L-2018-222, Subsequent License Renewal Application Safety Review - November 13, 2018 Public Meeting Discussion Topic Responses

Subsequent License Renewal Application Safety Review - November 13, 2018 Public Meeting Discussion Topic Responses

ML18348A580
Person / Time
Site:	Turkey Point
Issue date:	12/12/2018
From:	Maher W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-222
Download: ML18348A580 (15)

Text

L-2018-222 10 CFR 54.17 December 12, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Florida Power & Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review - November 13, 2018 Public Meeting Discussion Topic Responses

References:

1. FPL Letter L-2018-004 to NRC dated January 30, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application (ADAMS Accession No. ML18037A812)

2. FPL Letter L-2018-082 to NRC dated April 10, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application - Revision 1 (ADAMS Accession No. ML18113A134)

3. NRC Public Meeting Updated Agenda dated November 1, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application (ADAMS Accession No. ML18315A003)

4. FPL Letter L-2018-166 to NRC dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Re~ewal Application - Safety Review Requests for Additional information (RAI) Set 3 Responses (ADAMS Accession No. ML18296A024)

On April 10, 2018, Florida Power & Light Company (FPL) submitted to the NRC Revision 1 of the subsequent license renewal application (SLRA) for Turkey Point Units 3 and 4 (Reference 1 ), as well as supplemental information for the SLRA Environmental Report (ER) (Reference 2). On November 13, 2018, the NRC and FPL held a public meeting (teleconference) to discuss items associated the safety review of the SLRA for Turkey Point Units 3 and 4 (Reference 3).

The purpose of this letter is to provide, as attachments to this letter, responses to the discussion topic action items assigned to FPL during the referenced public meeting.

These responses revise and supersede the corresponding responses submitted in Reference 4.

Florida Power & Light Company

}(JP I

{V~(l 700 Universe Boulevard, Juno Beach, FL 33408

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2018-222 Page 2 of 2 If you have any questions, or need additional information, please contact me at 561-691-2294.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 12, 2018.

Sincerely, William Maher Senior Licensing Director Florida Power & Light Company WDM/RFO Attachments: 2 RAI Response Revisions (refer to Letter Attachment Index)

• LETTER ATTACHMENT INDEX Attachment NRC RAI Attachment 1

Set 3: B.2.3.28-2 2

cc:

Senior Resident Inspector, USNRC, Turkey Point Plant Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Plant Plant Project Manager, USNRC, SLRA Plant Project Manager, USNRC, SLRA Environmental Ms. Cindy Becker, Florida Department of Health NRC RAI Set 3: B.2.3.21-3

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.28-2 L-2018-222 Attachment 1 Page 1 of 7 NRC RAI Letter Nos. ML18243A006 and ML18243A007 dated September 17, 2018 RAI 8.2.3.28-2

Background:

SLRA Tables.3.3.2-1, 3.3.2-9, and 3.3.2-15 state that steel piping, fire hydrants, bolting, and valve bodies exposed to soil will be managed for loss of material using the Buried and Underground Piping and Tanks program. In addition, SLRA Tables 3.3.2-9, 3.3.2-12, and 3.4.2-2 state loss of material will be managed for stainless steel piping exposed to soil using the Buried and Underground Piping and Tanks program. Stress corrosion cracking is not addressed as an applicable aging effect.

SRP SLR items 3.3.1-144 and 3.4.1-72 state that steel and stainless steel components exposed to soil are susceptible to stress corrosion cracking (steel in carbonate/bicarbonate environment only).

GALL-SLR Report AMP XI.M41 states that steel components can experience stress corrosion cracking when exposed to a carbonate/bicarbonate environment depending on cathodic polarization level, temperature, and pH. This is based on the staff's review of NACE SP0169 2013, "Control of External Corrosion on Underground or Submerged Metallic Piping Systems," Figure 2, "SCC [stress corrosion cracking] Range of Pipe Steel in Carbonate/Bicarbonate Environments."

During its review of soil corrosivity testing during the audit, the staff could not determine if the carbonate/bicarbonate environment is applicable at Turkey Point.

Issue:

a) The SLRA does not address stress corrosion cracking of stainless steel exposed to soil.

b) The SLRA does not address stress corrosion cracking of steel exposed to soil, which can occur in a carbonate/bicarbonate environment depending on cathodic polarization level, temperature, and pH. Based on the staff's review of soil corrosivity testing during the audit, it is unclear why stress corrosion cracking is not an aging effect requiring management for steel piping exposed to soil.

Request:

State the basis for why stress corrosion cracking is not an aging effect requiring management for steel and stainless steel piping exposed to soil.

FPL Revised Response:

This revised RAI response supersedes in its entirety the RAI response provided in 6 of Reference 1 discussed during the November 13, 2018 NRC public meeting with FPL (Reference 2). The Table 3.3.2-1 line item associated with carbon

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.28-2 L-2018-222 Attachment 1 Page 2 of 7

• steel piping exposed to a soil environment is deleted.

Stainless steel piping exposed to soil is susceptible to stress corrosion cracking. Based on 2010 soil testing results, the pH of the soil may indicate the presence of a carbonate/bicarbonate environment; thus, steel piping exposed to soil is also assumed to be susceptible to stress corrosion cracking. As stated in SLRA Section B.2.3.28, the Buried and Underground Piping and Tanks AMP manages the cracking aging effect for components exposed to soil. SLRA Tables 3.3.2-1, 3.3.2-9, and 3.3.2-15 are revised to include rows associated with steel components exposed to a soil environment that are susceptible to stress corrosion cracking. SLRA Tables 3.3.2-9, 3.3.2-12, and 3.4.2-2 are revised to include rows associated with stainless steel components in a soil environment susceptible to stress corrosion cracking. The associated SLRA Table 1 items 3.3-1, 144 and 3.4-1, 072 are also updated to reflect the revised Table 2 items.

References:

1. FPL Letter L-2018-166 to NRC dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application, Safety Review Requests for Additional Information (RAI) Set 3 Responses, ADAMS Accession No. ML18296A024.

• 2. NRC Public Meeting updated agenda dated November 1, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application, ADAMS Accession No. ML18315A003.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRG RAI No. B.2.3.28-2 L-2018-222 Attachment 1 Page 3 of 7 Associated SLRA Revisions:

SLRA Tables 3.3-1, 3.4-1, 3.3.2-1, 3.3.2-9, 3.3.2-12, 3.3.2-15, and 3.4.2-2 are amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions. These revisions supersede the revisions provided in L-2018-166 Attachment 26.

Revise SLRA Table 3.3-1 item 144 as follows:

Table 3.3-1: Summary of Aging Management Evaluation for the Auxiliary Systems Further Item Component Aging Effect/

Aging Management Evaluation Discussion Number Mechanism Programs Recommended 3.3-1, 144 Stainless steel, steel, Cracking due to sec (steel AMP XI.M41, "Buried and No Consistent with NUREG-2191.

aluminum piping, piping in carbonate/bicarbonate Underground Piping and The Buried and Underground components, tanks environment only)

Tanks" Piping and Tanks AMP is used exposed to soil, concrete o manage cracking in stainless steel piping exposed to concrete and soil, carbon steel exoosed to soil. and arav cast iron exoosed to

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.28-2 L-2018-222 Attachment 1 Page 4 of 7 Revise SLRA Table 3.4-1 item 072 as follows:

Table 3.4-1: Summary of Aging Management Evaluation for the Steam and Power Conversion Systems Item Number 3.4-1, 072 Aging Effect/

Aging Management Component Mechanism Programs Stainless steel, steel, Cracking due to sec (steel MP XI.M41, "Buried aluminum piping, piping in carbonate/bicarbonate and Underground components, tanks environment only)

Piping and Tanks" exposed to soil, concrete Further Evaluation Recommended No Add the following rows to SLRA Table 3.3.2-1:

Table 3.3.2-1: Intake Coolin A Water-Summary of AAinA ManaAement Evaluation Aging Effect Component Intended Requiring Aging Management NUREG-Type Function Material Environment Management Program 2191 Item Bolting Pressure Carbon Soil {ext}

Cracking Buried and VII.I.A-425 bounda0£ steel Underground Piping and Tanks Piping Pressure Gra)l cast Soil {ext}

Cracking Buried and VII.I.A-425 bounda!)l iron Underground Piping and Tanks Discussion Table 1 Item Notes 3.3-11 144

~

3.3-11 144 A

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.28-2 L-2018-222 Attachment 1 Page 5 of_7 Add the following row to SLRA Table 3.3.2-9:

Table 3.3.2-9: Plant Air - Summary of Aging Management Evaluation Aging Effect Component Intended Requiring Type Function Material Environment Management Piping Pressure Carbon Soil {ext}

Cracking bounda~

steel Piping Pressure Stainless Soil {ext}

Cracking bounda~

steel Add the following row to SLRA Table 3.3.2-12:

Aging Management Program Buried and Underground Piping and Tanks Buried and Underground Piping and Tanks Table 3.3.2-12: Control Buildini:i Ventilation - Summary of Ai:iing Management Evaluation Aging Effect Component Intended Requiring Aging Management Type Function Material Environment Management Program Piping Pressure Stainless Soil {ext}

Cracking Buried and bounda~

steel Underground Piping and Tanks NUREG-Table 1 2191 Item Item Notes VII.I.A-425 3.3-11 144 A

VII.I.A-425 3.3-11 144 A

NUREG-Table 1 2191 Item Item Notes VII.I.A-425 3.3-11 144 A

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. 8.2.3.28-2 L-2018-222 Attachment 1 Page 6 of 7 Add the following rows to SLRA Table 3.3.2-15:

Table 3.3.2-15: Fire Protection - Summar,, of Aging Mana,1ement Evaluation Aging Effect Component Intended Requiring Aging Management Type Function Material Environment Management Program Fire Pressure Grall cast Soil {ext}

Cracking Buried and hlldrant bounda!Jl iron Underground Piping and Tanks Piping Pressure Carbon Soil {ext}

Cracking Buried and bounda!Jl steel Underground Piping and Tanks Piping Pressure Grall cast Soil {ext}

Cracking Buried and bounda!Jl iron Underground Piping and Tanks Valve bodll Pressure Grall cast Soil {ext}

Cracking Buried and bounda!Jl iron Underground Piping and Tanks Add the following row to SLRA Table 3.4.2-2:

Table 3.4.2-2: Feedwater and Blowdown - Summary of Aging Management Evaluation Aging Effect Component Intended Requiring Aging Management Type Function Material Environment Management Program Piping Pressure Stainless Soil (ext}

Cracking Buried and bounda!Jl steel Underground Piping and Tanks NUREG-Table 1 2191 Item Item Notes VII.I.A-425 3.3-11 144 A

VII.I.A-425 3.3-11 144 A

VII.I.A-425 3.3-11 144 A

VII.I.A-425 3.3-11 144 A

)

NUREG-Table 1 2191 Item Item Notes VIII.H.S-420 3.4-11 072 A

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.28-2 L-2018-222 Attachment 1 Page 7 of 7 Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.21-3 L-2018-222 Attachment 2 Page 1 of 6 NRC RAI Letter Nos. ML18243A006 and ML18243A007 dated September 17, 2018 RAI 8.2.3.21-3

Background:

The "detection of aging effects" program element of GALL-SLR AMP XI.M33, "Selective Leaching," states the following:

a. One-time inspections are only conducted for components exposed to closed-cycle cooling water (CCCW) or treated water when no plant-specific operating experience (OE) of selective leaching exists in these environments.

b. Opportunistic and periodic inspections are conducted for components exposed to raw water, waste water, or soil, and for components in CCCW or treated water where plant-specific OE includes selective leaching in these environments.

SLRA Section B.2.3.21 states "[t]o date, PTN site-specific OE has not revealed selective leaching in components exposed to treated water. Those components are only subject to a one-time inspection unless that inspection identifies selective leaching."

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

SLRA Table 3.0-1, "Service Environments for Mechanical Aging Management Reviews,"

states that "[t]reated water is demineralized water and is the base water for all clean systems."

Issue:

During its audit, the staff noted that selective leaching was identified on components exposed to a treated water environment. Based on this observation, it is unclear to the staff why one-time inspections are appropriate for components susceptible to selective leaching exposed to a treated water environment.

Request:

State the basis for why one-time inspections are appropriate for components susceptible to selective leaching exposed to a treated water environment.

FPL Revised Response:

This revised RAI response supersedes in its entirety the RAI response provided in 6 of Reference 2 discussed during the November 13, 2018 NRC public meeting with FPL (Reference 3). Copper alloy >8% aluminum and copper alloy >15%

zinc components exposed to a treated water environment will be subject to periodic and opportunistic inspections rather than one-time inspections.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. 8.2.3.21-3 L-2018-222 Attachment 2 Page 2 of 6 As documented in the response to RAI 8.2.3.21-1 (Attachment 10 to Reference 1),

selective leaching was discovered in gray cast iron components exposed to treated water. Therefore, all susceptible materials in a treated water environment are subject to periodic and opportunistic inspections consistent with the GALL-SLR Selective Leaching AMP XI.M33. SLRA Section 17.2.2.21, item 25 of Table 17-3, and 8.2.3.21 are revised to clarify that susceptible materials in all applicable environments at PTN will be subject to periodic and opportunistic inspections and that there are no copper alloy >8%

aluminum or copper alloy >15% zinc components exposed to soil at PTN.

References:

1. FPL Letter L-2018-152 dated August 31, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application, Safety Review Requests for Additional Information (RAI) Set 1 Responses, ADAMS Accession No. ML18248A257.

2. FPL Letter L-2018-166 to NRC dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application, Safety Review Requests for Additional Information (RAI) Set 3 Responses, ADAMS Accession No. ML18296A024.

3. NRC Public Meeting updated agenda dated November 1, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application, ADAMS Accession No. ML18315A003.

Associated SLRA Revisions:

SLRA Section 17.2.2.21, Table 17-3, and Section B.2.3.21 are amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions. These revisions supersede the revisions provided in L-2018-166 6.

Revise current SLRA Section 17.2.2.21 paragraphs 2 through 4, updated via L-2018-152 Attachment 10 (page 2 of 6) as follows:

This AMP includes a one time inspection for components exposed to a treated 'Nater environment \\\\'hen site specific OE has not revealed selective leaching in these environments. To date, no site specific OE at PTN has revealed selective leaching therefore, a one time inspection is required. The AMP a-Isa includes periodic inspections for components that are exposed to raw water, treated water, waste water, lubricating oil, or soil environments.:. a-R4-The AMP also includes opportunistic inspections whenever components are opened, or whenever buried or submerged surfaces are exposed.:., and these periodic Periodic inspections are conducted at an interval of no greater than every 10 years during the SPEO.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.21-3 L-2018-222 Attachment 2 Page 3 of 6 The scope of this AMP includes components made of gray cast iron, cast iron, ductile iron, and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc or greater than 8 percent aluminum exposed to a raw water, treated water, waste water, lubricating oil, or soil environment. Depending on environment, the The AMP includes one time, or opportunistic and periodic visual inspections of selected components that are susceptible to selective leaching, coupled with mechanical examination techniques (e.g., chipping, scraping). Destructive examinations of components to determine the presence of and depth of dealloying through-wall thickness are also conducted. These techniques can determine whether loss of material due to selective leaching is occurring and whether selective leaching will affect the ability of the components to perform their intended function for the SPEO. Inspections are conducted in accordance with site-specific procedures, including inspection parameters such as lighting, distance, offset, and surface conditions. When the acceptance criteria are not met such that it is determined that the affected component should be replaced prior to the end of the SPEO, additional inspections are performed.

Each of the one time andThe periodic inspections for these populations at each unit comprises a 3 percent sample or a maximum of 10 components. Gray cast iron, cast iron, and ductile iron components will be visually and mechanically inspected, and the rest will be visually inspected. In addition, for populations having 35 or more components, two destructive examinations will be performed for each material and environment population in each 10-year inspection interval at each unit. For each population with less than 35 susceptible components, one destructive examination will be performed.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.21-3 L-2018-222 Attachment 2 Page 4 of 6 Revise the current commitment for the Selective Leaching AMP in Table 17-3, item 25, as follows:

Aging Management NUREG-2191 Implementation Schedule No.

Program or Activity Section Commitment (Section) 25 Selective Leaching ( 17.2.2.21)

XI.M33 Implement the new PTN Selective Implement AMP and start Leaching AMP.

inspections no earlier than 1 O years prior to the SPEO.

Complete the one time inspection and the first periodic inspection no later than 6 months or the last RFO prior to SPEO.

Corresponding dates are as follows:

PTN3: 7/19/2022 - 1/19/2032 PTN4: 4/10/2023 - 10/10/2032

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.21-3 L-2018-222 Attachment 2 Page 5 of 6 Revise current SLRA Section B.2.3.21 Paragraphs 2 through 4, updated via L-2018-152 0 (pages 2 and 3 of 6) as follows:

Depending on environment, the The PTN Selective Leaching AMP includes either one time inspestions or opportunistic and periodic visual inspections of selected components that are susceptible to selective leaching, coupled with mechanical examination techniques (e.g., chipping, scraping). Destructive examinations of components to determine the presence of and depth of dealloying through-wall thickness are also conducted. These techniques can determine whether loss of material due to selective leaching is occurring and whether selective leaching will affect the ability of the components to perform their intended function for the SPEO.

To date, PTN site specific OE has not revealed selective leaching in components exposed to treated \\Nater. Those components are only subject to a one time inspection unless that inspestion identifies selestive leashing. For somponents in other environments, pPeriodic inspections will be performed every 10 years and opportunistic inspections will be performed when possible. The populations requiring examination and their type of required inspections for PTN 3 and 4 are:

• Copper alloy > 8 percent aluminum exposed to raw water (Periodic and Opportunistic)

• Copper alloy> 8 percent aluminum exposed to treated water (One Time Periodic and Opportunistic)

• Copper alloy > 8 persent aluminum exposed to soil (Periodis and Opportunistis)

• Copper alloy> 15 percent zinc and raw water (Periodic and Opportunistic)

• Copper alloy > 15 percent zinc and treated water (One Time Periodic and Opportunistic)

• Copper alloy > 15 percent zinc exposed to soil (Periodic and Opportunistic)

• Gray cast iron exposed to raw water (Periodic and Opportunistic)

• Gray cast iron and cast iron exposed to treated water (Periodic and Opportunistic)

• Gray cast iron and waste water (Periodic and Opportunistic)

• Gray cast iron and lubricating oil (Periodic and Opportunistic)

• Gray cast iron exposed to soil (Periodic and Opportunistic)

• Ductile iron exposed to raw water (Periodic and Opportunistic)

Eash of the one time andThe periodic inspections for these populations at each unit comprises a 3 percent sample or a maximum of 10 components. Gray cast.iron and ductile iron components will be visually and mechanically inspected; the rest will be visually inspected. In addition, for gray cast iron exposed to raw water and ductile iron

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. 8.2.3.21-3 L-2018-222 Attachment 2 Page 6 of 6 exposed to raw water (i.e., the only populations having 35 or more components), two destructive examinations will be performed for each material and environment population in each 10-year inspection interval at each unit. For each population with less than 35 susceptible components, one destructive examination will be performed.

Associated

Enclosures:

None