L-2019-033, Response to Requests for Additional Information Subsequent License Renewal Application Safety Review Revision 1, Set 8 First Submittal Responses

Response to Requests for Additional Information Subsequent License Renewal Application Safety Review Revision 1, Set 8 First Submittal Responses

ML19064A824
Person / Time
Site:	Turkey Point
Issue date:	03/01/2019
From:	Maher W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2019-033
Download: ML19064A824 (62)

Text

L-2019-033 10 CFR 54.17 March 1, 2019 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 Revision 1 Requests for Additional Information (RAI)

Set 8 First Submittal Responses

References:

1. FPL Letter L-2018-004 to NRG 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 NRG dated April 10, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application - Revision 1 (ADAMS Accession No.

ML18113A134)

3. NRG RAI E-Mail to FPL dated February 1, 2019 - Revision 1 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 8 (EPID No. L-2018-RNW-0002) (ADAMS Accession Nos. ML19032A397 and ML19032A616) 4 .. NRG RAI E-Mail to FPL dated February 22, 2019 - Response Date Extension for RAls Set 8, Revision 1, for the Safety Review of the Turkey Point Subsequent License Renewal Application (EPID No. L-2018-RNW-0002) (ADAMS Accession Nos. ML19032A396 and ML19032A397)

Florida Power & Light Company (FPL) submitted a subsequent license renewal application (SLRA) for Turkey Point Units 3 and 4 to the NRG on January 30, 2018 (Reference 1) and SLRA Revision 1 on April 10, 2018 (Reference 2).

The purpose of this letter is to provide, as attachments to this letter, responses to five of the 15 safety review revision 1 Set 8 RAls issued by the NRG on February 1, 2019 (Reference 3). The RAI responses and corresponding attachments are indexed on page 2 of this letter; the attachments identify revisions amending the SLRA (if applicable). The remaining ten revision 1 Set 8 RAI responses will be submitted on or before March 18, 2019 (Reference 4). A/) 'tt/-

Florida Power & Light Company Nf~

700 Universe Boulevard, Juno Beach, FL 33408

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2019-033 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 March 1, 2019.

Sincerely, a

William Maher Senior Licensing Director Florida Power & Light Company WDM/RFO Attachments: 5 RAI Responses (refer to Letter Attachments Index)

LETTER ATTACHMENTS INDEX Attachment NRC RAI Attachment NRC RAI 1 B.2.2.3-1 4 4.5-3 2 4.5-1 5 4.5-4 3 4.5-2 cc:

Senior Resident Inspector, USNRC, Turkey Point Nuclear Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Nuclear Plant Project Manager, USNRC, SLRA Plant Project Manager, USNRC, SLRA Environmental Ms. Cindy Becker, Florida Department of Health

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.2.3-1 L-2019-033 Attachment 1 Page 1 of 5 NRC RAI Letter Nos. ML19032A396 and ML19032A397 Dated February 1, 2019 Section IV - RAls Relevant to GALL-SLR AMP X.S1 Regulatory

Background:

Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21 (a)(3) requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the current licensing basi"S"for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21 (a)(3) by referencing the GALL-SLR Report and when evaluation of the matter in the GALL-SLR Report applies to the plant. SLRA Section B.2.2.3 states that the applicant's Concrete Containment Unbonded Tendon Prestress program is an existing AMP that will be consistent with enhancements with the GALL-SLR Report AMP X.S 1, "Concrete Containment Unbonded Tendon Prestress."

The GALL-SLR Report states:

If an applicant credits an AMP in the GALL-SLR Report, it is incumbent on the applicant to ensure that the conditions and operating experience (OE) at the plant are bounded by the conditions and OE for which the GALL-SLR Report program was evaluated. If these bounding conditions are not met, it is incumbent on the applicant to address any additional aging effects and augment the AMPs for SLR.

RAI B.2.2.3-1

Background:

GALL-SLR Report AMP X.S1, "Concrete Containment Unbonded Tendon Prestress" program description states that the program consists of an assessment of measured tendon prestress forces from required examinations performed in accordance with Subsection IWL of the ASME Code,Section XI, as supplemented in 10 CFR 50.55a(b)(2)(viii) and AMP program elements.

Turkey Point Units 3 and 4 (PTN) Containment lnservice Inspection (GISI) program complies with ASME Code Section XI, Subsection IWL, 2007 Edition through 2008 Addenda. IWL-2500 requires a predetermined "common" tendon to be selected from the first year of randomly populated sample tendon groups (e.g., horizontal or hoop, vertical, dome); and that these tendons are inspected at each surveillance. To ensure that prestress concrete containment (PCC) structural integrity is maintained, the Code requires randomly selected and common tendons to be periodically inspected for materiaJ deterioration and prestress lift-off force reduction. The specific requirements for the selection and service role of random and common prestressed tendons are noted in IWL-2521, which states:

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.2.3-1 L-2019-033 Attachment 1 Page 2 of 5 One tendon of each type (as defined in Table IWL-2521-1) shall be selected from the first year inspection sample and designated as a common tendon. Each common tendon shall be examined during each inspection. A common tendon shall not be detensioned unless required by IWL-3300. If a common tendon is detensioned, another common tendon of the same type shall be selected from the first year inspection sample.

The common tendon provides a historical assessment of a group's performance that includes effects of prestress force losses from the initial (e.g., initial elastic shortening of concrete) effects to those that occur over-time (creep, shrinkage, and steel tendon relaxation) and allows for an unbiased correlation of the common tendon's losses to those of the randomly selected sampled tendons over the life of the plant. The "parameters monitored" program element of GALL-SLR Report AMP X.S1 discusses the importance of the historical assessment and recommends that prestressing forces be measured on preselected common (control) tendons and tendons selected by random sampling of each tendon group using lift-off or equivalent tests.

Issue: to Audit Report "Turkey Point Units 3 and 4 - Audit of Structures and Civil Engineering Features," dated April 13, 1992 (ADAMS Accession No. ML17348B474),

states that through the 15th year of surveillance, PTN Technical Specifications (TSs) required nine preselected tendons (3 horizontal or hoop, 3 vertical, 3 dome) to be examined for tendon lift-off force measurements at every surveillance. It also states that beginning with the 20th year surveillance TSs required lift off force measurements of a random but representative sample of tendons (5 hoop, 4 vertical, 3 dome) with one "kept unchanged to develop a history" to assess the structural integrity of the PCCs every five years.

The staff audited PTN Procedure 12-ISI/IWL, "Reactor Containment Building-Concrete Containment lnservice Inspection Program," Revision 1, and noted that it states that the common tendons for the 20th through the 45th year inspections of Units 3 and 4 respectively are 51H18, 12V22, 3008 and 62H82, 45V10, 3020. However, in its review of the basis document PTN-BFSC-99-2205, "Containment Tendon Loss of Prestress Time Limited Aging Analysis (TLAA) for License Renewal and Subsequent License Renewal," it was not clear that the same "common" tendons had been selected for the first fifteen years of containment surveillance. The staff noted that in accordance with IWL-2521, common or controlled tendons should be selected from the first year sample and kept unchanged unless detensioned per ASME Code,Section XI, Subsection IWL-2521 and IWL-3300. Without testing the same "common" tendons during each inspection, it is not clear how an adequate tendon prestress force history (that is correlated to past and current observed lift-off force data of other randomly selected tendons) was developed. The staff needs additional information to verify that the lift-off data referenced in the application represent the loss of prestress history characteristically demonstrated by common tendons over the life of the plant.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.2.3-1 L-2019-033 Attachment 1 Page 3 of 5 Request:

1. From the pool of randomly selected or predetermined tendons state which are (or could be) identified as common tendons per IWL-2521, such that the tendon prestress force history data is clear and that observed data with past and future predictions can be correlated. Identify these in Figures 4.5-1 through 4.5-6 of the PTN SLRA to clearly describe the force history over the life of the plant; or

2. Justify an alternate method for demonstrating how each tendon group's loss of prestress historical assessment can be adequately predicted and age-managed such that their structural integrity intended function would be maintained through the subsequent period of extended operation (SPEO).

FPL Response:

This response (along with RAI responses 4.5-1, 4.5-2, 4.5-3, and 4.5-4 in this letter) supersede Attachment 8 of FPL's December 14, 2018 response (Reference 3) for clarity. The conclusions in Reference 3 Attachment 8 were carried forward and remain unchanged in this response. The following numbered responses correspond to the numbered requests above: *

1. Per original plant technical specification requirements, 9 tendons were originally selected for surveillance. These tendons were to be examined as part of every surveillance (Reference 4). New technical specification requirements, in effect beginning with the 20th year tendon surveillance (1992), required surveillance of a random but representative sample of at least 12 tendons (3 Dome, 4 Vertical, 5 Horizontal), and for each subsequent inspection, one tendon from each group may be kept unchanged to develop a history (Reference 4). The 1st_15th year surveillance historical tendons were not retained in the 20th year tendon surveillance (Reference 5). Additionally, the 20th Year Tendon Surveillance Final Report (Reference 6) recommended that one undisturbed tendon (not stressed/detensioned in previous surveillances) from each tendon group which has been inspected in a previous surveillance be kept as historical (control) tendon. The intent of this recommendation was that these tendons would be used to develop a history of the observed liftoff forces, ensure the accuracy of the predicted accelerated loss rate, and to ensure

• correlation between the predicted and the actual liftoff forces. This recommendation was consistent with the new technical specification requirement that went into effect prior to the 20th year tendon surveillance. Subsequently, Unit 3 tendons 51H18, 12V22, 308 and Unit 4 tendons 62H82, 45V10, 3020 were examined during the 20th, 25th, 30th, 35th, 4Qth and 45th year tendon surveillances as historical tendons (Reference 9). These tendons are identified in Figures 4.5-1 through 4.5-6 of the Turkey Point SLRA.

2. In 2001, the NRC accepted the Turkey Point Technical Specification requirement change to 4.6.1.6.1 such that, "The tendons' structural integrity shall be demonstrated by: Determining that tendons, selected in accordance with IWL-2521, have the average of all measured tendon forces for each type of tendon (dome,

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.2.3-1 L-2019-033 Attachment 1 Page 4 of 5 vertical and hoop) equal to or greater than the minimum required prestress specified at the anchorage for that type of tendon ... " (Reference 7). The section was revised to conform to IWL and 10 CFR 50.55(b)(2)(viii) requirements (Reference 8).

Therefore, the first tendon surveillance in accordance with IWL was the 3Qth year tendon surveillance. Per IWL-2521 (b) one tendon of each type shall be selected from the first year inspection sample and designated as a common tendon. Each common tendon shall be examined during each inspection. Since having a historical tendon from the first year inspection was not a requirement prior to the Turkey Point adoption of IWL in 2001 and since all of the tendons that were inspected during the first year inspection have since been detensioned for wire inspection during the 1st through 15th year surveillances (Reference 4), the best available alternative for subsequent surveillances was to continue the inspection of the historical tendons established at the 20th year tendon surveillance. Accordingly, these same tendons were examined during the 20th, 25th, 30th, 35th, 40th and 45th year tendon surveillances rather than inspecting a tendon that was examined during the 1st year tendon surveillance. The historical tendons selected from the 20th year surveillance have not been stressed or detensioned during the plant life; therefore, the force history associated with these tendons represents the force history throughout plant life. Continuing the surveillance of the historical tendons established at the 20th year tendon surveillance (1992) through the SPEO (approximately 2052) will provide 60 years of trended tendon history. Therefore, the surveillance of the historical tendons established at the 20th year tendon will continue such that each tendon group's loss of prestress historical assessment can be adequately predicted, trended and age-managed such that their structural integrity intended function will be maintained through the subsequent period of extended operation.

References:

1. FPL Letter L-2018-176 to NRC dated October 17, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application, Response to NRC On-Site Regulatory Audit Follow Up Items (ADAMS Accession No. ML18292A641)

2. Not used.

3. FPL Letter L-2018-223 to NRC dated December 14, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review - November 15, 2018 Public Meeting Action Item Responses (ADAMS Accession No. ML18352A885)

4. Audit Report, Turkey Point Units 3 and 4 - Audit of Structures and Civil Engineering Features, dated April 13th, 1992 (ADAMS Accession No. ML17348B474)

5. C-SJ539-01, Revision 2, Random Selection of Surveillance Tendons for 20th Year Surveillance

6. JPN-PTN-SECJ-93-004, Revision 0, Units 3 & 4 Twentieth Year Tendon Surveillance Final Report

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. B.2.2.3-1 L-2019-033 Attachment 1 Page 5 of 5

7. NRC letter from Kahtan N. Jabbour to Mr. T. F. Plunkett, Turkey Point Units 3 and 4

- Issuance of Amendments Regarding Changes to Containment Structural Integrity Technical Specifications (TAC NOS. MA9047 and MA9048), dated January 31, 2001 (ADAMS Accession No. ML010360301)

8. FPL letter from R.J. Hovey to NRC, L-2000-072, Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments Changes to Containment Structural Integrity Technical Specifications (ADAMS Accession No. ML003719523)

9. PTN/PSC-REP-1130-501, Revision 0, Tendon Selection and Predicted Forces for the 45th Year IWL Containment Tendon Surveillance Associated SLRA Revisions:

FPL letter L-2018-176 Attachment 3 (Reference 1) revised SLRA Sections 17.2.1.3, 17.2.2.31, and B.2.2.3 to clarify that the tendon surveillances include common (historical/control) and randomly sampled tendons. Additionally, FPL letter L-2018-223 Attachment 8 (Reference 3) revised SLRA Section 4.5 Figures 4.5-1 through 4.5-6 to differentiate the control tendons following the 201h year tendon surveillance for regression analysis. The FPL letter L-2018-223 Attachment 8 revisions related to control tendons were carried forward as shown in the Associated SLRA Revisions section of the response to RAI 4.5-2 (Attachment 3 to this letter). No further SLRA revisions are

• required.

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No.4.5-1 L-2019-033 Attachment 2 Page 1 of 4 NRC RAI Letter Nos. ML19032A396 and ML19032A397 Dated February 1, 2019 Section V - Relevant to SRP-SLR TLAA 4.5 RAI 4.5-1 Regulatory Background 10 CFR 54.21 (c)(1) requires the applicant to evaluate TLAAs. 10 CFR 54.21 (a)(3) requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21 (a)(3) by referencing the GALL-SLR Report and when evaluation of the matter in the GALL-SLR Report applies to the plant.

10 CFR 50.34(h)(3), "Conformance with the Standard Review Plan (SRP)," states:

[t]he SRP was issued to establish criteria that the NRC staff intends to use in evaluating whether an applicant/licensee meets the Commission's regulations. The SRP is not a substitute for the regulations, and compliance is not a requirement. Applicants shall identify differences from the SRP acceptance criteria and evaluate how the proposed alternatives to the SRP criteria provide an acceptable method of complying with the Commission's regulations.

Background:

The program description of GALL-SLR Report AMP X.S1 states that the program consists of an assessment of measured tendon prestress forces from required examinations performed in accordance with Subsection IWL of the ASME Code,Section XI, as supplemented in 10 CFR 50.55a(b)(2)(viii) and AMP program elements.

It also states that NRC Regulatory Guide (RG) 1.35.1, "Determining Prestressing Forces for Inspection of Prestressed Concrete Containments," may be used as guidance related to calculation of prestressing losses and predicted forces.

For the prediction of prestress force losses, RG 1.35.1 recommends establishing upper and lower tolerance bands to describe (for each tendon) the limits of measured allowable tendon prestressing force evaluation following time dependent losses in concrete and prestressing steel. The RG states that "the chance is small that the measured prestressing force will agree quite closely with the predicted value." The RG also provides guidance in grouping/subgrouping tendons for constructing group tolerance bands for comparison of measured prestressing forces with the forces predicted at inspection time. Table 4.7-1, "Examples of Potential Plant-Specific TLAA Topics," of SRP-SLR Section 4.7, "Other Plant-Specific Time-Limited Aging Analyses,"

describes the predicted lower limit (PLL) as a plant specific TLAA that needs to be

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No.4.5-1 L-2019-033 Attachment 2 Page 2 of 4 dispositioned in accordance with 10 CFR 54.21 (c)(1 )(i), (ii), or (iii) and 10 CFR 54.21 (d) with acceptance criteria for each as follows:

• For 10 CFR 54.21 (c)(1 )(i): "The applicant must demonstrate that the analysis remains valid for the subsequent period of extended operation. The analysis remains valid because it is shown to be bounding even during the subsequent period of extended operation. No changes to the existing analys,is are necessary."

• For 10 CFR 54.21 (c)(1 )(ii): "The applicant must demonstrate that the analysis has been projected to the end of the subsequent period of extended operation. The existing analysis is updated or recalculated to show acceptable results for the subsequent period of extended operation."

• For 10 CFR 54.21 (c)(1 )(iii): "The applicant must demonstrate that the effects of aging on the intended function(s) will be adequately managed for the subsequent period of extended operation. Appendix A.1 of this SRP-SLR [NU REG 2192]

provides the acceptance criteria for programs and activities used to manage the effects of aging."

Section B.2.3.3, "Concrete Containment Unbonded Tendon Prestress," of PTN SLRA states that "[t]he calculation of prestressing losses, predicted upper limits and predicted lower limits for each tendon group is in accordance with the guidelines of the NRC RG 1.35.1." SLRA Section 4.5, "Concrete Containment Tendon Prestress," states that the PLL "force values are developed consistent with the guidance presented in [RG] 1.35.1" and that the PLL force values are "calculated for each tendon prior to the surveillances to estimate the magnitude of th~ tendon relaxation and concrete creep and shrinkage for the given surveillance period."

Issue:

Section 4.5 of PTN SLRA and "Responses to the August 2018 NRC On-Site Regulatory Audit Follow-Up Items," letter dated October 17, 2018 (a voluntary letter to supplement the SLRA based on staffs concerns expressed during the audit) (ADAMS Accession No. ML18292A641) do not state how the PLL and baseline predicted force (BPF) are dispositioned in accordance with 10 CFR 54.21 (c)(1 ). Graphical representation of PLLs in Figures 4.5-1 through 4.5-6 of the SLRA and the "Responses to the August 2018 NRC On-Site Regulatory Audit Follow-Up Items," letter dated October 17, 2018, have the PLL for PTN's horizontal (or hoop), vertical, and dome tendons of PCCs and the alike BPF used in the reactor vessel closure head (RVCH) replacement projects projected as straight lines from the first surveillance to the end of SPEO. It is not clear from the graphs/text how the PLL and BPF are dispositioned in accordance with 10 CFR 54.21 (c)(1) TLAAs. Specifically, whether the analyses:

• Remain valid and bounding through the SPEO (i.e., PLL and/or BPF are dispositioned as 10 CFR 54.21 (c)(1 )(i)); or

• Were revised to be valid through the SPEO (i.e., PLL and/or BPF are dispositioned

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No.4.5-1 L-2019-033 Attachment 2 Page 3 of 4 as 10 CFR 54.21 (c)(1 )(ii)), or

• The aging effects associated with the TLAAs will be managed by an AMP or aging management activities in the same manner as described in the integrated plant assessment in 10 CFR 54.21 (a)(3) during the SPEO (i.e., PLL and/or BPF are dispositioned as 10 CFR 54.21 (c)(1 )(iii)).

Request:

1. Given the itemized acceptance criteria of SRP-SLR for 10 CFR 54.21 (c)(1) identify and explain how:

• PLL TLAAs in Figures 4.5-1 through 4.5-6 of Section 4.5 of the PTN SLRA; and

• BPF TLAAs shown in Figures 4.5-7 through 4.5-10 in "Responses to the August 2018 NRC On-Site Regulatory Audit Follow-Up Items," letter dated October 17, 2018, are dispositioned in accordance with the requirements of 10 CFR 54.21(c)(1) and 10 CFR 54.21 (d), as 10 CFR 54.21 (c)(1)(i), (ii), or (iii).

FPL Response:

This response and the responses to RAls B.2.2.3-1, 4.5-2, 4.5-3, and 4.5-4 in this letter supersede the responses in Attachment 8 of Reference 1 for clarity. The conclusions in Reference 1 Attachment 8 remain unchanged in this response. The following responds to RAI 4.5-1:

1. As shown in SLRA Table 4.1-2, the TLAA disposition for Concrete Containment Tendon Prestress is in accordance with 10 CFR 54.21 (c)(1 )(iii) such that the effects of aging on the intended function will be adequately managed for the period of extended operation. SLRA Appendix A section 17.2.1.3 and Appendix B Section B.2.2.3 (sections related to Concrete Containment Unbonded Tendon Prestress AMP) state that loss of containment tendon prestressing forces is a TLAA dispositioned in accordance with 10 CFR 54.21 (c)(1 )(iii). Additionally, SLRA Section 4.5 on page 4.5-3 states that the TLAA disposition is 10 CFR(c)(1)(iii). The Concrete Containment Unbonded Tendon Prestress AMP and ASME Section, XI Subsection IWL AMP will manage the effects of aging related to prestress forces on the containment tendon prestressing system such that the intended function will be adequately managed for the SPEO. The Concrete Containment Unbonded Tendon Prestress AMP is a TLAA aging management program that addresses the adequacy of prestressing forces in unbonded tendons of prestressed concrete containments.

The Concrete Containment Un bonded Tendon Prestress AMP consists of the assessment of measured tendon prestress forces from surveillances performed in accordance with ASME Code Section XI, Subsection IWL through the ASME Section XI, Subsection IWL AMP. FSAR supplement markups for the Concrete Containment Unbonded Tendon Prestress AMP and ASME Section XI, Subsection IWL AMP in accordance with 10 CFR 54.21 (2) are provided in Appendix A sections 17.2.1.3 and

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No.4.5-1 L-2019-033 Attachment 2 Page 4 of 4 17.2.2.31. Therefore, the Concrete Containment Tendon Prestress TLAA (which includes the predicted forces, either PLL or BPF, shown in SLRA Figures 4.5-1 through 4.5-10) is dispositioned in accordance with 10 CFR 54.21 (c)(1) and 10 CFR 54.21(d), as 10 CFR 54.21(c)(1)(iii). The SLRA Section 4.5 description of the TLAA disposition is updated for clarity.

References:

1. f:"PL Letter L-2018-223 to NRC Dated December 14, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review - November 15, 2018 Public Meeting Action Item Responses (ADAMS Accession No. ML18352A885)

Associated SLRA Revisions:

All associated SLRA revisions are in the Associated SLRA Revisions section of the response to RAI 4.5-2 (Attachment 3 to this letter).

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 1 of 43 NRC RAI Letter Nos. ML19032A396 and ML19032A397 Dated February 1, 2019 RAI 4.5-2

Background:

The GALL-SLR Report AMP X.S1, "Concrete Containment Unbonded Tendon Prestress" program description states that the program consists of assessment of measured tendon prestress forces from required examinations performed in accordance with Subsection IWL of the ASME Code,Section XI, as supplemented in 10 CFR 50.55a(b)(2)(viii) and AMP program elements. The GALL-SLR Report AMP X.S1 states that trend lines are constructed based on the guidance provided in the NRC Information Notice (IN) 99-10, Revision 1, "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments." The GALL-SLR Report AMP X.S1 also recommends the use of NRC RG 1.35.1, "Determining Prestressing Forces for Inspection of Prestressed Concrete Containments," for guidance related to calculation of prestressing force losses and predicted forces. IN 99-10 provides guidelines for the construction of regression trend lines and states that for statistically valid results the regression analysis for each group of tendons includes individual lift-off forces of sampled tendons during surveillances.

PTN's CISI program complies with ASME Code Section XI, Subsection IWL, 2007 Edition through 2008 Addenda, which requires separation of PCC tendons from the overall population of tendons subject to examination when they are affected by repair/replacement activities. In accordance with the Code, affected tendons are to be subjected to the augmented examination requirements of IWL-2521.2 initiating one year after the repair/replacement activity as delineated in Table IWL-2521-2, "Augmented Examination Requirements Following Post-Tensioning System Repair/Replacement Activities," (Item L2.10 "Tendon") and as specified in Table IWL-2500-1, "Examination Category L-B, Unbonded Post-Ten$ioning System. Tendons unaffected by repair/replacement activities should satisfy the requirements as presented in Table IWL 2500-1. Hence, for PCCs subjected to repair/replacement activities the Code requires examinations for two populations of tendons: (a) those that are not affected by the repair/replacement activities (i.e., original unaffected tendons), and (b) those that are affected. Consistent with the above program description of GALL-SLR Report AMP X,S1, PTN SLRA Section B.2.3.3 states:

The adequacy of the prestressing force for each tendon group based on type (i.e., hoop, vertical, and dome) and other considerations (e.g., geometric dimensions, whether affected by repair/replacement, etc.) establishes (a) acceptance criteria in accordance with Subsection IWL and (b) trend lines constructed based on the guidance provided in NRC IN 99-10 (Reference B.3.44), "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments." The calculation of prestressing losses, predicted upper limits and predicted lower limits for each tendon group is in accordance with the

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRG RAI No. 4.5-2 L-2019-033 Attachment 3 Page 2 of 43 guidelines of the NRG RG 1.35.1 (Reference B.3.18), "Determining Prestressing Forces or Inspection of Prestressed Concrete Containments."

Issue:

The staff noted that a 2004 (Unit 3) and 2005 (Unit 4) RVCH replacement required PTN PCC ~utouts and reinstallation/replacement of a number of horizontal (or hoop) and vertical tendons. By letter dated October 17, 2018 (ADAMS Accession No.

ML18292A641 ), the applicant supplemented SLRA Section 4.5 to provide information regarding monitoring time dependent characteristics of the tendons affected by the RVCH replacement PCC cutouts and also to add new Figures 4.5-7 through 4.5 10.

The supplemental figures show, for the affected tendons, the minimum required value (MRV) line and the SPF as the lower bound tendon prestress force line in accordance with RG 1.35.1. These lines are supplemented with sporadic tendon lift-off force data results for tendons that were repaired or replaced, with some plots limited to just a single year of affected tendon lift-off force results. In addition, while PTN RVCH replacement took place 32 years after the start of reactor operations for each unit, with containment repairs completed one year apart at each unit, reported data in Figures 4.5-7 through 4.5-10 indicate the MRV and BPF lines extending from years one and five to fifty years of reactor operation. It is not clear whether the referenced figures' x-axes relate to the time span from the initial surveillance at the start of reactor operations or to the time from retensioning of repaired/replaced tendons to the end of SPEO. It is also not clear why Figures 4.5-7 and 4.5-9 indicate that initial augmented examination for Unit 3 took place about five years after that of Unit 4 shown in Figures 4.5-8 and 4.5-10, when it was reported that completion of RVCH repair/replacement activities for the two units was one year apart. The results of augmented examinations for both are discussed in staff audited PTN PSC-TP-N981-508 "Final Report for the 35th year containment IWL inspection - 35th year tendon surveillance at Turkey Point," dated May 25, 2007. In addition, it is not clear how plots containing a single year lift-off force data can be used for the IN 99-10 recommended trending so that there is reasonable assurance the structural integrity of PCCs with cutouts can be maintained through the end of the SPEO.

Request:

1. For information provided in SLRA Figures 4.5-7 through 4.5-10 clarify: (i) whether referenced years relate to surveillance at the start of reactor operations or to that of retensioning the repaired/replaced tendons and (ii) the time discrepancy in performance of augmented examinations shown in SLRA Supplement Section 4.5 figures versus those reported in the 35th year of PTN PSC-TP-N981-508, relevant to PTN RVCH repair/replacement activities.

2. Provide Tables of non-normalized initial tendon prestress lock-off forces and of subsequent non-normalized augmented examinations lift-off force data for the replaced or repaired vertical and horizontal (or hoop) tendons associated with the PCC RVCH cutouts. Indicate years of examination.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 3 of 43

3. Update as necessary TLAA Figures 4.5-7 through 4.5-10 showing the MRV for horizontal (or hoop) and vertical prestress tendons extended through the end of SPEO. Provide trend lines for non-normalized lift off force data reported in request

2. If regression analysis for trend.ing is not performed in accordance with IN 99-10 (using non-normalized initial lock-off and lift-off forces of the randomly selected tendons from the pool of the affected horizontal and vertical repaired or replaced sampled prestressed tendons), provide justification.

FPL Response:

This response (along with RAI responses B,2.2.3-1, 4.5-1, 4.5-3, and 4.5-4 in Attachments 1, 2, 4, and 5 to this letter) supersede Attachment 8 of FPL's December 14, 2018 response (Reference 3) for clarity. The conclusions in Reference 3 Attachment 8 were carried forward and remain unchanged in this response. The following numbered responses correspond to the numbered requests above:

1.(i) The Unit 3 reactor vessel channel head (RVCH) replacement occurred in 2004 and the Unit 4 RVCH replacement occurred in 2005. The 35th Year Unit 3 and Unit 4 Tendon Surveillances occurred in 2007. Therefore, all data is related to age of tendon after replacement and retensioning. SLRA Figures 4.5-7 through 4.5-10 are updated to indicate data points related to the Tendon Surveillance interval.

Additionally, SLRA Tables 4.5-7 through 4.5-10 are added to clarify the year of examination that correlates with each Tendon Surveillance interval. For the tendons related to the RVCH replacement, the inspected tendon and examination year for each surveillance interval were obtained from the Final Report for each surveillance (References 4, 5, 6).

1.(ii) Unit 3 and Unit 4 RVCH replacement augmented scope tendons were physically inspected during the 35\h, 40th, and 45th Year Tendon Surveillances. SLRA Tables 4.5-7 through 4.5-10 are added to clarify the tendon inspection data and include all physical inspections,. and to include the initial tendon prestress lockoff forces which occurred in 2004 for Unit 3 and 2005 for Unit 4. SLRA Figures 4.5-7 through 4.5-10 are also updated to clarify any time discrepancy in performance of augmented scope surveillances by including all Unit 3 and Unit 4 tendon liftoff forces from the 35th, 40th, and 45th Year Tendon Surveillances. The inspected RVCH replacement tendon and original lock-off force for each surveillance interval were obtained from the Final Report for each surveillance (References 4, 5, 6).

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRG RAI No. 4.5-2 L-2019-033 Attachment 3 Page 4 of 43

2. SLRA Tables 4.5-1 through 4.5-4 are added to include the non-normalized initial tendon prestress lock-off forces which occurred in 2004 for Unit 3 and 2005 for Unit 4, and the subsequent non-normalized augmented examination liftoff force data.

These tables also clarify the year of examination that correlates with each Tendon Surveillance interval. The Normalization Factors are meant to take into account the effects of variation in original seating force as well as the effects of elastic shortening during installation of the tendons (Reference 8). The effects of elastic shortening due to the sequence of the original tendon stressing and the secondary effects of tendons stressed in other directions are considered negligible due to the large amount of time between the two stressing periods and the small percentage of containment area that has been affected. Therefore, the normalized factor is not applied to the average tendon liftoff forces. SLRA Figures 4.5-7 through 4.5-10 are also updated to reflect the non-normalized RVCH replacement augmented scope data included in the tables. The inspected RVCH tendon original lock-off force, surveillance liftoff forces, and examination year for each surveillance interval were obtained from the Final Report for each surveillance (References 4, 5, 6). Note that the average liftoff force value listed in SLRA Tables 4.5-7 through 4.5-10 for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon group. The time t and t1 for each surveillance interval is determined from the tendon selection document for each surveillance (Reference 7, 8, 9), and the BPF is calculated based on the respective equation listed in Section 8.1.16 of References 5 and 6.

3. SLRA Figures 4.5-7 through 4.5-10 are updated as necessary to reflect the above requests. The figures also show the MRV extended through the end of the SPEO as well as the trend lines for the non-normalized liftoff force data performed in accordance with IN 99-10. The MRV for each tendon type is determined from the tendon selection document for each surveillance (Reference 7, 8, 9). Any upward regression analysis trendline bias is due to the relatively low number of three surveillances (the Unit 3 and Unit 4 RVCH replacement augmented scope tendons were inspected during the 35th, 401h, and 45th Year IWL Tendon Surveillances), and the surveillance of random tendons at each surveillance interval rather than the same tendons.

References:

1. FPL Letter L-2018~176 to NRC Dated October 17, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application, Response to NRC On-Site Regulatory Audit Follow Up Items (ADAMS Accession No. ML18292A641)

2. FPL Letter L-2018-191 to NRC Dated November 28, 2018, Turkey Points Units 3 and 4 Subsequent License Renewal Application Safety Review Request for Additional Information (RAI) Set 7 Responses (ADAMS Accession No.

ML18334A182)

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 5 of 43

3. FPL Letter L-2018-223 to NRC Dated December 14, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review - November 15, 2018 Public Meeting Action Item Responses (ADAMS Accession No. ML18352A885)

4. PTN/PSC-TP-N981-508, Revision 0, Final Report for the 35th Year Containment IWL Inspection

5. REP-1076-510, Revision A, Final Report for the 4oth Year Tendon Surveillance at Turkey Point

6. REP-1130-510, Revision 0, Final Report for the 45th Year Tendon Surveillance at Turkey Point

7. PTN/PSC-TP-N981-501, Revision 1, Tendon Selection, Normalization and Lift-off Criteria for the 35th Year Containment Tendon Surveillance

8. PTN/PSC-TP-N1075-501, Revision 0, Tendon Selection and Predicted Forces for the 40th Year IWL Containment Tendon Surveillance

9. PTN/PSC-REP-1130-501, Revision 0, Tendon Selection and Predicted Forces for the 45th Year IWL Containment Tendon Surveillance Associated SLRA Revisions:

SLRA Section 4.5, 17.2.1.3, and B.2.2.3 are amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions. The SLRA revisions below incorporate the SLRA revisions related to RAI responses B.2.2.3-1, 4.5-1, 4.5-2, 4.5-3, and 4.5-4. The SLRA revisions to SLRA Section 4.5 supersede those provided in Attachment 8 of L-2018-223 (Reference 3). The SLRA revisions to SLRA Sections 17.2.1.3 and B.2.2.3 supplement those provided in Attachment 3 of L-2018-176 (Reference 1) and Attachment 12 of L-2018-191 (Reference 2).

Unrelated SLRA revisions are made to Sections 17.2.1.3 and B.2.2.3 by L-2018-176 (Reference 1). These revisions are related to OE associated with the Turkey Point Concrete Containment Un bonded Tendon Prestress AMP. Additionally, unrelated revisions are made to Section B.2.2.3 by L-2018-191 Attachment 12. The SLRA revisions are related to clarifications based on the implementation of the 2007 edition with 2008 addenda (SLRA Reference B.2.3.122) to the ASME Section XI for the current 50th year interval of the Turkey Point ASME Section XI Subsection IWL AMP.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 6 of 43 Revise the TLAA Description in Section 4.5 on page 4.5-1 as follows:

TLAA Description The Turkey Point Units 3 and 4 containment buildings are post-tensioned, reinforced concrete structures composed of vertical cylinder walls and a shallow dome, supported on a conventional reinforced concrete base slab. The cylinder walls are provided with vertical tendons and horizontal hoop tendons. The dome is provided with three groups of tendons oriented 120-degrees apart.

Over time, the containment prestressing forces decrease due to relaxation of the steel tendons and due to creep and shrinkage of the concrete. The containment tendon prestressing forces were calculated during the original design considering the magnitude of the tendon relaxation and concrete creep and shrinkage over the 40-year life of the plant. The Concrete Containment Unbonded Tendon Prestress AMP (Section 8.2.2.3) and ASME Section XI, Subsection IWL AMP (Section B.2.3.31) perform periodic surveillances of individual tendon prestressing values. Predicted lmNer limit fP-b-bj force values are calculated for each tendon prior to the surveillances to estimate the magnitude of the tendon relaxation and concrete creep and shrinkage for the given surveillance period. The prestressing forces are measured and plotted, and trend lines are developed, to ensure the average tendon group prestressing values remain above the respective minimum required values (MRVs) until the next scheduled surveillance.

The predicted lm.ver limit force values and regression analyses, utilizing actual measured tendon forces, are used to evaluate the acceptability of the containment structure to perform its intended function over the current 60-year life of the plant, and therefore, are TLAAs requiring evaluation for the SPEO.

The PTN Unit 3 and Unit 4 Reactor Vessel Closure Head (RVCH) replacements required a temporary containment access opening for each unit consisting of the removal and later replacement of a section of the containment structure walls.

The Unit 3 and Unit 4 tendons affected by the RVCH replacements are considered as augmented scope tendons and are analyzed separately from the Unit 3 and Unit 4 tendons for SLR. Since the Unit 3 and Unit 4 tendons affected by the RVCH replacements are considered as augmented scope, the RVCH tendons are considered with a separate regression analysis than those in the original scope.

Revise the TLAA Evaluation in Section 4.5 on page 4.5-1 and 4.5-2:

TLAA Evaluation The prestress of containment tendons decreases over time as a result of seating of anchorage losses, elastic shortening of concrete, creep of concrete, shrinkage of concrete, relaxation of prestressing steel, and friction losses. At the time of initial licensing, the magnitude of the prestress losses throughout the life of the plant was predicted and the estimated final effective preload at the end of 40 years was calculated for each tendon type. The final effective preload was then compared with the minimum required preload to confirm the adequacy of the design. The estimated final effective prestressing force at the end of plant life was projected to 60 years during the original

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 7 of 43 license renewal process. Described below is the summary of the evaluation for 80 years.

Predicted Lower Limit (PLL)

The containment tendon prestressing force values were calculated during the original design of the containment structure to determine the initial prestressing force required for each tendon group such that the prestressing force woul_d remain above the respective MRVs over the 40-year life of the plant. The initial tendon prestressing force was calculated for each tendon type to compensate for the steel tendon relaxation losses and concrete creep and shrinkage so that the estimated final effective tendon prestressing force at the end of the 40 years would be higher than the minimum required values (MRVs). The estimated final effective prestressing force was extended to 60 years during the original license renewal process. As part of the ASME Section XI, Subsection IWL AMP (Section B.2.3.31) inspections related to tendon examinations, PLL force values are calculated for each individual tendon scheduled for examination, for the given surveillance year. The PLL force values ara~ developed consistent with the guidance presented in Regulatory Guide 1.35.1 (Reference 4.5.1.1 ). Actual measured values for each tendon arawere compared to their respective PLL values, with acceptance criteria consistent with ASME Section XI, Subsection IWL requirements.

Baseline Predicted Force (BPF)

Acceptability of the RVCH tendons is based on comparing the regression of the surveillance data to the BPF and MRV. As an alternative to the PLL, Reg. Guide 1.35.1 allows for the use of the expected force based directly on plant design losses. It states, "In lieu of the variations [for concrete shrinkage, concrete creep, and steel relaxation], the designer may use the conservatively estimated design values for the time-dependent factors." The "actual" predicted prestress force will always be greater than the PLL. Using this method, the RVCH-affected tendon's Predicted Force uses the actual expected losses listed in PTN UFSAR, Section 5.1.4.4, and does not consider the tolerance allowance of Reg. Guide 1.35.1. The calculation of a tendon's individual Predicted Force, which is used as the final acceptance criteria for that tendon, begins with the calculation of the Baseline Predicted Force (BPF) described in Reg. Guide 1.35.1. The BPF considers the expected stress losses for the type of tendon and the time period over which the losses occur for each specific tendon. Equations are generated to calculate the expected force for any tendon at any particular time after installation. The BPF will be used in constructing the lower bound of all tendon prestress forces for tendon liftoff force evaluation during the SPEO.

Regression Analysis A regression analysis is developed for each of the three tendon groups to determine the trend over time in prestressing values of individual tendons within each tendon group.

The regression analysis consists of a trend line utilizing actual individual tendon

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 8 of 43 prestressing forces measured during successive ASME Section XI, Subsection IWL surveillances, consistent with NRC Information Notice 99-10, Attachment 3 (Reference 4.5.1.2). The trend lines are periodically updated with new tendon prestressing force data following each surveillance. The trend lines are used to demonstrate that the average group prestressing forces will remain above the group MRV until the next scheduled surveillance, and potentially for the life of the plant.

Assessment The regression analyses associated with the tendons have been reanalyzed to extend the trend lines from 60 years to 80 years. The extended trend lines have been calculated using individual tendon prestressing force values based on data incorporating the latest surveillances for Turkey Point Units 3 and 4 in 2017. In all cases, the regression analyses predict the prestressing forces will remain above the respective group MRVs through the SPEO.

The PLL methodology was used for tendon acceptance criteria at Turkey Point from the 15th surveillance year to the 35th surveillance year. The BPF methodology was used for tendon acceptance criteria at Turkey Point for the 4Qth and 45th surveillance years. The BPF methodology will be used going forward through the SPEC to ensure there is no loss of intended function. Both methodologies are acceptable according to Reg. Guide 1.35.1.

Figures 4.5-1 through 4.5-6 contain the reanalyzed regression analyses for each tendon group at PTN. Figures 4.5-1 through 4.5-6 provide a graphic representation of the PLL for horizontal (or hoop), dome, and vertical tendons through the SPEO.

Extended trend lines have been developed for all tendons within the respective group, including the control tendons (also referred to as common or historical tendons), and plotted with the MRVs (also referred to minimum prestressing force) over the 80-year period. The predicted lower limit force values and regression analyses, utilizing actual measured tendon forces, are also plotted to evaluate the acceptability of the containment structure to perform its intended function, and therefore, are TLAAs requiring evaluation for the SPEO. The control tendon (also referred to as common or historical tendon) for each regression analysis for the 20th through the 45th surveillance years are differentiated in Figures 4.5-1 through 4.5-6.

Figures 4.5-7 through 4.5-10 contain the reanalyzed regression analysis for the tendon groups affected by the RVCH replacements. Figures 4.5-7 through 4.5-10 use the BPF as best estimate for time dependent horizontal (or hoop) and vertical prestress tendon force losses for RVCH replacement tendons. The surveillance data is plotted with the MRVs over the 80-year period. The number of tendons selected for the augmented RVCH scope is defined by IWL2521.2 and Table IWL-2521-2.

The Concrete Containment Unbonded Tendon Prestress AMP (Section 8.2.2.3) will monitor and manage the TLAA and the associated loss of tendon prestressing forces

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 9 of 43 during the SPEO. The regression analyses are periodically updated following successive surveillances to ensure that estimated valuestrend lines indicate that actual forces will remain above the MRVs until the next scheduled surveillance, and potentially for the life of the plant. Individual measured tendon prestressing forces will be compared to predicted PLLpredicted force values and trend lines developed for the SPEO.

New upper limit curves, lower limit curves,predicted force lines and trend lines of measured prestressing forces have beenwill be established for all tendons through the SPEO as part of the Concrete Containment Unbonded Tendon Prestress AMP (Section B.2.2.3). The predicted final effective preloadforce at the end of 80 years exceeds the minimum required preloadvalue for all containment tendons.

Consequently, the post-tensioning system will continue to perform its intended function throughout the SPEO.

TLAA Disposition: 10 CFR 54.21(c)(1)(iii)

The concrete containment tendon prestress analysis has been projected to the end of the SPEO. Additionally, the Concrete Containment Unbonded Tendon Prestress AMP (Section B.2.2.3) and ASME Section XI, Subsection IVVL AMP (Section B.2.3.31) will manage the effects of aging related to prestress forces on the containment tendon prestressing system so that the intended function will be adequately managed for the SPEO.

The Concrete Containment Unbonded Tendon Prestress AMP (Section 8.2.2.3) is a TLAA aging management program that addresses the adequacy of prestressing forces in unbonded tendons of prestressing concrete containments. The Concrete Containment Unbonded Tendon Prestress AMP (Section 8.2.2.3) consists of the assessment of measured tendon prestress forces from surveillances performed in accordance with ASME Code Section XI, Subsection IWL through the ASME Section XI, Subsection IWL AMP (Section 8.2.3.31 ).

Therefore, the Concrete Containment Tendon Prestress TLAA (which includes the predicted tendon forces, either PLL or 8PF, shown in Figures 4.5-1 through 4.5-

10) is dispositioned in accordance with 10 CFR 54.21(c)(1) and 10 CFR 54.21(d),

as 10 CFR 54.21(c)(1)(iii). The effects of aging on the post-tensioning intended function will be adequately managed by the Concrete Containment Unbonded Tendon Prestress AMP and ASME Section, XI Subsection IWL AMP throughout the SPEO in accordance with 10 CFR 54.21(c)(1}(iii}.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 10 of 43 Revise Tables 4.5-1, 2, 3, 4, 5, 6, 7, 8, 9, 10 as follows:

Table 4.5-1 Unit 3 Hoop Tendons Predicted Nominal Average Predicted Predicted Tendon Year Liftoff MRV Lower Limit Upper Limit Year Tendon( 3> Force (Surveillance Force(4l (kips) (PLL) (PUL)

(PTF)

Year) (kips) (kips) (kips)

(kips) 42H70 619.94 491.60 615.58 590.22 635.04 1972 1st Year(2l 64H50 610.22 491.60 615.58 590.22 635.04 62H18 605.00 491.60 615.58 590.22 635.04 42H70 672.74 491.60 599.42 570.81 621.37 1974 3rd Year(2l 62H18 690.58 491.60 599.42 570.81 621.37 64H50 685.48 491.60 599.42 570.81 621.37 62H18 715.13 491.60 591.91 561.79 615.01 64H50 647.36 491.60 591.91 561.79 615.01 1977 5th Year(2l 64H51 732.37 491.60 591.91 561.79 615.01 42H70 714.92 491.60 591.91 561.79 615.01 62H18 712.48 491.60 581.71 549.55 606.39 1982 10th Year(2l 64H50 675.16 491.60 581.71 549.55 606.39 42H70 716.94 491.60 581.71 549.55 606.39 42H70 698.10 491.60 575.75 542.39 601.34 62H18 661.00 491.60 575.75 542.39 601.34 1988 15th Year(2l 64H50 657.50 491.60 575.75 542.39 601.34 13H47 598.90 491.60 575.75 542.39 601.34 13H29 607.30 491.60 571.52 537.30 597.76 13H32 614.65 491.60 571.52 537.30 597.76 13H33 578.10 491.60 571.52 537.30 597.76 13H34 610.30 491.60 571.52 537.30 597.76 42H9 643.00 491.60 571.52 537.30 597.76 42H31 575.80 491.60 571.52 537.30 597.76 42H32 576.30 491.60 571.52 537.30 597.76 1992 20th Year 42H33 600.75 491.60 571.52 537.30 597.76 35H51 589.30 491.60 571.52 537.30 597.76 35H52 577.85 491.60 571.52 537.30 597.76 35H53 581.75 491.60 571.52 537.30 597.76 64H60 575.60 491.60 571.52 537.30 597.76 64H61 563.40 491.60 571.52 537.30 597.76 64H62 565.10 491.60 571.52 537.30 597.76 51H18(1l 612.05 491.60 571.52 537.30 597.76

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 11 of 43 Predicted Nominal Average Predicted Predicted Tendon Year Tendon(3l Liftoff MRV Lower Limit Upper Limit Year Force (Surveillance Force(4l (kips) (PLL) (PUL)

(PTF)

Year) (kips) (kips) (kips) ki s 13H31 635.10 491.60 568.23 533.36 594.99 13H35 635.25 491.60 568.23 533.36 594.99 35H32 588.10 491.60 568.23 533.36 594.99 35H40 618.05 491.60 568.23 533.36 594.99 42H40 605.75 491.60 568.23 533.36 594.99 1996 25th Year 42H71 608.10 491.60 568.23 533.36 594.99 51H18( 1l 629.10 491.60 568.23 533.36 594.99 62H79 636.95 491.60 568.23 533.36 594.99 64H19 578.70 491.60 568.23 533.36 594.99 64H24 598.25 491.60 568.23 533.36 594.99 42H30 587.00 491.60 565.55 530.14 592.72 51H18( 1l 611.40 491.60 565.55 530.14 592.72 2001 30th Year 51H21 620.70 491.60 565.55 530.14 592.72 62H43 560.00 491.60 565.55 530.14 592.72 64H22 582.10 491.60 565.55 530.14 592.72 42H26 578.53 491.60 561.32 525.06 589.14 51 H11 644.24 491.60 561.32 525.06 589.14 2012 40th Year 51H18( 1l 612.66 491.60 561.32 525.06 589.14 51H28 599.55 491.60 561.32 525.06 589.14 62H21 596.50 491.60 561.32 525.06 589.14 2022 50th Year 491.60 558.04 521.12 586.36 2032 60th Year 491.60 555.36 517.90 584.09 2042 70th Year 491.60 553.09 515.18 582.18 2052 80th Year 491.60 551.12 512.82 580.52 Notes:

(1) Control Tendon (2) The 1st -15th Year Surveillances consist of ~reselected tendons. All other surveillances are randomll£ selected tendons.

(3) Tendons affected bl£ the RVCH re~lacement modification are listed in Tables 4.5-7 through 4.5-10.

(4) The average liftoff force value listed for each tendon re~resents the average of the actual measured liftoff force where two stressing l;!'oints exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon groul;!.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 12 of 43 Table 4.5-2 Unit 4 Hoop Tendons Nominal Predicted Average Predicted Predicted Year MRV Tendon Year Tendon(3> Liftoff Force(4 > Lower Limit Upper Limit (Surveillance (kips) Force (kips) (PLL) (kips) (PUL) (kips)

Year) (PTF) (kips) 13H15 641.36 491.60 615.58 590.22 635.04 1973 1st Year<2> 51H50 644.08 491.60 615.58 590.22 635.04 35H70 671.08 491.60 615.58 590.22 635.04 13H38 652.25 491.60 599.42 570.81 621.37 1975 3rd Year<2> 42H57 636.68 491.60 599.42 570.81 621.37 64H70 634.77 491.60 599.42 570.81 621.37 42H80 691.32 491.60 591.91 561.79 615.01 1977 5th Year<2 > 62H38 660.88 491.60 591.91 561.79 615.01 64H70 682.74 491.60 591.91 561.79 615.01 42H80 660.69 491.60 581.71 549.55 606.39 1982 10th Year<2 > 62H38 642.12 491.60 581.71 549.55 606.39 64H70 637.65 491.60 581.71 549.55 606.39 42H80 610.70 491.60 575.75 542.39 601.34 62H38 582.90 491.60 575.75 542.39 601.34 64H70 595.80 491.60 575.75 542.39 601.34 13H48 586.80 491.60 575.75 542.39 601.34 1988 15th Year<2 >

13H49 583.10 491.60 575.75 542.39 601.34 13H50 581.60 491.60 575.75 542.39 601.34 15H51 584.20 491.60 575.75 542.39 601.34 15H52 607.10 491.60 575.75 542.39 601.34 13H54 581.45 491.60 571.52 537.30 597.76 13H53 581.10 491.60 571.52 537.30 597.76 13H55 581.65 491.60 571.52 537.30 597.76 35H38 550.25 491.60 571.52 537.30 597.76 1992 20th Year 35H39 550.20 491.60 571.52 537.30 597.76 35H40 559.75 491.60 571.52 537.30 597.76 35H41 548.40 491.60 571.52 537.30 597.76 35H42 558.05 491.60 571.52 537.30 597.76 51H48 571.70 491.60 571.52 537.30 597.76 13H32 619.70 491.60 568.23 533.36 594.99 13H37 608.40 491.60 568.23 533.36 594.99 1996 25th Year 35H20 585.80 491.60 568.23 533.36 594.99 35H79 627.80 491.60 568.23 533.36 594.99 42H30 580.90 491.60 568.23 533.36 594.99

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 13 of 43 Nominal Predicted Average Predicted Predicted Year MRV Tendon Year 3 Tendon< l Liftoff Force<4l Lower Limit Upper Limit (Surveillance (kips) Force (kips) (PLL) (kips) (PUL) (kips)

Year) (PTF) (kips) 51H19 622.30 491.60 568.23 533.36 594.99 51H42 594.50 491.60 568.23 533.36 594.99 62H54 573.80 491.60 568.23 533.36 594.99 62H82< 1l 638.55 491.60 568.23 533.36 594.99 13H70 587.75 491.60 563.28 527.42 590.80 35H34 558.82 491.60 563.28 527.42 590.80 2007 35th Year 42H31 552.71 491.60 563.28 527.42 590.80 42H32 540.43 491.60 563.28 527.42 590.80 62H82< 1l 619.16 491.60 563.28 527.42 590.80 13H16 593.45 491.60 559.59 522.98 587.67 15H12 588.63 491.60 559.59 522.98 587.67 2017 45th Year 62H28 570.79 491.60 559.59 522.98 587.67 62H82< 1l 630.36 491.60 559.59 522.98 587.67 64H17 568.70 491.60 559.59 522.98 587.67 2027 55th Year 491.60 556.64 519.43 585.18 2037 65th Year 491.60 554.18 516.48 583.10 2047 75th Year 491.60 552.07 513.96 581.32 2052 80th Year 491.60 551.12 512.82 580.52 Notes:

{1) Control Tendon. The Unit 4 hoop control tendon for the 20th year surveillance is not shown since the initial control tendon selection in the 20th year was revised due to difficult access.

{2) The 1st -15th Year Surveillances consist of preselected tendons. All other surveillances are randomly selected tendons.

{3) Tendons affected by the RVCH replacement modification are listed in Tables 4.5-7 through 4.5-10.

{4) The average liftoff force value listed for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon group.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 14 of 43 Table 4.5-3 Unit 3 Dome Tendons Nominal Average Predicted Predicted Predicted Year Liftoff MRV Tendon Lower Limit Year Tendon(3l Upper Limit (Surveillance Force(4l (kips) Force (PTF) (PLL)

(PUL) (kips)

Year) (kips) (kios) (kips) 1027 645.08 531.00 615.58 590.22 635.04 2028 . 585.60 531.00 615.58 590.22 635.04 3028 609.80 531.00 615.58 590.22 635.04 1015 635.07 531.00 615.58 590.22 635.04 1018 625.25 531.00 615.58 590.22 635.04 1036 614.97 531.00 615.58 590.22 635.04 1972 1st Year(2l 2011 645.01 531.00 615.58 590.22 635.04 2021 609.85 531.00 615.58 590.22 635.04 2024 630.16 531.00 615.58 590.22 635.04 304 625.17 531.00 615.58 590.22 635.04 3021 590.09 531.00 615.58 590.22 635.04 3024 619.81 531.00 615.58 590.22 635.04 1015 723.12 531.00 599.42 575.37 621.37 1018 713.38 531.00 599.42 575.37 621.37 1027 717.20 531.00 599.42 575.37 621.37 1036 710.65 531.00 599.42 575.37 621.37 2011 666.30 531.00 599.42 575.37 621.37 2021 702.39 531.00 599.42 575.37 621.37 1974 3rd Year(2l 2024 687.45 531.00 599.42 575.37 621.37 2028 720.69 531.00 599.42 575.37 621.37 304 716.26 531.00 599.42 575.37 621.37 3021 682.11 531.00 599.42 575.37 621.37 3024 714.39 531.00 599.42 575.37 621.37 3028 710.16 531.00 599.42 575.37 621.37 1053 695.25 531.00 591.91 568.47 615.01 1977 5th Year(2l 2028 732.87 531.00 591.91 568.47 615.01 3028 730.37 531.00 591.91 568.47 615.01 1053 755.08 531.00 581.71 559.10 606.39 1982 10th Y ear(2l 2028 775.26 531.00 581.71 559.10 606.39 3028 755.23 531.00 581.71 559.10 606.39 1053 729.40 531.00 575.75 553.62 601.34 1988 15th Year(2l 2028 731.80 531.00 575.75 553.62 601.34 3028 728.50 531.00 575.75 553.62 601.34 1050 634.05 531.00 571.52 549.73 597.76 1992 2oth Year 209 640.70 531.00 571.52 549.73 597.76

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 15 of 43 Nominal Average Predicted Predicted Predicted Year 3 Liftoff MRV Tendon Lower Limit Year Tendon< > Upper Limit (Surveillance Force<4> (kips) Force (PTF) (PLL)

(PUL) (kips)

Year) (kips) . (kips) (kips) 308< 1> 665.10 531.00 571.52 549.73 597.76 108 684.20 531.00 568.23 546.72 594.99 1051 683.60 531.00 568.23 546.72 594.99 1996 25th Year 203 719.15 531.00 568.23 546.72 594.99 308<1> 717.50 531.00 568.23 546.72 594.99 3016 695.10 531.00 568.23 546.72 594.99 1048 658.10 531.00 565.55 544.26 592.72 2019 591.70 531.00 565.55 544.26 592.72 2001 30th Year 308< 1> 691.70 531.00 565.55 544.26 592.72 3043 650.20 531.00 565.55 544.26 592.72 1012 663.07 531.00 561.32 540.37 589.14 2054 679.87 531.00 561.32 540.37 589.14 2012 40th Year 3008< 1> 688.02 531.00 561.32 540.37 589.14 3018 649.78 531.00 561.32 540.37 589.14

. 2022 50th Year 531.00 558.04 537.35 586.36 2032 60th Year 531.00 555.36 534.89 584.09 2042 70th Year 531.00 553.09 532.80 582.18 2052 80th Year 531.00 551.12 531.00 580.52 Notes:

(1} Control Tendon (2} The 1st -15th Year Surveillances consist of Qreselected tendons. All other surveillances are randomly selected tendons.

(3} Tendons affected by the RVCH reQlacement modification are listed in Tables 4.5-7 through 4.5-10.

(4} The average liftoff force value listed for each tendon reQresents the average of the actual measured liftoff force where two stressing Qoints exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon grouQ.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 16 of 43 Table 4.5-4 Unit 4 Dome Tendons Average Predicted Nominal Year Predicted Predicted Liftoff MRV Tendon Year (Surveillance Tendon<3l Lower Limit Upper Limit Force<4l (kips) Force (PTF)

Year) (PLL) (kips) (PUL) (kips)

(kips) (kips) 1028 663.45 531.0 615.58 590.22 635.04 2

1973 1st Year< l 2028 661.90 531.0 615.58 590.22 635.04 3028 653.19 531.0 615.58 590.22 635.04 1028 688.49 531.0 599.42 575.37 621.37 1975 3rd Year<2l 2014 646.02 531.0 599.42 575.37 621.37 3028 659.45 531.0 599.42 575.37 621.37 1028 712.89 531.0 591.91 568.47 615.01 1977 5th Year<2l 203 703.06 531.0 591.91 568.47 615.01 3028 713.99 531.0 591.91 568.47 615.01 1028 694.98 531.0 581.71 559.1 O 606.39 1982 10th Y ear<2l 203 671.11 531.0 581.71 559.10 606.39 3028 687.64 531.0 581.71 559.10 606.39 1028 670.60 531.0 575.75 553.62 601.34 1988 15th Y ear<2l 2028 648.00 531.0 575.75 553.62 601.34 3028 666.40 531.0 575.75 553.62 601.34 1040 583.15 531.0 571.52 549.73 597.76 1038 602.20 531.0 571.52 549.73 597.76 1992 20th Year 1041 581.60 531.0 571.52 549.73 597.76 3020<1) 604.05 531.0 571.52 549.73 597.76 2024 587.95 531.0 571.52 549.73 597.76 1037 598.80 531.0 568.23 546.72 594.99 202 665.60 531.0 568.23 546.72 594.99 1996 25th Year 2011 638.10 531.0 568.23 546.72 594.99 3020<1) 626.20 531.0 568.23 546.72 594.99 3049 647.95 531.0 568.23 546.72 594.99 2008 633.64 531.0 563.28 542.17 590.80 3020< 1) 619.06 531.0 563.28 542.17 590.80 2007 35th Year 3025 593.88 531.0 563.28 542.17 590.80 3031 603.25 531.0 563.28 542.17 590.80 1030 598.07 531.0 559.59 538.78 587.67 1045 617.33 531.0 559.59 538.78 587.67 2017 45th Year 3020<1) 629.37 531.0 559.59 538.78 587.67 3032 610.10 531.0 559.59 538.78 587.67 2027 55th Year 531.0 556.64 536.06 585.18

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 17 of 43 Average Predicted Nominal Year Predicted Predicted Liftoff MRV Tendon Year (Surveillance Tendon< 3l Lower Limit Upper Limit Force<4l (kips) Force (PTF)

Year) (PLL) (kips) (PUL) (kips)

(kips) (kips) 2037 65th Year 531.0 554.18 533.81 583.10 2047 75th Year 531.0 552.07 531.87 581.32 2052 80th Year 531.0 551.12 531.00 580.52 Notes:

(1} Control Tendon (2} The 1st -15th Year Surveillances consist of preselected tendons. All other surveillances are randomly selected tendons.

(3} Tendons affected by the RVCH replacement modification are listed in Tables 4.5-7 through 4.5-10.

(4} The average liftoff force value listed for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for-a given tendon group.

/

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRG RAI No. 4.5-2 L-2019-033 Attachment 3 Page 18 of 43 Table 4.5-5 Unit 3 Vertical Tendons Nominal Average Predicted Predicted Predicted Year 3 Liftoff MRV Year Tendon< l

• Tendon Force Lower Limit Upper Limit (Surveillance Force<4l (kips)

(PTF) (kips) (PLL) (kips) (PUL) (kips)

Year) (kips) 61V1 619.92 522.00 645.29 627.30 660.24 1973 1st Year<2 J 23V1 609.80 522.00 645.29 627.30 660.24 45V7 619.90 522.00 645.29 627.30 660.24 23V1 670.41 522.00 632.91 612.64 649.79 1975 3rd Year<2J 45V7 645.17 522.00 632.91 612.64 649.79 61V1 670.50 522.00 632.91 612.64 649.79 23V1 695.04 522.00 627.16 605.82 644.93 1977 5th Vear<2 J 45V7 645.45 522.00 627.16 605.82 644.93 61V1 675.80 522.00 627.16 605.82 644.93 23V1 649.60 522.00 619.35 596.57 638.33 1982 10th Year<2 J 45V7 650.40 522.00 619.35 596.57 638.33 61V1 680.72 522.00 619.35 596.57 638.33 12V3 623.20 522.00 614.78 591.16 634.47 23V1 682.90 522.00 614.78 591.16 634.47 1988 15th Year<2 J 45V7 627.60 522.00 614.78 591.16 634.47 61V1 654.30 522.00 614.78 591.16 634.47 61V2 655.00 522.00 614.78 591.16 634.47 12v22<1i 619.60 522.00 611.54 587.32 631.74 34V11 680.00 522.00 611.54 587.32 631.74 1992 20th Year 45V29 629.90 522.00 611.54 587.32 631.74 56V21 657.50 522.00 611.54 587.32 631.74 12V16 640.60 522.00 609.03 584.34 629.61 12v22<1l 665.80 522.00 609.03 584.34 629.61 1996 25th Year 23V30 620.20 522.00 609.03 584.34 629.61 56V13 656.90 522.00 609.03 584.34

• 629.61 61V27 686.70 522.00 609.03 584.34 629.61 12V14 664.40 522.00 606.97 581.91 627.88 12v22<1i 637.90 522.00 606.97 581.91 627.88 12V24 632.20 522.00 606.97 581.91 627.88 2007 30th Year 34V15 638.40 522.00 606.97 581.91 627.88 61V8 658.00 522.00 606.97 581.91 627.88 61V10 632.70 522.00 606.97 581.91 627.88 2017 40th Year 12V17 662.36 522.00 603.73 578.07 625.14

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 19 of 43 Nominal Average Predicted Predicted Predicted Year Liftoff MRV Year Tendon< 3l Tendon Force Lower Limit Upper Limit (Surveillance Force<4l (kips)

(PTF) (kips) (PLL) (kips) (PUL) (kips)

Year) (kips) 12v22<1i 642.22 522.00 603.73 578.07 625.14 34V08 636.42 522.00 603.73 578.07 625.14 56V04 643.00 522.00 603.73 578.07 625.14 2027 50th Year 522.00 601.22 575.09 623.02 2037 60th Year 522.00 599.16 572.66 621.28 2047 70th Year 522.00 597.43 570.60 619.82 2052 80th Year 522.00 595.92 568.82 618.54 Notes:

(1) Control Tendon (2) The 1st -15th Year Surveillances consist of preselected tendons. All other surveillances are randomly selected tendons.

(3) Tendons affected by the RVCH replacement modification are listed in Tables 4.5-7 through 4.5-10.

(4) The average liftoff force value listed for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon group.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 20 of 43 Table 4.5-6 Unit 4 Vertical Tendons Nominal Average Predicted Predicted Predicted Year Liftoff MRV Year Tendon( 3l Tendon Force Lower Limit Upper Limit (Surveillance Force(4l (kips)

(PTF) (kips) (PLL) (kips) (PUL) (kips)

Year) (kips) 12V29 665.53 522.00 645.29 627.30 660.24 1973 1st Year(2l 34V29 670.86 522.00 645.29 627.30 660.24 56V29 655.81 522.00 645.29 627.30 660.24 12V29 725.59 522.00 632.91 612.64 649.79 1975 3rd Year(2l 34V29 694.22 522.00 632.91 612.64 649.79 56V29 705.44 522.00 632.91 612.64 649.79 12V29 714.76 522.00 627.16 605.82 644.93 1977 5th Year(2l 34V29 746.93 522.00 627.16 605.82 644.93 56V29 724.90 522.00 627.16 605.82 644.93 12V29 733.01 522.00 619.35 596.57 638.33 1982 10th Year(2 l 34V29 727.83 522.00 619.35 596.57 638.33 56V29 741.50 522.00 619.35 596.57 638.33 12V29 700.70 522.00 614.78 591.16 634.47 1988 15th Year(2l 34V29 714.90 522.00 614.78 591.16 634.47 56V29 707.70 522.00 614.78 591.16 634.47 12V25 634.70 522.00 611.54 587.32 631.74 12V27 624.25 522.00 611.54 587.32 631.74 12V28 634.70 522.00 611.54 587.32 631.74 1992 20th Year 23V30 633.70 522.00 611.54 587.32 631.74 45V1Q(1l 632.90 522.00 611.54 587.32 631.74 61V12 657.30 522.00 611.54 587.32 631.74 23V2 646.20 522.00 609.03 584.34 629.61 23V23 654.00 522.00 609.03 584.34 629.61 45V10(1l 642.60 522.00 609.03 584.34 629.61 1996 25th Year 45V18 646.50 522.00 609.03 584.34 629.61 45V28 644.90 522.00 609.03 584.34 629.61 61V4 645.80 522.00 609.03 584.34 629.61 34V02 626.17 522.00 605.23 579.85 626.41 34V23 667.01 522.00 605.23 579.85 626.41 2007 35th Year 45V10( 1l 624.67 522.00 605.23 579.85 626.41 45V23 611.87 522.00 605.23 579.85 626.41 23V08 657.67 522.00 602.40 576.50 624.02 2017 45th Year 34V05 622.37 522.00 602.40 576.50 624.02

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 21 of 43 Nominal Average Predicted Predicted Predicted Year Liftoff MRV Year Tendon( 3l Tendon Force Lower Limit Upper Limit (Surveillance Force(4l (kips)

(PTF) (kips) (PLL) (kips) (PUL) (kips)

Year) (kips) 45V10(1l 639.76 522.00 602.40 576.50 624.02 2027 55th Year 522.00 600.14 573.82 622.11 2037 65th Year 522.00 598.26 571.59 620.52 2047 75th Year 522.00 596.65 569.68 619.16 2052 80th Year *522.00 595.92 568.82 618.54 Notes:

(1) Control Tendon (2) The 1st -15th Year Surveillances consist of preselected tendons. All other surveillances are randomly selected tendons.

(3) Tendons affected by the RVCH replacement modification are listed in Tables 4.5-7 through 4.5-10.

(4) The average liftoff force value listed for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon group.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 22 of 43 Table 4.5-7 Unit 3 RVCH Hoo~ Tendons t1, (Time t1, (Time 2004 Nominal Average Stressed at Stressed at Original BPF (calculated Year t, (Time Liftoff MRV Year Tendon Plant License Plant License Lock-off from equation for (Surveillance Stressed) Force< 1l (kips)

Expiration - Expiration - Force 80 year)

Year) (kips) 60 years) 80 years) (kips) 51H35 2.34 26.64 46.64 625.15 597.32 491.6 541.13 2007 35 62H55 2.34 26.64 46.64 634.44 619.38 491.6 541.13 51H40 7.26 26.64 46.64 621.24 599.55 491.6 532.19 2012 40 62H46 7.27 26.65 46.65 632.11 626.23 491.6 532.18 62H44 12.14 26.64 46.64 628.8 595.7 491.6 528.12 2017 45 62H57 12.13 26.64 46.64 625.7 619.7 491.6 528.13 2022 50 17 26.64 46.64 491.6 525.46 2027 55 22 26.64 46.64 491.6 523.43 2032 60 27 26.64 46.64 491.6 521.81 2037 65 32 26.64 46.64 491.6 520.47 2042 70 37 26.64 46.64 491.6 519.32 2047 75 42 26.64 46.64 491.6 518.32 2052 80 47 26.64 46.64 491.6 517.43 Nomenclature:

t, the time period in years between the initial tendon stressing date and the date of tendon inspection liftoff testing t1 1 the period in years between the initial tendon stressing date and the plant license expiration date for hoop and vertical tendons (Note, t1 for the 35th and 50th - soth Surveillance Years was estimated based on the 40th and 45th Surveillance Year reports)

Notes:

(1) The average liftoff force value listed for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon group

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 23 of 43 Table 4.5-8 Unit 4 RVCH HooQ Tendons t1, (Time t1, (Time Nominal Stressed at 2005 Average BPF Age Stressed at Year Plant Original Liftoff MRV (calculated Year Tendon (Time Plant License (Surveillance License Lock-off Force( 1l (kips) from equation Stressed) Expiration -

Year) Expiration - Force (kips) (kips) for 80 year) 60 years) 80 ears) 51H40 1.72 26.75 46.75 634.46 606.06 491.6 543.56 2007 35 62H33 1.72 26.75 46.75 631.99 598.42 491.6 543.56 62H34 1.72 26.75 46.75 629.21 623.37 491.6 543.56 62H35 6.74 26.75 46.75 632.11 596.64 491.6 532.78 62H36 6.74 26.75 46.75 622.98 585.00 491.6 532.78 2012 40 62H44 6.74 26.75 46.75 634.86 618.13 491.6 532.78 62H49 6.74 26.75 46.75 630.9 594.40 491.6 532.78 15H35 11.61 26.75 46.75 626.8 615.96 491.6 528.49 2017 45 15H37 11.61 26.75 46.75 625 601.87 491.6 528.49 2022 50 17 26.75 46.75 491.6 525.48 2027 55 22 26.75 46.75 491.6 523.44 2032 60 27 26.75 46.75 491.6 521.83 2037 65 32 26.75 46.75 491.6 520.48 2042 70 37 26.75 46.75 491.6 519.34 2047 75 42 26.75 46.75 491.6 518.34 2052 80 47 26.75 46.75 491.6 517.45 Nomenclature:

t 1 the time period in )£ears between the initial tendon stressing date and the date of tendon inspection liftoff testing t1 1 the period in )£ears between the initial tendon stressing date and-the plant license expiration date for hoop and vertical tendons {Note 1 t1 for the 35th and 501h- 801h Surveillance Years was estimated based on the 401h and 45th Surveillance Year reports)

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 24 of 43 Notes:

{1) The average liftoff force value listed for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon group.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 25 of 43 Table 4.5-9 Unit 3 RVCH Vertical Tendons t1, (Time t1, (Time Nominal 2004 Averag Stressed at Stressed at SPF Age Original e Year Plant Plant MRV (calculated Year Tendon (Time Lock-off Liftoff (Surveillance License License (kips) from equation Stressed) Force Force( 1l Year) Expiration - Expiration - for 80 year)

(kips) (kips) 60 ears) 80 ears) 12V06 2.34 26.65 46.65 748.6 730.35 522 636.08 2007 35 56V22 2.34 26.65 46.65 758.2 739.63 522 636.08 61V01 2.34 26.65 46.65 753.5 690.5 522 636.08 12V02 7.27 26.65 46.65 738.3 708.27 522 623.82 2012 40 61V13 7.26 26.64 46.64 745.3 737.06 522 623.84 61V20 7.27. 26.66 46.66 755.98 732.43 522 623.83 12V11 12.14 26.65 46.65 746.6 724.5 522 618.28 2017 45 12V14 12.14 26.65 46.65 746.7 729.73 522 618.28 2022 50 17 26.65 46.65 522 614.64 2027 55 22 26.65 46.65 522 611.86 2032 60 27 26.65 46.65 522 609.64 2037 65 32 26.65 46.65 522 607.81 2042 70 37 26.65 46.65 522 606.24 2047 75 42 26.65 46.65 522 604.87 2052 80 47 26.65 46.65 522 603.65 Nomenclature:

t 1 the time 11eriod in )£ears between the initial tendon stressing date and the date of tendon ins11ection liftoff testing t1 1 the 11eriod in )£ears between the initial tendon stressing date and the 11lant license ex11iration date for hoo11 and vertical tendons (Note 1 t1 for the 35th and soth - soth Surveillance Years was estimated based on the 40th and 45th Surveillance Year re11orts}

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 26 of 43 Notes:

{1) The average liftoff force value listed for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon group.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 27 of 43 Table 4.5-10 Unit 4 RVCH Vertical Tendons Nominal t1, (Time t1, (Time 2005 Average BPF Age Stressed at Stressed at Original Year Liftoff MRV (calculated Year Tendon (Time Plant License Plant License Lock-off (Surveillance Force<1> (kips) from equation Stressed) Expiration - Expiration - Force Year) (kips) for 80 year) 60 years) 80 years) (kips) 12V03 1.72 26.75 46.75 749.87 718.23 522 639.41 2007 35 56V20 1.72 26.75 46.75 747.97 715.76 522 639.41 56V30 1.72 26.75 46.75 756.36 671.16 522 639.41 12V09 6.75 26.76 46.76 756.29 761.42 522 624.64 2012 40 56V19 6.74 26.75 46.75 748.38 737.63 522 624.65 61V14 6.74 26.75 46.75 758.42 742.46 522 624.65 56V29 11.62 26.76 46.76 757.6 730.39 522 618.77 2017 45 61V30 11.62 26.75 46.75 752.3 7.12.92 522 618.77 2022 50 17 26.75 46.75 522 614.66 2027 55 22 26.75 46.75 522 611.88 2032 60 27 26.75 46.75 522 609.66 2037 65 32 26.75 46.75 522 607.83 2042 70 37 26.75 46.75 522 606.26 2047 75 42 26.75 46.75 522 604.89 2052 80 47 26.75 46.75 522 603.68 Nomenclature:

t, the time ~eriod in :iears between the initial tendon stressing date and the date of tendon ins~ection liftoff testing t1, the ~eriod in :iears between the initial tendon stressing date and the ~lant license ex~iration date for hoo~ and vertical tendons {Note, t1 for the 35th and 501h- B01h Surveillance Years was estimated based on the 401h and 45th Surveillance Year re~orts}

Notes:

{1} The average liftoff force value listed for each tendon re~resents the average of the actual measured liftoff force where two stressing ~oints exist for the individual tendon not the average value of all tendon liftoff forces for a given tendon grou~.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 28 of 41 Revise Figures 4 .5- 1, 2, 3, 4, 5, 6, 7, 8, 9, 10 as follows:

Figure 4.5-1 Unit 3 Hoop Tendons 1st Through 45th Year Tendon Surveillance 700

680 *************

• • • • • • • *

• 660 ************* I

• • • • • • • • • • • • • • • • • • • • • • • • • • • • *

• 640 620

• • • • • • • • • • • • **

---

***********, ::::.~ ***:********

...( :::::,...*:::,*

Vl

• **

.S80

.:,L.

QJ

~60 LL C

.g40 C

QJ I-520 500 480

+ * * * * * * * * * ***

---

1 10 100 Surveillance Year( 1)

_ . _ Minimum Required Value (MRV)

- . - PTF

- . - PLL

- . - ruL

• Average Liftoff Force (All Tendons)

• Average Liftoff Force (Randomly Selected Tendons)

• Average Liftoff Force (Control Tendons)

• • ******* Log. (Average Liftoff Force (All Tendons)) y = -22 .031n(x) + 682.61

......... Log. (Average Liftoff Force (Randomly Selected Tendons)) y = 18.0651n(x) + 541.82

• • • ** **** Log. {Average Liftoff Force {Control Tendons)) Y = -6.4251n{x) + 637.67 Notes:

(1) After the 25th surveillance year, the liftoff force is only represented for the 30th and 40th year since Turkey Point meets the criteria of Section IWL-2421, which allows the two units alternate between "physical" and "visual" inspections at each surveillance period. Unit 3 underwent a "physical" inspection 30th and 40th surveillance years and will continue every ten years throughout the SPEO.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No . 4 .5-2 L-2019-033 Attachment 3 Page 29 of 41 Figure 4 .5-2 Unit 4 Hoop Tendons 1st Through 45th Year Tendon Surveillance 700

• 680 *

. *

• 660 ******************* *

----------:--------------------------------* . .

.... ,..! ..... .

I ******* * *****

600

• V, 0..

32580 Q) u I...

~560 C

0

-0

~540 f-520 500 480

• * * * * * * * *****

1.0 10.0 100.0 Surveillance Year( 1)

~ Minimum Required Value (MRV)

~ PTF

~ PLL

~ PUL

• Average Liftoff Force (All Tendons)

• Average Liftoff Force (Randomly Selected Tendons)

• Average Liftoff Force (Control Tendons)

......... Log. (Average Liftoff Force (All Tendons)) y = -25.191n(x) + 670.7

......... Log. (Average Liftoff Force (Randomly Selected Tendons)) y = 15.0321n(x) + 533 .96

......... Log. (Average Liftoff Force (Control Tendons)) Y = -16.331n(x) + 686.96 Notes:

(1) After the 25th surveillance year, the liftoff force is only represented for the 35th and 45th year since Turkey Point meets the criteria of Section IWL-2421, which allows the two units alternate between "physical" and "visual" inspections at each surveillance period. Unit 4 underwent a "physical" inspection 35th and 45th surveillance years and will continue every ten years throughout the SPEO.

Turkey Point Units 3 and 4 Docket Nos . 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 30 of 41 Figure 4.5-3 Unit 3 Dome Tendons 3rd Through 45th Year Tendon Surveillance 760 740

• • • • • • • • • • • • • • • I I 720 ****************I

• 700 .*************;****************************** . .....

• • • • • • • • • ~,,.,:. ***

• 680 I *************

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

• • **

660 640 . .

I V,

a.

620

• 600 I e ClJ u

I-0 LL 580 I

• I I I e C

0 560 "O

C ClJ 540 1--

520 500 1 10 100 Surveillance Year ( 1)( 2

-4o- Minimum Required Value (MRV)

-4o- PTF

-4o- PLL

-4o- PUL

• Average Liftoff Forc e (All Tendon s)

• Average Liftoff Force (Randomly Selected Tendons)

• Average Liftoff Force (Control Tendons)

• • • • • • • • • Log. (Average Liftoff Force (All Tendons)) Y = -15.591n(x) + 734.01

• • • • • • • • • Log. (Average Liftoff Force (Randomly Selected Tendons)) y = 0.9581n(x) + 666.29

• • • • • • • • • Log. (Average Liftoff Force (Control Tendons)) y = 18.1731n(x) + 630.13 Notes:

(1) After the 25th surveillance year, the liftoff force is only represented for the 30th and 40th year since Turkey Point meets the criteria of Section IWL-2421. which allows the two units alternate between "physical" and "visual" inspections at each surveillance period. Unit 3 underwent a "physical" inspection 30th and 40th surveillance years and will continue every ten years throughout the SPEO.

(2) The trend line exhibited an unexpected upward bias when considering all liftoff forces. The upward bias was due to the relatively high liftoff values recorded during the 3rd year vs the 1st year which is attributed to the restres- sing operation performed as a result of the Unit 3 dome concrete repair after the 1st year surveillance. Therefore, the 1st year surveillance dome tendons are not statistically relevant and are not considered in the regression analysis.

Turkey Point Units 3 and 4 Docket Nos . 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 31 of 41 Figure 4.5-4 Unit 4 Dome Tendons 1st Through 45th Year Tendon Surveillance 700

• • • • • • * **

680 *************** ....

....

• :

660 640 I

• .

• • • • • • • • • • • • • • • • • • *

• 620

• • • • • • • • • • ...**:::::,:.

.

it ...., ..

• ............

-;;;- 600 0.

~ 580 0

u...

C

.g 560 C

Cl)

I-540 520 500 1 10 100 1

Surveillance Yea/ )

~ Minimum Required Value (MRV)

~ PTF

~ PLL

~ PUL

• Average Liftoff Force (All Tendons)

• Average Liftoff Force (Random ly Selected Tendons)

• Average Liftoff Force (Control Tendons)

......... Log. (Average Liftoff Force (All Tendons)) y = -19.891n(x) + 692.31

......... Log. (Ave rage Liftoff Force (Randomly Select ed Tendons)) y = 13.84lln(x) + 566.81

......... Log. (Average Liftoff Force (Control Tendons)) y = 23.2921n( x) + 540.61 Notes:

ill After the 25th surveillance year, the liftoff force is only represented for the 35th and 45th year since Turkey Point meets the criteria of Section IWL-2421, which allows the two units alternate between "physical" and "visual" inspections at each surveillance period. Unit 4 underwent a "physical" inspection 35th and 45th surveillance years and will continue every ten years throughout the SPEO.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 32 of 41 Figure 4.5-5 Unit 3 Vertical Tendons 3rd Through 45th Year Tendon Surveillance 740.00 720.00 700.00

• 680.00

• * *

• 660.00 .

640.00  : .

I

==~.:..:. .::.*:**:*:*:*:*:*:*: ::=~;~~~~*J*c=*~-.. . . .--

• • • • • • • • • • • • • • • • • • • • • • • • • • • • ~

• I

..

,,,,................~~=:

............. ...  :

I I

~20.00 I e e I I I I ..

~00.00 0

LJ..

C

~80.00 C

QJ f-560.00 540.00 520.00 **--------*----41*-----*---*--*--*-*--**-.*-**-*-* .

500.00 1 10 100 2

Surveillance YeMH )

__.,_ Minimum Required Value (MRV)

--e-- PTF

--e-- PLL

--e-- PUL

• Average Liftoff Force (All Tendons)

• Average Tendon Force (Randomly Selected Tendons)

• Average Liftoff Force (Control Tendons)

• • • • • **** Log. (Average Liftoff Force (All Tendons)) y = -9 .1531n(x) + 677 .92

• • **** **

• Log. (Average Tendon Force (Randomly Se lected Tendons)) y = -5.981n(x) + 667.52

• • • • • • • • • Log. (Average Liftoff Force (Control Tendon s)) y = 17.9161n(x) + 581.79 Notes:

(1) After the 25th surveillance year, the liftoff force is only represented for the 30th and 40th year since Turkey Point meets the criteria of Section IWL-2421, which allows the two units alternate between "physical" and "visual" inspections at each surveillance

Turkey Point Units 3 and 4 Docket Nos . 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 33 of 41 period. Unit 3 underwent a "physical" inspection 30th and 40th surveillance years and will continue every ten years throughout the SPEO.

(2) The trend line exhibited an unexpected upward bias when considering all liftoff forces. The upward bias was due to the relatively high liftoff values recorded during the 3rd year vs the 1st year which is attributed to the retensioning of all Unit 3 vertcial tendons following the Unit 3 dome concrete repair after the 1st year surveillance.

Therefore, the 1st year surveillance vertical tendons are not statistically relevant and are not considered in the regression analysis.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No . 4 .5-2 L-2019-033 Attachment 3 Page 34 of 41 Figure 4.5-6 Unit 4 Vertical Tendons 1st Through 45th Year Tendon Surveillance 760.00 740.00 * *I 720.00 * *

• • • • • • .... *****

• • • • • • * * **

700 .00

• 680.00

• • • • • • *******

• • • • • • • • • • .

"vi' 664600 .0000 .

a.

~ 620.00

====~=::::::::::~-..

. *;**1**[******************

• -***_**;*~

• • • • • • • • .**.***********

~**

• • • • • • • • • **f*~~ ..- -

QJ u

o 600.00 LL C

• I I ..

.g C

580.00 QJ 1-560.00 540.00 520.00 **-------41*---411-----411---tl--tl-411--*--....*~41*--*~*,.*

500.00 1 10 100 Surveillance Year {l)

~ Minimum Required Value (MRV)

~ PTF

~ Pll

~ PUL

• Average Liftoff Force (All Tendons)

• Average liftoff Force (Randomly Selected Tendon s)

• Average Liftoff Force (Control Tendons)

• • • • • • • • • log. (Average Liftoff Force (All Tendons)) y = -18.511n(x) + 716.77

• • • • ***** log. (Average liftoff Force (Randomly Selected Tendons)) y = -2.52lln{x) + 647.67

• • • • • • *** Log. (Average Liftoff Force (Control Tendons)) y = -0.5111n(x) + 636.72 Notes:

(1) After the 25th surveillance year, the liftoff force is only represented for the 35th and 45th year since Turkey Point meets the criteria of Section IWL-2421, which allows the two units alternate between "physical" and "visual" inspections at each surveillance period. Unit 4 underwent a "physical" inspection 35th and 45th surveillance years and will continue every ten years throughout the SPEC.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 35 of 41 Figure 4.5-7 Unit 3 RVCH Hoop Tendons 640 620

• **

600

580 Vl a..

560 (1) u I...

~ 540 C

0

-0

~ 520 f-500

480 1 10 100 Surveillance Year

• Average Liftoff Force -+- Minimum Required Value (MRV)

-+- Baseline Predicted Force (BPF) ......... Log. (Average Liftoff Force) y = -1 .775\n(x) + 616.19

Turkey Point Units 3 and 4 Docket Nos . 50-250 and 50-251 FPL Response to NRC RAI No . 4.5-2 L-2019-033 Attachment 3 Page 36 of 41 Figure 4.5-8 Unit 4 RVCH Hoop Tendons 640 620 * **

600

• I 580

• Vl 0..

~ 560 QJ

....u 0

u.. 540 C

0

-0 C

QJ 520 I-500 480

1 10 100 Surveillance Year

• Average Liftoff Force ~ Minimum Required Value (MRV)

~ Baseline Predicted Force (BPF) ********* Log. (Average Liftoff Force) y = -ll.361n(x) + 646.14

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 37 of 41 Figure 4.5-9 Unit 3 RVCH Vertical Tendons 760 740 720 700

.*** *

...

680 660 640 V,

a.

.;2 620

<lJ

0 600 u...

C 580 0

-0 C

560

<lJ I- 540 520 **********

500 480 - -- -

1 10 100 Surveillance Year

• Average Liftoff Force ~ Minimum Required Value (MRV)

~ Baseline Predicted Force (BPF) ********* Log. (Average Liftoff Force) y= 29.3161n(x) + 616.52

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4 .5-2 L-2019-033 Attachment 3 Page 38 of 41 Figure 4.5-10 Unit 4 RVCH Vertical Tendons 780 760 740

• 720 700

• • • ~

• - ***

680 660

• Vl

a. 640

QJ 620 u

I...

0 u..

600 C

0 580 "O

C QJ 560 t-540 520 **********

500 480 1 10 100 Surveillance Year

• Average Liftoff Force ~ Min imum Required Value (MRV}

~ Baseline Predicted Force (BPF} ********* Log. (Average Liftoff Force) y = 107.051n(x) + 331.05

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 39 of 41 Revise the Concrete Containment Unbonded Tendon Prestress AMP in Section 17 .2.1.3 on page A-11 as follows:

The PTN Concrete Containment Unbonded Tendon Prestress AMP is an existing AMP that is part of the PTN lnservice Inspection (ISi) Program that is based on ASME Section XI, Subsection IWL, criteria, as supplernented by the requirements of 10 CFR 50.55a(b)(2)(viii). This AMP monitors and manages the loss of tendon prestress in the concrete containment prestressing system for the SPEO.

Loss of containment tendon prestressing forces is a TLAA evaluated in accordance with 10 CFR 54.21 (c)(1 )(iii). The PTN Concrete Containment Un bonded Tendon Prestress AMP, as part of the PTN ASME Section XI, Subsection IWL AMP, manages loss of containment tendon prestressing forces in the current period of extended operation (PEO). This TLAA AMP consists of the assessment of measured tendon prestressing forces from examinations performed through the PTN ASME Section XI, Subsection IWL AMP. The adequacy of the prestressing force for each tendon group based on type (i.e., hoop, vertical, and dome) and other consideratio~s (e.g., geometric dimensions, whether affected by repair/replacement, etc.) establishes (a) acceptance criteria in

. accordance with Subsection IWL and (b) trend lines constructed based on the guidance provided in NRC IN 99-10, "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments." The calculation of prestressing losses, predicted upper limits and predicted lower limits and predicted forces for each tendon group is in accordance with the guidelines of the NRC RG 1.35.1, "Determining Prestressing Forces or Inspection of Prestressed Concrete Containments."

The loss of concrete containment tendon prestressing forces is detected by comparing the measured data against the predicted force values from the respective containment tendon loss of prestress TLAA. Loss of prestressing forces are also detected by comparing the tendon force trend lines, constructed from surveillance measurements, against predicted force values. In addition to PTN Unit 3 and Unit 4 ASME Section XI, Subsection IWL examination requirements, all measured prestressing forces, up to the current examination, are plotted against time. The predicted lower limit (PLL)predicted forces, MRV, and trend-line curves are developed for each tendon group examined for the SPEO.- The trend line represents the general variation of prestressing forces with time based on the actual measured forces in individual tendons of the specific tendon group. The trend line for each tendon group is constructed by regression analysis of measured prestressing forces in individual tendons of that group obtained from previous examinations. The inspections are conducted every five years (i.e., 1, 3, 5, 10, 15, 20, 25, 30, 35, 40, 45th year, etc.) on alternating units. The trend lines will be updated after each scheduled examination using methods consistent with RG 1.35.1.

The prestressing force trend line for each tendon group shall not cross the appropriate MRV curve prior to the next scheduled examination. In addition, the constructed trend line shall not cross the appropriate PLL curvepredicted force line for any of the tendon groups. In case any of the two precedent criteria fail, the cause shall be determined, evaluated and corrected in a timely manner.* If acceptance criteria are not met, then

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 40 of 41 either systematic re-tensioning of tendons or a reanalysis of the concrete containment is warranted so that the design adequacy of the containment is demonstrated.

Revise the Concrete Containment Unbonded Tendon Prestress AMP in Section B.2-.2.3 on pages B-36 and B-37 as follows:

Program Description The PTN Concrete Containment Unbonded Tendon Prestress AMP is an existing condition monitoring AMP. The PTN Concrete Containment Unbonded Tendon Prestress AMP is based on the ASME Code Section XI, Subsection IWL requirements in the 2001 Edition, with 2003 Addenda (Reference B.3.132). The PTN Concrete Containment Unbonded Tendon Prestress AMP includes confirmatory actions that monitor and evaluate loss of containment tendon prestressing forces during the current term and will continue through the SPEO.

Loss of containment tendon prestressing forces is a TLAA evaluated in accordance with 10 CFR 54.21 (c)(1 )(iii). The PTN Concrete Containment Unbonded Tendon Prestress AMP, as part of the PTN ASME Section XI, Subsection IWL AMP, manages loss of containment tendon prestressing forces in the current period of extended operation (PEO). This TLAA AMP consists of the assessment of measured tendon prestressing forces from examinations performed through the PTN ASME Section XI, Subsection IWL AMP. The adequacy of the prestressing force for each tendon group based on type (i.e., hoop, vertical, and dome) and other considerations (e.g., geometric dimensions, whether affected by repair/replacement, etc.) establishes (a) acceptance criteria in accordance with Subsection IWL and (b) trend lines constructed based on the guidance provided in NRC IN 99-10 (Reference B.3.44), "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments." The calculation of prestressing

• 1osses, predicted upper limits and predicted lower limitsand predicted forces for each tendon group is in accordance with the guidelines of the NRC RG 1.35.1 (Reference B.3.18), "Determining Prestressing Forces or Inspection of Prestressed Concrete Containments."

This AMP periodically evaluates tendon forces measured by the PTN ASME Section XI, Subsection IWL AMP (Section B.2.3.31 ), such that corrective action can be taken, if required, prior to tendon forces falling below minimum required values (MRV) established in the design. This AMP addresses the TLAA assessment of unbonded tendon prestressing forces measured at control and randomly selected tendon samples (dome, hoop, and vertical) at PTN Unit 3 and Unit 4. The prestressing forces of the concrete containment tendons are measured for sample tendons using the lift-off method, or equivalent method.

The loss of concrete containment tendon prestressing forces is detected by comparing the measured data against the predicted force values from the respective containment tendon loss of prestress TLAA. In addition, loss of prestressing forces are also detected by comparing the tendon force trend lines, constructed from surveillance measurements, against predicted force values. In addition to PTN Unit 3 and Unit 4

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-2 L-2019-033 Attachment 3 Page 41 of 41 ASME Section XI, Subsection IWL examination requirements, all measured prestressing forces, up to the current examination, are plotted against time. The predicted lower limit (PLL)predicted force, MRV, and trend-line curves are developed

• for each tendon group examined for the SPEO. The trend line represents the general variation of prestressing forces with time based on the actual measured forces in individual tendons of the specific tendon group. The trend line for each tendon group is constructed by regression* analysis of measured prestressing forces in individual tendons of that group obtained from previous examinations. The inspections are conducted every five years (i.e., 1, 3, 5, 10, 15, 20, 25, 30, 35, 40, 45th year, etc.) on alternating units. The Pbbpredicted force line, MRV, and trend line for each tendon group have been projected to the end of the SPEO as described in Section 4.5. The trend lines will be updated after each scheduled examination using methods consistent with RG 1.35.1.

The prestressing force trend line for each tendon group shall not cross the appropriate MRV curve prior to the next scheduled examination. In addition, the constructed trend line shall not cross the appropriate PLL curvepredicted force line for any of the tendon groups. In case any of the two precedent criteria fail, the cause shall be determined, evaluated and corrected in a timely manner. If acceptance criteria are not met, then either systematic re-tensioning of tendons or a reanalysis of the concrete containment is warranted so that the design adequacy of the containment is demonstrated.

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-3 L-2019-033 Attachment 4 Page 1 of 4 NRC RAI Letter Nos. ML19032A396 and ML19032A397 Dated February 1, 2019 RAI 4.5-3

Background:

PTN's GISI program complies with ASME Code Section XI, Subsection IWL, 2007 Edition through 2008 Addenda. For each sampled tendon and at each lift off tendon force examination, ASME Code Section XI, Subsection IWL-3221.1 states the acceptance criteria based on tendon's predicted prestress force and for its expected elongation.

GALL-SLR Report AMP X.S1, "Concrete Containment Unbonded Tendon Prestress" program description states that the program consists of assessment of measured tendon prestress forces from required examinations performed in accordance with Subsection IWL of the ASME Code,Section XI, as supplemented in 10 CFR 50.55a(b)(2) and AMP program elements. It also states that NRG RG 1.35.1, "Determining Prestressing Forces for Inspection of Prestressed Concrete Containments," may be used for guidance related to calculation of prestressing force losses and predicted forces. RG 1.35.1 provides guidance for the determination of low (PLL) and high (predicted upper limit (PUL)) forces based on the influence of time dependent variations due to shrinkage and creep of concrete; and relaxation of prestressing steel, provided the tolerance-adjusted base values are subtracted from each tendon's modified initial prestress force (Fi). The, PUL and PLL are the upper and lower bounds of long term F1 losses. Alternatively, the RG allows the designer to use the conservatively estimated design values as base values for the time-dependent factors where the line drawn using these values is considered now as the lower bound base line. predicted force, or BPF.

The "monitoring and .trending" program element of GALL-SLR Report AMP X.S1 states that the PLL, MRV, and trend lines are c;leveloped for each tendon group examined during the SPEO. The trend line represents the general variation of prestressing forces over time based on the actual measured forces in individual tendons for a specific tendon group. The "acceptance criteria" program element of GALL-SLR Report AMP X.S1 states that "if the trend line crosses the PLL line, its cause should be determined, evaluated, and corrected. The trend line crossing the PLL line is an indication that the existing prestressing forces in concrete containment could fall below the MRV."

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-3 L-2019-033 Attachment 4 Page 2 of 4 The "scope of program" program element of PTN SLRA Section B.2.2.3, "Concrete Containment Unbonded Tendon Prestress," AMP is enhanced to include guidance of RG 1.35.1 for determining the adequacy of prestressing forces during the SPEO.

Figures 4.5-1 through 4.5-6 of Section 4.5 of PTN SLRA and PTN letter dated October 17, 2018 (ADAMS Accession No. ML18292A641), provide a graphic representation of the PLL for horizontal (or hoop), dome, and vertical tendons through the SPEO. The PTN letter also includes Figures 4.5-7 through 4.5-10 that use the BPF as best estimate for time dependent horizontal (or.hoop) and vertical ptestress tendon force losses for RVCH replacement affected tendons.

Issue:

Staff audited PTN Bechtel Report C-SJ599-12 documents for each tendon group, surveillance lift-off force requirements resulting from the containment reanalysis for the 25th year and beyond. The report also defines the PLL based on low and high (over time) variations of recalculated design values used for creep, shrinkage, and relaxation .

of steel as outlined in RG 1.35.1 for horizontal (or hoop) and vertical tendons. For dome tendons, however, it is not clear how the PLL was calculated. It appears that the PLL in Figures 4.5-3 and 4.5-4 is adjusted to intersect the MRV exactly at eighty years of reactor operation. The staff reviewed PTN Report BFSC 99-2005, "Containment Tendon Loss of Prestress Time Line Aging Analysis (TLAA) for License Renewal and Subsequent License Renewal," Revision 2, the TLAA 4.5 basis document, and noted that the dome PLL is "adjusted" to intersect the MRV force at eighty years with f_urther actions to be taken if surveillance data falls below the MRV. The staff audited PTN PSC 40th and 45th year Surveillance Reports, however, changed the RG 1.35.1 defined tendon prestress force lower bound from PLL for all prestress tendon groups (i.e.,

horizontal or hoop, dome, and vertical) to that of BPF. However, apparent lower bound in Figures 4.5-1 through 4.5"'6 seems to be based on PLL, while those in Figures 4.5-7 through 4.5-10 seems to be based on BPF. It appears that the SLRA used two different approaches in defining group tendon force lower bounds. In view of the information provided in the 40th and 45th year Surveillance Reports, it is not clear which approach the applicant intends to use in constructing the lower bound for each tendon. It is also not clear whether the dome tendon lower bounds have considered aggregate variations of time dependent shrinkage and creep of concrete, and relaxation of prestressing steel as suggested by RG 1.35.1 to which the applicant subscribes.

Request:

1. For each group of tendons, horizontal (or hoop), dome, and vertical, clarify and justify which methodology (PLL or BPF) will be used in constructing the lower bound of tendon prestress forces for tendon lift-off force evaluation during the SPEO.

2. State whether and how an evaluation of dome prestress tendon force lower bounds was performed based on the guidance provided in RG 1.35.1 or justify an alternate approach that would consider over time losses due to material variability in the PTN's PCC dome tendons.

Turkey Point_ Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-3 L-2019-033 Attachment 4 Page 3 of 4 FPL Response:

This response (along with RAI responses B.2.2.3-1, 4.5-1, 4.5-2, and 4.5-4 in this letter) supersedes Attachment 8 of FPL's December 14, 2018 response (Reference 3) for clarity. The conclusions in Reference 3 Attachment 8 were carried forward and remain unchanged in this response. The following numbered items correspond to the numbered requests above:

1. The following information is summarized from Reference 4. The PTN Concrete Containment Unbonded Tendon Prestress AMP includes confirmatory actions that monitor and evaluate loss of containment tendon prestressing forces during the current term and will continue through the SPEO. In order to determine the effective-

. ness of an individual tendon, as well as the performance of the combined sample of each tendon group, the as-found liftoff force is compared to the expected liftoff force, called the predicted force. The calculated predicted force for any tendon at any time after installation is derived using initial lock-off force (or seating force), as well as the expected force losses. The expected losses for PTN tendons include initial losses (elastic shortening and loss of tendon wires) and time dependent losses (concrete shrinkage, concrete creep, and stress relaxation of the tendon steel). Therefore, the predicted force(s) are based on the design requirements of the containment build-ings. Reg. Guide 1.35.1 was published to assist in the determination of the antici-pated post-tensioning prestress forces. Reg. Guide 1.35.1 provides guidance for the determination of low (predicted lower limit (PLL)) and high (predicted upper limit (PUL)) forces based on the influence of time dependent variations due to shrinkage and creep of concrete; and relaxation of prestressing steel, provided the tolerance-adjusted base values are subtracted from each tendon's modified initial prestress force. The PUL and PLL are the upper and lower bounds of long term prestress force losses with the PLL considered for acceptability of a tendon liftoff force.

Alternatively, Reg. Guide 1.35.1 allows the use of the conservatively estimated design values as base values for the time-dependent factors where the line drawn using these values is considered the lower bound base line predicted force, or BPF.

The PLL methodology was used for tendon acceptance criteria at Turkey Point from the 15th surveillance year to the 35th surveillance year. The BPF methodology was used for tendon acceptance criteria at Turkey Point for the 40th and 45th surveillance years. Based on the recommendation in Reference 4 provided by the PTN con-tractor who performs the IWL tendon surveillances, the BPF methodology will be used going forward. Accordingly, SLRA Section 4.5 is updated to clarify that the BPF methodology will be used going forward through the SPEO to ensure there is no loss of intended function, but both methodologies are acceptable according to Reg. Guide 1.35.1.

2. The expected losses for PTN tendons include initial losses (elastic shortening and loss of tendon wires) and time dependent losses (concrete shrinkage, concrete creep, and stress relaxation of the tendon steel) (Reference 4). Reference 5 lists the time dependent losses based on the design criteria of the containment buildings as

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-3 L-2019-033 Attachment 4 Page 4 of 4 well as the magnitude of the design losses due to concrete shrinkage, concrete creep, and steel relaxation at the end of 40 years for a typical dome, hoop, and vertical tendon. The predicted force values (PLL and PUL) were determined based on the recommended variations to each loss per Reg. Guide 1.35.1. When calculating force loss curves for all tendon groups, all long-term losses were originally assumed to be complete at the end of plant life (about 40 years). This assumption is modified for dome tendons, in order to keep acceptance criteria above the required minimum design force when extending the curves to 80 years. Dome tendons are assumed to achieve full long-term loss 80 years after the corresponding Initial Structural Integrity Test. Alternatively, hoop and vertical loss curves remain based on the original license expiration date (about 40 years). This approach will cause the hoop and vertical tendon predicted forces to fall below the original design losses; however, this approach still results in acceptance criteria above the minimum design at the end of plant life.

References:

1. Not used.

2. Not used.

3. FPL Letter L-2018-223 to NRC Dated December 14, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review - November 15, 2018 Public Meeting Action Item Responses (ADAMS Accession No. ML18352A885)

4. REP-1130-300, Revision 1, Comparative Analysis of Methods Used to Calculate Predicted Forces

5. C-SJ599-12, Revision 0, Turkey Point Tendon Surveillance Lift-off Force Requirements Associated SLRA Revisions:

All associated SLRA revisions are in the Associated SLRA Revisions section of the response to RAI 4.5-2 (Attachment 3 to this letter).

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-4 L-2019-033 Attachment 5 Page 1 of 6 NRC RAI Letter Nos. ML19032A396 and ML19032A397 Dated February 1, 2019 RAI 4.5-4 Backgrou*nd:

SRP-SLR Section 4.5, "Concrete Containment Unbonded Tendon Prestress Analysis,"

states that "[t]he prestressing forces generated by the tendons diminish over time due to losses in prestressing forces in the tendons and in the surrounding concrete." For plants dispositioning the TLAA in accordance with 10 CFR 54.21 (c)(1 )(iii), the SRP-SLR references the GALL-SLR Report AMP X.S1, "Concrete Containment Unbonded Tendon Prestress" as an acceptable AMP to monitor and assess concrete containment tendon prestressing forces. The SRP-SLR also states that the applicant should consider applicable portions of the operating experience noted in IN 99-10 as it might affect prestress tendon force losses.

SLRA Section 8.2.2.3 states that the applicant's Concrete Containment Unbonded Tendon Prestress Program is an existing AMP that, with enhancements, will be consistent with the GALL-SLR Report AMP X.S1.

The GALL-SLR Report AMP X.S1, program description recommends that while assessment of the adequacy of prestress tendon lift-off force follows the ASME Code Section XI, Subsection IWL requirements, trending of the lift-off forces is based on the guidance of NRC's IN 99-10, "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments [(PCCs)]." IN 99-10 states that proper comparison and trending analysis of lift-off forces is critical in determining the future trends of prestressing forces in PCCs. The IN 99-10 also states that for trending results to be statistically valid, the true variation in the loss of prestressing forces can only be obtained through a regression analysis using measured individual lift-off forces rather than the average of the lift-off forces of randomly selected tendons in the sampled tendon group.

The "monitoring and trending" program element of the GALL-SLR Report AMP X.S1 in part states:

The trend line represents the general variation of prestressing forces with time based on the actual measured forces in individual tendons of the specific tendon group. The trend line for each tendon group is constructed by regression analysis of all measured prestressing forces in individual tendons of that group obtained from all previous examinations.

PTN SLRA Figures 4.5-1 through 4.5-6, also provided in PTN letter "Responses to the August 2018 NRC On-Site Regulatory Audit Follow-Up Items," dated October 17, 2018 (ADAMS Accession No. ML18292A641), and letter dated December 14, 2018 (ADAMS Accession No. ML18352A885), (which supplement the SLRA) include lift-off force measurements of preselected and randomly selected tendons.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-4 L-2019-033 Attachment 5 Page 2 of 6 Issue:

1. Attachment 2_to Audit Report "Turkey Point Units 3 and 4 - Audit of Structures and Civil Engineering Features," dated April 13, 1992 (ADAMS Accession No.

ML173488474), states that through the 15th year of surveillance lift-off force measurements were made on preselected tendons. The PTN PSC Report TP-N981-501, dated April 16, 2007, indicates that for the 35th year of tendon surveillance, tendon lift-off force evaluation at PTN PCCs is based on randomly selected tendons. During its audit, the staff noted that PTN Report BSFC-99-2005,.

"Containment Tendon Loss of Prestress Time Limited Aging Analysis (TLAA) for License Renewal and Subsequent License Renewal," Revision 2, which is the TLAA 4.5 basis document, indicates that tendon lift-off force measurements made were subsequently plotted in graphs similar to those submitted as SLRA Figures 4.5-1 through 4.5-6 and used for trending to evaluate PCC structural integrity. It is not clear which of the tendons in SLRA Figures 4.5-1 through 4.5-6 are preselected and which are randomly selected.

2. In addition, the IN 99-10 states that a systematic way of correlating scattered tendon prestress lift-off forces for trending is with actual measured lift-off force data of randomly selected prestress tendons. It is also not clear whether the plotted lift-off force data is measured actual lift-off force data, normalized average lift-off force data, a mixture of the previous two, or a different approach in trending. Further, it is not clear why some preselected tendon lift-off forces (e.g., common tendons) have increased over time instead of diminishing.

It is not clear how the applicant's AMP is consistent with the GALL-SLR Report AMP X.S1 "monitoring and trending" program element and the guidance of IN 99-10, if the trended lift-off force data in SLRA Figures 4.5-1 through 4.5-6 does not represent the actual measured lift-off prestressing forces in individual tendons obtained from all previous examinations.

Request:

1. Provide a table oflift off force data for each group of tendons (i.e., horizontal or hoop, dome, vertical) that are plotted and used for trending in PTN SLRA Figures 4.5-1 through 4.5-6 and its subsequent supplements. Indicate which of these points are randomly selected, which are preselected, which belong to RVCH replacement, which are actual measured, which are normalized, and that are common (control) tendons.

2. For any of the preselected prestressed tendon force measurements in Request 1 that indicate an increased value over time, explain the reason for the increased value and justify their validity if used for trending.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-4 L-2019-033 Attachment 5 Page 3 of 6

3. Based on the response to Request 1, clarify whether the Concrete Containment Unbonded Tendon Prestress Program is consistent with the GALL-SLR Report AMP X.S1 recommendations that the prestressing force trend lines should be based on actual measured forces in individual tendons obtained from all previous examinations. If so, provide trend lines (for the randomly selected and common tendons) that only consider the actual lift-off force of the individual tendons from all previous examinations in accordance with GALL-SLR Report AMP X.S1 recommendations to follow the IN 99-10 trending methodology.

4. If the Concrete Containment Unbonded Tendon Prestress Program takes exception to the GALL-SLR Report AMP X.S1 recommendations for the construction of prestressing force trend lines:

(a) Provide a description of FPL's proposed alternate approach for trending of the prestressing forces that details the methodology used in developing the lift off force data sets in Request 1. *

(b) Provide (for all preselected, including common tendons, and randomly selected tendons) the trend lines resulting from this alternate approach.

(c) Justify the mathematical/statistical validity of the proposed alternate approach for trending such that assessments of the adequacy of the tendon prestressing forces could be made prior to crossing the PLL/BPF lines and corrective actions could be taken during the SPEO before there is a loss of intended function of the prestress tenoons.

FPL Response:

This response (along with RAI responses B.2.2.3-1, 4.5-1, 4.5-2, and 4.5-3 in Attachments 1 , 2, 3, and 4 to this letter) supersede Attachment 8 of FPL's December 14, 2018 response (Reference 3) for clarity. The conclusions in Reference 3 Attachment 8 were carried forward and remain unchanged in this response. The following numbered responses correspond to the numbered requests above:

1. SLRA Tables 4.5-1 through 4.5-6 are added to clarify the tendon inspection data used to create SLRA Figures 4.5-1 through 4.5-6. Only the actual measured tendon liftoff forces are included in the tables which were obtained from the surveillance reports (References 4 through 20). Note that the average liftoff force value listed in SLRA Tables 4.5-1 through 4.5-6 for each tendon represents the average of the actual measured liftoff force where two stressing points exist for the individual tendon, not the average value of all tendon lift-off forces for a given tendon group.

Liftoff forces from the 151through the 1Qth tendon surveillance years have been calculated from a kips/wire force value. The pt -15th year surveillances consist of preselected tendons. All other surveillances tested randomly selected tendons due to a technical specification change in effect beginning with the 20th year tendon surveillance. This technical specification change required surveillance of a random but representative sample of tendons (see RAI B.2.2.3-1 response in Attachment 1 to this letter for further discussion). The common (control) tendons for each tendon

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-4 L-2019-033 Attachment 5 Page 4 of 6 group are identified in SLRA Tables 4.5-1 through 4.5-6 and SLRA Figures 4.5-1 through 4.5-6 (see RAI B.2.2.3-1 response in Attachment 1 to this letter for further discussion). The tendons affected by the RVCH replacement are identified in SLRA Tables 4.5-7 through 4.5-10 (see RAI 4.5-2 response in Attachment 3 to this letter for further discussion). The predicted forces are calculated from the formulas in Reference 21.

2. As shown in SLRA Tables 4.5-1 through 4.5-6 and SLRA Figures 4.5-1 through 4.5-6, some preselected tendon force measurements (from the 1st through the 15th tendon surveillances) have an increased value over time. These increased values are attributed to the use of tendons which had been detensioned for wire removal in the surveillance population (Reference 22 Section 2.0A). Tendons which undergo wire inspection are detensioned for wire removal and retensioned. The tendons are retensioned by adding additional shims in order to achieve a force equal to or greater than the measured liftoff force but below the maximum allowable force limit (Reference 13). These tendons remain valid for trending the tendon history since the regression analysis is based on measured individual lift-off forces rather than the average of the lift-off forces of randomly selected tendons in the sampled tendon group as suggested by IN 99-10. Additionally, the PTN Concrete Containment Unbonded Tendon Prestress Program requires the regression analysis trendline to be constructed from measured prestressing forces obtained from all previous examinations (not only randomly selected tendons).

3. Consistent with the GALL-SLR Report AMP X.S1 and IN 99-10 recommendations, prestressing force trend lines are based on actual measured forces in individual tendons obtained from all previous, examinations. SLRA Figures 4.5-1 through 4.5-6 show the trend line for (1) all actual measured forces in individual tendons from all previous examinations, (2) the trendline for only randomly selected tendons, and (3)

.the trendline for only common (control) tendons for each tendon group.

4. The PTN Concrete Containment Unbonded Tendon Prestress Program does not take exception to the GALL-SLR Report AMP X.S1. The trend lines for each tendon group are constructed by regression analysis of all measured prestressing forces in individual tendons of that group obtained from all previous examinations. Therefore, an alternate approach is not performed, and no further information is required.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-4 L-2019-033 Attachment 5 Page 5 of 6

References:

1. Not used.

2. Not used.

3. FPL Letter L-2018-223 to NRC Dated December 14, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review - November 15, 2018 Public Meeting Action Item Responses (ADAMS Accession No. ML18352A885)

4. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 3 Containment Building Post-Tensioning System One-Year Surveillance

5. Florida Power & Light Company Turkey Point Plant Unit No. 4 Containment Building Post-Tensioning System One-Year Surveillance

6. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 3 Containment Structure Post-Tensioning System Third-Year Surveillance

7. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 4 Containment Structure Post-Tensioning System Third-Year Surveillance

8. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 3 Containment Structure Post-Tensioning System Fifth-Year Surveillance

9. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 4 Containment Structure Post-Tensioning System Flfth-Year Surveillance

10. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 3 Containment Structure Post-Tensioning System Tenth-Year Surveillance

11. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 4 Containment Structure Post-Tensioning System Tenth-Year Surveillance

12. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 3

, Containment Structure Post-Tensioning System Fifteenth-Year Surveillance

13. Florida Power & Light Company Turkey Point Nuclear Power Plant Unit 4 Containment Structure Post-Tensioning System Fifteenth-Year Surveillance

14. JPN-PTN-SECJ-92-027, Revision 0, Florida Power and Light Unit 3 Twentieth Year Containment Tendon Surveillance Final Report

15. JPN-PTN-SECJ-93-004, Revision 0, Florida Power and Light Unit 4 Twentieth Year Containment Tendon Surveillance Final Report

16. PTN-ENG-SECS-97-011, Revision 0, Unit 3 and Unit 4 25th Year Containment Tendon Surveillance Final Report

17. PTN/PSC-01-TP-004, Revision 0, Turkey Point Nuclear Plant Units 3 & 4 30th Year Containment Tendon Surveillance

18. PTN/PSC-TP-N981-508, Revision 0, Final Report for the 35th Year Containment IWL Inspection

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Response to NRC RAI No. 4.5-4 L-2019-033 Attachment 5v Page 6 of 6

19. REP-1076-510, Revision A, Final Report for the 401h Year Tendon Surveillance at Turkey Point

20. REP-1130-510, Revision 0, Final Report for the 45th Year Tendon Surveillance at Turkey Point

21. PTN-BRSC-99-2005, Revision 1, Containment Tendon Loss of Prestress Time Limited Aging Analysis (TLAA) for License Renewal 22.Audit Report, Turkey Point Units 3 and 4 -Audit of Structures and Civil Engineering Features, dated April 131h, 1992 (ADAMS Accession No. ML17348B474)

Associated SLRA Revisions:

All associated SLRA revisions are in the Associated SLRA Revisions section- of the response to RAI 4.5-2 (Attachment 3 to this letter).

Associated Enclosures None