ML25044A286
| ML25044A286 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/13/2025 |
| From: | Mack K Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-2025-018 | |
| Download: ML25044A286 (1) | |
Text
F=PL..
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE: Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 Turkey Point Subsequent License Renewal Commitment 32 Revision
References:
February 13, 2025 L-2025-018
- 1. Safety Evaluation Report, "Related to the Subsequent License Renewal of Turkey Point Generating Units 3 and 4," July 2019 (ADAMS Accession No. ML19191A057)
- 2. NUREG-2191, Volume 2, "Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report August 2016 (ADAMS Accession No. ML17187A204)
Florida Power and Light Company (FPL) hereby submits this notification of a regulatory commitment change for Turkey Point Units 3 and 4. Reference 1 documents the NRC review of FPL's Buried and Underground Piping and Tanks program and concludes the program elements have demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the current licensing basis (CLB) for the subsequent period of extended operation (SPEO), as required by 10 CFR 54.21 (a)(3).
Turkey Point has installed a buried piping cathodic protection system and has performed soil testing in accordance with the committed guidance. Fourteen of sixteen soil samples demonstrated a soil resistivity of greater than 10,000 ohm-cm when saturated with water. Two samples demonstrated results marginally lower than 10,000 ohm-cm when saturated with water.
The two exceptions were the test stations (ICW-04 and ICW-05) corresponding to the ICW discharge piping, located within the plant heavy haul path on the west/discharge side of the power block, where lower resistivity values led to higher predicted corrosion rates. Overall, the results of the analysis, demonstrate that most of the Subsequent License Renewal in-scope buried piping systems are subjected to relatively low levels of soil corrosivity.
Based upon the installed cathodic protection system and field testing, FPL is revising Commitment 32 to change the cathodic protection acceptance criteria from -850 mV relative to copper/copper sulfate reference electrode (CSE) to an acceptance criterion of 100 mV. In addition, FPL is committing to an additional means of verification of the effectiveness using Corrosion Rate Monitoring (CRM) electrical resistance probes in accordance with the acceptance criteria associated with Reference 2 Section XI.M41, "Buried and Underground Piping and Tanks." Testing will be performed annually by measuring the loss of material rate.
Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2025-018 Page 2 of 2 FPL is taking an exception to the 100 mV polarization criterion for two test stations, ICW-04 and ICW-05 (within the heavy haul path on the west/discharge side of the power block), where lower resistivity values led to higher predicted corrosion rates. The justification for this exception is that (CRM) will be performed to verify there is less than 1 mil per year (mpy) loss of material.
Loss of material rates in excess of 1 mpy may be acceptable if an engineering evaluation demonstrates that the corrosion rate would not result in a loss of intended function prior to the end of SPEO.
Should you have any questions regarding this submittal, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 13th day of February 2025.
Sincerely, Director, Licensing and Regulatory Compliance Florida Power and Light Company Attachment (1) cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. Clark Eldredge, Florida Department of Health
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 UFSAR Table 17-3 Change NOTE Bold is the new information.
Implement the new PTN Buried and Underground Piping and Tanks AMP.
L-2025-018 Install cathodic protection systems, and perform effectiveness reviews in accordance with Table XI.M41-2 in NUREG-2191,Section XI.M41.
Perform soil testing following the guidance of item E.b.iii of Table XI.M41-2 (including a minimum soil resistivity value of 10,000 ohm-cm) to determine if the soil is corrosive.
If after five years of operation the cathodic protection system does not meet the effectiveness acceptance criteria defined by NUREG-2191, Table XI.M41-2 and -3(-850100 mV relative to a CSE, instant off, for at least 80% of the time, and in operation for at least 85% of the time), the number of inspections will be as follows:
If soil testing has determined the soil is not corrosive per Item E.b.iii of Table XI.M41-2 of NUREG-2191 (including a minimum soil resistivity value of 10,000 ohm-cm), FPL commits to performing two additional buried steel piping inspections beyond the number required by Preventative Action Category F resulting in a total of thirteen inspections being completed six months prior to SPEO.
If soil testing has determined the soil is corrosive per Item E.b.iii of Table XI.M41-2 of NUREG-2191, FPL commits to performing five additional buried steel piping inspections beyond the number required by Preventative Action Category F resulting in a total of sixteen inspections being completed six months prior to SPEO.
Section 6.m of XI.M41 applies for the 100 mV minimum polarization. FPL shall Verify there is less than 1 mil per year (mpy) loss of material. Loss of material rates in excess of 1 mpy may be acceptable if an engineering evaluation demonstrates that the corrosion rate would not result in a loss of intended function prior to the end of the subsequent period of extended operation. An engineering evaluation will be performed to demonstrate acceptability.
FPL is taking an exception to the 100 mV polarization criterion, for two test stations ICW-04 and ICW-05 (within the heavy haul path on the west/discharge side of the power block), where lower resistivity values led to higher predicted corrosion rates.
The justification for this exception is that corrosion rate monitoring (CRM) will be
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 UFSAR Table 17-3 Change L-2025-018 performed to verify there is less than 1 mil per year (mpy) loss of material. Loss of material rates in excess of 1 mpy may be acceptable if an engineering evaluation demonstrates that the corrosion rate would not result in a loss of intended function prior to the end of SPEO.
Verification of the effectiveness of the cathodic protection system demonstrating loss of material rate is acceptable, will involve use of the installed electrical resistance corrosion rate probes. The external loss of material rate is verified as follows:
Every year when verifying the effectiveness of the cathodic protection system by measuring the loss of material rate.
Every 2 years when using the 100 mV minimum polarization.