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| {{#Wiki_filter:U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-00001 Re: Turkey Point Unit 4 Docket No. 50-251 Response to Request for Additional Information Regarding Steam Generator Tube Inspection Report | | {{#Wiki_filter:MAR 1 4 2017 L-2017-034 10 CFR 50.36 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-00001 Re: Turkey Point Unit 4 Docket No. 50-251 Response to Request for Additional Information Regarding Steam Generator Tube Inspection Report |
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| ==Reference:== | | ==Reference:== |
| | : 1. Florida Power & Light Company letter, L-2016-178, "Turkey Point Unit 4, Docket No. 50-251, Steam Generator Tube Inspection Report," October 18, 2016 (ML16298A391) |
| | : 2. NRC E-mail, ''RAI for Turkey Point 4 RF029 SGTIR Review - MF8523," |
| | February 10, 2017(ML17044A205) |
| | By letter dated October 18, 2016, Florida Power & Light Company (FPL) submitted the Turkey Point Unit 4 Cycle 29 Refueling Outage Steam Generator Tube Inspection Report (Reference 1) in accordance with Technical Specification 6.8.4.j, Steam Generator (SG) Program. |
| | On February 10, 2017, the NRC requested additional information regarding Reference 1. |
| | Attachment 1 to this letter provides FPL's response to the request for additional information (Reference 2). |
| | Should there be any questions, please contact Mr. Mitch Guth, Licensing Manager, at (305) 246-6698. |
| | Sincerely~ ~ |
| | ~sSummers Regional Vice President - Southern Region Turkey Point Nuclear Plant Enclosure cc: Regional Administrator, Region II, USNRC. |
| | Senior Resident Inspector, USNRC, Turkey Point Plant Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035 |
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| MAR 1 4 2017 L-2017-034 10 CFR 50.36 1. Florida Power & Light Company letter, L-2016-178, "Turkey Point Unit 4, Docket No. 50-251, Steam Generator Tube Inspection Report," October 18, 2016 (ML16298A391)
| | L-2017-034ATTACHMENT1 Response to Request for Additional Information Regarding Unit 4 Steam Generator Tube Inspection Report |
| : 2. NRC E-mail, ''RAI for Turkey Point 4 RF029 SGTIR Review -MF8523," February 10, 2017(ML17044A205)
| | |
| By letter dated October 18, 2016, Florida Power & Light Company (FPL) submitted the Turkey Point Unit 4 Cycle 29 Refueling Outage Steam Generator Tube Inspection Report (Reference
| | Attachment 1 to L-2017-034 Page 1of3 NRC RAI # 1: |
| : 1) in accordance with Technical Specification 6.8.4.j, Steam Generator (SG) Program. On February 10, 2017, the NRC requested additional information regarding Reference
| | Beginning on page 11 of 14 of the report, the licensee discusses a 77 percent through-wall foreign object wear indication reported during RFO 29 (2016) in SG B in a tube at row 17, column 71 (R 17C71) at the 01 H tube support structure. The staff notes that wear was detected in a tube close to this location in 2012. Given that there was no detected degradation or possible loose part indication in R17C71 in 2012, and the wear indication was sized at 77 percent through-wall in 2016, the staff requests the licensee to discuss the operational assessment performed to justify operation until the next planned inspection in 2019. |
| : 1. Attachment 1 to this letter provides FPL's response to the request for additional information (Reference 2). Should there be any questions, please contact Mr. Mitch Guth, Licensing Manager, at (305) 246-6698.
| | FPL Response for RAI #1: |
| Regional Vice President
| | The justification of continued operation until the next inspection in 2019 was based on the condition monitoring (CM) and operational assessment (OA) performed for the 2016 inspection. |
| -Southern Region Turkey Point Nuclear Plant Enclosure cc: Regional Administrator, Region II, USNRC. Senior Resident Inspector, USNRC, Turkey Point Plant Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035 L-2017-034ATTACHMENT1 Response to Request for Additional Information Regarding Unit 4 Steam Generator Tube Inspection Report NRC RAI # 1: Attachment 1 to L-2017-034 Page 1of3 Beginning on page 11 of 14 of the report, the licensee discusses a 77 percent through-wall foreign object wear indication reported during RFO 29 (2016) in SG B in a tube at row 17, column 71 (R 17C71) at the 01 H tube support structure.
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| The staff notes that wear was detected in a tube close to this location in 2012. Given that there was no detected degradation or possible loose part indication in R17C71 in 2012, and the wear indication was sized at 77 percent through-wall in 2016, the staff requests the licensee to discuss the operational assessment performed to justify operation until the next planned inspection in 2019. FPL Response for RAI #1: The justification of continued operation until the next inspection in 2019 was based on the condition monitoring (CM) and operational assessment (OA) performed for the 2016 inspection. | |
| The CM and OA for foreign object degradation followed the guidance of EPRI SG ISPT guidelines, Rev. 4, EPRI SG IA guidelines, Rev. 3, and Turkey Point engineering procedures for evaluation of secondary-side foreign objects. The volumetric indication in R17C71 at 01 Hin SG B detected in 2016 by the bobbin coil was attributed to foreign object wear. The subsequent rotating +Point coil examination revealed no associated foreign object at the wear indication location, and tubes surrounding R17C71 showed no tube damage. Tube R17C71 in SG B was removed from service by plugging with stabilization. | | The CM and OA for foreign object degradation followed the guidance of EPRI SG ISPT guidelines, Rev. 4, EPRI SG IA guidelines, Rev. 3, and Turkey Point engineering procedures for evaluation of secondary-side foreign objects. The volumetric indication in R17C71 at 01 Hin SG B detected in 2016 by the bobbin coil was attributed to foreign object wear. The subsequent rotating +Point coil examination revealed no associated foreign object at the wear indication location, and tubes surrounding R17C71 showed no tube damage. Tube R17C71 in SG B was removed from service by plugging with stabilization. |
| The indication. | | The indication. at 01 H in tube R 17C71 had a measured depth of 77% TW with an axial length of 0.35 in. and circumferential extent of 0.51 in. using EPRI +Point technique 27904.1 (tapered round hole calibration standard). The same indication was sized at 27% TW using EPRI +Point technique 27905.1 (flat wear calibration standard). The +Point volts peak-to-peak for the indication was 0.67 volts. Subsequent line-by-line depth sizing with EPRI +Point technique 27904.1 gave a maximum depth of 72% TW. The depth sizing profile further indicated the shape of the flaw is relatively flat and indicates that sizing with technique 27904.1 is conservative for CM and OA purposes. ln~addition, the tapered round hole standard for technique 27904.1 has a drill-hole diameter <0.14 in. at the reported depth size. The axial/circumferential extent for the wear indication (0.35 in. by 0.51 in.) is much larger than that for a tapered hole. This suggests that the actual depth of the indication is most likely closer to the 27% TW size reported with technique 27905.1. |
| at 01 H in tube R 17C71 had a measured depth of 77% TW with an axial length of 0.35 in. and circumferential extent of 0.51 in. using EPRI +Point technique 27904.1 (tapered round hole calibration standard). | | The profile conservatively sized with technique 27904.1 was evaluated for tube integrity and the calculated burst pressure at 95-50 lower bound met the SIPC margin requirement of 4542 psi (3xNOPD), with margin. The depth of a flaw to cause possible leakage under a postulated limiting accident event (i.e., through-wall penetration due to remaining ligament pop-through failure), including analysis uncertainties at the 95-50 limits, was not exceeded for the detected indication. Therefore, the AILPC leakage margin requirements at 1xLAPD (2550 psi) for the past operating period were satisfied. |
| The same indication was sized at 27% TW using EPRI +Point technique 27905.1 (flat wear calibration standard). | | In support of the CM calculations, the voltage screening limits in the EPRI ISPT guidelines were also evaluated for this indication. Comparison of the measured voltage and length sizes with the exemption criteria was performed. Applying the voltage screening methods in accordance with |
| The +Point volts peak-to-peak for the indication was 0.67 volts. Subsequent line-by-line depth sizing with EPRI +Point technique 27904.1 gave a maximum depth of 72% TW. The depth sizing profile further indicated the shape of the flaw is relatively flat and indicates that sizing with technique 27904.1 is conservative for CM and OA purposes. | | |
| the tapered round hole standard for technique 27904.1 has a drill-hole diameter <0.14 in. at the reported depth size. The axial/circumferential extent for the wear indication (0.35 in. by 0.51 in.) is much larger than that for a tapered hole. This suggests that the actual depth of the indication is most likely closer to the 27% TW size reported with technique 27905.1. The profile conservatively sized with technique 27904.1 was evaluated for tube integrity and the calculated burst pressure at 95-50 lower bound met the SIPC margin requirement of 4542 psi (3xNOPD), with margin. The depth of a flaw to cause possible leakage under a postulated limiting accident event (i.e., through-wall penetration due to remaining ligament pop-through failure), including analysis uncertainties at the 95-50 limits, was not exceeded for the detected indication. | | Attachment 1 to L-2017-034 Page 2 of 3 the EPRI ISPT guidelines concluded that the wear indication is exempt from proof (burst) testing (Vpp s 2 volts and length s1 in.) and exempt from leakage testing (Vpp s 1.6 volts, axial length s 0.5 in. and circumferential angle s 90°). This includes accident-induced bending stresses up to 27.7 ksi, which bounds the bending stress calculated at tube support plates for the Turkey Point steam generators for faulted loads. Therefore, the voltage-based screening criteria were met, with margin, for both leakage and structural requirements for R17C71 and ISPT was not required. |
| Therefore, the AILPC leakage margin requirements at 1xLAPD (2550 psi) for the past operating period were satisfied. | | For the OA, two possible scenarios were considered: 1) the loose part affecting R17C71 is a new foreign object, and 2) the loose part is the same foreign object that affected R17C74 in 2012 and had migrated three tubes over to R17C71. For the OA performed at EOC 28, foreign object wear was evaluated under the assumption that the foreign object was new and would migrate to another location in Cycle 29 (Scenario 1). The likely source for new foreign objects in SG B is metal fragments generated from a SG feed pump suction strainer failure in 2013. A foreign object evaluation was performed by Turkey Point Engineering on the most likely metal fragments arising from the strainer failure. A list of credible debris was determined based on strainer construction, historical debris trapped in the strainer, and the parts of the strainer(s) that were retrieved after the failure. Using credible part configurations residing in a stable captured position and exposed to full gap velocity, the operating periods to reach the minimum allowable tube wall thickness were evaluated. The resulting limiting inspection interval was calculated as 3.68 EFPY to reach the minimum allowable tube wall thickness. This interval exceeds the planned inspection interval (Cycles 29 and 30), which is 2.84 EFPY. This limiting calculation supports a 2-cycle inspection interval to EOC 30. |
| In support of the CM calculations, the voltage screening limits in the EPRI ISPT guidelines were also evaluated for this indication. | | As a check on the above assessment and to address Scenario 2, the next inspection interval of 2.84 EFPY was compared to the last inspection interval of 2.15 EPFY in conjunction with the CM evaluation for R 17C71. The next inspection interval is -3% longer than the previous one (2.84/2.75 = 1.03). Under the assumption that the suspected loose part will migrate to another: |
| Comparison of the measured voltage and length sizes with the exemption criteria was performed. | | location and is in direct contact with a tube, and the expected depth and shape of the resulting wear at EOC 30 will be similar to the indication in R17C71 observed at EOC 28, the minimum burst pressure and leakage potential were calculated and compared to the SIPC and AILPC margin requirements. Given the established condition that the indication in R17C71 met CM margin requirements in 2016 (both analytically and voltage-based) with margin, a postulated indication under the same scenario from the past operating period as described above, having again been conservatively sized using technique 27904.1, will satisfy the CM margin requirements at the next inspection in 2019. |
| Applying the voltage screening methods in accordance with Attachment 1 to L-2017-034 Page 2 of 3 the EPRI ISPT guidelines concluded that the wear indication is exempt from proof (burst) testing (Vpp s 2 volts and length s1 in.) and exempt from leakage testing (Vpp s 1.6 volts, axial length s 0.5 in. and circumferential angle s 90°). This includes accident-induced bending stresses up to 27.7 ksi, which bounds the bending stress calculated at tube support plates for the Turkey Point steam generators for faulted loads. Therefore, the voltage-based screening criteria were met, with margin, for both leakage and structural requirements for R17C71 and ISPT was not required. | | |
| For the OA, two possible scenarios were considered: | | Attachment 1 to L-2017-034 Page 3 of 3 NRC RAl#2: |
| : 1) the loose part affecting R17C71 is a new foreign object, and 2) the loose part is the same foreign object that affected R17C74 in 2012 and had migrated three tubes over to R17C71. For the OA performed at EOC 28, foreign object wear was evaluated under the assumption that the foreign object was new and would migrate to another location in Cycle 29 (Scenario 1). The likely source for new foreign objects in SG B is metal fragments generated from a SG feed pump suction strainer failure in 2013. A foreign object evaluation was performed by Turkey Point Engineering on the most likely metal fragments arising from the strainer failure. A list of credible debris was determined based on strainer construction, historical debris trapped in the strainer, and the parts of the strainer(s) that were retrieved after the failure. Using credible part configurations residing in a stable captured position and exposed to full gap velocity, the operating periods to reach the minimum allowable tube wall thickness were evaluated. | | Regarding the channel head, upper steam drum, and in-bundle tube support visual inspections, the staff requests the licensee to confirm that the descriptions of no anomalies/abnormalities means that no degradation was observed. If this is not the case, the staff requests the licensee to describe the degradation it observed. |
| The resulting limiting inspection interval was calculated as 3.68 EFPY to reach the minimum allowable tube wall thickness. | | FPL Resp~nse for RAI #2: |
| This interval exceeds the planned inspection interval (Cycles 29 and 30), which is 2.84 EFPY. This limiting calculation supports a 2-cycle inspection interval to EOC 30. As a check on the above assessment and to address Scenario 2, the next inspection interval of 2.84 EFPY was compared to the last inspection interval of 2.15 EPFY in conjunction with the CM evaluation for R 17C71. The next inspection interval is -3% longer than the previous one (2.84/2.75 | | Channel Head Visual Inspections The Steam Generator (SG) Tube Inspection Report stated that no anomalies were observed in any of the three SG channel heads. For the channel head visual inspections, no degradation was detected in any of the three SG channel heads. |
| = 1.03). Under the assumption that the suspected loose part will migrate to another: location and is in direct contact with a tube, and the expected depth and shape of the resulting wear at EOC 30 will be similar to the indication in R17C71 observed at EOC 28, the minimum burst pressure and leakage potential were calculated and compared to the SIPC and AILPC margin requirements. | | In-Bundle Tube Support Visual Inspections With regards to the in-bundle tube support visual inspection (only performed in SG A) the report stated that no abnormal conditions were observed. For the in-bundle tube support visual inspections, no degradation was detected. |
| Given the established condition that the indication in R17C71 met CM margin requirements in 2016 (both analytically and voltage-based) with margin, a postulated indication under the same scenario from the past operating period as described above, having again been conservatively sized using technique 27904.1, will satisfy the CM margin requirements at the next inspection in 2019. | |
| NRC RAl#2: Attachment 1 to L-2017-034 Page 3 of 3 Regarding the channel head, upper steam drum, and in-bundle tube support visual inspections, the staff requests the licensee to confirm that the descriptions of no anomalies/abnormalities means that no degradation was observed.
| |
| If this is not the case, the staff requests the licensee to describe the degradation it observed. | |
| FPL for RAI #2: Channel Head Visual Inspections The Steam Generator (SG) Tube Inspection Report stated that no anomalies were observed in any of the three SG channel heads. For the channel head visual inspections, no degradation was detected in any of the three SG channel heads. In-Bundle Tube Support Visual Inspections With regards to the in-bundle tube support visual inspection (only performed in SG A) the report stated that no abnormal conditions were observed. | |
| For the in-bundle tube support visual inspections, no degradation was detected. | |
| Upper Steam Drum Visual Inspections During the inspection of the feedring and J-tubes, a few instances were noted where the J-Tube to feedring interface (on the inside diameter of the feedring) shows some minor erosion. This is not new degradation and does not appear to be changing over time. There was no new degradation in any of the steam drum components. | | Upper Steam Drum Visual Inspections During the inspection of the feedring and J-tubes, a few instances were noted where the J-Tube to feedring interface (on the inside diameter of the feedring) shows some minor erosion. This is not new degradation and does not appear to be changing over time. There was no new degradation in any of the steam drum components. |
| Acronyms AILPC CM *EFPY EOC EPRI IA ISPT LAPD NOPD OA 01H SG %TW SIPC Vpp psi ksi Induced Leakage Performance Criteria Condition Monitoring Effective Full Power Years* End of Cycle Electric Power Research Institute Integrity Assessment In Situ Pressure Test Limiting Accident Pressure Differential Normal Operating Pressure Differential Operational Assessment First (lowest) Broached Supp,art plate on the Hot-Leg side of the SG Steam Generator Percentage through the tube wall Structural Integrity Performance Criteria Voltage Peak-to-Peak pounds per square inch kilo pounds per square inch}} | | Acronyms AILPC Accid~nt Induced Leakage Performance Criteria CM Condition Monitoring |
| | *EFPY Effective Full Power Years* |
| | EOC End of Cycle EPRI Electric Power Research Institute IA Integrity Assessment ISPT In Situ Pressure Test LAPD Limiting Accident Pressure Differential NOPD Normal Operating Pressure Differential OA Operational Assessment 01H First (lowest) Broached Supp,art plate on the Hot-Leg side of the SG SG Steam Generator |
| | %TW Percentage through the tube wall SIPC Structural Integrity Performance Criteria Vpp Voltage Peak-to-Peak psi pounds per square inch ksi kilo pounds per square inch}} |
Letter Sequence Response to RAI |
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CAC:MF8523, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection (Approved, Closed) |
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Category:Letter type:L
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Seabrook Station; and Point Beach, Units 1 and 2 - Supplement to License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22022-12-0909 December 2022 Turkey Points, Units 3 & 4; Seabrook Station; and Point Beach, Units 1 and 2 - Supplement to License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 L-2022-181, Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 52022-12-0101 December 2022 Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5 L-2022-182, Emergency Response Data System (Eros) Changes2022-11-17017 November 2022 Emergency Response Data System (Eros) Changes L-2022-180, CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2022-11-0909 November 2022 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums L-2022-168, and Point Beach Units 1 and 2 - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report2022-10-26026 October 2022 and Point Beach Units 1 and 2 - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report L-2022-171, 10 CFR 50.59(d)(2) Summary Report2022-10-20020 October 2022 10 CFR 50.59(d)(2) Summary Report L-2022-167, Submittal of Periodic Reports2022-10-13013 October 2022 Submittal of Periodic Reports L-2022-166, Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement2022-10-0505 October 2022 Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement L-2022-149, U4R33 Steam Generator Tube Inspection Report2022-10-0404 October 2022 U4R33 Steam Generator Tube Inspection Report L-2022-160, Station,, Point Beach Units 1 and 2, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22022-10-0404 October 2022 Station,, Point Beach Units 1 and 2, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 L-2022-148, Florida Power & Light Company, Comments on NRC Inspection Procedure (IP) 71111.21 N.03, Commercial Grade Dedication2022-09-16016 September 2022 Florida Power & Light Company, Comments on NRC Inspection Procedure (IP) 71111.21 N.03, Commercial Grade Dedication L-2022-151, Evacuation Time Estimate Study2022-09-15015 September 2022 Evacuation Time Estimate Study L-2022-142, Revised Diversity and Defense-In-Depth Evaluation (D3), Framatome Document No. 51-9324096-0042022-08-19019 August 2022 Revised Diversity and Defense-In-Depth Evaluation (D3), Framatome Document No. 51-9324096-004 L-2022-136, Response to Request for Additional Information Regarding Turkey Point Unit 3 Cycle 32 Steam Generator Tube Inspection Report2022-08-12012 August 2022 Response to Request for Additional Information Regarding Turkey Point Unit 3 Cycle 32 Steam Generator Tube Inspection Report L-2022-109, Inservice Inspection Program - Owner'S Activity Report (OAR-1)2022-06-27027 June 2022 Inservice Inspection Program - Owner'S Activity Report (OAR-1) L-2022-076, Subsequent License Renewal Application - Appendix E Environmental Report Supplement 22022-06-0909 June 2022 Subsequent License Renewal Application - Appendix E Environmental Report Supplement 2 2024-01-25
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARL-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, L-2023-110, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-08-25025 August 2023 Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 L-2023-094, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-07-27027 July 2023 Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project L-2023-069, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-05-31031 May 2023 Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project ML23151A4362023-05-24024 May 2023 License Amendment Request Revision 3 for the Technical Specifications Conversion to NUREG - 1431 Revision 5 ML23151A4372023-05-24024 May 2023 Attachment 3: Turkey Point Nuclear Plant, Units 3 and 4, Improved Technical Specifications Conversion License Amendment Request NRC Request for Additional Information and FPL Responses Database ML23095A0082023-04-0404 April 2023 Attachment 2 - Improved Technical Specifications Conversion License Amendment Request NRC Request for Additional Information and FPL Responses Database L-2023-040, Response to Requests for Additional Information (Rals) and Requests for Confirmation of Information (Rc Ls) Following Regulatory Audit of Subsequent License Renewal Application2023-03-0303 March 2023 Response to Requests for Additional Information (Rals) and Requests for Confirmation of Information (Rc Ls) Following Regulatory Audit of Subsequent License Renewal Application L-2022-181, Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 52022-12-0101 December 2022 Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5 L-2022-166, Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement2022-10-0505 October 2022 Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement L-2022-136, Response to Request for Additional Information Regarding Turkey Point Unit 3 Cycle 32 Steam Generator Tube Inspection Report2022-08-12012 August 2022 Response to Request for Additional Information Regarding Turkey Point Unit 3 Cycle 32 Steam Generator Tube Inspection Report L-2022-051, Fifth Ten-Year Inservice Inspection Interval Relief Request No. 10 Part-II, Supplement Information and Response to Request for Additional Information2022-03-29029 March 2022 Fifth Ten-Year Inservice Inspection Interval Relief Request No. 10 Part-II, Supplement Information and Response to Request for Additional Information L-2021-213, Response to Request for Additional Information Regarding License Amendment Request 273, Update Listing of Approved LOCA Methodologies to Adopt Full Spectrum LOCA Methodology2021-11-19019 November 2021 Response to Request for Additional Information Regarding License Amendment Request 273, Update Listing of Approved LOCA Methodologies to Adopt Full Spectrum LOCA Methodology L-2021-207, Response to Request for Additional Information for ISI Relief Request No. 102021-10-25025 October 2021 Response to Request for Additional Information for ISI Relief Request No. 10 L-2021-197, Response to Request for Additional Information for ISI Relief Request No. 102021-10-15015 October 2021 Response to Request for Additional Information for ISI Relief Request No. 10 ML21258A3792021-09-14014 September 2021 Response to Request for Additional Information, Relief Requests 8 and 9 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1), Extension of Inspection Interval for Turkey Point Unit 3 and Unit 4 Reactor. L-2020-111, Response to Request for Additional Information Regarding Steam Generator Tube Inspection Report2020-06-24024 June 2020 Response to Request for Additional Information Regarding Steam Generator Tube Inspection Report L-2020-081, Response to Request for Additional Information Regarding License Amendment Request 264, Adopt Emergency Action Level Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactor2020-06-0808 June 2020 Response to Request for Additional Information Regarding License Amendment Request 264, Adopt Emergency Action Level Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactor L-2020-083, Supplemental Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Re2020-05-21021 May 2020 Supplemental Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Re L-2020-071, Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements2020-04-16016 April 2020 Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements L-2020-064, Exigent License Amendment Request 272, One-Time Extension of TS 6.8.4 Steam Generator Inspection Program - Response to Request for Additional Information2020-04-0909 April 2020 Exigent License Amendment Request 272, One-Time Extension of TS 6.8.4 Steam Generator Inspection Program - Response to Request for Additional Information ML20098F3412020-04-0707 April 2020 Exigent License Amendment Request 272, One-Time Extension of TS 6.8.4 Steam Generator Inspection Program - Response to Request for Additional Information L-2019-135, Response to Request for Additional Information Regarding License Amendment Request 266, Clarify Requirements When One Unit Is Outside the Applicability of Certain Technical Specifications2019-07-22022 July 2019 Response to Request for Additional Information Regarding License Amendment Request 266, Clarify Requirements When One Unit Is Outside the Applicability of Certain Technical Specifications ML19158A5032019-06-0707 June 2019 NRC to NMFS, NRC Responses to NMFS Requests for Additional Information for Turkey Point ESA Section 7 Consultation L-2019-114, Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 10, RAI No. B.2.3.28-1b Updated Response2019-06-0404 June 2019 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 10, RAI No. B.2.3.28-1b Updated Response L-2019-048, Response to Request for Additional Information (Rai), Subsequent License Renewal Application Safety Review Revision 1, Second Submittal Set 82019-03-15015 March 2019 Response to Request for Additional Information (Rai), Subsequent License Renewal Application Safety Review Revision 1, Second Submittal Set 8 L-2019-037, Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 9 Responses2019-03-0606 March 2019 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 9 Responses L-2019-033, Response to Requests for Additional Information Subsequent License Renewal Application Safety Review Revision 1, Set 8 First Submittal Responses2019-03-0101 March 2019 Response to Requests for Additional Information Subsequent License Renewal Application Safety Review Revision 1, Set 8 First Submittal Responses ML19056A1252019-02-25025 February 2019 Turky Point SLRA RAIs 1 2 3 4 5 6 7 8 9 11 - Set 8 Rev 1 Irradiated Concrete-Steel Responses L-2019-012, Response to Follow-on NRC RAI No. B.2.3.9-1 a2019-02-13013 February 2019 Response to Follow-on NRC RAI No. B.2.3.9-1 a L-2019-023, Response to Request for Additional Information Regarding License Amendment Request 265, Revise NFPA-805 License Condition for Reactor Coolant Pump Seals2019-01-31031 January 2019 Response to Request for Additional Information Regarding License Amendment Request 265, Revise NFPA-805 License Condition for Reactor Coolant Pump Seals L-2018-234, Subsequent License Renewal Application Safety Review Request for Additional Information (RAI) Set 5 Response 4.3.5-2 Revision2018-12-21021 December 2018 Subsequent License Renewal Application Safety Review Request for Additional Information (RAI) Set 5 Response 4.3.5-2 Revision L-2018-223, Subsequent License Renewal Application Safety Review - November 15, 2018 Public Meeting Action Item Responses2018-12-14014 December 2018 Subsequent License Renewal Application Safety Review - November 15, 2018 Public Meeting Action Item Responses L-2018-222, Subsequent License Renewal Application Safety Review - November 13, 2018 Public Meeting Discussion Topic Responses2018-12-12012 December 2018 Subsequent License Renewal Application Safety Review - November 13, 2018 Public Meeting Discussion Topic Responses L-2018-218, Supplemental Response to Request for Additional Information (RAI) Set 1, Subsequent License Renewal Application Environmental Review2018-11-28028 November 2018 Supplemental Response to Request for Additional Information (RAI) Set 1, Subsequent License Renewal Application Environmental Review L-2018-191, Supplemental Responses Requests for Additional Information (RAI) Set 7 Subsequent License Renewal Application Safety Review2018-11-28028 November 2018 Supplemental Responses Requests for Additional Information (RAI) Set 7 Subsequent License Renewal Application Safety Review L-2018-193, Set 6 Responses to Request for Additional Information (RAI) on Subsequent License Renewal Application Safety Review2018-11-0202 November 2018 Set 6 Responses to Request for Additional Information (RAI) on Subsequent License Renewal Application Safety Review L-2018-166, WCAP-15355-NP, Revision 0, a Demonstration of Applicability of ASME Code Case N-481 to the Primary Loop Pump Casings.2018-10-31031 October 2018 WCAP-15355-NP, Revision 0, a Demonstration of Applicability of ASME Code Case N-481 to the Primary Loop Pump Casings. ML18299A1142018-10-24024 October 2018 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 4 Responses L-2018-175, Subsequent License Renewal Application, Safety Review Requests for Additional Information (RAI) Set 5 Responses2018-10-17017 October 2018 Subsequent License Renewal Application, Safety Review Requests for Additional Information (RAI) Set 5 Responses L-2018-176, Subsequent License Renewal Application, Responses to the August 2018 NRC On-Site Regulatory Audit Follow-Up Items2018-10-17017 October 2018 Subsequent License Renewal Application, Responses to the August 2018 NRC On-Site Regulatory Audit Follow-Up Items ML18296A0242018-10-16016 October 2018 Set 3 Response to Request for Additional Information to Subsequent License Renewal Application Safety Review ML18299A1162018-10-15015 October 2018 Structural Integrity Associates Engineering Report No. 1700109.401P, Revision 7 - Redacted, Evaluation of Environmentally-Assisted Fatigue for Turkey Point Units 3 and 4 for Subsequent License Renewal ML18299A1172018-10-12012 October 2018 Framatome Calculation No. 32-9280712, Rev. 002, Tp CRDM Lower Joint Environmentally Assisted Fatigue Dated October 12, 2018 (Non-Proprietary) L-2018-174, Structural Integrity Associates Engineering Report No. 0901350.401, Revision 4, Leak-Before-Break Evaluation - Accumulator, Pressurizer Surge, and Residual Heat Removal Lines2018-10-12012 October 2018 Structural Integrity Associates Engineering Report No. 0901350.401, Revision 4, Leak-Before-Break Evaluation - Accumulator, Pressurizer Surge, and Residual Heat Removal Lines ML18299A1182018-10-12012 October 2018 Structural Integrity Associates Engineering Report No. 0901350.304, Revision 3, Fatigue Crack Growth Evaluation, October 12, 2018 ML18283A3102018-10-0505 October 2018 Responses to Requests for Additional Information for Subsequent License Renewal Application Environmental Review L-2018-169, Responses to Requests for Additional Information for Subsequent License Renewal Application No. HC-7-a L-2018-169 Environmental Review2018-10-0505 October 2018 Responses to Requests for Additional Information for Subsequent License Renewal Application No. HC-7-a L-2018-169 Environmental Review L-2018-154, Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 2 Responses2018-09-14014 September 2018 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 2 Responses 2023-08-07
[Table view] |
Text
MAR 1 4 2017 L-2017-034 10 CFR 50.36 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-00001 Re: Turkey Point Unit 4 Docket No. 50-251 Response to Request for Additional Information Regarding Steam Generator Tube Inspection Report
Reference:
- 1. Florida Power & Light Company letter, L-2016-178, "Turkey Point Unit 4, Docket No. 50-251, Steam Generator Tube Inspection Report," October 18, 2016 (ML16298A391)
- 2. NRC E-mail, RAI for Turkey Point 4 RF029 SGTIR Review - MF8523,"
February 10, 2017(ML17044A205)
By letter dated October 18, 2016, Florida Power & Light Company (FPL) submitted the Turkey Point Unit 4 Cycle 29 Refueling Outage Steam Generator Tube Inspection Report (Reference 1) in accordance with Technical Specification 6.8.4.j, Steam Generator (SG) Program.
On February 10, 2017, the NRC requested additional information regarding Reference 1.
Attachment 1 to this letter provides FPL's response to the request for additional information (Reference 2).
Should there be any questions, please contact Mr. Mitch Guth, Licensing Manager, at (305) 246-6698.
Sincerely~ ~
~sSummers Regional Vice President - Southern Region Turkey Point Nuclear Plant Enclosure cc: Regional Administrator, Region II, USNRC.
Senior Resident Inspector, USNRC, Turkey Point Plant Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035
L-2017-034ATTACHMENT1 Response to Request for Additional Information Regarding Unit 4 Steam Generator Tube Inspection Report
Attachment 1 to L-2017-034 Page 1of3 NRC RAI # 1:
Beginning on page 11 of 14 of the report, the licensee discusses a 77 percent through-wall foreign object wear indication reported during RFO 29 (2016) in SG B in a tube at row 17, column 71 (R 17C71) at the 01 H tube support structure. The staff notes that wear was detected in a tube close to this location in 2012. Given that there was no detected degradation or possible loose part indication in R17C71 in 2012, and the wear indication was sized at 77 percent through-wall in 2016, the staff requests the licensee to discuss the operational assessment performed to justify operation until the next planned inspection in 2019.
FPL Response for RAI #1:
The justification of continued operation until the next inspection in 2019 was based on the condition monitoring (CM) and operational assessment (OA) performed for the 2016 inspection.
The CM and OA for foreign object degradation followed the guidance of EPRI SG ISPT guidelines, Rev. 4, EPRI SG IA guidelines, Rev. 3, and Turkey Point engineering procedures for evaluation of secondary-side foreign objects. The volumetric indication in R17C71 at 01 Hin SG B detected in 2016 by the bobbin coil was attributed to foreign object wear. The subsequent rotating +Point coil examination revealed no associated foreign object at the wear indication location, and tubes surrounding R17C71 showed no tube damage. Tube R17C71 in SG B was removed from service by plugging with stabilization.
The indication. at 01 H in tube R 17C71 had a measured depth of 77% TW with an axial length of 0.35 in. and circumferential extent of 0.51 in. using EPRI +Point technique 27904.1 (tapered round hole calibration standard). The same indication was sized at 27% TW using EPRI +Point technique 27905.1 (flat wear calibration standard). The +Point volts peak-to-peak for the indication was 0.67 volts. Subsequent line-by-line depth sizing with EPRI +Point technique 27904.1 gave a maximum depth of 72% TW. The depth sizing profile further indicated the shape of the flaw is relatively flat and indicates that sizing with technique 27904.1 is conservative for CM and OA purposes. ln~addition, the tapered round hole standard for technique 27904.1 has a drill-hole diameter <0.14 in. at the reported depth size. The axial/circumferential extent for the wear indication (0.35 in. by 0.51 in.) is much larger than that for a tapered hole. This suggests that the actual depth of the indication is most likely closer to the 27% TW size reported with technique 27905.1.
The profile conservatively sized with technique 27904.1 was evaluated for tube integrity and the calculated burst pressure at 95-50 lower bound met the SIPC margin requirement of 4542 psi (3xNOPD), with margin. The depth of a flaw to cause possible leakage under a postulated limiting accident event (i.e., through-wall penetration due to remaining ligament pop-through failure), including analysis uncertainties at the 95-50 limits, was not exceeded for the detected indication. Therefore, the AILPC leakage margin requirements at 1xLAPD (2550 psi) for the past operating period were satisfied.
In support of the CM calculations, the voltage screening limits in the EPRI ISPT guidelines were also evaluated for this indication. Comparison of the measured voltage and length sizes with the exemption criteria was performed. Applying the voltage screening methods in accordance with
Attachment 1 to L-2017-034 Page 2 of 3 the EPRI ISPT guidelines concluded that the wear indication is exempt from proof (burst) testing (Vpp s 2 volts and length s1 in.) and exempt from leakage testing (Vpp s 1.6 volts, axial length s 0.5 in. and circumferential angle s 90°). This includes accident-induced bending stresses up to 27.7 ksi, which bounds the bending stress calculated at tube support plates for the Turkey Point steam generators for faulted loads. Therefore, the voltage-based screening criteria were met, with margin, for both leakage and structural requirements for R17C71 and ISPT was not required.
For the OA, two possible scenarios were considered: 1) the loose part affecting R17C71 is a new foreign object, and 2) the loose part is the same foreign object that affected R17C74 in 2012 and had migrated three tubes over to R17C71. For the OA performed at EOC 28, foreign object wear was evaluated under the assumption that the foreign object was new and would migrate to another location in Cycle 29 (Scenario 1). The likely source for new foreign objects in SG B is metal fragments generated from a SG feed pump suction strainer failure in 2013. A foreign object evaluation was performed by Turkey Point Engineering on the most likely metal fragments arising from the strainer failure. A list of credible debris was determined based on strainer construction, historical debris trapped in the strainer, and the parts of the strainer(s) that were retrieved after the failure. Using credible part configurations residing in a stable captured position and exposed to full gap velocity, the operating periods to reach the minimum allowable tube wall thickness were evaluated. The resulting limiting inspection interval was calculated as 3.68 EFPY to reach the minimum allowable tube wall thickness. This interval exceeds the planned inspection interval (Cycles 29 and 30), which is 2.84 EFPY. This limiting calculation supports a 2-cycle inspection interval to EOC 30.
As a check on the above assessment and to address Scenario 2, the next inspection interval of 2.84 EFPY was compared to the last inspection interval of 2.15 EPFY in conjunction with the CM evaluation for R 17C71. The next inspection interval is -3% longer than the previous one (2.84/2.75 = 1.03). Under the assumption that the suspected loose part will migrate to another:
location and is in direct contact with a tube, and the expected depth and shape of the resulting wear at EOC 30 will be similar to the indication in R17C71 observed at EOC 28, the minimum burst pressure and leakage potential were calculated and compared to the SIPC and AILPC margin requirements. Given the established condition that the indication in R17C71 met CM margin requirements in 2016 (both analytically and voltage-based) with margin, a postulated indication under the same scenario from the past operating period as described above, having again been conservatively sized using technique 27904.1, will satisfy the CM margin requirements at the next inspection in 2019.
Attachment 1 to L-2017-034 Page 3 of 3 NRC RAl#2:
Regarding the channel head, upper steam drum, and in-bundle tube support visual inspections, the staff requests the licensee to confirm that the descriptions of no anomalies/abnormalities means that no degradation was observed. If this is not the case, the staff requests the licensee to describe the degradation it observed.
FPL Resp~nse for RAI #2:
Channel Head Visual Inspections The Steam Generator (SG) Tube Inspection Report stated that no anomalies were observed in any of the three SG channel heads. For the channel head visual inspections, no degradation was detected in any of the three SG channel heads.
In-Bundle Tube Support Visual Inspections With regards to the in-bundle tube support visual inspection (only performed in SG A) the report stated that no abnormal conditions were observed. For the in-bundle tube support visual inspections, no degradation was detected.
Upper Steam Drum Visual Inspections During the inspection of the feedring and J-tubes, a few instances were noted where the J-Tube to feedring interface (on the inside diameter of the feedring) shows some minor erosion. This is not new degradation and does not appear to be changing over time. There was no new degradation in any of the steam drum components.
Acronyms AILPC Accid~nt Induced Leakage Performance Criteria CM Condition Monitoring
- EFPY Effective Full Power Years*
EOC End of Cycle EPRI Electric Power Research Institute IA Integrity Assessment ISPT In Situ Pressure Test LAPD Limiting Accident Pressure Differential NOPD Normal Operating Pressure Differential OA Operational Assessment 01H First (lowest) Broached Supp,art plate on the Hot-Leg side of the SG SG Steam Generator
%TW Percentage through the tube wall SIPC Structural Integrity Performance Criteria Vpp Voltage Peak-to-Peak psi pounds per square inch ksi kilo pounds per square inch