the detection of aging effects program element as recommended by the GALL-SLR Report.

RAI B.2.3.35-2

Background:

The parameters monitored or inspected and detection of aging effects program elements of GALL-SLR Report AMP XI.S6, Structures Monitoring, recommends monitoring and trending leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if through-wall leakage or groundwater infiltration is identified. The GALL-SLR Report also recommends, in part, assessing the indication thru engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties.

Additionally, it recommends to include analysis of the leakage pH, along with mineral, chloride, sulfate and iron content in the water when leakage volumes allow such analyses.

The subsequent license renewal application (SLRA), Section B.2.3.35, Structures Monitoring, states that structures are monitored to confirm the absence of water in-leakage or signs of concrete leaching, chemical attack or steel reinforcement degradation. The SLRA also states that the aging management program (AMP), with exception and enhancements, will be consistent with the 10 elements of NUREG-2191,Section XI.S6, Structures Monitoring.

Issue:

During the audit, the staff reviewed procedure 0-ADM-561, Structures Monitoring Program, and Report No. FPLCORP020-REPT-107, Aging Management Program Basis Document -

Structures Monitoring, and was not able to verify consistency with the parameters monitored or inspected and detection of aging effects program elements of the GALL-SLR Report because

the AMP (1) does not provide requirements to monitor and trend leakage volumes and chemistry for signs of concrete or steel reinforcement degradation when through-concrete leakage is identified, and (2) does not clearly identify how indications of groundwater infiltration or through-concrete leakage will be assessed for aging effects.

The staff notes that the program currently monitors structures elements to confirm the absence of water in-leakage. However, no AMP enhancement was provided in the SLRA to include the monitoring, trending and assessment of aging effects if through-concrete leakage is identified, to be consistent with the GALL-SLR Report recommendations.

Request:

Clarify how Turkey Point Structures Monitoring Program will be consistent with the parameters monitored or inspected, and detection of aging effects program elements from the GALL-SLR Report, with respect to through-concrete leakage. Otherwise, provide adequate justification if an exception is taken to the GALL-SLR Report recommendations.

RAI B.2.3.35-3

Background:

The detection of aging effects program element of GALL-SLR Report AMP XI.S6, Structures Monitoring, recommends that a plant-specific aging management program (AMP) accounting for the extent of the degradation experienced should be implemented to manage the concrete aging during the subsequent period of extended operation if the plant has an aggressive groundwater/soil environment. The GALL-SLR Report provides examples of what actions may be included as part of the plant-specific AMP. The SRP-SLR Appendix A provides the staff positions and guidance for a plant-specific AMP.

The subsequent license renewal application (SLRA), Section B.2.3.35, Structures Monitoring, states that groundwater/soil at Turkey Point is aggressive (chlorides > 500 ppm), and that the AMP, with exception and enhancements, will be consistent with the 10 elements of NUREG-2191,Section XI.S6, Structures Monitoring. The SLRA provides an enhancement to address aggressive groundwater/soil that may include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil. The SLRA enhancement also states that the respective evaluation, inspection and testing interval is not to exceed 5 years.

During the on-site audit the staff noted several plant-specific operating experience items related to corrosion degradation in accessible areas of concrete structures exposed to air-outdoor environment. These degradations were attributed to the significant chloride level present at the site, which is the same aging effect mechanism expected from an aggressive groundwater/soil environment.

Issue:

The staff was not able to verify consistency with the detection of aging effects program element of the GALL-SLR Report since the enhancement provided in the SLRA restates the general examples provided in the GALL-SLR Report for a plant-specific AMP, and does not provide an adequate plant-specific AMP description or enhancements to the different program elements in accordance with SRP-SLR Appendix A, Section A.1, to ensure that structures and components exposed to an aggressive groundwater/soil environment will be adequately managed as required by 10 CFR 54.21(a)(3). Staff review of the SLRA AMP program elements did not identify how the applicant plans to address the aging effects of structures and components exposed to an aggressive groundwater/soil environment using the focused inspections, evaluations, and/or destructive testing suggested by GALL-SLR Report, and/or using other acceptable method(s). Also, it is not clear how the plant-specific operating experience associated with corrosion from accessible areas of the structures were considered in the implementation of the plant-specific AMP to ensure that inaccessible areas exposed to aggressive groundwater/soil environment are adequately managed. The staff notes that the aging effect mechanism present in accessible areas of concrete structures exposed to an air-outdoor environment is the same as in the inaccessible areas of the structures exposed to an aggressive ground/soil environment (i.e. significant chloride levels).

Request:

Provide the Turkey Point plant-specific AMP description or enhancements for each of the program elements in the Structures Monitoring Program (as applicable) to demonstrate that structures and components exposed to an aggressive groundwater/soil environment will be adequately managed for the subsequent period of extended operation. The proposed program or enhancements should account for any plant-specific OE with aggressive groundwater, and the on-going corrosion degradation observed in accessible areas of the structures due to the presence of chloride.

RAI B.2.3.35-4

Background:

The scope of program, parameters monitored or inspected, and acceptance criteria program elements of GALL-SLR Report AMP XI.S6, Structures Monitoring, recommends that sliding surfaces within the scope of Structures Monitoring Program be monitored for indication of significant loss of material due to wear or corrosion, and for accumulation of debris or dirt. The GALL-SLR Report also states that identified conditions in sliding surfaces are acceptable when there are (a) no indications of excessive loss of material due to corrosion or wear and (b) no debris or dirt that could restrict or prevent sliding of the surfaces as required by design.

The program description in subsequent license renewal application (SLRA), Section B.2.3.35, Structures Monitoring, states that the program inspects accessible sliding surfaces for indication of significant loss of material due to wear or corrosion, and for accumulation of debris or dirt. The SLRA does not include an enhancement associated with sliding surfaces, and does not have an aging management review line item associated with sliding surfaces being managed by the Structures Monitoring Program.

Issue:

The staff was unable to verify consistency between 0-ADM-561, Revision 5 (Attachment 2),

Turkey Point Plant Structures Monitoring Program, and the GALL-SLR Report AMP XI.S6 program elements associated with sliding surfaces. Also, it is not clear which sliding surface components that are subject to aging management review will be managed by the Structures Monitoring Program, to be consistent with the Program Description Section of SLRA, Section B.2.3.35, Structures Monitoring.

The staff notes that the Program Description in SLRA Section B.2.3.35 states that the program manages the effects of aging in accessible sliding surfaces, however, no parameters or acceptance criteria is provided in the Structures Monitoring Program procedure to effectively manage the effects of aging in sliding surfaces. The staff also notes that no enhancement was provided in the SLRA to ensure that the effects of aging for these components will be adequately managed by the Structures Monitoring Program during the subsequent period of extended operations.

Request:

Clarify if there are sliding surfaces components that are within the scope of subsequent license renewal and subject to aging management review that will be managed by the Structures Monitoring Program, as described in the Program Description section of SLRA, Section B.2.3.35, Structures Monitoring.

For those sliding surfaces components managed using the Structures Monitoring Program, clarify how Turkey Point Structures Monitoring Program will be consistent with the scope of program, parameters monitored or inspected, and acceptance criteria program elements of GALL-SLR Report AMP XI.S6 by addressing the issue described above. Otherwise, provide adequate justification if an exception is taken to the GALL-SLR Report recommendations.

RAI 3.5.1.100-1

Background:

SRP-SLR Table 3.5-1, item 100, recommends that aluminum and stainless steel support members, welds, bolted connections and support anchorage to building structures be managed for loss of material and cracking due to stress corrosion cracking (SCC) by either the AMP XI.M32, One-Time Inspection; AMP XI.S6, Structures Monitoring; or AMP XI.M36, External Surfaces Monitoring of Mechanical Components program. This Table 1 line item is associated with a further evaluation, SRP-SLR Section 3.5.2.2.2.4, which states the acceptance criteria for the review and the recommended actions (including AMP enhancements) when loss of material or cracking has occurred and is sufficient to potentially affect the intended function of these components.

Item 3.5-1, 099 in the subsequent license renewal application (SLRA) Table 3.5-1 was not used by the applicant and states that item 3.5-1, 100 will be use instead to manage loss of material for aluminum and stainless steel support members, welds, bolted connections, and support anchorages using the Structures Monitoring Program. SLRA Table 3.5-1, item 100, associated

with SLRA Section 3.5.2.2.2.4, states that this item is consistent with the GALL-SLR Report recommendation. SLRA Section 3.5.2.2.2.4, states that cracking due to SCC and loss of material due to pitting and crevice corrosion are applicable aging effects for these components, and that they will be monitored by the Structures Monitoring Program.

Issue:

The staff notes that line items for some components only address the aging effect of loss of material, and do not address the aging effect of cracking due to SCC as recommended by the GALL-SLR Report. Several items/components in SLRA Tables 3.5.2-X associated with Table 1 Item 3.5-1, 100, are not being managed for cracking due to SCC, consistent with the GALL-SLR Report recommendation. The staff also notes that no technical justification was provided in the application for not requiring management of the aging effect of cracking due to SCC for these components. For those components that will be managed for cracking due to SCC, it is not clear how the proposed AMP was enhanced to adequately manage the aging effect of SCC, as recommended in SRP-SLR Section 3.5.2.2.2.4.

Request:

Clarify why some components in SLRA Tables 3.5.2-X that are associated with Table 1 Item 3.5-1, 100, are not being managed for cracking due to SCC as recommended by the GALL-SLR Report. Otherwise if an exception is taken to the GALL-SLR Report recommendations, provide adequate technical justification for not requiring management of this aging effect.

For those components that will be managed for SCC, describe how the credited AMP will be capable to adequately manage cracking due to SCC.

RAI 3.5.1.66-1

Background:

The GALL-SLR Report, Chapter III, Structures and Component Supports, includes aging management review (AMR) line items for tanks and missile barriers to ensure that the structural aging effects in their foundations, sub-foundations, supports, structural steel and bolting are adequately managed for the extended period of operation, consistent with the 10 CFR 54.21(a)(3) requirement.

The subsequent license renewal application (SLRA) Section 17.2.2.17 states, in part, that tanks external surfaces, other than the tank-to-concrete interface, are accessible and inspected through the External Surfaces Monitoring of Mechanical Components AMP (SLRA Section 17.2.2.23) or the Structures Monitoring AMP (SLRA Section 17.2.2.35).

Issue:

It is not clear how GALL-SLR Report Group 7 (concrete tanks and missile barriers) and Group 8 (steel tanks and missile barriers) structures are being managed for structural aging effects since no line items in the SLRA associated with tanks or missile barriers credits the structural AMP or references associated GALL-SLR structural AMR line items for aging management (e.g. items associated with SRP-SLR Table 3.5-1 items 042, 054, 066, 067, 080).

Request:

For Group 7 and 8 structures subject to AMR, describe how the structural effects of aging (e.g.,

SRP-SLR Table 3.5-1 items 042, 054, 066, 067, 077, 080, etc.) will be adequately managed.

Otherwise, provide adequate technical justification for not requiring management on the effects of aging.

If the response identifies alternate AMPs, explain how the identified AMPs will be able to identify and manage the associated structural aging effects. If the Structures Monitoring Program is not being credited for aging management, clarify the statement crediting such in SLRA Section 17.2.2.17 accordingly.

10. Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, GALL AMP XI.M23 Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21(a)(1)(i) and (ii) state that systems, structures and components within the scope of license renewal and subject to an aging management review shall encompass those structures and components that (i) perform an intended function, as described in 10 CFR 54.4, without moving parts or without a change in configuration or properties; and (ii) are not subject to replacement based on a qualified life or specified time period.

10 CFR 54.21(a)(3) requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report and when evaluation of the matter in the GALL-SLR Report applies to the plant.

RAI B.2.3.13-1

Background:

SLRA Section B.2.3.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, states that the Turkey Point Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Program is an existing AMP that will be consistent with enhancements with the GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. GALL-SLR

Report AMP XI.M23 addresses the inspection and monitoring of crane-related structures and components to provide reasonable assurance that the handling system does not affect the intended function of nearby safety-related equipment. The GALL-SLR Report Volume 1, page VII B-1, states that the primary components that the GALL-SLR Report AMP XI.M23 is concerned with are the structural girders and beams that make up the bridge and the trolley.

Issue:

SLRA Section B.2.3.13 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 position is that, depending on the lifting capacity of a crane, trolleys and rigging may include structural girders and beams that are passive components that should be within the scope of this AMP and subject to AMR in accordance with 10 CFR 54.4 and 54.21.

The staff noted that although the SLRA states that trolleys and rigging components will not be managed for aging effects, the SLRA has AMRs assigned to trolleys (e.g., trolley structures of the turbine gantry crane and polar crane in SLRA Tables 3.5.2-17 and 3.5.2-14) and rigging (e.g., intake cooling water (ICW) valve pit rigging beam, LRA Table 3.5.2-11) components of some of its in-scope cranes. Furthermore, SLRA Section 4.7 reviews the TLAA of the Intake cooling water (ICW) valve pit rigging beam. It is not clear whether trolleys and rigging of other cranes have such passive components that need to be included in the scope of program, program element of SLRA AMP B.2.3.13.

Request:

1. Clarify whether structural component(s) (e.g., girders and beams), of trolleys and rigging used in load handling systems listed in SLRA Section B.2.3.13, are not in the scope of program of the Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling AMP and not subject to an AMR.

2. For each such component that is not within the scope of program program element of the AMP and not subject to an AMR provide your basis as to how such determination is consistent with the regulatory requirements in 10 CFR 54.4 and 54.21, and the guidance in the GALL-SLR Report AMP XI.M23.

3. If these components are to be age managed in a manner that is not consistent with the guidance in GALL-SLR Report AMP XI.M23, describe the exception(s) to the GALL-SLR Report AMP XI.M23 and provide the basis for such exception(s).

RAI 3.3.1.199-1

Background:

SLRA Section B.2.3.13 states that the Turkey Point Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Program is an existing AMP that will be consistent with enhancements with the GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. The staff noted that GALL-SLR

Report AMR 3.3-1, item 199 recommends that cranes 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.

Issue:

During its audit 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 also noted that SLRA AMP B.2.3.13 is enhanced to account for aging effects of bolted connections.

However the components in the following tables do not include structural bolting for cranes:

• SLRA Table 3.5.2-11 Intake Structures component types intake structures cranes and intake cooling water (ICW) valve pit rigging beam; and

• SLRA Table 3.5.2-12, Main Steam and Feedwater, component type main steam platform rails The staff noted that that these crane components may have bolting that should be age managed for loss of preload, loss of material, and cracking aging effects as recommended in the guidance of GALL-SLR AMR 3.3-1, item 199. If these cranes have bolting, it is not clear how the aforementioned aging effects will be managed during the subsequent period of extended operation (SPEO).

Request:

1. Clarify if the intake structures cranes, ICW valve pit rigging beam, and main steam platform rails have bolted components.

2. If so, state how the aging effects for loss of preload, loss of material, and cracking will be managed during the SPEO to be consistent with GALL-SLR.

11. Bolting Integrity, GALL AMP XI.M18 RAI B.2.3.9-1

Background:

Section 54.21(a)(3) 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report and when evaluation of the matter in the GALL-SLR Report applies to the plant.

SLRA Section B.2.3.9, Bolting Integrity states that the Turkey Point Bolting Integrity Program is an existing AMP that will be consistent with enhancements with the GALL-SLR Report AMP XI.M18, Bolting Integrity.

Issue:

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 SCC. LRA Section B.2.3.9 states that there is currently no high strength bolting within the scope of the Bolting Integrity Program. However, during the In-Office audit the staff noted that specification SPEC-M-004, Maintenance Bolting Specification for St. Lucie Units 1 & 2 and Turkey Point Units 3 & 4, Revision 15, 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 ksi and a diameter of 3 inches or less. Based on specification SPEC-M-004 it appears that bolting material ASTM No. SA/A540, Grade B23 C1.1 can be installed as closure bolting, and the staff cannot confirm the applicants claim that high strength bolts are not being used in systems, structures, and components (SSCs) within the scope of the Bolting Integrity Program. If this material is used it is not clear how the Bolting Integrity AMP will adequately manage the aging effect of cracking due to SCC of the closure bolting and how the AMP is consistent with the recommendations in the parameters monitored or inspected and detection of aging effects program elements of GALL-SLR Report AMP XI.M18.

Request:

Clarify whether closure bolting with material ASTM No. SA/A540, Grade B23 C1.1, or any other high strength closure bolting material with a yield strength greater than or equal to 150 ksi and a diameter greater than 2 inches, will be used or precluded from use in SSCs within the scope of the Bolting Integrity AMP during the subsequent period of extended operation. If such material will be precluded from use clarify how this will be accomplished given that the specification appears to authorize its use. If such material can be used state whether and how the aging effects of cracking due to stress corrosion cracking will be managed consistent with recommendations in GALL-SLR Report AMP XI.M18.

12. Fatigue Analysis of Cranes (crane cycle limits), TLAA 4.7.6 Regulatory Basis:

Title 10 of the Code of Federal Regulations (10 CFR), Section 54.21(c)(1) requires the applicant to evaluate time limited aging analyses (TLAAs). 10 CFR 54.21(a)(3) requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL-SLR Report and

when evaluation of the matter in the GALL-SLR Report applies to the plant. The SRP-SLR and GALL-SLR documents provide guidance for SLR applicants that voluntary choose and plan to demonstrate consistency with the GALL-SLR Report.

RAI 4.7.6-1

Background:

The staffs guidance in SRP-SLR Section 4.7.3.1.1 states, in part, the following:

Justification provided by the applicant is reviewed to verify that the existing analysis remains valid for the subsequent period of extended operation [(SPEO)]. [] The applicant describes the TLAA with respect to the objectives of the analysis, assumptions used in the analysis, conditions, acceptance criteria, relevant aging effects, and intended function(s). For those TLAAs that consider cyclic loading, each load should be identified along with the corresponding number of total cycles assumed in the analysis and the number of cycles that are anticipated to occur through the SPEO.

Turkey Points SLRA Section 4.7.6, Crane Load Cycle Limit, states that the EOCI-61, Electric Overhead Crane Institute, compliant cranes are acceptable for 2,000,000 cycles and as such for these cranes to exceed this cycle limit through the extended period of operation they have to experience 68 cycles per day which is far more than what the cranes would experience during the SPEO. The staff noted that the applicant established a limit of 2,000,000 load cycles for these cranes using Section 1.7.3 of the American Institute of Steel Construction (AISC) Manual (6th Edition). The staff also noted that the applicant claims that these cranes will be managed consistent with the guidance in the GALL-SLR Report.

Issue:

Section 1.7.3 of the AISC Manual (6th Edition) states that for cranes that meet its stress criteria the load cycle limits range from 100,000 to 2,000,000. It is not clear on what basis the applicant concluded in SLRA Section 4.7.6 that the load cycle limit for these cranes is the upper limit of 2,000,000 instead of the more conservative lower limit of 100,000, or any other value of load cycles within that range. It is also noted that the SLRA does not identify the derivation of the related loads and the corresponding estimated number of load cycles for each of the EOCI-61 cranes through the SPEO. To complete its review and determine the adequacy of the associated TLAAs the staff needs a description of the applied loads and the derivation of the number of cycles expected for each of these cranes through the SPEO.

Request:

For the TLAAs associated with each of the EOCI-61 cranes listed in SLRA Section 4.7.6:

1. Provide the basis for the selection of 2,000,000 load cycles as the design limit.

2. Provide a description of the design loads and the corresponding number of load cycles estimated to occur through the end of the SPEO. Include a description of conditions and

assumptions made to reach the conclusion for the estimated number of cycles through the end of the SPEO.

RAI 4.7.6-2

Background:

The staffs guidance in SRP-SLR Section 4.7.3.1.1 states, in part, the following:

Justification provided by the applicant is reviewed to verify that the existing analysis remains valid for the subsequent period of extended operation [(SPEO)]. [] The applicant describes the TLAA with respect to the objectives of the analysis, assumptions used in the analysis, conditions, acceptance criteria, relevant aging effects, and intended function(s). For those TLAAs that consider cyclic loading, each load should be identified along with the corresponding number of total cycles assumed in the analysis and the number of cycles that are anticipated to occur through the SPEO.

SLRA Section 4.7.6 states that the spent fuel bridge cranes design was in accordance with CMAA-70 [], with added seismic requirements, and is acceptable for up to 200,000 load cycles of maximum loads. The SLRA also states:

For original license renewal, the projected number of cycles for these cranes was 16,000. Applying a simple 80/60 multiplier, the total number of cycles for SLR would be conservatively estimated to be 22,000. This is well below the design cycles of 200,000.

The staff noted that its review of the spent fuel bridge crane TLAA for the original license renewal of Turkey Point is documented in Section 4.7.4 of NUREG-1759, Safety Evaluation Report Related to the License Renewal of Turkey Point Nuclear Plant, Units 3 and 4, (ADAMS Accession No. ML021280532). The staff also noted that its conclusion for safety determination for the spent fuel bridge crane TLAA was based on its evaluation of the applicants response to RAI 4.7.4-1 (ADAMS Accession No. ML011170195).

Issue:

It is not clear whether the added crane seismic requirements referenced in SLRA Section 4.7.6 are part of the spent fuel bridge cranes TLAAs and have been included in the applicants estimate for the SPEO. It is also not clear whether the conditions and assumptions described by the applicant in response to RAI 4.7.4-1 dated April 19, 2001, are still valid and applicable with regards to load (lift) cycles and usage of the spent fuel bridge cranes for the estimated number of load cycles during the SPEO.

Request:

For the TLAAs associated with the spent fuel bridge cranes:

1. Clarify whether the seismic requirements (including seismic load cycles and their accountability in stresses) are part of the cranes TLAAs. If so, in accordance with 10 CFR 54.21(c)(1), account for their inclusion in the TLAAs through the SPEO.

2. Clarify whether the conditions and assumptions {e.g., type of loads (fuel assemblies, fuel assembly shuffles, etc.,) and number of load cycles} described in response to RAI 4.7.4-1 dated April 19, 2001, are still valid for the Turkey Point SLRA and applicable through the SPEO. If the conditions and assumptions are no longer valid and applicable provide the revised conditions and assumptions made to determine the validity of the disposition of the TLAA as 10 CFR 54.21(c)(1)(i) for the loads and the corresponding number of load cycles experienced thus far and estimated through the end of the SPEO.

13. PWR Reactor Vessel Internals, GALL AMP XI.M16A Regulatory Basis:

Section 54.21(a)(3) of states that for each structure and component identified in paragraph (a)(1) of this section, the applicant shall demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the subsequent period of extended operation.

Background:

For each structure and component identified in 10 CFR 54.21(a)(1), the applicant for subsequent license renewal (SLR) has the option to demonstrate compliance with 10 CFR 54.21(a)(3), by including in the SLR application (SLRA) an aging management program (AMP) that is consistent with the applicable AMP described in NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, July 2017.

The Turkey Point SLRA Section B.2.3.7 states that the reactor vessel internals (RVI) AMP with enhancements will be consistent with GALL-SLR Report AMP XI.M16A. (Note: The AMP enhancements are unrelated to this RAI.) The GALL-SLR Report AMP XI.M16A specifies that for existing RVI AMPs that are based on implementation of MRP-227-A inspection and evaluation guidelines, the guidelines are supplemented through a gap analysis that identifies changes to the AMP that are needed to address an 80-year operating period. Further, the GALL-SLR Report AMP Scope of Program element specifies that if the SLRA AMP is based on MRP-227-A with a gap analysis, the scope of the program focuses on identification and justification of the following:

a. RVI components that screen in for additional aging degradation mechanisms (DMs) when assessed for the 60-to-80-year operating period (SPEO);

b. RVI components that previously screened in for certain DMs, and the severity of these 60-year DMs could significantly increase for the 60-to-80 year SPEO;

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

RAI B.2.3.7-1 Issue:

Two Class 1 RVI components listed in SLRA Table 4.3-1, deep beam and lower support plate, are not listed in the SLRA gap analysis summary table, nor in SLRA Table 3.1.2-4 AMR results.

One component, lower support plate to core barrel weld, shows an EPU CUF value that is inconsistent with the CUF for the lower core barrel flange weld in the gap analysis summary table. (Note 5 in Attachment 4 of the gap analysis states that the lower core barrel flange weld and the support plate to core barrel weld are the same component.)

Request:

Please either justify or correct these apparent inconsistencies.

RAI B.2.3.7-2 Issue:

Most of the RVI components evaluated in the gap analysis are not designated as Class 1 RVI components, and as such they do not show a specific EPU CUF value. Many of these were generically screened as not susceptible to fatigue for the 60-year AMP based on the MRP-191 generic assessments because their CUF was generically determined to be less than 0.1. These components remain screened out for fatigue for 80-years. The gap analysis provides no apparent update to the EPU CUF screening results for these non-Class 1 RVI components to address an 80-year period.

Request:

For the RVI components evaluated in the gap analysis that screened out for fatigue for 60 and 80 years, and that do not have a specific EPU CUF listed in the gap analysis summary table, please address how the MRP-191 generic fatigue screening results for the 60-year AMP were determined to remain valid for 80 years.

RAI B.2.3.7-3 Issue:

SLRA Gap Analysis, Attachment 4, Primary Components - Control Rod Guide Tube (CRGT)

Assembly Guide Cards: SLRA Gap Analysis, Attachment 4, including Note 7 for Turkey Point Unit 4, appears to propose long term inspection of guide cards for Turkey Point 3 and Turkey Point 4 in accordance with MRP-227-A. It is not apparent to the NRC staff how the proposed program addresses interim inspection guidance for guide cards contained MRP Letter 2014-006, PWROG Letter OG-14-55, and WCAP-17451-P, Revision 1 that were issued under NEI 03-08.

Request:

CRGT Guide Cards (Primary): Please address how the above SLRA Gap Analysis guide card inspections for Turkey Point 3 and Turkey Point 4, including Turkey Point 4 Note 7, are consistent with the above-cited interim guidance, revise the gap analysis to be consistent with the guidance, or justify an alternate approach.

RAI B.2.3.7-4 Issue:

SLRA Gap Analysis, Attachment 4, Primary Components - Baffle-Former Bolts: Attachment 4 of the gap analysis shows that inspection criteria for baffle-former bolts are the same as those in the original MRP-227-A. It is not apparent to the NRC staff how the proposed program addresses interim inspection guidance for baffle-former bolts contained in MRP Letter 2017-009 and issued under NEI 03-08.

Request:

Baffle-Former Bolts (Primary): Please address how the above SLRA Gap Analysis baffle-former bolt inspections are consistent with the above-cited interim guidance, revise the gap analysis to be consistent with the guidance, or justify an alternate approach.

RAI B.2.3.7-5 Issue:

SLRA Gap Analysis, Attachment 3, Existing Programs Components - Alignment and Interfacing Components, Clevis Insert Bolts: The clevis insert bolt inspection criteria are listed in of the gap analysis. This includes some new Note 2 inspection guidance to look for degradation at clevis insert and radial key interfaces and evidence of degraded bolting components. However, SLRA Section B.2.3.7 states that the clevis insert bolts are already categorized as a Primary component.

Request:

Clevis Insert Bolts (Existing Programs): Given the industry OpE with clevis insert bolt degradation and the statement in SLRA Section B.2.3.7 that they are Primary components, please address whether EVT-1 or UT exams for this bolting should be included with the Primary Components inspections in Attachment 4 of the gap analysis, or address whether the current Note 2 guidance in Attachment 3 is adequate for the bolting. Please amend the clevis insert bolting OpE discussion in SLRA Section B.2.3.7 and/or the SLRA Gap Analysis Attachment 3 inspection table to ensure they are consistent.

RAI B.2.3.7 deleted because the error was corrected in Revision 1 of the SLRA Issue:

SLRA Gap Analysis, Attachment 3, Existing Programs Components - Guide Tube Assemblies (GTA), GTA Support Pins: Attachment 3 of the gap analysis points to a Note 3 in the inspection table entry for GTA support pin reference documents. However, Note 3 is missing at the bottom of this table.

Request:

GTA Support Pins (Existing Programs): Please amend Attachment 3 of the SLRA Gap Analysis to include Note 3 for the GTA support pins.

RAI B.2.3.7-7 Issue:

SLRA Gap Analysis, Attachment 1, 60-to-80 Year Results, No Additional Measures Components: Attachment 1 provides a summary of the 60-to-80 year DM screening, FMECA scoring, and categorization of the Turkey Point RVI components. Several of the components with new DMs that screen in for 80 years are to remain No Additional Measures components for SPEO. The staff noted, in particular, that the upper support column bolting shows new 80-year DMs of IASCC and IE, which is in addition to the 60-year DMs of wear, fatigue, and irradiation-induced stress relaxation (ISR).

Request:

Upper Support Column Bolting (No Additional Measures Components): Considering the new DMs of IASCC and IE that screen in for 80 years, please address why the upper support column bolting shows no change in the FMECA score (L,M,1) and Severity Category of A for 60-to-80 years and why no additional action (inspections) are required, or revise the analysis to account for the additional potential for degradation.