ML18299A116

Structural Integrity Associates Engineering Report No. 1700109.401P, Revision 7 - Redacted, Evaluation of Environmentally-Assisted Fatigue for Turkey Point Units 3 and 4 for Subsequent License Renewal

ML18299A116
Person / Time
Site:	Turkey Point
Issue date:	10/15/2018
From:	Gerber D A Structural Integrity Associates
To:	Florida Power & Light Co, Office of Nuclear Reactor Regulation
References
L-2018-174 1700109.401P, Rev 7
Download: ML18299A116 (61)

Text

WITHHELD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.3.3-2 L-2018-174 Attachment 13 Enclosure 3 Page 1 of 61 Enclosure 3 Structural Integrity Associates Engineering Report No. 1700109.401P, Revision 7 -REDACTED, "Evaluation of Environmentally-Assisted Fatigue for Turkey Point Units 3 and 4 for Subsequent License Renewal," October 2018 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 2 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Prepared by: Reviewed by: Approved by: Report No. 1700109.401P Revision 7 REDACTED Project No. 1700109 October 2018 Evaluation of Environmentally-Assisted Fatigue for Turkey Point Units 3 and 4 for Subsequent License Renewal Prepared for: Florida Power & Light Company Juno Beach, FL Purchase Order No. 2000230248 dated 02/16/2017 Prepared by: Structural Integrity Associates, Inc. San Jose, California Date: 10/15/2018 Date: 10/16/2018 Date: 10/16/2018 David A. Geri?ei-,i.E.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 3 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION REVISION CONTROL SHEET Document Number: 1700109.401P REDACTED Title: Evaluation of Environmentally-Assisted Fatigue for Turkey Point Units 3 and 4 for Subsequent License Renewal Client: Florida Power & Light Company SI Project Number: 1700109 Quality Program: [XI Nuclear D Commercial Section Pages Revision Date Comments 1.0 1-1-1-7 0 11/13/2017 Initial Issue 2.0 2-1-2-13 3.0 3-1-3-17 4.0 4-1 2 5.0 5-1 6 App.A A-1-A-7 2.0 2-12, 2-13, 1 12/9/2017 Insertion of 60-year CUF values for CRDM 3.0 3-7-3-9 components and 80-year CUF, Fen and 5.0 3-11 14, CUFen values for CRDM and RPV 3-18-3-20, components.

Annotation of"P" on file names of vendor proprietary documents 5-5 7 added. Added new references.

Change highlighted text to bold italicized text. 3.0 3-11-3-14 2 12/17/2017 Update of two CRDM CUF values and 5.0 5-5, 5-7 correction of the Vent Nozzle CUF value in Table 3-3, replacement of Reference

[23] in Table 3-3, removal of References

[41] and [43] from List of References, addition of three footnotes in Table 3-4, update of CUFen of CRDM Upper Joint and update of revision number of Reference

[29]. 2.0, 3.0, 2-15, 3-2, 3-3 1/4/2018 Remove GALL Rev. 2 references.

5.0 7, 3-8, 3-15, 5-5 2.0 2-11, 2-13, 3-4 3/28/2018 Updated References

[32-33] and [35-40]. 3.0 11, 3-12 Changed pressurizer immersion heater CUF values to proprietary.

l5s1ructural lilteg;;1y Assoc_iat~s,lnq.(!;

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 4 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 5.0 5-5 5 4/2/2018 Updated References

[29], [30a] and [30c]. 1.0 1-2, 1-4, 1-7 6 10/4/2018 Revised References

[5] and [6]. Added 3.0 3-1, 3-7, 3-8, References

[23] and [27]. Updated Fen 3-10 14, values to reflect NUREG/CR-6909, Rev. 1 Final from References

[35 -40]. Editorial 3-16 corrections to faulty hyperlinks.

5.0 5-1, 5-2, 5-4 6 App.A A-2, A-4, A-6, A-7 3.0 3-11, 3-13, 7 10/16/2018 Revised Reference

[ 40] for new revision 3-16 and revised results for CRDM Lower Joint 5.0 5-7 for bounding result. IJ Sth1cturafii1tegrity A$so~iates, l[l_q.<tr.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 5 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table of Contents Section Page 1:0 INTRODUCTION

..........................................................................................................

1-1 1.1 Background

............................................................................................................

1-1 1 ;2 GALL-SLR Guidance for EAF ..............................................................................

1-1 1.2.1 Summary of the NRC's SLR Guidance for EAF. ......................................................

1-2 1.2.2 Summary of the EAF TLAAs Performed for PTNfor 60 Years ...............................

1-5 1.3 Report Objectives

...................................................................................................

1-7 2:0 PLANT-SPECIFIC FATIGUE BACKGROUND FORPTN ....................................

2-1 2;1 PTN Cycle Counting Program ........................

......................................................

2-2 2.2 PTN EAF Assessment.

...........................................................................................

2-7 2.3 PTN Surge Line Inspection Program ...................................................................

2-12 3.0 PLANT-SPECIFIC ASSESSMENT OF ENVIRONMENTALLY-ASSISTED FATIGUE EFFECTS FOR SUBSEQUENT LICENSE RENEW AL ...................................

3-1 3;1 PTN Cycle Counting Program ...............................................................................

3-2 3.2 PTN EAF Assessment.

...........................................................................................

3-7 3.3 Plant-Specific Limiting Locations

.......................................................................

3-14 3.4 Summary of PTN EAF Assessment

.....................................................................

3-14 4;0

SUMMARY

AND CONCLUSIONS

............................................................................

4-1

5.0 REFERENCES

...............................................................................................................

5-1 APPENDIX A FEN CALCULATIONS

....................................................................................

A-1 Report No. 1700109.401P.R7 iii Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 6 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION List of Tables Table 2-1: Projected Number of Transients Compared to Design-Basis Number of Transients

-PTN Class 1 Components for 60 Years ...........................................................................

2-4 Table 2-2: Summary of the PTN EAF Assessment for 60 Years of Operation

..........................

2-9 Table 3-1: Summary of Transient Projections for 80 Years of Operation (PTN Unit 3) ...........

3-3 Table 3-2: Summary of Transient Projections for 80 Years of Operation (PTN Unit 4) ...........

3-5 Table 3-3: Other Class 1 RCPB Components with a CUF Value (1) .........................................

3-9 Table 3-4: Summary of the PTN EAF Assessment for SLR (80 Years of Operation)

.............

3-10 Table 3-5: Minimum Cycles Used in EAF Analyses ................................................................

3-18 Report No. 1700109.401P.R7 iv IJ Strugtural ln_tegtity A~soqlates, Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 7 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION PROPRIETARY INFORMATION NOTICE This report contains information that is proprietary to other vendors that is protected under one or more Non-Disclosure Agreements (NDAs). Such information is identified by red , bold-faced font surrounded by brackets.

An example is { this wording}. Release of such information is not authorized without the express written permission of the authorized owner of the information. Report No. 1700109.401P.R7 V e Structural Integrity Associates, Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 8 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

1.0 INTRODUCTION

1.1 Background

Florida Power & Light Company (FPL) is developing a Subsequent License Renewal (SLR) application (SLRA) to extend plant operations at Turkey Point Nuclear Plant Units 3 and 4 (PTN) from 60 to 80 years. The PTN SLRA will build off the content from the original PTN license renewal application (LRA) submitted to the U.S. Nuclear Regulatory Commission (NRC) in 2000 [1], and adjust the content as necessary so that it follows the updated NRC guidance for SLR. In response to FPL's original LRA submittal for PTN, the NRC issued renewed operating licenses on June 6, 2002 to operate an additional 20 years beyond the original 40-year operating licenses [2]. Structural Integrity Associates, Inc. (SI) provided support to FPL in 2000 and 2001 as a part of the LRA development and NRC approval for PTN. SI's support included the preparation of engineering documents, calculations, and evaluations associated with certain time limited aging analyses (TLAAs) for PTN. This report addresses TLAAs associated with environmentally-assisted fatigue (EAF) for both PTN units. As such, this report documents the EAF TLAAs necessary to support operating license renewals from 60 to 80 years for PTN that satisfy all the requirements specified by the NRC for SLR. 1.2 GALL-SLR Guidance for EAF Two of the NRC's applicable guidance documents for SLR were published in July 2017, and two others for EAF are still under development.

Specifically, this guidance includes the following four documents:

• NUREG-2191, "Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR)

Report" [3]. Report No. 1700109.401P.R7 1-1 S3sttuctural Integrity Ass.ociates, Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 9 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

• NUREG-2192, "Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants" [4].

• Regulatory Guide RG 1.207, Revision 1, "Guidelines for Evaluating the Effects of Water Reactor Water Environments in Fatigue Analyses of Metal Components" [5].

• NUREG/CR-6909, Revision 1, "Effect ofLWR Water Environments on the Fatigue Life of Reactor Materials" [ 6]. This report satisfies all applicable NRC requirements for the EAF TLAAs based on the NRC's final guidance for SLR and EAF, plus any additional knowledge gained from ongoing interactions between the industry and NRC as the documents approach final publication.

The following two subsections provide an overview of the NRC's guidance for EAF, and summarize the P1N EAF TLAAs prepared for FPL's 60-year LRA. Section 1.3 describes the report objectives and identifies the updates needed to assess EAF for P1N for 80 years of operation based on the NRC's SLR guidance.

1.2.1 Summary

of the NRC's SLR Guidance for EAF The NRC's Standard Review Plan for SLR (SRP-SLR)

[4] provides guidance to NRC staff reviewers for SLRA content to ensure the quality and uniformity of NRC staff reviews, and to present a well-defined base from which to evaluate applicant programs and activities for SLR. The SRP-SLR is a companion document to the NRC's Generic Aging Lessons Learned Report for SLR (GALL-SLR)

[3], which provides guidance for SLR applicants and contains the NRC staffs generic evaluation of plant aging management programs (AMPs) and establishes the technical basis for their adequacy.

Section 4.3, "Metal Fatigue," of the SRP-SLR specifies the areas ofreview to ensure that the metal component fatigue parameter evaluations are valid for SLR. For EAF, these areas include component fatigue life estimates based on cumulative usage factor (CUP) calculations, and CUP adjusted to account for the effects of the reactor water environment (CUP en). The acceptance criteria for such calculations follow the requirements of Part 54 to Title 10 of the U.S. Code of Report No. 1700109.401P.R7 1-2 l;sttlictural Integrity

'Assoc/ates, /n_q/i Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 10 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Federal Regulations (10 CFR 54) [7]. Specifically, pursuant to 10 CFR 54.21(c)(l)(i) through (iii), an applicant must demonstrate one or more of the following for each analysis:

1. The analyses remain valid for the period of extended operation;

11. The analyses have been projected to the end of the period of extended operation; or 111. The effects of aging on the intended function(s) will be adequately managed for the period of extended operation.

For components evaluated for CUFen, the acceptance criteria depend on the applicant's choice of 10 CFR 54.21(c)(l)(i), (ii), or (iii). Applicants must also include CUFen calculations for additional component locations if they are more limiting than those previously evaluated for 60 years of operation.

Examples of critical components are identified in NUREG/CR-6260

[8]; however, plant-specific component locations in the reactor coolant pressure boundary (RCPB) may be more limiting than those considered in NUREG/CR-6260, and thus must also be considered.

Plant-specific justification can be provided to demonstrate that calculations for the NUREG/CR-6260 locations do not need to be included.

Chapter X, "Aging Management Programs That May Be Used to Demonstrate Acceptability of Time-Limited Aging Analyses in Accordance with 10 CFR 54.21(c)(l)(iii)," of the GALL-SLR Report provides an AMP acceptable to the NRC for managing EAF. Specifically,Section X.Ml, "Fatigue Monitoring," defines an acceptable basis for managing structures and components (SCs) that are the subject of metal fatigue or cycle-based TLAAs or other analyses that assess fatigue or cyclical loading, in accordance with the 10 CFR 54.21(c)(l), including EAF assessments of CUF en. In Section X.Ml of the GALL-SLR Report, the NRC staff evaluated an AMP for monitoring and tracking the number of occurrences and the severity of critical cyclic loadings for selected components.

The scope of the X.Ml AMP includes those mechanical or structural components with fatigue TLAAs or other analyses that depend on the number of occurrences and severity of transient cycles associated with the plarit license renewal period. The X.Ml AMP has two aspects, one that verifies the continued acceptability of existing analyses through cycle counting, Report No. 1700109.401P.R7 1-3 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 11 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION and the other that provides periodically updated evaluations of the fatigue analyses to demonstrate that they continue to meet the appropriate limits. In the former, the program assures that the number of occurrences and severity of each transient remains within the limits of the fatigue analyses, which in tum ensure that the analyses remain valid. For the latter, actual plant operating conditions monitored by this program can be used to inform updated evaluations of the fatigue analyses to ensure the analyses continue to meet the design or analysis-specific limit, thus minimizing the likelihood of failures from fatigue-induced cracking of the components caused by cyclic strains in the component's material.

EAF effects on fatigue are evaluated by assessing the specific set of sample critical components for the plant. The X.Ml AMP monitors and tracks the number of occurrences and severity of each of the critical thermal and pressure transients for the selected components to maintain the CUFen below the design limit of 1.0. This program also relies on the GALL-SLR Report AMP XI.M2, "Water Chemistry," to provide monitoring of appropriate environmental parameters for calculating environmental fatigue multiplier (Fen) values, which are used to calculate CUFen from CUF. EAF effects on fatigue for the critical components can be evaluated using the positions described in RG 1.207, Revision 1 1 [5], NUREG/CR-6909, Revision O [10] (with "average temperature" used consistent with the clarification that was added to NUREG/CR-6909, Revision 1) [6], or other subsequent NRC-endorsed alternatives.

1 If and when published as RG 1.207, Revision 1 Final. In some cases, flaw tolerance evaluations are used to establish inspection frequencies for components that, for example, exceed CUF or CUFen fatigue limits. As an example, ASME Code,Section XI, Nonmandatory Appendix L [9] provides guidance on the performance of fatigue flaw tolerance evaluations to determine acceptability for continued service ofRCPB components subjected to cyclic loadings.

In flaw tolerance evaluations, the predicted size of a postulated fatigue flaw, whose initial size is typically based on the resolution of the inspection method, is a computed parameter that is used to determine the appropriate inspection frequency.

The X.Ml AMP monitors and tracks the number of occurrences and severity of critical thermal Report No. 1700109.401P.R7 1-4 IJsttuctural Integrity Associates,:

/f1¢.01.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-17 4 Attachment 13 Enclosure 3 Page 12 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION and pressure transients for the selected components that are used in the fatigue flaw tolerance evaluations to verify that the inspection frequencies remain appropriate.

Component locations within the scope of this program are updated based on operating experience (OE), plant modifications, and inspection findings.

The GALL-SLR Report may be referenced in a SLRA and should be treated in the same manner as an approved topical report. In referencing the GALL-SLR Report, the applicant should indicate that the material referenced is applicable to their plant and should provide the information necessary to support the finding of program acceptability as described and evaluated in the report. 1.2.2 Summary of the EAF TLAAs Performed for PTN for 60 Years As part of the PTN LRA for 60 years of operation, a report was prepared to describe how the TLAAs on fatigue and the technical issue associated with EAF evaluation in response to Generic Safety Issue (GSI) 190 [11] were addressed for PTN [12]. That work was further enhanced through responses to NRC Requests for Additional Information (RAis) [13]. Because the work pre-dated the initial revision of the GALL Report [14], guidance for EAF evaluation was still being developed and has continued to evolve based on industry experience.

The recommended approach for PTN accomplished two objectives.

First, the TLAAs on fatigue design were resolved by confirming that the original transient design limits remain valid for the 60-year operating period. Fatigue monitoring was used to ensure these transient limits would not be exceeded.

Second, EAF effects on fatigue life were examined using the most recent data from laboratory simulation of the reactor coolant environment

[15,16]. These two evaluations were kept separate, since fatigue design is a TLAA and part of the plant current licensing basis (CLB), while the consideration of reactor water environmental effects on fatigue life, as described in GSI-190, was not a part of the original PTN CLB. The SIR-00-089 report [12] examined the PTN fatigue design basis as it applied to the resolution of fatigue design TLAAs and described existing plant programs for managing fatigue crack Report No. 1700109.401P.R7 1-5 l'.J Structural Integrity Associat~s,:

IQ_ci-Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 13 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION initiation and growth that were to be used to continue to manage the effects of fatigue during the license renewal term. It also described the results from regulatory and industry studies on the effect of environmental fatigue that were used to address EAF effects in response to GSI-190 for PTN. The results from the PTN plant cycle monitoring program were shown to satisfy license renewal requirements for the fatigue TLAAs, specifically paragraph 10 CFR 54.21(c)(l)(i), where the number of plant transient design cycles for 40 years of operation and transient severity were shown to remain valid for the period of extended operation.

With respect to EAF, the report addressed reactor water environmental effects on the fatigue life of selected fatigue-sensitive reactor coolant system (RCS) components, in accordance with the resolution of GSI-190. The method chosen for this EAF evaluation was based on existing industry evaluations that were pertinent to PTN. Principally, this information was obtained from NUREG/CR-6260, as well as generic industry environmental fatigue studies and additional laboratory data [15,16]. Existing plant programs were described for managing the effects of fatigue and any modifications or enhancements required for the renewal period. EAF effects were shown to be acceptable for all NUREG/CR-6260 components except for the pressurizer surge line. This remaining component was therefore addressed through inspection programs.

Based on results ofhigh calculated CUFen values, the surge line was determined to be a candidate for additional inspection considerations during the license renewal period. All welds in the surge line were therefore included as a part of future ISI programs.

The surge line inspection approach was submitted to the NRC for review in 2012 [17], and was subsequently approved by the NRC in 2013 [18]. Additional EAF evaluations were undertaken for the reactor pressure vessel (RPV) shell and the RCS components/nozzles and connected systems in 2010 as a part of an Extended Power Uprate (EPU) project for PTN [19]. In addition, the pressurizer spray nozzle was reevaluated for EAF using finite element methods in 2011/2012

[20]. Additional analyses were undertaken by Westinghouse

[21, 22] and Areva, NP [21, 23] for EPU. The results of all these evaluations supersede the applicable results from SIR-00-089.

Collectively, these analyses documented that the TLAAs for fatigue and EAF effects were properly evaluated for PTN for 60 years of operation, so the approach was included in FPL's Report No. 1700109.401P.R7 1-6 IJsttuctutal Integrity Assoti?te.s, Jn_c.oi

• Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 14 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION LRA for PTN. The approach was subsequently approved by the NRC when the PTN renewed operating licenses were issued in 2002. As such, they form the CLB for PTN, and serve as the input for the EAF evaluation for SLR. 1.3 Report Objectives Based on the summaries provided in Section 1.2, the objectives of this report are as follows: (i) To perform updated EAF screening for SLR for critical locations using all available CUF values for all PTN Class 1 RCPB components exposed to the water environment for 60 years of operation. (ii) To develop updated PTN environmental multipliers that adopt the latest Fen methods provided in RG 1.207, Revision 1. (iii) To calculate updated CUFen values for all bounding PTN CUF locations using updated transient projections for 80 years and the updated Fen values. (iv) To demonstrate that the PTN EAF analyses will remain valid for 80 years in accordance with the requirements of 10 CFR 54.21 ( c )(1 )(i). (v) To serve as a replacement for Attachments 8.1 and 8.2 to FPL Document No. LRAM-00-0055 that reflects an updated PTN EAF assessment for SLR. The relevant plant-specific fatigue background for PTN, which established the CLB for 60 years of operation and serves as the starting point for assessing EAF for SLR, is described in Section 2.0. The plant-specific assessment ofEAF effects for PTN for SLR is contained in Section 3.0. A summary of the key results of this report and the conclusions relevant to SLR are provided in Section 4.0. Report No. 1700109.401P.R7 1-7 l:)strlicturai Integrity Assaq_iates,Jbc,~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 15 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 2.0 PLANT-SPECIFIC FATIGUE BACKGROUND FOR PTN The plant-specific fatigue background for PTN was initially compiled and summarized for FPL's 60-year LRA in Section 2.0 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM 0055, Revision 1 (SI Report No. SIR-00-089)

[12]. That summary is duplicated in this section, with appropriate updates from the NRC's review and approval of the LRA and EPU, as well as updates made for SLR. With respect to EAF, as described*

in Section 1.2.2, there are six sets of previous analyses that form the CLB for PTN and serve as the input for the EAF evaluation for SLR, as follows: I. Section 3.0 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1 (SI Report No. SIR-00-089)

[12], which describes how reactor water environmental effects on the fatigue life of selected fatigue-sensitive RCS components, in accordance with the resolution of GSI-190, were addressed for PTN. 2. Attachment 8.2 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1 (SI Report No. SIR-01-042, Rev. 0) [13], which further enhanced the Item 1 report through responses to NRC RAis 1. 3. Section 4.0 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1 (SI Report No. SIR-00-089), which addressed EAF management of the PTN surge line weld locations through a PTN plant-specific program utilizing the ASME Code Section XI inspection program. The plant-specific surge line inspection program was approved by the NRC in 2013 [18]. 4. SI Calculation No. 0900948.302, which performed an additional EAF evaluation for the RPV shell as a part ofEPU implementation for PTN in 2010 [19.b]. SI Calculation No. 0900948.301 determined that EAF evaluations for RCS components/nozzles and connected systems were not impacted by EPU [19.a]. Some of the results of the EPU evaluations supersede the applicable results from Items 1 and 2 above. 1 Throughout this section, reference is made to the RAI responses filed in the NRC's Agencywide Documents Access and Management System (ADAMS) as the source of any data rather than Attachment 8.1 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1. Report No. l 700109.401P.R7 2-1 S;Jsttuctural Integrity Associates, ln_c.i Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-17 4 Attachment 13 Enclosure 3 Page 16 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

5. SI Calculation Nos. 1100768.301 through 1100768.304, which performed an updated finite element EAF evaluation for the pressurizer spray nozzle in response to license renewal commitments for PTN in 2011/2012

[20]. Those results supersede the applicable results from Items 1 and 2 above. 6. Westinghouse

[21, 22] and Areva evaluations

[21, 23] for EPU. PTN's TLAAs on fatigue were resolved for 60 years of operation by the above analyses through a combination of three demonstrations: (i) fatigue monitoring of all relevant plant thermal transients to confirm that the original transient design limits remain valid for the 60-year operating period (i.e., the PTN Cycle Counting Program), (ii) reactor water environmental effects on fatigue life were examined using the most recent data from laboratory simulations of the reactor coolant environment (i.e., the PTN EAF Assessment), and (iii) inspection of the surge line welds under a plant-specific program utilizing the ASME Code Section XI inspection program to verify the absence of fatigue cracking (i.e., the PTN Surge Line Inspection Program).

Each of these three demonstrations are summarized in the sections that follow and form the bases for the PTN-specific program described in Section 3.0 for addressing EAF effects for SLR. 2; 1 PTN Cycle Counting Program Section 3.1 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1 (SI Report No. SIR-00-089)

[12] summarizes the PTN cycle counting program implemented for 60 years of operation.

FPL implemented a cycle counting procedure at PTN to ensure that the design-basis transient counts are not exceeded during 60 years of plant operation

[2421]. All significant plant events are captured and recorded via this procedure.

The results from this program provide assurance that the structural design bases of the Class 1 plant components (both ASME Section III and ANSI B31.l piping) are maintained for the 60-year operating period. In addition, a transient evaluation was performed for PTN that extrapolated the actual transient counts established by the FPL cycle counting program to 60 years of plant operation

[25]. The results of the extrapolation concluded that the existing primary system design transients are conservative for use as a basis for 60 years of operation.

Report No. 1700109.401P.R7 2-2 l)structural lntegtJty Ass.oc,iates,, l!Jc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-17 4 Attachment 13 Enclosure 3 Page 17 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION As stated in Section 4.3.1 of the PTN LRA [1] and discussed in Section 2.2 of this report, the evaluation verified the structural integrity of the RPV, RPV internals, pressurizer, steam generators (SGs), reactor coolant pumps (RCPs), and the pressurizer surge lines will remain valid for the period of extended operation.

Similarly, Section 4.3.4 of the PTN LRA [1] stated similar results for the PTN piping designed in accordance with ANSI B3 l .1, "Power Piping." The results of the transient evaluation that form the CLB for PTN for 60 years of operation are summarized in Table 2-1 [29]. [Footnotes for Table 2-2 in [29} are not included in Table 2-1}. These results demonstrated that the design basis (i.e., 40-year) transient definitions were adequate for 60 years of operation, thus satisfying

§54.21(c)(l)(i) of the License Renewal Rule [7], as identified in Section 4.3.l of the PTN LRA [1] and approved by the NRC in the LRA Safety Evaluation Report (SER) [2.b]. The PTN Fatigue Monitoring Program for license renewal is described in Section 16.2.7 of the PTN UFSAR. Report No. 1700109.401P.R7 2-3 1Jsttuct11ral Integrity Assogiates,.

/nct Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 18of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Transient Number I 2 3 4 5 6 7 8 9 10 IL 12 13 14 Table 2-1: Projected Number of Transients Compared to Design-Basis Number of Transients

-PTN Class 1 Components for 60 Years PTNUnit3 PTNUnit4 Projected 40-Year Projected 40-Year Description Number of Design-Basis

%Used Number of Design-Basis After60 Cycles for 60 Numbe1*of Years Cycles for 60 Number of Years Cycles Years Cycles Station Heatup at 100°F/hour 156 200 78.0% 191 {lO) 200 Station Cooldown at 100°F/hour 155 200 77.5% 190 {lO) 200 Pressurizer Cooldown to 400 psia at 200°F/br 142 200 71.0% 179 200 Pressurizer Cooldown from 400 psia at 200°F/br 142 200 71.0% 179 200 Station Loading at 5% power per minute 2,720 14,500 18.8% 2,320 14,500 Station Unloading at 5% power per minute 2,140 14,500 14.8% 2,190 14,500 Step Load Increase of 10% of Full Power 109 2,000 5.5% 112 2,000 Step Load Decrease of 10% of Full Power 220 2,000 11.0% 123 2,000 Step Load Decrease of 50% of Full Power 167 200 83.5% 110 200 Steady State Flucniations, +/-100 psi,+/-6°F Exempted Infinite -Exempted Infinite Feedwater Cycling at Hot Standby Exempted 2,000 --Exempted 2,000 Boron Concentration Equalization 6,358 36,600 17.4% 6,041 36,600(1)

Shipping, Handling, Refueling Events ---------Turbine Roll Test 0 10 0.0% 0 10 %Used Mter60 Years 95.5% 95.0% 89.5% 89.5% 16.0% 15.1% 5.6% 6.2% 55.0% ----16.5% --0.0% ReportNo.

1700109.401P.R7 2-4 estructural Integrity Associates.

lnc.,g Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 19of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Transient Number 15 16 17 18 19 Table 2-1: Projected Number of Transients Compared to Design-Basis Number of Transients

-PTN Class 1 Components for 60 Years (continued)

PTNUnit3 PTNUnit4 Projected 40-Year Projected 40-Year Desc1iption Number Design-%Used Design-of Cycles Basis Mter 60 Number of Basis for60 Number of Years Cycles for Number of Years Cycles 60 Yeai*s Cycles Primary Side Hydrostatic Test a. Hydrostatic Test at 3107 psig Pressure, 1 (10)) 1 100.0% 1 {10)) 1 100°F Temperanrre

<1)<4> b. Hydrostatic Test at 2485 psig Pressure 3 (10) 5 60.0% 3 (10) 5 and 400°F Temperattrre

<1><5) Secondary Side Hydrostatic Test to 1356 psig <8><9> Steam Generator Loop A (pre-and post-1987) 21 35 60.0% 15 35 Steam Generator Loop B (pre-and post-1987) 17 35 48.6% 15 35 Steam Generator Loop C (pre-and post-1987) 17 35 48.6% 13 35 Primary to Secondary Side Leak Test to 2,250 0 15 0.0% 0 15 Secondary Leak Test to 1.085 psig <9> Steam Generator Loop A 4 50 8.0% 4 50 Steam Generator Loop B 7 50 14.0% 11 50 Steam Generator Loop C 4 50 8.0% 7 50 % Used After 60 Years 100.0% 60.0% 42.9% 42.9% 37.1% 0.0% 8.0% 22.0% 14.0% Report No. l 700I09.401P.R7 2-5 S)structural Integrity Associates.

lnc.r&

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disdosure Under 10 CFR 2.390 L-2018-17 4 Attachment 13 Endosure 3 Page 20of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Transient Numbe1* 20 21 22 23 24 25 26 27 28 29 30 Table 2-1: Projected Number of Transients Compared to Design-Basis Number of Transients

-PTN Class 1 Components for 60 Years ( concluded)

PTNUnit3 PTNUnit4 Projected 40-Year Projected 40-Year Desc1iption Number Design-%Used Design-of Cycles Basis Mter60 Number of Basis for60 Numbe1*of Years Cycles for Nnmberof Years Cycles 60 Years Cycles Secondary to Primary Side Leak Test to 840 psig <11> Steam Generator Loop A 8 15 53.3% 14 15 Steam Generator Loop B 15 15 100.0% 15 15 Steam Generator Loop C 9 15 60.0% 15 15 Loss of Load without hmnediate Turbine Trip 43 80 53.8% 38 80 Loss of AC Power 28 40 70.0% 29 40 Partial Loss of Flow (Reverse Flow) 43 80 53.8% 43 80 Loss of Secondary Pressure 2 6 33.3% 0 6 Reactor Trip <1> 291 (lO) 400 72.8% 337 (lO) 400 Inadvertent Auxiliary Spray 0 IO 0.0% 0 IO Operating Basis Earthquake (QBE) 0 50 0.0% 0 50 Loss of Coolant Accident 0 1 0.0% 0 1 Steam Line Break 0 1 0.0% 0 1 Safe Shutdown Earthquake (SSE) 0 1 0.0% 0 1 o/oUsedMter 60 Years 93.3% 100.0% 100.0% 47.5% 72.5% 53.8% 0.0% 84.3% 0.0% 0.0% 0.0% 0.0% 0.0% ReportNo.

1700I09.401P.R7 2-6 e Structural Integrity Associates.

Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 21 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 2.2 PTN EAF Assessment Section 3.2 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1 (SI Report No. SIR-00-089)

[12] summarizes the PTN evaluation ofreactor water environmental effects for 60 years of operation.

Attachment 8.2 to FPL Document No. PTN-ENG-LRAM 0055, Revision 1 (SI Report No. SIR-01-042, Rev. 0) [13] further enhanced the PTN EAF assessment through responses to NRC RAis. The PTN LRA pre-dated GALL requirements, so treatment of EAF effects was still being finalized by the NRC in the wake of the resolution of GSI 190. Based on this, FPL evaluated EAF effects using a combination of methods that included NUREG/CR-6260

[8], NUREG/CR-5704 [16], and NUREG/CR-6583

[15]. The use ofNUREG/CR-6260 was directly relevant to PTN because the "Older Vintage Westinghouse Plant" evaluated in Section 5.5 of that document matched PTN in the design codes used, as well as the analytical approach and techniques used. In addition, the evaluated transient cycles matched or bounded PTN. The PTN EAF assessment for 60 years was performed in five parts:

• First, Section 3.2.1 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1 performed an evaluation of the selected components from NUREG/CR-6260.

This included the RPV at the core support guide weld, the RPV inlet and outlet nozzles, the surge line hot leg nozzle safe end, the charging nozzle, the safety injection nozzle, and the RHR line tee.

• Second, Section 3.2.2 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM 0055, Revision 1 performed an evaluation of Class 1 components that FPL originally excluded from the transient evaluation to demonstrate long-term structural acceptability for continued operation beyond 40 years for PTN. This included the pressurizer lower head, pressurizer surge and spray nozzles, pressurizer surge and spray lines, charging lines and associated charging nozzles, and all branch lines subject to NRC Bulletin 88-08 loading conditions.

Report No. 1700109.401P.R7 2-7 IJstrlictµr~I Integrity Assoc._iates, /(]_¢.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 22 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

• Third, some of the above results were enhanced in responses to NRC RAis.

• Fourth, some of the above results were updated as a part ofEPU implementation at PTN in 2010 [21].

• Fifth, some of the above results were updated as a part of fulfilling license renewal commitments for PTN in 2011/2012.

A summary of the EAF assessments that form the CLB for PTN for 60 years of operation is provided in Table 2-2. These results demonstrated that the CUFen values for all evaluated components except the surge line weld locations were within the allowable value of 1.0 for 60 years of plant operation, as identified in Section 4.3.5 of the PTN LRA [1]. Report No. 1700109.401P.R7 2-8 IJ$ttu.cti,ral Integrity ilssaciates,.:

.. (JJ_c/t Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disdosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Endosure 3 Page 23 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 2-2: Summary of the PTN EAF Assessment for 60 Years of Operation Component 60-YearCLB Fen Material Latest 60-Year CUF CUFen RPV Shell at Core Support Pads (l.2) 0.478 <2> / 0.509 1.76 (2) Low Alloy/Carbon (3) 0.8413 (2) (UFSAR)<2>

RPV Inlet Nozzle <1 , 4> 0.073 <4> / 0.066 2.45 (4) Low Alloy/Carbon

<4> 0.179 (4) (inside surface) (UFSAR)<4> RPV Outlet Nozzle (l,5) 0.056 <5> I 0.063 2.45 (5) Low Alloy/Carbon (3) 0.137 (5) (inside surface) (UFSAR) CS> RCS Piping Surge Line Hot Leg 0.944 (6) 4.5 (6) Stainless steel (3) 4.248 (6) Nozzle (l,6) RCS Piping Safety Injection Nozzle 0.046 (I) 7.11 (I) Stainless steel (3) 0.327 (I) (1,7) RCS Piping Charging Nozzle (l,8) 0.030 (8) 10.63 (8) Stainless steel (3) 0.319 (8) RCS Piping Residual Heat Removal 0.022 (9) 9.32 (9) Stainless steel (3) 0.205 (9) (RHR) Piping Tee Cl,9) Pressurizer Surge Nozzle (lO) { } (10) Addressed by inspection AMP (see Section 2.3) Pressurizer Spray Nozzle <11> { } /0.24667 4.0 (ll) Not reported in [26] < 1.0 (11) (11) Pressurizer Safety and ReliefNozzle

{ } (12) 4.0 (12) Not reported in [26] < 1.0 (12) (12) Pressurizer Lower Head, Heater Well 0.461 / 4.2 (I3) Stainless steel <13> 1.94 (13) (13) { } (13) Pressurizer Lower Head/Perforation

{ } (14) 4.0 (l4) Not reported in [26] < 1.0 (14) (14) Pressurizer Upper Head and Shell (lS) Negligible/

{ } 4.0 (lS) Not reported in [26] < 1.0 (15) (15) Pressurizer Support Skirt/Flange (l6) 0.0165 (l6) 4.0 (l6) Not reported in [26] < 1.0 (16) Pressurizer Manway Pad (17) { } (17) 4.0 (l7) Not reported in [26] < 1.0 (17) Pressurizer Manway Cover (l8) 0.0 (IS) 4.0 (l8) Not reported in [26] < 1.0 (18) Pressurizer Manway Bolts (IS) 0.0 (IS) 4.0 (18) Not reported in [26] < 1.0 (18) Pressurizer Welded Manway { } (l!l) 4.0 (19) Not reported in [26] < 1.0 (19) Diaphragm

<19> Pressurizer Support Lug <2°> Not Installed

<20) ----Pressurizer Instrument Nozzle (2I) { } (21) 4.0 (2l) Not reported in [26] < 1.0 (21) Pressurizer Immersion Heater (22) { } (22) 4.0 (22) Not reported in [26] < 1.0 (22) Pressurizer Valve Support Bracket <2°> Not Installed (20) -----For notes, see next page. Report No. 1700I09.401P.R7 2-9 estructura/

Integrity Associates, Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 24 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 2-2: Summary of the PTN EAF Assessment for 60 Years of Operation ( concluded)

Notes for Table 2-2: 1. NUREG/CR-6260 component location, per Table 1 in the response to RAI 4.3.5-1 [26]. 2. For the RPV Shell at Core Support Pads location, a revised CUF value of0.4030 and a CUFen value of0.9894 was obtained in Table 5 of SI Calculation No. 0900948.302, Revision 1 [19.b]. The value of0.478 shown was reported for EPU [21, Table 2.2.2.3-1].

The Fen was calculated as (0.8413/0.478)

= 1.76 for PTN-4. The CUF was reported in the UFSAR as 0.509 [22]. 3. As identified in the response to RAI 4.3.5-1 [26]. 4. For the RPV Inlet Nozzle, the value reported as UPTN in Table 1 in the response to RAI 4.3.5-1 [26] was updated to the value shown as a part ofEPU implementation

[21]. The refined CUFen value of 0.3 72 shown in Table 3 in the response to RAI 4.3 .5-1 [26] was also revised, and the value of 0.073 shown was reported for EPU [21, Table 2.2.2.3-1].

The Fen was calculated as (0.179/0.073)

= 2.45. 5. For the RPV Outlet Nozzle, the value reported as Uprn in Table 1 in the response to RAI 4.3.5-1 [26] was updated to the value shown as a part ofEPU implementation

[21]. The CUFen value was also revised, and the value of 0.056 shown was reported for EPU [21, Table 2.2.2.3-1].

The Fen was calculated as (0.137/0.056)

= 2.45. 6. For the RCS Piping Surge Line Hot Leg Nozzle, the CUF value is Uprn in Table 1 in the response to RAI 4.3.5-1 [26]. The CUFen value is U6260 in Table 1 in the response to RAI 4.3.5-1 [26]. The Fen was calculated as (4.248/0.944)

= 4.5. 7. For the RCS Piping Safety Injection Nozzle, the PTN location was evaluated to ANSI B3 l.1 rules and does not produce a fatigue usage value, so the NUREG/CR-6260 (Ucode) value was used from Table 1 of the response to RAI 4.3.5-1 [26]. The value was not revised for EPU. The CUFen value is U6260 from Table 1 in the response to RAI 4.3 .5-1 [26]. The Fen was calculated as (0.327 /0.046) = 7.11. 8. For the RCS Piping Charging Nozzle, the PTN location was evaluated to ANSI B3 l. l rules and does not produce a fatigue usage value, so the NUREG/CR-6260 (Ucode) value was used from Table 1 of the response to RAI 4.3.5-1 [26]. The value was not revised for EPU. The CUFen value is U6260 from Table 1 in the response to RAI 4.3.5-1 [26]. The Fen was calculated as (0.319/0.030)

= 10.63. 9. For the RCS Piping RHR Piping Tee Nozzle, the PTN location was evaluated to ANSI B31.1 rules and does not produce a fatigue usage value, so the NUREG/CR-6260 (Ucode) value was used from Table 1 of the response to RAI 4.3.5-1 [26]. The value was not revised for EPU. The CUFen value is U6260 from Table 1 in the response to RAI 4.3.5-1 [26]. The Fen was calculated as (0.205/0.022.)

= 9.32. 10. For the Pressurizer Surge Nozzle, the CUF value of 0.5202 from the table in the response to RAI 4.3 .1-4 [26] was updated to { } as a part of EPU implementation

[21, 22]. EAF for the PTN surge line components is satisfactorily addressed through a PTN plant-specific program utilizing the ASME Code Section XI inspection program, as discussed in Section 2.3. 11. For the Pressurizer Spray Nozzle, the CUF value of 0.8906 from the table in the response to RAI 4.3.1-4 [26] was updated to 0.24667 in Table 5 of SI Calculation No. 1100768.304, Revision 0 [20.d] in 2012. A value of { } was reported as a part ofEPU implementation in 2010 [21, 22]. In the response to RAI 4.3 .1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 12. For the Pressurizer Safety and Relief Nozzle, the CUF value of0.148 from the table in the response to RAI 4.3 .1-4 [26] was updated to { } as a part of EPU implementation

[21, 22]. In the response to RAI 4.3 .1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 13. For the Pressurizer Lower Head, Heater Well, the CUF value of0.461 from the table in the response to RAI 4.3 .1-4 [26] was updated to { } as a part of EPU implementation

[21, 22]. In Report No. 1700109 .40 IP .R 7 2_ 1 O S)sttucturallntegi'ity Assopiatesi Im/*

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 o CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 25 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION the response to RAI 4.3 .1-4 [26], an Fen of 4.2 was used to determine a maximum CUF en value of 1.94, which was qualitatively dispositioned based on inherent margins in the calculational process, the low risk significance associated with these penetrations, current visual inspections performed on the penetrations as part of the ASME Section XI, Subsections IWB, IWC, and IWD Inservice Inspection Program, and the fact that the surge line is significantly more limiting from a fatigue perspective when considering reactor water environmental effects. 14. For the Pressurizer Lower Head/Perforation, the CUF value of 0.0165 from the table in the response to RAI 4.3 .1-4 [26] was updated to { } as a part of EPU implementation

[21, 22]. In the response to RAI 4.3 .1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 15. For the Pressurizer Upper Head and Shell, the CUF value of 0.7737 from the table in the response to RAI 4.3 .1-4 [26] was qualitatively revised to a negligible value in the RAI response.

That value was updated to { } as a part of EPU implementation

[21, 22]. In the response to RAI 4.3 .1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 16. For the Pressurizer Support Skirt/Flange, the CUF value of 0.0165 from the table in the response to RAI 4.3 .1-4 [26] was not revised as a part of EPU implementation

[21, 22]. In the response to RAI 4.3 .1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 17. For the Pressurizer Manway Pad, the CUF value ofO.O from the table in the response to RAI 4.3 .1-4 [26] was updated to { } as a part of EPU implementation

[21, 22]. In the response to RAI 4.3.1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 18. For the Pressurizer Manway Cover and Bolts, the CUF values of 0.0 from the table in the response to RAI 4.3.1-4 [26] were not updated as a part ofEPU implementation

[21, 22]. In the response to RAI 4.3.1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 19. For the Pressurizer Manway Welded Diaphragm, the CUF value of 0.0321 from the table in the response to RAI 4.3.1-4 [26] was updated to { } as a part ofEPU implementation

[21, 22]. In the response to RAI 4.3.1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 20. For the Pressurizer Support Lug and Valve Support Bracket, there was no CUF value reported in the table in the response to RAI 4.3 .1-4 [26] as these components are not installed at PTN. 21. For the Pressurizer Instrument Nozzle, the CUF value of 0.0627 from the table in the response to RAI 4.3.1-4 [26] was updated to { } as a part ofEPU implementation

[21, 22]. In the response to RAI 4.3.1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25. 22. For the Pressurizer Immersion Heater, the CUF value of { } is from [22]. In the response to RAI 4.3 .1-4 [26], a screening Fen of 4.0 was used to justify acceptability of all pressurizer locations with a CLB CUF less than 0.25.

• Report No. 1700109.401P.R7 2-11 e SUuctural Integrity Associates, Inc.Ii!.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-17 4 Attachment 13 Enclosure 3 Page 26 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 2;3 PTN Surge Line Inspection Program As discussed in Section 3.2.2.2 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM 0055, Revision 1 (SI Report No. SIR-00-089)

[12] and indicated by the results shown in Table 2-2, the CUFen results for locations in the PTN surge line (the RCS Piping Surge Line Hot Leg Nozzle and the Pressurizer Surge Nozzle) could not be reduced to below the allowable value of 1.0. Therefore, FPL identified the surge line as a candidate for additional inspection considerations during the license renewal period. Thus, the entire surge line was included as a part of the ASME Code Section XI risk informed inservice inspection (RI-ISI) program, as described in Section 4.0 of Attachment 8.1 to FPL Document No. PTN-ENG-LRAM-00-0055, Revision 1. In their response to RAI 4.3.5-2 [26], FPL committed to an inspection-based AMP to address fatigue of the PTN pressurizer surge lines during the period of extended operation using an approach like that documented in the ASME Code,Section XI, Nonmandatory Appendix L [9]. Because the NRC had not endorsed the Appendix L approach at the time of PTN' s LRA submittal, FPL committed to inspection of all surge line welds on both PTN units during the fourth inservice inspection interval, prior to entering the extended period of operation, and using the inspection results to assess the appropriate approach for addressing EAF of the surge lines using one or more of the following:

1. Further refinement of the fatigue analysis to lower the CUF(s) to below 1.0, or 2. Repair of the affected locations, or 3. Replacement of the affected locations, or 4. Manage the effects of fatigue by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at irispection intervals to be determined by a method accepted by the NRC). If selected, the inspection details for Option 4, such as scope, qualification, method, and frequency, required submittal to the NRC for review and approval prior to entering the period of extended operation.

Report No. 1700109.401P.R7 2-12 l)sttu,ct11ra1 Jntefiiity

~.$so~iat~s.;/rJr;.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 27 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION The surge line inspection program was developed and submitted to the NRC for review in 2012 [17]. This program was based on a flaw tolerance evaluation performed in accordance with ASJ\.1E Code,Section XI, Appendix L using initial postulated flaw sizes consistent with sizes that are detectable by qualified nondestructive examination (NDE) techniques and fatigue crack growth rates that account for the effects of the reactor coolant environment.

The results also determined that there was additional margin between the inspection frequency and the shortest allowable operating period for the most limiting flaw assumed in the evaluation.

The analysis concluded that a IO-year inspection frequency was adequate for detecting cracking caused by EAF of the pressurizer surge line welds before there is a loss of intended function.

The surge line inspection program was approved by the NRC in 2013 [18]. Based on its review of the surge line inspection program, the NRC found the program acceptable because it satisfies the ten elements for an acceptable AMP, as described in Section A.1.2.3 of the SRP-SLR [4], and it adequately manages cracking caused by EAF in the pressurizer surge line welds. The NRC staff also found that FPL determined an appropriate approach for addressing EAF of the pressurizer surge lines and thus fulfilled their license renewal commitment.

Based on this, the PTN CLB for assessing EAF of the pressurizer surge line welds is inspection every ten years to verify the absence of fatigue cracking.

Therefore, CUF en analyses for surge line components are not necessary for SLR. Report No. 1700109.401P.R7 2-13 IJ Sttucturai Integrity A~sogiates, /ii_q.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 28 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 3.0 PLANT-SPECIFIC ASSESSMENT OF ENVIRONMENTALLY-ASSISTED FATIGUE EFFECTS FOR SUBSEQUENT LICENSE RENEWAL The relevant plant-specific fatigue background for 60 years of operation summarized in Section 2.0 forms the CLB for P1N, and serves as the starting point for assessing EAF for SLR. The plant-specific assessment of EAF effects for P1N for SLR is contained in this section. The plant-specific assessment is separated into four parts, with the following objectives:

1. PTN Cycle Counting Program. Section 3.1 describes the latest results from the P1N Cycle Counting Program and provides a summary of the updated evaluation of transient counts and severities performed for SLR. 2. PTN EAF Assessment.

Section 3.2 describes the P1N-specific EAF calculations for all limiting locations for SLR. The assessment incorporates the CUFs for all Class 1 RCPB components that are exposed to a water environment, revises the prior PTN environmental multipliers in Table 2-2 to adopt the latest Fen methods provided in RG 1.207, Revision 1, and calculates CUFen values for all relevant P1N components listed in Table 2-2 using the updated transient projections for SLR and the updated Fen values. 3. Plant-Specific Limiting Locations.

Section 3.3 provides the bases for why the specific limiting locations evaluated for EAF in Section 3.2are limiting locations per GALL-SLR Chapter X.Ml requirements for PTN. 4. Summary of PTN EAF Assessment.

Section 3.4 summarizes the plant-specific EAF assessment results and the relevant changes to the P1N fatigue bases for SLR. These four parts are addressed in the sections that follow, and collectively, they serve as a replacement to the PTN 60-year EAF assessment that reflects an updated P1N EAF assessment for SLR. Report No. 1700109.401P.R7 3-1 IJsttlicturat Integrity AssQC.iates,, .lnc.ot Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 29 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 3.1 PTN Cycle Counting Program The PTN Cycle Counting Program is addressed through FPL Procedure No. O-ADM-553

[21]. For PTN's first license renewal for 60 years of operation, this program was investigated to project transient counts out to 60 years and evaluate transient severities.

That investigation concluded that the original 40-year design basis transient counts and severities remained valid for 60 years of operation.

Therefore, as discussed in Section 1.2.2, FPL concluded that the PTN Cycle Counting Program satisfied the license renewal requirements for fatigue TLAAs in 10 CFR 54.21(c)(l)(i).

For SLR, an updated investigation was performed to develop revised transient projections and evaluate transient severities for 80 years of operation

[29]. That investigation concluded that the original 40-year design basis transient counts and severities, which are also the CLB for PTN for 60 years of operation, remain valid for SLR. A summary of the transient projections for 80 years of operation from the investigation are shown in Table 3-1 (Unit 3) and Table 3-2 (Unit 4), excerpted from [29] (footnoted References for the tables are for [29]). Based on the 80-year evaluation performed for SLR, the same transients and transient counts used for the 60-year EAF assessment remain applicable for 80 years of operation, and were used in the updated EAF assessment for 80 years that is discussed in the following section. Report No. 1700109.401P.R7 3-2 l5~1ructurai lntegrJty Associates, lil_c.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 30 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-1: Summary of Transient Projections for 80 Years of Operation (PTN Unit 3) PTN-3 Through 2016 60Year SO-Year Projections source of Allowables Transient Design Percent of Projection Percent of Weighted Number Count through BO Year UFSAR II UFSAR 0-ADM-Number Transient Design ,., Design Projection Minimum 131 2016 Number Projection Number Method 111 Table4.1-_B Table4.1-10 553 Normal 1 Station Heat up at lOO'F/hour 200 109 55% 156 164 82% X 200 200 200 200 2 station Cool down at lOO'F/hour 200 109 55% 155 164 82% X 200 200 200 200 3 Pressurizer Cooldown at 200'F/hour

<*ll 17 l 200 95 48% 142 148 74% X ---200 200 200 5 Station Loadingat5%

power per minute 14500 293 2% 2no 533 4% 14500(U} -14500 2200 11*1 6 station Unloading at5% power per minute 14500 242 2% 2140 440 3% 14500(U) -14500 2200 (le} 7 Step Load Increase of 10% of Full Power 2000 43 2% 109 79 4% 2000 --2000 2000 8 Step Load Decrease of 10% of Full Power 2000 90 5% 220 164 8% 2000 --2000 2000 9 Step Load Decrease of 50% of Full Power 200 68 34% 167 82 41% X 200 --200 200 Steady State Fluctuations 1" 1 0 Exempted 0 --Fe edw ater Cycling at Hot Standby 1151 2000 Exempted 2000 ---2000 Boron Concentration Equalization

<*I 36000 Not Counted -----36600 Test 14 Turbine Roll Test 10 1 (4){20} 10% 1 (20) 1 10% ----------15 Hydrostatic Test at 3107 pslg Pressure, lOO'F Temperature C6JC 19 l 1 1 100% 1 1 100% 1 -5 1 16 Hydrostatic Test at 2485 psig Pressure and 400"F Tern perature <7 l 5 1 20% 3 2 40% 5 5 ---5 17 Secondary Side Hydrostatic Test to 1356 pslg -----------------------Steam GeneratorLoopA (ioJ 10 17 /9('4) 90% 21 9 90% -10 35 (l3) 10 Steam Generator Loop B 1101 10 13 /7(l4) 70% 17 7 70% ---10 35 (23) 10 Steam Generator Loop c 1101 10 13 /7(141 70% 17 7 70% --10 35 (23) 10 Primary to Secondary Side Leak Test to 2435 psig 171 150 1 1% ----2 1% ---150 150 150 18 Primary to Secondary Side Leak Test to 2250 pslg l*I 15 1 7% 0 2 13% --15 ---15 19 Secondary Side Leak Test~ 1085 psig 121 ------------------------Steam Generator Loop A 1"'1 50 9 18% 4 21 42% -50 50 50 Steam Generator Loop B 1" 1 50 7 14% 7 16 32% ---50 50 50 Steam Generator Loop C 1" 1 50 7 14%. 4 16 32% -50 50 50 Secondary to Primary Side Leak Test to 840 psig C6Jl*J ----------------------------steam Generator Loop A 15 8 53% 8 8 53% --15 ---15 steam Generator Loop B 15 15 100% 15 15 100% --15 --15 Steam Generator Loop C 15 9 60% 9 9 60% --15 --15 Table continued on next page. Report No. 1700109.401P.R7 3-3 SJ Structural Integrity Associates, Inc.*

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 31 of 61 Transient Number (3) 21 22 23 25 26 27 Footnotes

., (1) ., (2) ., (3) ., (4) ., (5) ., (6) ., (7) ., (8) ., (9) ., (10) ., (11) ., (12) ., (13) ., (14) ., (15) ., (16) ., (17) ., (18) ., (19) ., (20) ., (21) ., (22) ., (23) THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-1: Summary of Transient Projections for 80 Years of Operation (PTN Unit 3) (concluded)

PTN-3 Thro ugh 2016 60Year 80-Year Projections Source of Allowables Design Percent of Projection Percent of Weighted Number Count through 80 Year UFSAR UFSAR Transient Design (9) Design Projection 2016 Number Projection Number Method 111 Table 4.1-8 Table 4.1-10 Upset Loss of Load without Immediate Turbine Trip or Reactor Trip 80 15 19% 43 28 35% ---Loss of Off-Site AC Electrical Power 40 6 15% .. 25% 28 10 X ---Loss of Flow in One Reactor Coolant Loop 80 14 18% 43 26 33% ---Reactor Trip 400 183 46% 291 272 68% X 400 Inadvertent Auxiliary Spray 1 1*11 21 1 10 0 0% 0 1 10% ---OBE1221 so 0 0% 0 10 20% ---Loss of Secondary Pressure (Press Loss) 161 6 1 17% 2 2 33% ---Weighted projection method used for counted normal and upset transients in which 60-year projections for either unit are over 70% of design numbers in SIR-00-089

[1] . Labelled as "Secondary Leak Test" in O-ADM-553

[7]. Labelled as "Hydrostatic Pressure Test" in Table 4.1-10 [28] . Transient numbers from Table 3-1 of SIR-00-089

[1] . Not expected to have any additional cycles on RSGs . Applies to Pressurizer only . Applies to Steam Generator only. Labelled as "Secondary Leak Test" in 0-ADM-553

[7] . Limited by Reactor Coolant Pump Analysis [16, Attachment 1, pages 44 and 45] . Leak Test Procedure cancelled per [30] . 60-year projections from [5, PTN-LR-00-0l27Table 10.3-1] . Not expected to have any additional cycles on RSGs . Cycle limits for baffle-former bolts only is being lowered from 14,SOOto 2,200 due EPU RCS conditions (Table 4.1-8 of UFSAR [8]) . Not counted, not significant contributor to fatigue usage factor . 80-year plant life projected cycles computed using 65 years of life for the RSGs . Values are [ (pre-and post-1987)

/ (post-1987)]

cycles [5, PTN-LR-00-0127Table 10.3-1]. Not counted, intermittent slug feeding at hot standby not performed . Limit of 2,200 cycles established for baffle former bolts only per UFSAR Table 4.1-8 [8] . Represents 200 cycles each of: (1) pressurizer cool down cycles at,,; 200°F/hrfrom nominal pressure and (2) pressurizer cool down cycles at,,; 200°F/hrfrom 400 psi a [28]. Spray water temperature differential to 560°F . Applies to Steam Generator only. Represents pre-operational test [16, Note 3 on Attachment 1, pages 44 and 45] . Adjustment in 60-year projection in [S, PTN-LR-00-0127Table 10.3-1] -recorded as a value of O when 1 was assumed in pre-operational startup . One cycle is projected for 80 years to remain within the analytical basis if that event occurs . One cycle of 10 events is projected for 80years to remain within the analytical basis if that event occurs . Recommended revision O-ADM-553 to align with UFSAR Table 4.1-10. 80 40 80 400 10 ------0-ADM-553 80 40 80 400 ------6 Minimum 80 40 80 400 10 20 6 Report No. 1700I09.401P.R7 3-4 SJ Stiuctural Integrity Associates, /he.*

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION L-2018-174 Attachment 13 Enclosure 3 Page 32 of 61 Table 3-2: Summary of Transient Projections for 80 Years of Operation (PTN Unit 4) PTN-4 Through 2016 60Year 80-Year Projections Source of Allowables Transient Design Percent of Projection Percent of Weighted Number Count 80Year UFSAR UFSAR Table 0-ADM-Number Transient Design (9) Design Projection Minimum (3) through 2016 Number Projection Number Method 111 Table 4.1-8 4.1-10 553 Normal 1 Station Heatup at 100°F/hour 200 121 61% 191 181 91% X 200 200 200 200 2 Station Cool down at 100°F/hour 200 121 61% 190 181 91% X 200 200 200 200 3 Pressurizer Cool down at 200°F/hour l 5 ll 17 l 200 104 52% 179 158 79% X ---200 200 200 5 Station Loading at 5% power per minute 14500 260 2% 2320 484 3% 14500 1111 ---14500 2200116) 6 Station Unloading at 5% power per minute 14500 242 2% 2190 451 3% 14500 1111 ---14500 2200 1161 7 Step Load Increase of 10"/o of Full Power 2000 44 2% 112 82 4% 2000 ---2000 2000 8 Step Load Decrease of 10"/o of Full Power 2000 57 3% 123 107 5% 2000 ---2000 2000 9 Step Load Decrease of 50"/o of Full Power 200 42 21% 110 51 26% X 200 ---200 200 Steady State Fluctuations 1 12 1 0 Exempted 0 ----Feedwater Cycling at Hot Standby 1 15 1 2000 Exempted 2000 ------2000 Boron Concentration Equalization 1 5 1 36000 Not Counted ---------36600 Test 14 Turbine Roll Test 10 1 (41(20) 10"/o 1 (20) 1 10"/o -------------15 Hydrostatic Test at 3107 psig Pressure, l00°F Temperature 16 11 19 1 1 1 100% 1 1 100% 1 ---5 1 16 Hydrostatic Test at 2485 psig Pressure and 400°F Temperature 171 5 1 20"/o 3 2 40"/o 5 5 ---5 17 Secondary Side Hydrostatic Test to 1356 psig ---------------------------------------Steam Generator Loop A (lo) 10 11/6 1141 60"/o 15 6 90"/o ---10 35 1231 10 Steam Generator Loop B 1101 10 11/ 6 (14) 60"/o 15 6 70"/o ---10 35 1231 10 Steam Generator Loop c 1io1 10 9/ 5 (14) 50"/o 13 5 70"/o ---10 35 1231 10 Primary to Secondary Side Leak Test to 2435 psig 171 150 1 1% ----2 1% ---150 150 150 18 Primary to Secondary Side Leak Test to 2250 psig 1 6 1 15 1 7% 0 2 13% ---15 ---15 19 Secondary Side Leak Test;,: 1085 psig 121 ----------------------------------------Steam Generator Loop A 1131 50 6 12% 4 14 28% ---50 50 50 Steam Generator Loop B 1 13 1 50 6 12% 11 14 28% ---50 50 50 Steam Generator Loop C l 13 l 50 5 10"/o 7 12 24% ---50 50 50 Secondary to Primary Side Leak Test to 840 psig 1 6 11*1 ---------------------------Steam Generator Loop A 15 14 93% 14 14 93% ---15 ---15 Steam Generator Loop B 15 15 100"/o 15 15 100"/o ---15 ---15 Steam Generator Loop C 15 15 100"/o 15 15 100% ---15 ---15 Table continued on next page. Report No. l 700109.401P.R7 3-5 I) Stiuctuial Integrity Associates; Inc.(/!;

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 33 of 61 Transient Number (3) Upset 21 22 23 25 26 27 Footnotes

,. (1) ,. (2) ,. (3} ,. (4) ,. (5) ,. (6} ,. (7) ,. (8) ,. (9) ,. (10) ,. (11) ,. (12) ,. (13) ,. (14} ,. {15) ,. (16) ,. (17) ,. (18) ,. {19) ,. {20} ,. {21) ,. {22} ,. (23} THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-2: Summary of Transient Projections for 80 Years of Operation (PTN Unit 4) (concluded)

PTN-4 Through 2016 60Year 80-Year Projections Source of Allowables Design Percent of Projection Percent of Weighted Number Count 80Year UFSAR UFSARTable Transient Design Design Projection (9) through 2016 Number Projection Number Method 111 Table 4.1-8 4.1-10 Loss of Load without Immediate Turbine Trip or Reactor Trip 80 14 18% 38 27 34% ---Loss of Off-Site AC Electrical Power 40 13 33% 29 " 19 48% X ---Loss of Flow in One Reactor Coolant Loop 80 11 14% 43 21 26% ---Reactor Trip 400 187 47% 337 292 73% X 400 Inadvertent Auxiliary Spray 1 1*11 21 1 10 0 0% 0 1 10"/o ---QBE 1221 so 0 D"/o 0 10 20"/o ---Loss of Secondary Pressure (Press Loss} 1611211 6 0 D"/o 0 1 17% ---Weighted projection method used for counted normal and upsettransients in which 60-year projections for either unit are over70"/o of design numbers in SIR-00-089

[1]. Labelled as "Secondary Leak Test" in D-ADM-55317].

Labelled as "Hydrostatic Pressure Test" in Table 4.1-10 (28]. Transient numbers from Table 3-1 of SIR-00-089

[l]. Not expected to have any additional cycles on RSGs. Applies to Pressurizer only. Applies to Steam Generator only. Labelled as "Secondary Leak Test" in O-ADM-553

[7]. Limited by Reactor Coolant Pump Analysis [16, Attachment 1, pages 44 and 45]. Leak Test Procedure cancelled per (30]. 60-year projections from [S, PTN-LR-0D-0127Table 10.3-1]. Not expected to have any additional cycles on RSGs. Cycle limits for baffle-former bolts only is being lowered from 14,SOOto 2,200 due EPU RCS conditions (Table 4.1-8 of UFSAR [8]}. Not counted, not significant contributor to fatigue usage factor. 80-year plant life projected cycles computed using 66years of life for the RSGs. Values are [ (pre-and post-1987)

/ (post-1987)]

cycles (5, PTN-LR-00-0127Table 10.3-1]. Not counted, intermittent slug feeding at hot standby not performed.

Limit of 2,200cycles established for baffle former bolts only per UFSAR Table 4.1-8 [8]. Represents 200 cycles each of: (1) pressurizercooldown cycles at s; 200°F/hrfrom nominal pressure and (2) pressurizer cool down cycles at s; 200°F/hrfrom 400 psi a [28]. Spray water temperature differential to 560°F. Applies to Steam Generator only. Represents pre-operational test (16, Note 3 on Attachment 1, pages 44 and 45]. Adjustment in 60-year projection in [5, PTN-LR-00-0127Table 10.3-2] -recorded as a value ofOwhen 1 was assumed in pre-operational startup. One cycle is projected for 80 years to remain within the analytical basis if that event occurs. One cycle of 10 events is projected for 80 years to remain within the analytical basis if that event occurs. Recommended revision O-ADM-553 to align with UFSAR Table 4.1-10. 80 40 80 400 10 ------0-ADM-553 80 40 80 400 ------6 Minimum 80 40 80 400 10 20 6 Report No. 1700109.401P.R7 3-6 '3 Structural Integrity Associates, Jnctw:

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 34 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 3.2 PTN EAF Assessment For SLR, PTN-specific EAF calculations were performed for the limiting PTN components.

All components with CUF values were considered in the EAF assessment so that the plant-specific limiting locations were addressed by the assessment to be consistent with GALL-SLR guidance.

The assessment serves as an update and replacement to the EAF assessment performed for 60 years that is summarized in Table 2-2. The PTN EAF assessment for SLR was performed using the applicable guidance from the SLR [4]. Section 4.3.2.1.2, "Components Evaluated for CUFen," of the SRP-SLR for components evaluated for CUFen states the following:

Applicants should also include CUF en calculations for additional component locations if they are considered to be more limiting than those previously evaluated.

This sample set includes the locations identified in NUREG/CR-6260 and additional plant-specific component locations in the reactor coolant pressure boundary if they may be more limiting than those considered in NUREG/CR-6260.

Plant-specific justification can be provided to demonstrate that calculations for the NUREG/CR-6260 locations do not need to be included.

Environmental effects on fatigue for these critical components can be evaluated using the positions described in Regulatory Guide (RG) 1.207, Revision 1 1; NUREG/CR-6909, Revision O (with "average temperature" used consistent with the clarification that was added to NUREG/CR-6909, Revision 1); or other subsequent NRC-endorsed alternatives.

1 If and when published as RG 1.207, Revision 1 Final. For PTN, the older-vintage Westinghouse PWR plant is applicable; in fact, the "Older Vintage Westinghouse Plant" evaluated in Section 5.5 ofNUREG/CR-6260 is directly relevant to PTN because the design codes, analytical approach and techniques used for that plant matches those used for PTN. In addition, the evaluated transient cycles matched or bounded PTN. Therefore, the evaluation from NUREG/CR-6260 is directly applicable to PTN. Report No. 1700109.401P.R7 3-7 IJstrlictural Integrity Assogi~tes, ln_qt Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 35 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Based on the foregoing discussion, the updated SLR EAF assessment for PTN was performed as follows:

• The plant-specific NUREG/CR-6260 locations were reevaluated for SLR.

• To ensure that any locations that may be more limiting than the NUREG/CR-6260 locations were addressed, the reactor coolant pressure boundary (RCPB) components with existing ASME Code fatigue analyses CUFs presented in Tables 2-2 and 3-3 were evaluated for EAF for SLR.

• Revised plant-specific EAF multipliers applicable for SLR were calculated based on the latest Fen methods using the guidance in NUREG/CR-6909, Revision 1 [6]. The SLR EAF assessment results from Appendix A are summarized in Table 3-4. These results are discussed in Section 3 .4. Report No. 1700109.401P.R7 3-8 IJstriictural lnlegtity AsSOfiates, foe'.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page36of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-3: Other Class 1 RCPB Components with a CUF Value (1) Component Location 60-Year CLB CUF RPV Head Flange 0.083 Vessel Flange 0.531 Closure Studs 0.81 CRDM Housing -J-weld 0.730 CROM Housing -Bi-metallic Weldl 0.620 VentNozzle 0.49 Shell-to-Shell Juncture 0.034 Bottom Head-to-Shell Juncture 0.023 Bottom Mounted Instrumentation Nozzles 0.002 Core Suooort Pads 0.020 Control Rod Drive Mechanisms

• Latch Housing { } (CRDMs) Rod Travel Housing { } Cap { } Lower Joint { } Middle Joint } UooerJoint

{ } Steam Generators (S/Gs) Divider Plate { } (Primary Side) Primary Chamber, Tubesheet and Stub { } Barrel Comnlex Tube-to-Tubesheet Weld f } Tubes } Steam Generators (S/Gs) Uooer Shell Drain } (Secondary Side) Feedwater Nozzle } Secondarv Manway Bolts } Uooer Shell Remnants } Secondarv Hand-Hole

& Insoection Port } Steam Outlet Nozzle Flow Limiters { } Reactor Coolant Pumps (R.CPs) Main Flange Studs 0.29 Main Flange 0.025 Casing 0.001 Reactor Internals Upper Suooort Plate { } DeeoBeam { } Uooer Core Plate { } Uooer Core Plate Alilm1llent Pins f } Uooer Suooort Columns f } Lower Suooort Plate } Lower Suooort Plate to Core Barrel Weld { } Lower Core Plate { } Lower Suooort Columns { } Core Barrel Flange { } Core Barrel Outlet Nozzle f } Radial Kevs and Clevis Insert Assembly f } Footnote for Table 3-3: 1. From Table 2-2 of Reference

[29]. Report No. l 700109.401P.R7 3-9 estructura/

Integrity Associates, Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 37 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-4: Summary of the PTN EAF Assessment for SLR (80 Years of Operation)

Component (1) 80-Year CUF <2> Fm <3> Matelial (-1) 80-Year CUF.,, (5) 0.509 (2 4) / 6.28/ 3.197 / 0.910 (27) RPV Shell at Core Support Pads { } (B) { } (8) Low alloy steel Carbon steel with RPV Inlet Nozzle 0.066 (24) stainless steel clad and (inside surface) 6.28 a stainless steel weld 0.414 butter safe end Carbon steel with RPV Outlet Nozzle 0.063 (2 4) stainless steel clad and (inside surface) 6.28 a stainless steel weld 0.396 butter safe end Head Flange 0.083 (25) 6.28 Low Alloy Steel (23) 0.521 Vessel Flange 0.531 (25) I 6.28/ Low alloy steel (23) 3.333/ 0.373 (26) { } (20) { } (20) CRDM Housing -J-Groove Weld <14> 0.73 (25) / { }(15) 3.75 (2l) / Inconel 2.738/ 0.299 (l.5) { }(15) CRDM Housing -Bi-Metallic 0.62 (25) I { }(18) 3.75 / Inconel 2.323 I 0.646 <1 8> (Nozzle-to-Adapter)

Weld { } (18) Vent Nozzle Cl4) 0.49 (25) I { }(16) 3.75 (2l) / Inconel 1.84 / 0.230 (l6) { } (16) Shell-to-Shell Juncture 0.034 (25) 12.81 Carbon steel with 0.436

• stainless steel clad Bottom Head-to-Shell Juncture 0.023 (25) 12.81 Carbon steel with 0.295 stainless steel clad Bottom Mounted Instrumentation 0.002 (25) 12.81 Stainless steel 0.026 Nozzles Core Support Pads 0.020 (25) 3.75 Inconel 0.075 RCS Piping Safety Injection Nozzle 0.046 C2 4) 12.81 Stainless steel 0.589 RCS Piping Charging Nozzle 0.030 <2 4>

• 12.81 Stainless steel 0.384 RCS Piping Residual Heat Removal 0.022 <2 4) 12.81 Stainless steel 0.282 (RHR) Piping Table continued on next page. Report No. 1700109.40IP.R7 3-10 estructura/

Integrity Associates, Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disdosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Endosure 3 Page 38of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-4: Summary of the PTN EAF Assessment for SLR (80 Years of Operation) ( continued)

Component (l) 80-Year CUF <1> Fen C3> Mate1ial (4) 80-Year CUFen (5) Carbon steel with { } {24) / 12.81 / stainless steel clad, { }/ Pressurizer Spray Nozzle 0.0721 {ll) 6.80 {ll) stainless steel thermal 0.4904 (])(ll) sleeve, and a stainless steel safe end Carbon steel with Pressurizer Safety and ReliefNozzle

{ } {24) 12.81 stainless steel clad and { } a stainless steel safe end Carbon steel with Pressurizer Lower Head, Heater Well { }{24) / 12.81 / stainless steel clad and { }/ { } {12) { } (12) J-groove weld cover 0.093 <12> filet Pressurizer Lower Head/ Perforation

{ } {24) 12.81 Carbon steel with { } stainless steel clad { }<24)/ 6.28/ { }/ Pressurizer Upper Head and Shell { } (8) { }00 Low alloy steel 0_974(27)

Pressurizer Support Skirt/Flange 0.0165 {2 4) 6.28 Carbon steel 0.104 Pressurizer Manway Pad { } {24) 6.28 Carbon steel { } Pressurizer Manway Cover 0.0 {2 4) 6.28 Carbon steel 0.000 Pressurizer Manway Bolts 0.0 {2 4) 6.28 Low Alloy Steel 0.000 Pressurizer Welded Manway { } {24) 3.75 Nickel Alloy { } Diaphragm Pressurizer Instrument Nozzle { } {24) 12.81 Stainless steel { } Pressurizer Immersion Heater { } {24) 12.81 Stainless steel { } CRDM Latch Housing { } (25) / 12.81/ Stainless steel { } / 0.250 {l9) { } (19) { } (19) CRDM Rod Travel Housing { } (25) 12.81 Stainless steel { } CRDMCap { } (25) 12.81 Stainless steel { } { } (25) / 12.81/ Stainless Steel { }/ CRDM Lower Joint { } (17) { } (17) { } {17) CRDM Middle Joint { } (25) 12.81 Stainless Steel { } CRDM Upper Joint { } (25) 12.81 Stainless Steel { } Table continued on next page. Report No. 1700109.401P.R7 3-11 estruclural Integrity Associates, Inc.lg Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disdosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 39of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-4: Summary of the PTN EAF Assessment for SLR (80 Years of Operation) (concluded)

Component (I) 80-Year CUF <1> F.n <3> Matelial (4) 80-Year CUFen (5) { } (25) I 3.75 I { } I SIG Divider Plate { } (9) { } (9) Inconel 0.881 (28) SIG Primary Chamber, Tubesheet and { } (25) 12.81 Carbon steel with { } Stub Barrel Complex stainless steel clad SIG Tube-to-Tubesheet Weld <13> { } (25) 3.75 Inconel { }(13) { } (25) I 3.75 I { } I S/GTubes { } (9) { } (9) Inconel 0.903 (28) RCP Main Flange 0.025 (25) 12.81 Unknown -use 0.320 maxnnwn RCPCasing 0.001 (25) 12.81 Unknown -use 0.013 maximwn Report No. 1700109.401P.R7 3-12 tJstructural Integrity Associates, lnc.r&

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 40 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Footnotes for Table 3-4: 1. Components are those components in Table 2-2. 2. "CUF (for 80 Years)" from Table 2-2. Based on the transient counts and severities remaining valid for SLR (see Section 3.1), the 80-Year CUF value remains equal to the 60-Year CUF value unless noted otherwise.

3. The maximum Fen value for the material.

4. The component material corresponding to the maximum Fen value obtained from [28]. 5. The allowable value for CUFen is 1.0. 6. NOTUSED 7. The value ofCUFen shown results from evaluation of one (1) Inadvertent Auxiliary Spray (IAS) transient.

Evaluation of four (4) IAS transients results in a CUFen = 0.9036. 8. From [32]. 9. From [33]. 10. NOTUSED 11. CUF and CUFen values from [30.c]. Calculation contains vendor proprietary references.

12. CUF and CUFen values from [31.c]. Calculation contains vendor proprietary references.

13. S/G Tube-to-Tubesheet Weld will be included in the S/G inspection program. Accordingly, the S/G Tube-to-Tubesheet Weld is not included in the SLRA. 14. The location with the highest CUFen that is wetted by reactor coolant will be identified and values provided in lieu of the locations currently listed. 15. { } [38]. 16. { } [37]. 17. From [40]. Bounding analysis.

18. From [35]. 19. From [36]. 20. From [39]. 21. Although the location is not wetted, a Fen* value of3.75 was used. 22. Not Available (NA). 23. Head Flange is SA-508 Class 2 material and Vessel Flange is SA-508 Class 3 material [34] 24. From Table 2-2. 25. From Table 3-3. 26. From [39]. 27. From [23]. 28. From [27] Report No. 1700109.401P.R7 3-13 l:)strlictural Integrity Assogiates,:

lrj_c.or.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 41 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 3.3 Plant-Specific Limiting Locations Consistent with the SRP-SLR requirements discussed in Section 3.2, Chapter X.Ml of the GALL-SLR Report [3] states, in part, the following:

CUFen is CUF adjusted to account for the effects of the reactor water environment on component fatigue life. For a plant, the effects of reactor water environment on fatigue are evaluated by assessing a set of sample critical components for the plant. Examples of critical components are identified in NUREGICR-6260; however, plant-specific component locations in the reactor coolant pressure boundary may be more limiting than those considered in NUREGICR-6260, and thus should also be considered.

The locations evaluated for EAF in Section 3.2 for*PTN represent the limiting locations from a CUF perspective per GALL-SLR Chapter X.Ml requirements for PTN based on the following:

• In the PTN 60-year LRA, the plant-specific NUREG/CR-6260 locations for the vintage Westinghouse plant were evaluated.

The older-vintage Westinghouse plant evaluated in NUREG/CR-6260 is directly relevant to PTN because the design codes, analytical approach and techniques used match those used at PTN. In addition, the evaluated transient cycles matched or bounded PTN. In all the CUF calculations documented in Section 5.5, "Older Vintage Westinghouse Plant," ofNUREG/CR-6260, EAF evaluation was consistently performed for "the locations of highest design CUF." Therefore, use of maximum plant-specific Fen values, coupled with these highest CUF values, ensures bounding CUFen values for PTN.

• Based on the comprehensive review of the PTN fatigue bases that was recently performed for SLR [29], all Class 1 locations evaluated for CUF were evaluated in the EAF assessment in Appendix A except for those locations that are not part of the RCPB or those locations that are not exposed to a water environment such that EAF effects do not apply, as follows: o All surge line locations were excluded from CUF en calculations because they were evaluated for EAF via inspection management, as discussed in Section 2.3. This Report No. 1700109.401P.R7 3-14 S)sttuctural_lntegrlty Asspc_iates, ln_c.ri Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 42 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION includes the RCS Piping Surge Line Hot Leg Nozzle and the Pressurizer Surge Nozzle. o The following locations are not exposed to the environment so EAF assessment is not required:

The RPV Closure Studs and the RCP Main Flange Studs. o The following locations are not part of the RCPB: All SIG Secondary Side locations and all Reactor Internals locations.

Only RCPB locations require EAF assessment per Section 4.3.2.1.2, "Components Evaluated for CUFen" of the SLR [4].

• For each CUF value evaluated for EAF, bounding Fen multipliers were used for the materials present in the component location.

In cases where the materials were not known, Fen values for all three Fen material groupings (carbon and low alloy steels, stainless steels, and nickel alloys) were determined and the maximum multiplier was used. Therefore, the SLR EAF assessment for PTN satisfies GALL-SLR Chapter X.Ml guidance for components selection as the PTN EAF assessment considers the NUREG/CR-6260 locations as well as all other plant-specific limiting locations.

3.4 Summary

of PTN EAF Assessment The following summarizes SLR EAF assessment for PTN:

• Based on an 80-year transient evaluation performed for SLR, the same transients, transient severity and transient counts used for the 60-year EAF assessment are bounding for 80 years of operation.

Therefore, the 60-year CLB CUP values remain unchanged and were used in the updated EAF assessment for 80 years. These CUF values use design transients counts for all locations and reflect power uprate.

• The SLR EAF assessment for PTN considers the NUREG/CR-6260 locations, as well as all other plant-specific limiting locations with a CUF calculation that are exposed to a water environment and are part of the RCPB. Therefore, it satisfies GALL Chapter X.Ml and related SRP-SLR guidance for component selection.

Report No. 1700109.401P.R7 3-15 S)sttI!ctural_JntegtJty Asso~iatesi lrj¢~~

• Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 43 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

• The PTN EAF assessment uses plant-specific Fen values, coupled with the highest CUF values, to determine bounding CUF en values.

• Revised plant-specific EAF multipliers applicable for SLR were calculated that generally make use of the latest Fen methods provided in RG 1.207, Revision 1 [5]. As noted in Appendix A, the PTN CUF values still reflect the use of the fatigue curves from the applicable Section III used in each component's CUF calculation because detailed fatigue tables for each PTN component locations are not available.

Therefore, the guidance of Section C.1.1 ofRG 1.207, Revision 1 [5] (for carbon and low alloy steel), Section C.2.1 (for SS), and Section C.3.1 (for Ni-Cr-Fe alloys) could not be fully implemented in the calculations for all locations.

This shortcoming should be addressed as part of the resolution of high CUFen values discussed below.

• The CUFen values calculated using the ASME Code fatigue curves ofrecord for each location are above the allowable of 1.0 for 13 locations:

(1) RPV Shell at Core Support Pads, (2) RPV Vessel Flange, (3) RPV CRDM Housing-I-Groove Weld, (4) RPV CRDM Housing-Bi-Metallic Weld, (5) RPV Vent Nozzle, (6) Pressurizer Spray Nozzle, (7) Pressurizer Lower Head Heater Well, (8) Pressurizer Upper Head and Shell, (9) CRDM Latch Housing, (10) CRDM Lower Joint, (11) SIG Divider Plate, (12) SIG Tube-to-Tubesheet Weld and (13) SIG Tubes. The SIG Tube-to-Tubesheet Weld is no longer subject to further EAF assessment consistent with the SRP-SLR [4] and is excluded from this list because it is no longer part of the reactor coolant pressure boundary.

This location is being managed with a permanently approved H* alternate repair criteria for both the hot-and cold-leg sides of the steam generator.

For the 12 remaining locations that must be managed for EAF effects, FPL should satisfactorily assess EAF using one or more of the following options: o Further refinement of the EAF analysis to lower the CUFen values to below 1.0, or o repair of the affected locations, or o replacement of the affected locations, or o management ofEAF effects using an inspection program that has been reviewed and approved by the NRC (the approach intended for the SIG Tube-to-Tubesheet Weld). Report No. 1700109.401P.R7 3-16 l)strlictural Integrity Associates, Inc.@;

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 44 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION To fully satisfy GALL-SLR AMP requirements, FPL should complete one of these options at least two years prior to the period of SLR operation.

If the last option is selected, FPL should provide the NRC with the inspection details of the AMP requiring staff approval prior to the period of SLR operation.

• The components shown in Table 3-3 with 80-year CUFen values less than 1.0 are acceptable for 80 years of operation.

• Some of the EAF-analyzed components required refined analysis techniques and use 80-year projected cycles for selected transients to achieve a CUFen value below 1.0. Table 3-5 provides which 80-year projected transients and their minimum values which have been used in the EAF analyses.

• The PTN EAF assessment should be coupled with the PTN Cycle Counting Program to verify the continued acceptability of all EAF analyses through cycle counting and periodically updated evaluations, if necessary, to demonstrate that they continue to meet the appropriate limits throughout the SLR period. The PTN-specific EAF assessment and the above recommendations to use updated fatigue curves and resolve unacceptable CUF en values serve as an acceptable AMP that satisfies SLR Report, Chapter X.Ml guidance to manage SCs that are the subject of fatigue TLAAs in accordance with the requirements in 10 CFR 54.21 ( c )(1 )(iii). Report No. 1700109.401P.R7 3-17 SJsttuctutal Integrity Assoc_iates, _loq.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Component Footnotes for Table 3-5: Withheld From Public Disclosure Under 1 O CFR 2.390 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Table 3-5: Minimum Cycles Used in EAF Analyses Pressurizer Design Number Spray Nozzle Pressurizer Lower Head RSG Divider Plate Pzr Upper RSGTubes Head and Shell CRDM Bi-Metallic RV Core (Nozzle-to-Support Blocks Adapter) Weld CRDM Latch Housing L-2018-174 Attachment 13 Enclosure 3 Page 45 of 61 RVCH CRDM Nozzle and J Groove Weld Vessel Flange Minimum CRDM Lower Joint (from RVCH installation Cycles ot 80 years for bounding Unit4) (1) One (1) occurrence of the IAS transient is specified in Tables 3-1 and 3-2. Evaluation of the pressurizer spray nozzle shows that evaluation of two (2) IAS transients results in an acceptable CUFen::; 1.0 value [30.c]. (2) Transient not counted. Report No. 1700109.401P.R7 3-18 SJ Structural Integrity Associates, lnq.(§;

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 46 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 4.0

SUMMARY

AND CONCLUSIONS This report addresses TLAAs associated with EAF for both PTN units. As such, this report documents the EAF TLAAs necessary to support operating license renewals from 60 to 80 years for both PTN units that satisfy all the requirements specified by the NRC for SLR. Section 2.0 summarizes PTN's TLAAs on fatigue that were resolved for 60 years of operation by analyses that used a combination of three demonstrations: (i) fatigue monitoring of all relevant plant thermal transients to confirm that the original transient design limits remain valid for the 60-year operating period (i.e., the PTN Cycle Counting Program), (ii) reactor water environmental effects on fatigue life using the most recent data from laboratory simulation of the reactor coolant environment (i.e., the PTN EAF Assessment), and (iii) inspection of the surge line welds under the ASME Code Section XI inspection program to verify the absence of fatigue cracking (i.e., the PTN Surge Line Inspection Program).

Collectively, these three demonstrations form the EAF CLB for PTN and represent the inputs to the PTN-specific program for addressing EAF effects for SLR. Section 3.0 contains the plant-specific assessment ofEAF effects for PTN for SLR. The specific assessment is separated into four parts, the PTN Cycle Counting Program, the PTN EAF Assessment, discussion of the plant-specific limiting locations evaluated in the PTN EAF Assessment, and a summary of the PTN EAF Assessment and how it satisfies NRC requirements for SLR. Collectively, these four parts serve as a replacement to the PTN 60-year EAF assessment that reflects an updated assessment applicable to SLR. The PTN EAF assessment should be coupled with the PTN Cycle Counting Program to verify the continued acceptability of all EAF analyses through cycle counting and periodically updated evaluations, if necessary, to demonstrate that they continue to remain valid and meet the appropriate limits throughout the SLR period. The PTN-specific EAF assessment and the associated recommended options for resolving unacceptable CUFen values serve as an acceptable AMP that satisfies GALL-SLR Report, Chapter X.Ml guidance to manage SCs that are the subject ofEAF TLAAs in accordance with the requirements in 10 CFR 54.21(c)(l)(iii).

Report No. 1700109.401P.R7 4-1 SJ Sttucturai Integrity Associates, l(i_c.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 47 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Based on the evaluation and results presented in this report, the TLAAs for EAF are adequately evaluated for PTN, and the potential effects of the reactor water environment have been properly evaluated, as required by the GALL-SLR [3]. Therefore, the proposed approach described in this report is recommended for inclusion in FPL's SLRA for PTN to address EAF. Report No. 1700109.401P.R7 4-2 l'.Jsttuctural integrity Associates,:

/(J_c.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 o CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 48 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

5.0 REFERENCES

1. FPL Letter No. L-2000-177, "Application for Renewed Operating Licenses, Turkey Point Units 3 and 4," September 8, 2000, ADAMS Accession No. ML003749654.

2. NRC Extended Operating License Approval, including:

a. NRC Letter frol!l Rajendar Auluck to J. A. Stall, "Issuance of Renewed Facility Operating Licenses Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Units Nos. 3 and 4," U.S. Nuclear Regulatory Commission, Washington, DC, June 6, 2002, ADAMS Accession No. ML021550105.

b. NUREG-1759, "Safety Evaluation Report Related to the License Renewal of Turkey Point Nuclear Plant, Units 3 and 4," U.S. Nuclear Regulatory Commission, Washington, DC, April 2002, ADAMS Accession No. ML021280541.

c. NUREG-1759, Supplement 1, "Safety Evaluation Report Related to the License Renewal of Turkey Point Nuclear Plant, Units 3 and 4," U.S. Nuclear Regulatory Commission, Washington, DC, May 2002, ADAMS Accession No. ML021560094.

3. NUREG-2191, Final Report, "Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR)

Report," Volumes 1 and 2, U.S. Nuclear Regulatory Commission, Washington, DC, July 2017, Agencywide Documents Access and Management System (ADAMS) Accession Nos. MLl 7187A031and MLl 7187A204.

4. NUREG-2192, Final Report, "Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants," U.S. Nuclear Regulatory Commission, Washington, DC, July 2017, ADAMS Accession No. MLl 7188A158.

5. NRC Regulatory Guide 1.207, Revision 1, "Guidelines for Evaluating the Effects of Light-Water Reactor Water Environments in Fatigue Analyses of Metal Components," U.S. Nuclear Regulatory Commission, Washington, DC, June 2018, ADAMS Accession No. ML16315A130.

Report No. 1700109.401P.R7 5-1 l:)sttuctural Integrity Assa~iates, /[JC,~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 49 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

6. NUREG/CR-6909, Revision 1, "Effect ofLWR Water Environments on the Fatigue Life of Reactor Materials," Final Report, U.S. Nuclear Regulatory Commission, Washington, DC, May 2018, ADAMS Accession No. ML16319A004.

7. U.S. Code of Federal Regulations, Title 10, Chapter I --Nuclear Regulatory Commission, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." 8. NUREG/CR-6260 (INEL-95/0045), "Application ofNUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components," U.S. Nuclear Regulatory Commission, Washington, DC, March 1995, ADAMS Accession No. ML031480219.

9. ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, Nonmandatory Appendix L, "Operating Plant Fatigue Assessment," American Society of Mechanical Engineers, New York, NY, 2013 Edition. 10. NUREG/CR-6909 (ANL-06/08), "Effect of L WR Coolant Environments on Fatigue Life of Reactor Materials," U.S. Nuclear Regulatory Commission, Washington, DC, February 2007, ADAMS Accession No. ML070660620.

11. NUREG-0933, Supplement 24, "A Prioritization of Generic Safety Issues," Section 3, New Generic Issues," Issue 190, "Fatigue Evaluation of Metal Components for 60-Year Plant Life (Rev. 2)," U.S. Nuclear Regulatory Commission, Washington, DC, June 30, 2000, ADAMS Accession No. ML020740117.

12. Attachment 8.1 to FPL Document No. P1N-ENG-LRAM-00-0055, Revision 1, "Engineering Evaluation of Environmental Effects of Fatigue," (SI Report No. SIR-00-089, Revision 0, "Position Document to Address GSI-190 Issues Related to Fatigue Evaluation for Turkey Point Units 3 and 4," July 2000, SI File No. FPL-lOQ-401).

13. Attachment 8.2 to FPL Document No. P1N-ENG-LRAM-00-0055, Revision 1, "Engineering Evaluation of Environmental Effects of Fatigue," (SI Report No. SIR-01-Report No. 1700109.401P.R7 5-2 esttuctura[

Integrity AsSocjates, Inc.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 50 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION 042, "Transmittal of Final RAI Responses on Fatigue," April 13, 2001, SI File No. FPL-I OQ-402). 14. NUREG-1801, Revision 0, "Generic Aging Lessons Learned (GALL) Report," U.S. Nuclear Regulatory Commission, Washington, DC, July 2001, ADAMS Accession Nos. ML012060392, ML012060514, ML012060539, and ML012060521.

15. NUREG/CR-6583 (ANL-97/18), "Effects ofLWR Coolant Environments on Fatigue Design Curves of Carbon and Low-Alloy Steels," U.S. Nuclear Regulatory Commission, Washington, DC, March 1998, ADAMS Ac~ession No. ML031480391.

16. NUREG/CR-5704 (ANL-98/31), "Effects of LWR Coolant Environments on Fatigue Design Curves of Austenitic Stainless Steels," U.S. Nuclear Regulatory Commission, Washington, DC, April 1999, ADAMS Accession No. ML031480394.

17. PTN Surge Line Appendix L Evaluation, including:

a. SI Calculation Nos. 1100756.301 through 1100756.306 (EC 276235) and SI Report No. 1100756.401 (EC 276242), "Turkey Point on the Pressurizer Surge Nozzle Flaw Tolerance Using Appendix L," April 2012. b. FPL Letter No. L-2012-214 from Michael Kiley to U.S. Nuclear Regulatory Commission, "Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251, License Renewal Commitment, Submittal of Pressurizer Surge Line Welds Inspection Program," May 16, 2012, ADAMS Accession No. ML12152A156.

18. Letter from Farideh E. Saba, Senior Project Manager (NRC) to Mr. Mano Nazar (NextEra Energy), "Turkey Point Nuclear Generating Units 3 and 4 -Review of License Renewal Commitment for Pressurizer Surge Line Welds Inspection Program (TAC Nos. ME8717 and ME8718)," U.S. Nuclear Regulatory Commission, Washington, DC, May 29, 2013, ADAMS Accession No. ML13141A595.

19. SI evaluations performed for Extended Power Uprate (EPU), including:

Report No. 1700109.401P.R7 5-3 13 Structural Integrity Assoc_iates,, lnq_.e Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 51 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

a. SI Calculation No. 0900948.301, Revision 1, "Environmental Fatigue Evaluation of Reactor Coolant System Components/Nozzles and Connected Systems," April 30, 2010. b. SI Calculation No. 0900948.302, Revision 1, "Environmentally-Assisted Fatigue Evaluation of the RPV Shell Using 60-Year Projected Cycles and Enveloping Cycles," April 22, 2010. 20. SI evaluations performed in response to License Renewal Commitments, including

a. SI Calculation No. 1100768.301, Revision 1, "Pressurizer Spray Nozzle Design Loads Calculation," December 1, 2011. b. SI Calculation No. 1100768.302, Revision 0, "Finite Element Model of the Pressurizer Spray Nozzles," November 1, 2011. c. SI Calculation No. 1100768.303, Revision 0, "Thermal and Mechanical Stress Analyses of Pressurizer Spray Nozzles," February 7, 2012. d. SI Calculation No. 1100768.304, Revision 0, "Pressurizer Spray Nozzle Fatigue Analysis," February 7, 2012. 21. Turkey Point, Units 3 and 4 License Amendment Request for Extended Power Uprate (LAR No. 205), Attachment 4, ADAMS Accession No. ML103560177, SI File No. 1700109.210.

22. Westinghouse Letter No. LTR-MRCDA-17-81-P, Revision 3, "Requested Cumulative Fatigue Usage Factors from Turkey Point Unit 3 and Unit 4 EPU Licensing Report," transmitted by Westinghouse Letter No. WEC-FPL-TP-SLR-17-033, NEXT-17-213, PROPRIETARY INFORMATION, December 14, 2017, SI File No. 1700109.11 lP. 23. Westinghouse Letter No. L TR-SDA-11-17-15, Environmentally Assisted Fatigue Evaluation of the Turkey Point Unit 3 and 4 Pressurizer Upper Head and Reactor Vessel Core Support Blocks, Rev. 0, dated October 16, 2017, SI File No. 1700804.204.

24. FPL Procedure No. O-ADM-553, Revision 3, "Maintaining Records for Design Cycles," 9/13/12, SI File No. 1700109.203.

Report No. 1700109.401P.R7 5-4 l> Structural lntegf,ty Assoc_iates, ln_c.i Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 52 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

25. FPL Letter No. PTN-LR-00-0127, "Florida Power & Light Company, Turkey Point Units 3 & 4, License Renewal Project, GSI-190 Position Paper," July 12, 2000, SI File No. FPL-IOQ-204.

26. FPL Letter No. L-2001-75, "Response to Request for Additional Information for the Review of the Turkey Point Units 3 and 4 License Renewal Application," April 19, 2001, ADAMS Accession No. MLOl 1170195. 27. Westinghouse Letter No. LTR-CEC0-17-016, Environmentally Assisted Fatigue Evaluation of the Turkey Point Unit 3 and 4 Replacement Steam Generators, Rev. 0, dated October 25, 2017, SI File No. 1700804.205.

28. FPL Request for Input No. RFI-FPL-SI-004, "Turkey Point Units 3 and 4 Subsequent License Renewal (SLR) Time Limited Aging Analyses (TLAAs) Project," approved 5/24/17, SI File No. 1700109.205.

29. SI Report No. 1700109.402P, Revision 4, "Evaluation of Fatigue of ASME Section III, Class 1 Components for Turkey Point Units 3 and 4 for Subsequent License Renewal," March 2018. Contains Vendor Proprietary Information.

30. SI evaluations performed for the Pressurizer Spray Nozzle, including:

a. SI Calculation No. 1700804.313P, Revision 2, "Pressurizer Spray Nozzle Loads," April 2, 2018. Contains Vendor Proprietary Information

b. SI Calculation No. 1700804.314P, Revision 1, "Pressurizer Spray Nozzle Finite Element Model and stress Analysis," December 7, 2017. Contains Vendor Proprietary Information.

c. SI Calculation No. 1700804.315P, Revision 3, "Pressurizer Spray Nozzle Fatigue Analysis," August 22, 2018. Contains Vendor Proprietary Information.

31. SI evaluations performed for the Pressurizer Lower Head, Heater Penetration:

Report No. 1700109.401P.R7 5-5 IJstriictural lntegtlty_

Assac_iates, Inc.*

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174Attachment 13 Enclosure 3 Page 53 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

a. SI Calculation No. 1700804.316P, Revision 0, "3-D Finite Element Model of Pressurizer Bottom Head, Skirt Assembly and Heater Wells," September 28, 2017. Contains Vendor Proprietary Information.

b. SI Calculation No. 1700804.317, Revision 0, "Pressurizer Lower Head Green's Functions and Unit Pressure," October 5, 2017. c. SI Calculation No. 1700804.318, Revision 1, "Pressurizer Lower Head Loads, Fatigue and EAF Analysis," August 21, 2018. 32. Westinghouse Letter No. LTR-SDA-II-17-13-P, Environmentally Assisted Fatigue Evaluation of the Turkey Point Unit 3 and 4 Pressurizer Upper Head and Reactor Vessel Core Support Blocks, Rev. 2, dated November 30, 2017, SI File No. 1700804.204P.

Contains Vendor Proprietary Information.

3 3. Westinghouse Letter No. L TR-CEC0-17-025-P, Environmentally Assisted Fatigue Evaluation of the Turkey Point Unit 3 and 4 Replacement Steam Generators, Rev. 1, dated November 30, 2017, SI File No. 1700804.205P.

Contains Vendor Proprietary Information.

34. FPL Drawing Number 5613-M-460-2, Spec. Drawing for Replacement Reactor Vessel Closure Head, Revision 0, SI File No. 1700109.212.

35. Framatome Calculation No. 32-9279174-002, Turkey Point-3 & 4 CRDM Nozzle to Adapter Weld Connection EAF Evaluation, dated September 27, 2018, SI File No. 1700804.206P.

PROPRIETARY

36. Framatome Calculation No. 32-9279367-002, TP CRDM Latch Housing Environmentally Assisted Fatigue, dated September 27, 2018, SI File No. 1700804.206P.

PROPRIETARY

37. Framatome Calculation No. 32-9279362-002, TP Vent Nozzle Environmentally Assisted Fatigue, dated September 27, 2018, SI File No. 1700804.206P.

PROPRIETARY Report No. 1700109.401P.R7 5-6 l5s1ructural lnteg~Jty Associates, /n_c.01-Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 54 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

38. Framatome Calculation No. 32-9279212-002, Turkey Point-3 & 4 Replacement RVCH CRDM Nozzle EAF Analysis, dated September 27, 2018, SI File No. 1700804.206P.

PROPRIETARY

39. Framatome Calculation No. 32-9279161-002, Turkey Point SLR EAF Analysis for Reactor Vessel Flange, dated September 27, 2018, SI File No. 1700804.206P.

PROPRIETARY

40. Framatome Calculation No. 32-9280202-003, TP CRDM Lower Joint Environmentally Assisted Fatigue, dated October 12, 2018, SI File No. 1700804.206P.

PROPRIETARY Report No. 1700109.401P.R7 5-7 i3striictptal Integrity Assogiates, Jncf!-

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 55 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION APPENDIX A FEN CALCULATIONS Report No. 1700109.401P.R7 A-1 '3 Suuctural Integrity_

• A'ssogiates, fo_c'.~

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 56 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION This appendix contains the details of the environmentally adjusted cumulative usage factor (CUFen) calculations for Turkey Point Nuclear Plant, Units 3 and 4 (PTN) for Subsequent License Renewal (SLR) operation out to 80 years. Chapter X.Ml of the GALL-SLR Report [3] states, in part, the following:

CUFen is CUF adjusted to account for the effects of the reactor water environment on component fatigue life. For a plant, the effects of reactor water environment on fatigue are evaluated by assessing a set of sample critical components for the plant. Examples of critical components are identified in NUREG/CR-6260; however, plant-specific component locations in the reactor coolant pressure boundary may be more limiting than those considered in NUREG/CR-6260, and thus should also be considered.

Environmental effects on fatigue for these critical components may be evaluated using the guidance in Regulatory Guide (RG) 1.207, Revision 1 1; alternatively, the bases in NUREG/CR-6909, Revision O (with "average temperature" used consistent with the clarification that was added to NUREGICR-6909, Revision I); or other subsequent US. Nuclear Regulatory Commission (NRC)-endorsed alternatives.

1 If and when published as RG 1.207, Revision 1 Final. Consistent with this guidance, environmental adjustment factor (Fen) calculations are performed in this appendix for PTN for SLR using the methods documented in RG 1.207, Revision l [ 5]. Section C ofRG 1.207, Revision 1 refers to the equations in Appendix A ofNUREG/CR-6909, Revision 1 for calculating Fen values. Therefore, the Fen equations from Appendix A of NUREG/CR-6909, Revision 1 [ 6] are summarized here and used in updated PTN CUF en calculations.

Report No. 1700109.401P.R7 A-2 l;sthictural lntegrJty

'Associates, lifp.i Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR *2.390 L-2018-174 Attachment 13 Enclosure 3 Page 57 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Carbon and Low Alloy Steels The nominal environmental fatigue adjustment factor for both carbon and low-alloy steels, Fen-CS-LAS, is expressed as: Fen-CS-LAS=

exp ((0.003 -0.031 E*) S* T* O*) (Eqn. A-1) where S*, T*, O*, and t* are transformed sulfur (S) content, transformed material temperature (T), transformed dissolved oxygen (DO) level, and transformed strain rate (t), respectively, defined as: S* = 2.0 + 98 S (S :S 0.015 wt.%) S* = 3.47 (S > 0.015 wt.%) (Eqn. A-2) T* = 0.395 (T < 150 °C) T* = (T-75)/190 (150 °C :ST :S 325 °C) (Eqn. A-3) O* = 1.49 (DO < 0.04 ppm) O* = In (D0/0.009)

(0.04 ppm :S DO :S 0.5 ppm) O* = 4.02 (DO > 0.5 ppm) (Eqn. A-4) t* =O (t > 2.2%/s) t* = In (t/2.2) (0.0004%/s

St :S 2.2%/s) t* = In (0.0004/2.2) (t < 0.0004%/s) (Eqn. A-5) A threshold value of 0.07% for strain amplitude (one-half the strain range for the cycle, Ea) is defined, below which environmental effects on the fatigue lives of these steels do not occur. Thus, Fen-CS-LAS is equal to 1.0 when Ea is less than or equal to 0.07%. Section C.1.1 of RG 1.207, Revision 1 [5] states that the CUF for carbon and low alloy steel components should be computed using the design fatigue curves provided in Figures A. I and A.2 and Table A.1 in Appendix A to NUREG/CR-6909, Revision 1, or, alternatively, using the fatigue design curve for carbon and low-alloy steel in Appendix I to Section III of the 2013 Edition of the ASME Code. Report No. 1700109.401P.R7 A-3 1Js1;,1ctural Integrity Associates, lflc.ot Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 58 of61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Stainless Steels The nominal environmental fatigue adjustment factor for wrought and cast austenitic stainless steels (SSs), Fen-ss, is expressed as: Fen-SS = exp (-T* 0* E*) (Eqn. A-6) where T*, O*, and .s* are transformed material temperature (T), transformed dissolved oxygen (DO) level, and transformed strain rate (.s), respectively, defined as: T*=O (T :S 100 °C) T* = (T-100)/250 (100 °C :ST :S 325 °C) .s* =O .s* = In (E/7) .s* = ln (0.0004/7)

(.s > 7%/s) (0.0004%/s

SE :S 7%/s) (.s < 0.0004%/s) (Eqn. A-7) (Eqn. A-8) For all wrought and cast SSs and heat treatments, SS weld metals, and sensitized carbon wrought and cast SSs: O* = 0.29 (for any DO level) For all wrought SSs except sensitized high-carbon SSs: O* = 0.14 (DO 2: 0.1 ppm) (Eqn. A-9) A threshold value of 0.10% for Ea is defined, below which environmental effects on the fatigue lives of these steels do not occur. Thus, Fen-SS is equal to 1.0 when Ea is less than or equal to 0.10%. Section C.2.1 ofRG 1.207, Revision 1 [5] states that the CUF for SS components should be computed using the design fatigue curves provided in Figure A.3 and Table A.2 in Appendix A to NUREG/CR-6909, Revision 1. Nickel Alloys The nominal environmental fatigue adjustment factor for Ni-Cr-Fe steels, Fen-Ni, is expressed as: Report No. 1700109.401P.R7 A-4 IJ Sttlictural ltltegrity Assoqiates, file.*

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 59 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Fen-Ni= exp (-T* O* t*) (Eqn. A-10) where T*, O*, and t* are transformed material temperature (T), transformed dissolved oxygen (DO) level, and transformed strain rate (t), respectively, defined as: T* =O (T :S 50 °C) T* = (T -50)/275 (50 °C :ST :S 325 °C) t* = 0 (t > 5.0%/s) t* = ln (t/5.0) (0.0004%/s

SE :'.S 5.0%/s) t* = ln (0.0004/5.0) (t < 0.0004%/s)

O* = 0.06 O* = 0.14 (DO 0.1 ppm) (DO < 0.1 ppm) (Eqn. A-11) (Eqn. A-12) (Eqn. A-13) A threshold value of 0.10% for ca is defined, below which environmental effects on the fatigue lives of these steels do not occur. Thus, Fen-Ni is equal to 1.0 when ca is less than or equal to 0.10%. Section C.3.1 ofRG 1.207, Revision 1 [5] states that the CUF for Ni-Cr-Fe alloy components should be computed using the design fatigue curves provided in Figure A.3 and Table A.2 in Appendix A to NUREG/CR-6909, Revision 1, or, alternatively, the fatigue design curve for Cr-Fe alloys in Section III of the 2013 Edition of the ASME Code may be used. The environmentally adjusted cumulative usage factor for 80 years is computed as: where: CUFen-80 Report No. 1700109.401P.R7 CUF en-80 = Fen CUF 80 (Eqn. A-14) environmentally adjusted cumulative usage factor for 80 years of operation A-5 ~structural Integrity Associates,, /11_c.e Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 10 CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 60 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION Fen CUFso environmental adjustment factor for the specific component material using Equation A-1 for carbon and low alloy steels, Equation A-6 for SSs, or Equation A-10 for Ni-Cr-Fe alloys. cumulative usage factor for 80 years of operation PTN-Specific CUFen-80 Calculations The following is considered with respect to the PTN-specific CUFen-80 calculations:

• In the absence of detailed fatigue tables for each PTN component locations, the following inputs were used for all calculations:

o Dissolved Oxygen, DO. A DO value that bounds normal operating conditions and represents the controlled value of 5 parts per billion (ppb ), or 0.005 parts per million (ppm), from the PTN Water Chemistry Program (FPL Procedure No. O-ADM-651)

[28, excerpted]

is considered in the calculations to yield bounding Fen values. The threshold DO level of 0.040 ppm is used in the carbon and low alloy steel Fen calculations, the threshold DO level of 0.1 ppm is used in the Cr-Fe alloy Fen calculations, and the DO level does not affect the SS Fen calculations for pressurized water reactors (PWRs). Therefore, the PTN controlled value for the DO level is well removed from any levels that would affect the Fen calculations.

In addition, PTN's FPL's procedure requires that a Condition Report be initiated to take remedial actions if this level is exceeded.

o Temperature, T. A maximum temperature value of 617 °F (325 °C) was used to yield bounding Fen values, which represents the maximum RCS temperature that all components may be exposed to for plant operations.

o Sulfur Content, S. In the absence of Certified Material Test Reports (CMTRs) for all carbon and low alloy steel components, the Fen upper bound S threshold of 0.015 wt.% for Equation A-2 is used to yield bounding Fen values. o Strain Rate, E. In the absence of detailed transient load pair information, the bounding E of 0.0004 %/sec is used in Equations A-5, A-8, and A-12 to yield bounding Fen values. Report No. 1700109.401P.R7 A-6 IJsttuctural Integrity Associates, lnc.g Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Withheld From Public Disclosure Under 1 O CFR 2.390 L-2018-174 Attachment 13 Enclosure 3 Page 61 of 61 THIS REPORT CONTAINS VENDOR PROPRIETARY INFORMATION

• Fen calculations are performed for each of the materials present in each component, and the maximum Fen for all materials in each component is used to compute bounding, component-specific CUFen-80 values. The Fen value is computed from the CUFen and CUF values where they are available.

In cases where the materials are not known, Fen values for all three F ert material groupings ( carbon and low alloy steels, stainless steels, and nickel alloys) are determined and the maximum multiplier is used. The maximum Fen values used are: o Stainless Steel-12.81 o Ni-Cr-Fe-3.75 o Carbon / Low Alloy Steel -6.28

• The PTN CUF values still reflect the use of the fatigue curves from the applicable Section III Code of record for each location because detailed fatigue tables for each PTN component locations are not available.

Therefore, the guidance of Section C.1.1 ofRG 1.207, Revision 1 [5] (for carbon and low alloy steel), Section C.2.1 (for SS), and Section C.3.1 (for Ni-Cr-Fe alloys) could not be fully implemented in the calculations.

Report No. 1700109.401P.R7 A-7 SJithictliral Integrity Ass.o~iates,, Jn_c_.e