ML21032A020

Issuance of Amendment Nos. 295 and 268 Concerning Extension of Containment Leak Rate Testing Frequency

ML21032A020
Person / Time
Site:	Turkey Point
Issue date:	02/26/2021
From:	Ellen Brown Plant Licensing Branch II
To:	Moul D Florida Power & Light Co
Brown E
References
EPID L-2020-LLA-0016, EPID L-2020-LLA-003
Download: ML21032A020 (34)

Text

February 26, 2021 Mr. Don Moul Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd.

Juno Beach, FL 33408

SUBJECT:

TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 - ISSUANCE OF AMENDMENT NOS. 295 AND 268 CONCERNING EXTENSION OF CONTAINMENT LEAK RATE TESTING FREQUENCY (EPID L-2020-LLA-0016)

(L-2020-LLA-003)

Dear Mr. Moul:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 295 to Subsequent Renewed Facility Operating License No. DPR-31 and Amendment No. 268 to Subsequent Renewed Facility Operating License No. DPR-41 for the Turkey Point Nuclear Generating Unit Nos. 3 and 4, respectively (Turkey Point). The amendments change the Technical Specifications in response to the application from Florida Power & Light Company dated January 27, 2020 (Agencywide Documents Access and Management System No. ML20034D803).

The amendments modify Section 6.8.4.h, Containment Leakage Rate Testing Program, of the Turkey Point technical specifications to support the extension of the frequency of the Type A Integrated Leak Rate Test from 10 to 15 years and allow the extension of the containment isolation valves leakage test intervals (i.e., Type C tests) from their current 60-month frequency to 75 months.

D. Moul A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Eva A. Brown, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosures:

1. Amendment No. 295 to DPR-31

2. Amendment No. 268 to DPR-41

3. Notices and Environmental Findings

4. Safety Evaluation cc: Listserv

FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT NUCLEAR GENERATING UNIT NO. 3 AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE Amendment No. 295 Subsequent Renewed License No. DPR-31

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company (the licensee) dated January 27, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Subsequent Renewed Facility Operating License No. DPR-31 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 295, are hereby incorporated into this subsequent renewed license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this subsequent renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Undine S. Undine S. Shoop Date: 2021.02.26 Shoop 09:59:15 -05'00' Undine S. Shoop, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Subsequent Renewed Facility Operating License and Technical Specifications Date of Issuance: February 26, 2021

FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT NUCLEAR GENERATING UNIT NO. 4 AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE Amendment No. 268 Subsequent Renewed License No. DPR-41

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company (the licensee) dated January 27, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

D. Moul 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Subsequent Renewed Facility Operating License No. DPR-41 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 268 are hereby incorporated into this subsequent renewed operating license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this subsequent renewed license.

The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Undine S. Undine S. Shoop Date: 2021.02.26 Shoop 09:59:43 -05'00' Undine S. Shoop, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Subsequent Renewed Facility Operating License and Technical Specifications Date of Issuance: February 26, 2021

ATTACHMENT TO LICENSE AMENDMENT NOS. 295 AND 268 TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NOS. DPR-31 AND DPR-41 DOCKET NOS. 50-250 AND 50-251 Replace page 3 of Subsequent Renewed Facility Operating License No. DPR-31 with the attached page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Replace page 3 of Subsequent Renewed Facility Operating License No. DPR-41 with the attached page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Replace the following page of the Appendix A Technical Specifications with the attached page.

The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert 6-9 6-9

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

9. Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives greater than 8 days in gaseous effluents released from each unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I;

10. Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.

The provisions of Specifications 4.0.2 and 4.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.

g. DELETED

h. Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, and as modified by approved exemptions. This program shall be in accordance with Nuclear Energy Institute (NEI) 94-01, Revision 3-A, Industry Guidance for Implementing Performance Based Option of 10 CFR 50 Appendix J, and the conditions and limitations specified in NEI 94-01, Revision 2-A, with the following deviations or exemptions:

1) A vacuum test will be performed in lieu of a pressure test for airlock door seals at the required intervals (Amendment Nos. 73 and 77, issued by NRC November 11, 1981).

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is defined here as the containment design pressure of 55 psig.

The maximum allowable containment leakage rate, La, at Pa, shall be 0.20% of containment air weight per day.

Leakage Rate acceptance criteria are:

1) The As-found containment leakage rate acceptance criterion is < 1.0 La. Prior to increasing primary coolant temperature above 200F following testing in accordance with this program or restoration from exceeding 1.0 La, the As-left leakage rate acceptance criterion is <0.75 La, for Type A test.

2) The combined leakage rate for all penetrations subject to Type B or Type C testing is as follows:

TURKEY POINT - UNITS 3 & 4 6-9 AMENDMENT NOS. 295 AND 268

NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. 295 TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AND AMENDMENT NO. 268 TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251

1.0 INTRODUCTION

By application dated January 27, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20034D803), Florida Power & Light Company (FPL, or the licensee) requested changes to the Technical Specifications (TSs) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point), which are contained in Appendix A of Subsequent Renewed Facility Operating License Nos. DPR-31 and DPR-41, respectively. The licensee proposed to modify Section 6.8.4.h, "Containment Leakage Rate Testing Program," of the Turkey Point TSs to support the extension of the frequency of the Type A Integrated Leak Rate Test from 10 to 15 years and allow the extension of the containment isolation valves leakage test intervals (i.e., Type C tests) from their current 60-month frequency to 75 months.

2.0 STATE CONSULTATION

In accordance with the Commissions regulations, the U.S. Nuclear Regulatory Commission (NRC) staff notified the State of Florida official (Ms. Cynthia Becker, M.P.H., Chief of the Bureau of Radiation Control, Florida Department of Health) on January 25, 2021, of the proposed issuance of the amendments. The State official had no comments.

3.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the use of facility components located within the restricted area as defined in Title 10 of the Code of Federal Regulations (10 CFR)

Part 20, Standards for Protection Against Radiation. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding, which was published in the Federal Register on March 10, 2020 (85 FR 13951) that the amendments involve no significant hazards consideration, and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

February 26, 2021 TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 - SAFETY EVALUATION CONCERNING EXTENSION OF CONTAINMENT LEAK RATE TESTING FREQUENCY (EPID L-2020-LLA-0016) (L-2020-003)

LICENSEE INFORMATION Licensee: Florida Power and Light Company (FPL, the licensee)

Plant Name and Units: Turkey Point Nuclear Generating Unit Nos. 3 and 4 Subsequent Renewed Facility Operating Licenses: DPR-31 and DPR-41 Docket Nos.: 50-250 and 50-251 Amendment Numbers: 295 and 268 APPLICATION INFORMATION Submittal Date: January 27, 2020 Submittal Agencywide Documents Access and Management System (ADAMS) Accession No.: ML20034D803

1.0 PROPOSED CHANGE

By application dated January 27, 2020, the licensee requested changes to the Technical Specifications (TSs) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point),

which are contained in Appendix A of Subsequent Renewed Facility Operating License Nos. DPR-31 and DPR-41, respectively. The licensee proposed to modify Turkey Point, TS 6.8.4.h, Containment Leakage Rate Testing Program, to support the extension of the frequency of the Type A Integrated Leak Rate Test (ILRT) from 10 years to 15 years and to allow the extension of the Containment Isolation Valves (CIVs) leakage test intervals (i.e.,

Type C tests) from their current 60-month frequency to 75 months. This testing supports the containment leak rate program described in Section 50.54(o) of Title 10 of the Code of Federal Regulations (10 CFR).

For the proposed change, the maximum surveillance interval for the Type A ILRTs will change to no longer than 15 years from the last ILRT based on satisfactory performance history. The proposed change would require the performance of the next Unit 3 ILRT by no later than July 2027, and the next Unit 4 ILRT by no later than February 2028.

Enclosure 3

1.1 Proposed Technical Specification Turkey Point, Units 3 and 4, TS 6.8.4.h, proposed to require a program in accordance with Nuclear Energy Institute (NEI)Topical Report (TR) NEI 94-01, Revision 3-A, Industry Guideline for Implementing Performance-based Option of 10 CFR Part 50, Appendix J, and the conditions and limitations specified in NEI 94 01, Revision 2-A.

Turkey Point, Units 3 and 4, TS 6.8.4.h, currently states, in part:

A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B, and as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program, dated September 1995, as modified by the following deviations or exemptions:

1. Type A tests will be performed either in accordance with Bechtel Topical Report BN-TOP-1, Revision 1, dated November 1, 1972, or the guidelines of RG 1.163.

2. Type A testing frequency in accordance with NEI 94-01, Revision 0, Section 9.2.3, except:

a. For Unit 3, the first Type A test performed after the November 1992, Type A test shall be performed no later than November 2007.

b. For Unit 4, the first Type A test performed after October 1991, shall be performed no later than October 2006.

3. A vacuum test will be performed in lieu of a pressure test for airlock door seals at the required intervals (Amendment Nos. 73 and 77, issued by U.S. Nuclear Regulatory Commission (NRC),

November 11, 1981).

The proposed changes would revise TS 6.8.4.h, by replacing the reference to RG 1.163 with a reference to NEI 94-01, Revision 3-A. The conditions and limitations from RG 1.163 to implement the performance-based leakage testing program in accordance with Option B of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix J will be removed by deleting the first two deviations or exemptions, and renumbering and revising the third to read as follows:

A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B, and as modified by approved exemptions.

This program shall be in accordance with the Nuclear Energy Institute (NEI) 94-01, Revision 3-A, Industry Guidance for Implementing Performance-based Option of 10 CFR Part 50, Appendix J, and the conditions and limitations specified in NEI 94-01, Revision 2-A, with the following deviations or exemptions:

1) A vacuum test will be performed in lieu of a pressure test for airlock door seals at the required intervals. (Amendment Nos. 73 and 77, issued by U.S. Nuclear Regulatory Commission (NRC),

November 11, 1981).

2.0 REGULATORY EVALUATION

2.1 Regulatory Requirements Section 50.54(o) of 10 CFR requires that the primary reactor containments for water-cooled power reactors shall be subject to the requirements set forth in Appendix J to 10 CFR Part 50, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors.

Appendix J to 10 CFR Part 50 includes two options: Option A - Prescriptive Requirements, and Option B - Performance-based Requirements, either of which can be chosen for meeting the requirements of the Appendix. The testing requirements in 10 CFR Part 50, Appendix J ensure that (a) leakage through containments or systems and components penetrating containments does not exceed allowable leakage rates specified in the TS; and (b) integrity of the containment structure is maintained during the service life of the containment. The licensee has established and has been implementing Option B for meeting the requirements of Appendix J to 10 CFR Part 50.

Option B of Appendix J to 10 CFR 50, specifies performance-based requirements and criteria for preoperational and subsequent leakage rate testing. These requirements are met by the performance of:

Type A tests to measure the containment system overall integrated leakage rate; Type B pneumatic tests to detect and measure local leakage rates across pressure-retaining leakage-limiting boundaries such as penetrations; and Type C pneumatic tests to measure CIVs leakage rates.

After the preoperational tests, these tests are required to be conducted at periodic intervals based on the historical performance of the overall containment system (for Type A tests), and based on the safety significance and historical performance of each boundary and isolation valve (for Type B and C tests) to ensure the integrity of the overall containment system as a barrier to fission product release.

Under the performance-based option of 10 CFR Part 50, Appendix J, the test frequency is based upon an evaluation that reviewed as-found leakage history to determine the frequency for leakage testing, which provides assurance that leakage limits will be maintained.

Section 50.65(a) to 10 CFR states in part that the licensee shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, are capable of fulfilling their intended functions. These goals shall be established commensurate with safety and, where practical, take into account industrywide operating experience.

Currently, Turkey Point, TS 6.8.4.h, specifies requirements for implementing Section 50.54(o) and Appendix J, Option B, to 10 CFR, in accordance with the guidelines contained in RG 1.163.

The Turkey Point TS include approved deviations and exemptions to allow Type A testing to be performed in accordance with Bechtel TR BN-TOP-1, Revision 1, Testing Criteria for Integrated Leakage Rate Testing of Primary Containment Structures for Nuclear Power Plants, dated November 1, 1972, and allow testing of the airlock door seals by vacuum test in lieu of pressure test.

2.2 Endorsed Guidance The NRC staff reviewed NEI 94-01, Revision 2, and Electric Power Research Institute (EPRI)

EPRI TR-1009325, Revision 2, Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals, (EPRI TR) (ADAMS Accession No. ML072970206). In a safety evaluation (SE) dated June 25, 2008 (ADAMS Accession No. ML081140105), the NRC staff determined that NEI 94-01, Revision 2 describes an acceptable approach for implementing the optional performance-based requirements of Option B to 10 CFR Part 50, Appendix J. The approved version (NEI 94-01, Revision 2-A, ADAMS Accession No. ML100620847) was issued by NEI on November 19, 2008. It includes provisions for extending ILRT intervals up to 15 years and incorporates the regulatory positions stated in RG 1.163. The NEI report was approved as an acceptable approach for implementing the requirements for Option B to 10 CFR Part 50, Appendix J, provided that licensees satisfy the following conditions:

1. For calculating the Type A leakage rate, the licensee should use the definition in the NEI TR 94-01, Revision 2, in lieu of that in American National Standards Institute/American Nuclear Society (ANSI/ANS)-56.8-2002.

2. The licensee submits a schedule of containment inspections to be performed prior to and between Type A tests.

3. The licensee addresses the areas of the containment structure, potentially subjected to degradation.

4. The licensee addresses any tests and inspections performed following major modifications to the containment structure, as applicable.

5. The normal Type A test interval should be less than 15 years. If a licensee has to utilize the provision of Section 9.1 of NEI TR 94-01, Revision 2, related to extending the ILRT interval beyond 15 years, the licensee must demonstrate to the NRC staff that it is an unforeseen emergent condition.

6. For plants licensed under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, applications requesting a permanent extension of the ILRT surveillance interval to 15 years should be deferred until after the construction and testing of containments for that design have been completed, and applicants

have confirmed the applicability of NEI TR 94-01, Revision 2, and EPRI TR-1009325, Revision 2, including the use of past containment ILRT data.

The NRC staff notes that the last condition of the approval is not applicable to Turkey Point Units 3 and 4.

in the June 25, 2008 approval, the NRC staff found that the Type A testing methodology described in ANSI/ANS-56.8-2002, Containment System Leakage Testing Requirements, and the modified testing frequencies recommended by NEI 94-01, Revision 2, serve to ensure continued leakage integrity of the containment structure.

For EPRI TR-1009325, Revision 2, a risk-informed methodology using plant-specific risk insights and industry ILRT performance data is provided to revise ILRT surveillance frequencies. The NRC staff found that this guidance was acceptable for referencing by licensees proposing to amend their TS regarding containment leakage rate testing subject to the limitations and conditions noted in Section 4.2 of the June 25, 2008 NRC approval. The EPRI TR uses the approach in RG 1.200 An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities (ADAMS Accession No. ML090410014) to demonstrate the technical adequacy of the probabilistic risk assessment (PRA), in total or the parts that are used to support this application, is sufficient to provide confidence in the results. As noted in the June 25, 2008 NRC approval, the EPRI TR was approved as an acceptable approach for implementing the requirements for Option B to Appendix J of 10 CFR Part 50, provided that licensees satisfy the following conditions:

1. The licensee submits documentation indicating that the technical adequacy of their PRA is consistent with the requirements of RG 1.200 relevant to the ILRT extension application.

2. The licensee submits documentation indicating that the estimated risk increase associated with permanently extending the ILRT surveillance interval to 15 years is small, and consistent with the clarification provided in Section 3.2.4.5 of this SE.

Specifically, a small increase in population dose should be defined as an increase in population dose of less than or equal to either 1.0 person-rem per year or 1 percent of the total population dose, whichever is less restrictive. In addition, a small increase in conditional containment failure probability (CCFP) should be defined as a value marginally greater than that accepted in previous onetime 15-year ILRT extension requests. This would require that the increase in CCFP be less than or equal to 1.5 percentage point. While acceptable for this application, the NRC staff is not endorsing these threshold values for other applications. Consistent with this limitation and condition, EPRI TR-1009325 will be revised in the -A version of the report, to change the population dose acceptance guidelines and the CCFP guidelines.

3. The methodology in EPRI TR-1009325, Revision 2, is acceptable except for the calculation of the increase in expected population dose (per year of reactor operation).

In order to make the methodology acceptable, the average leak rate for the pre-existing containment large leak rate accident case (accident case 3b) used by the licensees shall be 100 La instead of 35 La.

4. An amendment request is required in instances where containment overpressure is relied upon for emergency core cooling system (ECCS) performance.

Guidance for implementing the Appendix J performance-based requirements are provided in NEI 94-01, Revision 3 (ADAMS Accession No. ML12221A202). It also incorporates, by reference, the provisions of ANSI/ANS-56.8-2002 and the requirements of Subsections IWE and IWL of Section XI of the American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (Code). The ASME Code requirements are incorporated by reference in 10 CFR 50.55a, with modifications and limitations. The modifications and limitations vary in accordance with the edition and the addenda of the ASME Code as required by 10 CFR 50.55a.

Also, NEI TR 94-01, Revision 3 includes provisions for extending Type C, LLRT intervals up to 75-months. The NRC staff reviewed NEI TR 94-01, Revision 3 and determined that it described an acceptable approach for implementing the optional performance-based requirements of Option B to 10 CFR Part 50, Appendix J, as modified by the conditions and limitations summarized in Section 4.0 of the associated SE dated June 8, 2012 (ADAMS Accession No. ML121030286). Specifically, the NEI report was approved as an acceptable approach for implementing the requirements for Option B of Appendix J to 10 CFR Part 50, provided that licensees satisfy the two conditions specified in the SE.

In Table 3.2.1-1 of Enclosure 1 to the submittal, the licensee presented the IWE Inspection Intervals to date. Turkey Point is currently in the Third 10-Year Inspection Interval (July 15, 2018, to July 14, 2028) and is utilizing the 2007 Edition of ASME,Section XI with addenda through 2008, as modified by 10 CFR 50.55a. For IWL, Turkey Point recently completed the Second 10-Year Inspection Interval (September 9, 2008- September 8, 2018) that included the 40th Year Surveillance (2012) and the 45th Year Surveillance (2017) and used 2001 Edition through the 2003 Addenda.

3.0 TECHNICAL EVALUATION

Using the guidance contained in both NEI 94-01, Revision 2-A and NEI 94-01, Revision 3-A, the licensee relied on historical plant-specific containment leakage testing program results and a plant-specific risk assessment to demonstrate containment leak-tight integrity. The NRC staff performed a comparison of the licensee proposal against the applicable regulations and guidance, reviewed the technical assumptions associated with the use of the approved topical reports (Revisions 2-A and 3-A of NEI 94-01 and EPRI TR-1009325, Revision 2-A) as well as confirmed the licensees adoption of the various topical reports limitations and conditions provided in the associated NRC staff topical report approval SEs.

3.1 CONFIRMATION OF APPLICABILITY AND CONDITIONS IN NEI 94-01, REVISION 2-A The purpose of NEI TR 94-01, Revision 2-A, is to assist licensees in the implementation of Option B to 10 CFR Part 50, Appendix J, and in extending Type A ILRT intervals beyond 10 years. Specifically, NEI TR 94-01, Revision 2-A, includes guidance that would permit the licensees to permanently extend the ILRT surveillance interval to 15 years and incorporates the regulatory positions stated in RG 1.163. It delineates a performance-based approach for determining Type A, Type B, and Type C containment leakage rate testing frequencies.

3.1.1 Use of Applicable Definition of Performance Leakage Rate (Revision 2-A Condition 1)

In Section 3.4 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for NEI 94-01, Revision 2-A were met. The first condition states that the licensee should use the definition of performance leakage rate in the NEI TR 94-01, Revision 2, in lieu of that in ANSI/ANS-56.8-2002 to determine the Type A leakage rate. The licensee indicated that upon implementation, the tests would be conducted consistent with the NEI definition of performance leakage rate in Revision 3-A. The licensee noted that the definition in Revision 2-A was the same as Revision 3-A of NEI 94-01; therefore, using either revision would meet the condition.

The NRC staff reviewed the definitions of performance leakage rate contained NEI 94-01, Revision 2, Revision 2-A and Revision 3-A. The NRC staff concluded that the definitions contained in all three revisions are identical. Based on this, the NRC staff found that the definition remained unchanged from Revision 2-A to Revision 3-A of NEI 94-01. Therefore, the NRC staff confirmed that the licensee will use the definition of performance leakage rate in Section 5.0 of NEI 94-01, Revision 2, for calculating the Type A leakage rate in the Turkey Point Containment Leakage Rate Testing Program.

3.1.2 Schedule of Containment Inspections Prior to and Between Type A Tests (Revision 2-A Condition 2)

In Section 3.4 of Enclosure 1 to the submittal, the licensee outlined how the conditions of the approval for NEI 94-01, Revision 2-A were met. The second condition states that the licensee should submit a schedule of containment inspections to be performed prior to and between Type A tests. In Table 3.4-1 of Section 3.4 of the submittal, the licensee indicated that visual observations of the accessible interior and external surfaces of the containment structure will continue to be conducted in accordance with the TS requirements prior to and between Type A tests and during at least three other outages before the next Type A test if the interval for the Type A test has been extended to 15 years. These tests are to be performed in conjunction or coordinated with the examinations required by the American Society Mechanical Engineers (ASME) Code,Section XI, Subsections IWE and IWL and are intended to identify potential containment degradation that may affect containment leak-tight integrity.

The NRC staff reviewed the licensees testing schedule against the conditions in NEI 94-01, Revision 2-A. As the proposed prior testing should identify structural problems that may affect either the containment structure leakage integrity or the performance of the Type A test, and the schedule continues to provide a supplemental means of identifying potential containment degradation, the NRC staff finds the proposed schedule acceptable.

3.1.3 Areas of the Containment Structure, Potentially Subjected to Degradation (Revision 2-A Condition 3)

In Section 3.4 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for NEI 94-01, Revision 2-A were met. The third condition states that the licensee should address the areas of the containment structure, potentially subjected to degradation.

Turkey Point is currently in the Third 10-Year Inspection Interval, which began on July 15, 2018, and is scheduled to end on July 14, 2028. This interval will be conducted in accordance with the 2007 Edition of the ASME Code,Section XI, with Addenda through 2008 as modified by 10 CFR 50.55a.

Section 3.2.1 of Enclosure 1 to the submittal discusses the IWE Program at Turkey Point, which provides periodic inspection and examination of the containment liner and its integral attachments. The program is conducted in accordance with ASME Code,Section XI, Subsection IWE, subject to the limitations and modifications in 10 CFR 50.55a(b)(2),

10 CFR 50.55a(g)(4), and 10 CFR 50.55a(g)(6). Under the program, surfaces are examined for evidence of cracking, discoloration, wear, pitting, excessive corrosion, arc strikes, gouges, surface discontinuities, dents, or other signs of surface irregularities; pressure-retaining bolting is examined for loosening and material conditions that affect either containment leak-tightness or structural integrity; and moisture barriers are visually inspected for degradation. Acceptability of inaccessible areas of the liner is evaluated when conditions found in accessible areas indicate the presence of, or could result in, flaws or degradation in inaccessible areas.

The licensee indicated that during the Unit 3 refueling outage in October 2010, a scheduled visual examination of the containment liner plate in the reactor cavity sump revealed significant corrosion in a localized region of the vertical wall section, immediately adjacent to the concrete floor. Metallurgical investigation determined that the corrosion was caused by chemical attack from boric acid and the root cause was determined to be degradation of a coating system that was not designed for immersion service. Corrective actions were taken to remove the degraded portion of the liner plate and weld in replacement plate in accordance with the rules of the ASME Code, and the condition was entered into the Turkey Point Corrective Action Program.

Visual inspections of the moisture barrier in 2015 on Unit 3 and in 2016 on Unit 4 noted various areas of damaged or degraded sealant. The moisture barrier is a watertight seal installed between the concrete cover slab and the containment wall liner. The sealant was found to have physical damage, loss of adhesion and tearing, and was repaired in accordance with ASME Code,Section XI, Subsection IWE. Engineering evaluations determined that these conditions did not constitute degradation of the liner.

Table 3.2.1-2 of Enclosure 1 to the submittal reflects the inspections scheduled for the Third Interval. The table identified that no component has been identified as requiring augmented examination. The NRC staff noted that Turkey Point utilizes an IWE data management system to schedule and track the inspections for individual components. The licensee discusses several instances in which the visual inspections identified small signs of degradation that initiated more detailed evaluations that identified a larger degradation. This resulted in the repair of these boundaries prior to jeopardizing the containment integrity.

The NRC staff reviewed the licensees testing schedule against the conditions in NEI 94-01, Revision 2-A. As the proposed prior testing should identify structural problems that may affect either the containment structure leakage integrity or the performance of the Type A test, and the schedule continues to provide a supplemental means of identifying potential containment degradation, the NRC staff finds the proposed schedule acceptable.

The IWL Program at Turkey Point provides periodic inspection and examination of the concrete containment and post-tensioning system in accordance with ASME Code,Section XI, Subsection IWL, subject to the limitations and modifications in 10 CFR 50.55a(b)(2),

10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(6) and TS 3.6.1.6. Under the IWL program, accessible concrete surfaces are subject to visual inspections to detect deterioration and distress. Tendon wires and anchorage hardware surfaces are inspected for loss of material, cracking, and mechanical damage. The tendon corrosion protection medium is tested for the pH, presence of free water, and soluble ion concentration. Individual wires are removed from selected sample tendons and tested for yield strength, ultimate tensile strength, and elongation.

Turkey Point has recently completed the Second 10-Year Inspection Interval (9/9/08 thru 9/9/18), which included the 40th Year Surveillance (2012) and the 45th Year Surveillance (2017) and was performed pursuant to the 2001 Edition thru the 2003 Addenda of Section XI of the ASME Code. The most recent 45th Year Surveillance consisted of a visual inspection of Unit 3 and a physical inspection of Unit 4 since Turkey Point exercised the option allowed by IWL-2421(b) for dual unit sites utilizing the same pre-stressing system. The scope of the Second Interval IWL examinations included Examination Category L-A, Concrete, that includes examination of all accessible surface areas and suspect areas, and Examination Category L-B, Unbonded Post-Tensioning System. The submittal stated that the inspection reports for both surveillances (40th and 45th Year) concluded that the containment structure had experienced no abnormal degradation of the post-tensioning systems. Measured tendon forces were all within acceptance limits, and tendon test wires had acceptable results. Visual examinations of the concrete found no significant issues. Some loss of corrosion medium (grease) was detected for a number of tendons. No active corrosion was found on tendon ends and anchorage components. All indications were documented and will continue to be monitored for evidence of degradation.

In Section 3.2.3 of Enclosure 1 to the submittal, the licensee stated that the Turkey Point Containment Leak Rate Testing Program also includes requirements for visual inspection of accessible interior and exterior surfaces of the containment structure in accordance with several TS requirements to identify deterioration that may affect the structural integrity or leak-tightness of the containment. The Program currently requires these examinations prior to initiating a Type A test and during two other refueling outages before the next Type A test. If the interval for the Type A test is extended to 15 years, NEI 94-01, Revision 3-A, states that a general visual examination of accessible interior and exterior surfaces must be conducted prior to each Type A test and during at least three other outages before the next Type A test. Examinations performed under ASME IWE/IWL Programs may be credited for the subject visual inspections of the containment.

Based on the above, the NRC staff finds that the licensee has an adequate containment inspection program in place at Turkey Point as demonstrated by the implementation of overlapping inspection activities performed as part of the IWE/IWL programs and activities developed to support renewal of the original operating license. These programs periodically examine, monitor and manage structural deterioration, and aging degradation of the containment pressure boundary such that the primary containment can perform its intended function as a leak-tight barrier.

3.1.4 Tests and Inspections Performed following Major Modifications to the Containment Structure (Revision 2-A Condition 4)

In Section 3.4 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for NEI 94-01, Revision 2-A were met. The fourth condition states that the licensee should address any tests and inspections performed following major modifications to the containment structure. The licensee indicated that major modifications to the containment structure occurred when openings were cut in the containment to support replacement activities for the steam generators and the reactor vessel heads.

In its submittal, the licensee states that in general, the NRC staff considers the cutting of a large hole in the containment for replacement of steam generators or reactor vessel heads or replacement of large penetrations, to be a major repair or modification to the containment. The licensee states that such repairs already occurred on both Units. The licensee performed a

Type A test following the completion of the repairs. As short duration structural tests of the containment were performed consistent with the condition in NEI 94-01, Revision 2-A, the NRC staff finds the licensee has acceptably addressed the tests and inspections performed following major modifications to the containment structure.

3.1.5 Demonstration of Unforeseen Emergent Condition (Revision 2-A Condition 5)

In Section 3.4 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for NEI 94-01, Revision 2-A were met. The NRC staff believes that extensions of the performance-based Type A test interval beyond the required 15 years should be infrequent and used only for compelling reasons. Therefore, the fifth condition states that the licensee must obtain NRC permission to extend Type A testing beyond 15 years.

The NRC staff notes that the licensee indicated that any request for an extension beyond the 15-year interval must be justified in accordance with the NRC staffs position contained in RIS 2008-27. The licensee stated that if an extension beyond the 15-year interval is needed, it will request prior NRC approval pursuant to 10 CFR 50.90.

Therefore, the NRC finds that the licensee will request NRC approval for any extension of the Type A test interval beyond the upper-bound performance-based limit of 15 years and that any requested permission (i.e., for such an extension) will demonstrate to the NRC staff that an unforeseen emergent condition exists.

3.1.6 Deferral of Extension Until After Construction (Revision 2-A Condition 6)

The sixth condition is applicable only to plants licensed under 10 CFR Part 52; as such it is not applicable to Turkey Point.

3.1.7 Conclusion Regarding Applicability of Conditions for NEI 94-01, Revision 2-A Based on the above evaluation of each condition, the NRC staff finds that the licensee satisfies the conditions and limitations of NEI 94-01, Revision 2-A, to support extending the frequency of the Type A Integrated Leak Rate Test from 10 to 15 years and allow the extension of the containment isolation valves leakage test intervals (i.e., Type C tests) from their current 60-month frequency to 75 months.

3.2 CONFIRMATION OF APPLICABILITY AND CONDITIONS EPRI TR-1009325, REVISION 2-A The purpose of EPRI TR-1009325, Revision 2-A is to provide a generic assessment of the risks associated with a permanent extension of the ILRT surveillance interval to 15 years, and a risk-informed methodology/template to be used to confirm the risk impact of the ILRT extension on a plant-specific basis. Various PRA methods are used, in combination with ILRT performance data and other considerations, to justify the extension of the ILRT surveillance interval.

3.2.1 Technical Adequacy of Plant Specific Probabilistic Risk Assessment (Revision 2-A Condition 1)

In Section 3.5 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for EPRI TR-1009325, Revision 2-A were met. The first condition states that the licensee should document that the technical adequacy of their PRA is consistent with the requirements of RG 1.200 relevant to the ILRT extension application.

The licensee addresses the Turkey Point PRA technical adequacy in Section 3.5.2 and , Turkey Point Nuclear Plant Permanent ILRT Interval Extension Risk Assessment, of Enclosure 1 to the submittal. The licensee indicated that the Turkey Point risk assessment performed to support the ILRT application utilized the current models for Internal Events, Internal Flood, and Fire PRA models. These models and all of the PRA upgrades have been peer-reviewed. The licensee states that the PRA models credited in this request are the PRA models used in the NRC approved NFPA 805 application (ADAMS Accession No. ML15061A237) with maintenance updates applied. Capability Category II of the NRC-endorsed ASME/ANS PRA Standard was the target capability level for the NFPA 805 application and was found to be technically acceptable by the NRC staff.

Appendix A1 of Enclosure 3 to the submittal provides a more detailed discussion of the external hazard evaluations and the PRA acceptability for the ILRT interval extension risk impact assessment. The information in Appendix A1 of Enclosure 3 demonstrates that the PRA is of sufficient quality and level of detail to support this submittal and has been subjected to a peer-review process assessed against the appropriate standards.

3.2.2 Estimated Risk Increase with permanent ILRT Surveillance Interval is Small (Revision 2-A Condition 2)

In Section 3.5 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for EPRI TR-1009325, Revision 2-A were met. The second condition states that the licensee should demonstrate that the estimated risk increase associated with permanently extending the ILRT surveillance interval to 15 years is small, and consistent with the clarification provided in the NRC staffs safety evaluation (SE) indicating that appropriate application of the Jeffreys non-informative prior distribution in the baseline analysis is required.

The second condition stipulates that the licensee submit documentation indicating that the estimated risk increase associated with permanently extending the ILRT interval to 15 years is small, consistent with the guidance in RG 1.174 and the clarification provided in Section 4.2 of the NRC SE for NEI 94-01, Revision 2, and EPRI TR-1009325, Revision 2-A. Specifically, a "small" increase in population dose should be defined as an increase in population dose of less than or equal to either 1.0 person-rem per year or 1 percent of the total population dose, whichever is less restrictive. In addition, a "small" increase in conditional containment failure probability (CCFP) should be defined as a value marginally greater than that accepted in previous one-time 15-year ILRT extension requests. This would require that the increase in CCFP be less than or equal to 1.5 percentage points. Lastly, for plants that rely on containment over-pressure for net positive suction head (NPSH) for ECCS injection, both core damage frequency (CDF) and large early release frequency (LERF) will be considered in the ILRT evaluation and compared with the risk acceptance guidelines in RG 1.174. The RG 1.174 defines very small changes in risk as resulting in increases of CDF and LERF of less than 1.0E-6/year, and 1.0E-07/year (yr), respectively. Thus, the associated risk metrics include LERF, population dose, CCFP, delta CDF and LERF

The licensee reported the results of the plant-specific risk assessment in Section 5.6 of to the submittal. External events are considered in Section 6.3. The reported risk impacts are based on a change in the Type A containment ILRT frequency from three tests in 10 years (the test frequency under 10 CFR Part 50, Appendix J, Option A) to one test in 15 years and account for the risk from undetected containment leaks due to steel liner corrosion.

Based on the review of Sections 5.6 and 6.3 of Enclosure 3 to the submittal, the NRC staff determined there is no quantifiable change in CDF as a result of the proposed ILRT Type A test interval extension. Therefore, the RG 1.174 acceptance guideline for a very small change in CDF is considered to be met as the impact on CDF for the Type A test interval extension is negligible. Thus, the relevant acceptance criterion is LERF. The resulting total LERF for Unit 3 is approximately 1.89E-06/yr. The resulting total LERF for Unit 4 is approximately 2.14E-06/yr.

The licensee demonstrated that the total LERF for both Units 3 and 4 are below the RG 1.174 acceptance criteria for total LERF of 1.0E-05/yr , and therefore this change satisfies both the incremental and absolute criteria with regards to the RG 1.174 LERF metric.

3.2.3 Calculation of the Increase in Expected Population Dose (Revision 2-A Condition 3)

In Section 3.5 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for EPRI TR-1009325, Revision 2-A were met. The third condition stipulates that the average leak rate for the pre-existing containment large leak rate accident case (i.e., accident case 3b) used by the licensees should be 100 La (maximum allowable leak rate) instead of 35 La. As noted by the licensee in Table 3.5.1 of Enclosure 1 to the submittal, the methodology in EPRI TR-1009325, Revision 2-A incorporated the use of 100 La as the average leak rate for the pre-existing containment large leakage rate accident case (accident case 3b), and this value has been used in the Turkey Point plant-specific risk assessment. Accordingly, the third condition is considered met.

3.2.4 Reliance on Containment Overpressure (Revision 2-A Condition 4)

In Section 3.5 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for EPRI TR-1009325, Revision 2-A were met. The fourth condition stipulates that a request for a license amendment would be required in instances where containment over-pressure is relied upon for ECCS performance. In Table 3.5.1 of Enclosure 1 of the submittal, the licensee states that Turkey Point does not rely on containment overpressure for ECCS performance. The NRC staff confirmed that credit for containment overpressure was not taken to support ECCS performance. Accordingly, the fourth condition is not applicable.

3.2.5 Conclusion Regarding Applicability of Conditions for EPRI TR-1009325, Revision 2-A In summary, the independence of barriers will not be degraded as a result of the requested change, and the use of the quantitative risk metrics collectively ensure that the balance between prevention of core damage, prevention of containment failure, and consequence mitigation is preserved. Therefore, NRC staff finds that the licensee satisfies the conditions and limitations associated with EPRI TR-1009325, Revision 2-A.

3.3 CONFIRMATION OF APPLICABILITY AND CONDITIONS NEI 94-10, REVISION 3-A The purpose of NEI 94-01, Revision 3-A is to provide guidance for implementing the Appendix J performance-based requirements and incorporates, by reference, the provisions of ANSI/ANS-56.8-2002 and the requirements of Subsections IWE and IWL of Section XI of the ASME Boiler & Pressure Vessel Code. The ASME Code requirements are incorporated by reference in 10 CFR 50.55a, with modifications and limitations. The modifications and limitations vary in accordance with the applicable edition and the addenda of the ASME Code as required by 10 CFR 50.55a. As discussed in the June 8, 2012 approval, the NRC staff has found that the use of NEI TR 94-01, Revision 3 is an acceptable reference for use in licensee TSs to extend the Option B to 10 CFR Part 50, Appendix J, Type B test and Type C test intervals beyond 60 months, provided two conditions are satisfied.

3.3.1 Post Outage Report Leak Rate Summation Margin (Revision 3-A Condition 1)

In Section 3.4.2 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for NEI 94-01, Revision 3-A were met. The first condition states that the licensee should include the margin between the leakage rate summation and the regulatory limit for Type B and Type C, LLRTs. Condition 1 presents three (3) separate issues that are required to be addressed:

Issue 1 - The allowance of an extended interval for Type C, LLRTs of 75 months carries the requirement that a licensee's post-outage report include the margin between the Type B and Type C leakage rate summation and its regulatory limit; Issue 2 - A corrective action plan shall be developed to restore the margin to an acceptable level; and, Issue 3 - The use of the allowed 9-month extension for eligible Type C valves is only authorized for non-routine emergent conditions.

The NRC staff reviewed NEI TR 94-01, Revision 3 against the licensees responses for the three issues associated with Condition 1 in Section 3.4.2 of Enclosure 1 to the submittal. The NRC staff confirmed that the licensee established its intent to comply with these requirements.

Accordingly, the NRC staff considers the first condition met.

3.3.2 Scheduling of Any LLRT Interval Beyond 60-Months (Revision 3-A Condition 2)

In Section 3.4.2 of Enclosure 1 of the submittal, the licensee outlined how the conditions of the approval for NEI 94-01, Revision 3-A were met. Condition 2 presents two (2) separate issues that are to be addressed:

Issue 1 - Extending the Type C, LLRT intervals beyond 5 years to a 75-month interval should be similarly conservative provided an estimate is made of the potential understatement and its acceptability determined as part of the trending specified in NEI TR 94-01, Revision 3-A, Section 12.1; and,

Issue 2 - When routinely scheduling any LLRT valve inspection interval beyond 60-months and up to 75-months, the primary containment leakage rate testing program trending or monitoring must include an estimate of the amount of understatement in the Type B and C total and must be included in a licensee's post-outage report. The report must include the reasoning and determination of the acceptability of the extension, demonstrating that the LLRT totals calculated represent the actual leakage potential of the penetrations.

The NRC staff reviewed NEI TR 94-01, Revision 3-A against the licensees responses for the two issues associated with Condition 2 in Section 3.4.2 of Enclosure 1 to the submittal. The June 8, 2012, NRC approval for NEI TR 94-01, Revision 3 indicates that allowing for longer intervals between LLRTs means that more leakage rate test results from farther back-in time are summed with fewer just tested penetrations and that total used to assess the current containment leakage potential. This leads to the possibility that the LLRT totals calculated understate the actual leakage potential of the penetrations. Given the required margin included with the performance criterion and the considerable extra margin most plants consistently show with their testing, any understatement of the LLRT total using a 5-year test frequency is thought to be conservatively credited. Extending the LLRT intervals beyond 5 years to a 75-month interval should be similarly conservative provided an estimate is made of the potential understatement and its acceptability determined. The NRC staff confirmed that the licensee established its intent to comply with the understatement and scheduling requirements. In addition, the licensee confirmed that the estimate would be included in the post-outage report to support demonstrating that the totals calculated reflect the actual leakage potential of the penetrations. Accordingly, the NRC staff considers the second condition met.

3.3.3 Conclusion Regarding Applicability of Conditions for NEI TR 94-01, Revision 3-A Type C testing is intended to ensure that individual containment isolation valves are essentially leak-tight. In addition, aggregate Type C leakage rates support the leakage tightness of primary containment by minimizing potential leakage paths. In summary, the NRC staff finds that completion of these conditions as indicated by the licensee provides reasonable assurance that Type C, LLRT at an extended periodicity will ensure that Type C components maintain their intended functions during the period of extended operation.

3.4 Licensees Proposal for Extension of Type A Test Interval up to 15 Years As discussed in the submittal, the licensee justified the proposed change, in part, by demonstrating adequate performance of the Turkey Point containment based on plant-specific containment leakage testing program results and a plant-specific risk assessment. The NRC staff reviewed the licensees performance history with regard to containment structural and leak-tight integrity, to support the request to extend the current ILRT interval to 15 years.

3.4.1 Turkey Point Type A Test Performance History As indicated above, TS 6.8.4.h, requires the performance of Type A testing in accordance with 10 CFR Part 50, Appendix J, Option B. Previously, the licensees leak rate test methods followed Bechtel TR BN-TOP-1, Testing Criteria for Integrated Leakage Rate Testing of Primary Containment Structures for Nuclear Power Plants or ANSI/ANS-56.8-2002. Both of these methods use the Absolute Method for calculation of the containment air mass, but the determination of leakage rate differs.

The Turkey Point containment was analyzed to a peak containment accident pressure, Pa, of 49.9 psig. Per TS, the maximum containment leakage rate at Pa was 0.25 percent of containment air weight per day. Following the implementation of an extended power uprate, the licensee recalculated the peak containment accident pressure and increased Pa to 55.0 psig.

The maximum allowable containment leakage at Pa has changed to 0.20 percent of containment air weight per day. , Section 3.1.1, Tables 3.1.1-1 and 3.1.1-2 present the results of past Type A tests for Turkey Point Unit 3 and 4. In the submittal, the licensee indicates that all Type A tests results were within the TS limits.

NEI 94-01, Revision 3-A, Section 9.2.3, defines acceptable performance history as successful completion of two consecutive periodic Type A tests where the calculated performance leakage rate was less than 1.0 La. The staff finds that the licensee has demonstrated acceptable performance history. Since the licensee has demonstrated adequate ILRT test performance history, a test frequency of 15 years in accordance with NEI 94-01, Revision 3-A and the conditions and limitations of NEI 94-01, Revision 2-A would be acceptable for Turkey Point.

Based on the historical Turkey Point ILRT test results, the NRC staff concludes that the requirements of Sections 9.1.2 and 9.2.3 of NEI 94-01, Revision 3-A have been satisfied.

3.4.2. Turkey Type B and Type C Test Performance History 3.4.2.1 As-Left Leakage Rate Test Results Turkey Point TS 6.8.4.h, requires that a program be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B. The containment leakage rate testing program requires testing of electrical penetrations, airlocks, hatches, flanges, and containment isolation valves in accordance with 10 CFR Part 50, Appendix J, Option B and RG 1.163. Turkey Point combined as-left leakage rate for all penetrations shall be less than 0.60 La or 166,355 standard cubic centimeters per minute (sccm). In Section 3.1.2 of Enclosure 1 to the submittal, the licensee indicated that the Type B & C test results from 2009 through 2019 show generally very good performance of the penetrations. The submittal further indicates that in the Unit 4 2016 refueling outage the as-found combined leakage rate for a check valve was 250,000 sccm or 150 percent of the acceptance criteria. The licensee determined that the check valve had been retained within the Containment Leakage Rate Testing Program for defense in depth purposes; however, since the check valve was not required to be included within the program, the licensee subsequently removed the valve from it.

The licensee indicated that for Turkey Point Unit 3, the past three outages found one (1) Type B penetration and three (3) Type C penetrations exceeded their administrative leakage limits.

However, the as-found minimum pathway combined leakage was determined to be within administrative limits. All valves were repaired, and the as-left results were within their administrative leakage limits.

The licensee indicated that for Turkey Point Unit 4, the past three outages found all Type B penetrations to be satisfactory, but five (5) Type C penetrations were found to exceed their administrative leakage limits. However, the as-found minimum pathway combined leakage was determined to be within administrative limits. All valves were repaired, and the as-left results were within their administrative leakage limits. Subsequently, the licensee evaluated the

charging pump to regen heat exchanger check valve, and determined that the valve was part of a closed-loop and did not need to be included in the Containment Leakage Rate Testing Program and therefore, it was removed from the program.

Based on the review of the data contained in the Tables 3.1.2-1 and 3.1.2-2, the NRC staff concluded that the aggregate results of the As-Found Minimum Pathway and As-Left Minimum Pathway for all the Type B and C tests from 2009 through 2019 demonstrate a history of successful tests since the aggregate test results were significantly less than the Type B and Type C test TS limit of 0.60 La contained in TS 6.8.4.h.

The licensees submittal indicates that for Unit 3 the total number of Type B tested components that are on an extended performance-based test interval is 54 out of 57 eligible components, which is 95 percent of eligible components. The three (3) eligible penetrations that are not on an extended performance-based test interval are the fuel transfer tube (Pen. No. 39), equipment hatch (Pen. No. 40), and a service penetration (Pen. No. 65A),

which are opened each outage and therefore remain on a one-cycle interval. Historical test results for all eligible Type B components on Unit 3 were provided in Table 3.1.3-2 pf to the submittal, which shows that there are no Type B penetrations on-base interval due to performance. Table 3.1.3-2 groups these components into thirteen (13) different penetrations; Pen. No. 38 includes 42 components and Pen. No 48 includes 6 components. The NRC staff noted that Pen. No 39 failed its most recent test, but the penetration was already excluded from the extended performance-based test interval, since it is open every refueling.

The submittal indicates that for Unit 4 the total number of Type B tested components that are on an extended performance-based test interval is 55 out of 58 eligible components, which is 95 percent of eligible components. The three (3) eligible penetrations that are not on extended performance-based test interval are the fuel transfer tube (Pen. No 39), equipment hatch (Pen. No. 40), and a service penetration (Pen. No. 65A), which are opened each outage and therefore remain on a one-cycle interval. Historical test results on Unit 4 for all eligible Type B components were provided in submittal Table 3.1.3-4 which shows that no Type B penetrations have failed their latest two leakage tests. Table 3.1.3-4 groups these components into fifteen (15) different penetrations; Pen. No. 38 includes 41 components and Pen. No 48 includes 6 components.

The submittal indicates that for Unit 3, the total number of Type C tested penetrations that are on an extended performance-based test interval is seventeen (17) out of twenty-six (26) eligible penetrations, which is 65 percent of eligible penetrations. Table 3.1.3-6 of Enclosure 1 to the submittal identifies for Unit 3 all the eligible penetrations and the current test frequency. The eligible penetrations not on extended intervals are:

Pen. No. 6 PRT Nitrogen Supply; Pen. No. 19A Containment Spray (Header A);

Pen. No. 19B Containment Spray (Header B);

Pen. No. 23 Containment Sump Discharge; Pen. No. 29 Instrument Air Supply; Pen. No. 31 RCDT Gas Analyzer Sample; Pen. No. 32 Cont. Air Sample Return; Pen. No. 34 Service Air Supply; Pen. No. 42 Nitrogen Supply to SI Accumulators.

Penetrations No. 6, 29, 32 and 42 are excluded from the extended performance-based test interval due to ASME Section XI, inservice test (IST) requirements for the associated check valves; these penetrations remain on one-cycle interval. Penetration No. 31 has received maintenance that could impact the leak-tightness; therefore, the licensee has reset the test frequency to one-cycle interval until acceptable test history is established.

Penetrations No. 19A, 19B, and 23 are excluded from the extended performance-based test interval as a conservative measure. The NRC staff noted that the leakage rates for penetration 19A, valve MOV-3-880A 3-883M were less than 77 percent of the administrative Limit.

The results of the two (2) most recent Type C tests identified two (2) penetrations that exceeded the administrative limits. Penetration 34, valve 3-40-204 demonstrated a leak rate of 10,500 sccm, or 119 percent of the administrative limit. The licensee inspected the valve and identified degradation in the valve seat; the valve was repaired and restored to within allowed leakage rate. The penetration has been placed back on a one-cycle interval until satisfactory test history is reestablished.

Penetration No. 36 is considered a purge valve, which per NEI 94-01, Section 10.2 are limited to intervals of 30 months; thus, these are considered not eligible for extended performance-based test interval. The licensee indicated that this penetration is currently on a 9-month leakage test interval.

The submittal indicates that for Unit 4 the total number of Type C tested penetrations that are on an extended performance-based test interval is seventeen (17) out of twenty-six (26) eligible penetrations, which is 65 percent of eligible penetrations. Table 3.1.3-8 of Enclosure 1 to the submittal identifies for Unit 4 all eligible penetrations and the current test frequency. The eligible penetrations not on extended intervals are:

Pen. No. 6 PRT Nitrogen Supply; Pen. No. 19A Containment Spray (Header A);

Pen. No. 19B Containment Spray (Header B);

Pen. No. 20 RCS Hot Leg Sample; Pen. No. 23 Containment Sump Discharge; Pen. No. 29 Instrument Air Supply; Pen. No. 32 Cont. Air Sample Return; Pen. No. 33 Containment Air Sample; Pen. No. 42 Nitrogen Supply to SI Accumulators.

The results of the two (2) most recent Type C tests are summarized in Table 3.1.3 Unit 4 Type C Penetrations - Most Recent Testing. Penetrations No. 6, 29, 32 and 42 are excluded from the extended performance-based test interval due to ASME Section XI IST requirements for the associated check valves; these penetrations remain on one-cycle interval. Penetrations No. 20, 23, and 33 received maintenance or valve replacement; therefore, the licensee has reset the test frequency to one-cycle interval until acceptable test history is established.

Penetration No. 19A was excluded from the extended performance-based test interval as a conservative measure; the valve leakage remained within administrative limits, but this valve is similar to Penetration 19B, which has experienced recent performance issues.

Penetration No. 19B, Containment Spray Header B, exceeded administrative limits in its latest test. This valve has experienced excessive leakage in two of its last three most recent tests.

The licensee inspected the valve and identified significant accumulation of rust deposits around the valve seats. In 2019, the valve was subject of a corrective overhaul, and is currently on a one-cycle interval. The as-left testing resulted in satisfactory leakage, within administrative limits. Penetration No. 19B is currently on a one-cycle interval.

Given the results provided in Section 3.1 of Enclosure 1 to the submittal, the NRC staff concludes that the Type B and Type C components on extended frequencies have demonstrated good performance and supports allowing an extended test interval of up to 75 months for Type C tested CIVs in accordance with the guidance of NEI 94-01, Revision 3-A.

3.4.2.2 Corrective Actions The NRC staff reviewed the corrective actions identified in Section 3.1.2 of Enclosure 1 to the submittal associated with the following Units 3 and 4 valves:

CV-3-855 in PT3-28; Valve 3-40-204 in PT3-29; POV-3-2602 in PT3-30; CK-4-312C in PT4-29; CK-4-890B in PT4-29; CV-4-2822 in PT4-29; CK-4-11-003 in PT4-29; and, CK-4-890B in PT4-31.

The NRC staff found that the licensee identified the cause of the valve failures and performed adequate repairs that resulted in as-left leakage values within acceptable values. Except for Unit 4, valve CK-4-890B, the repaired valves did not have recurrent performance issues. Valve CK-4-890B was overhauled during the last refueling, and it is currently on a one-cycle testing interval. The NRC staff also noted that a minority of Type C components (35 percent, 9 of 26 components in each unit) currently requires testing every refueling outage.

In summary, the NRC staff concludes that:

the cumulative Type B and C test results were below the acceptance limit of TS 6.8.4.h, the licensee has a corrective action program that appropriately addresses poor- performing valves.

Therefore, the NRC staff finds that the licensee is effectively implementing the Type B and Type C leakage rate test program, as required by Option B of 10 CFR Part 50, Appendix J.

3.4.3 Containment Inspection Program In Section 3.2 of Enclosure 1 to the submittal, the licensee indicates that inspections performed to fulfill the requirements in 10 CFR 50.55a and 10 CFR Part 50, Appendix J, such as the ASME Section XI, Subsection IWE/IWL Program, and the Containment Leakage Rate Testing Program, will provide continuing supplemental means of identifying potential containment degradation that may affect leak-tightness. These inspections examine the containment system

for signs of degradation, damage, and other irregularities and provide assurance that degradation of the containment is detected and corrected. ASME Subsection IWE requires visual examinations three-times within a 10-year interval for ASME Class MC components and their integral attachments, whereas IWL requires two examinations within a 10-year interval for ASME Class CC components and their integral attachments. The licensee also stated that overlapping inspection activities are also performed as part of the Containment Inservice Inspection Program and the Containment Coatings Inspection and Assessment Program.

3.4.3.1 ASME IWE Program As stated in the submittal, the IWE Program at Turkey Point provides periodic inspection and examination of the containment liner and its integral attachments. The program is conducted in accordance with ASME Code,Section XI, Subsection IWE, subject to the limitations and modifications in 10 CFR 50.55a(b)(2), 10 CFR 50.55a(g)(4), and 10 CFR 50.55a(g)(6). Under the program, surfaces are examined for evidence of cracking, discoloration, wear, pitting, excessive corrosion, arc strikes, gouges, surface discontinuities, dents, or other signs of surface irregularities; pressure-retaining bolting is examined for loosening and material conditions that affect either containment leak-tightness or structural integrity; and moisture barriers are visually inspected for degradation. Acceptability of inaccessible areas of the liner is evaluated when conditions found in accessible areas indicate the presence of, or could result in, flaws or degradation in inaccessible areas.

Turkey Point is currently in the Third 10-Year Inspection Interval, which began on July 15, 2018 and is scheduled to end on July 14, 2028. This interval will be conducted in accordance with the 2007 Edition of ASME Code,Section XI, with Addenda through 2008 as modified by 10 CFR 50.55a. The submittal stated that during the Unit 3 refueling outage in October 2010, a scheduled visual examination of the containment liner plate in the reactor cavity sump revealed significant corrosion in a localized region of the vertical wall section, immediately adjacent to the concrete floor. The Metallurgical investigation determined that the corrosion was caused by a chemical attack from boric acid and the root cause was determined to be degradation of a coating system that was not designed for immersion service. Corrective actions were taken to remove the degraded portion of the liner plate and weld in replacement plate in accordance with the rules of the ASME Code, and the condition was entered into the Turkey Point Corrective Action Program.

Visual inspections of the moisture barrier in 2015 on Unit 3 and in 2016 on Unit 4 noted various areas of damaged or degraded sealant. The moisture barrier is a watertight seal installed between the concrete cover slab and the containment wall liner. The sealant was found to have physical damage, loss of adhesion and tearing, and was repaired in accordance with ASME Section XI, Subsection IWE. Engineering evaluations determined that these conditions did not constitute degradation of the liner.

3.4.3.2 ASME IWL Program The IWL Program at Turkey Point provides periodic inspection and examination of the concrete containment and post-tensioning system in accordance with ASME Code,Section XI, Subsection IWL, subject to the limitations and modifications in 10 CFR 50.55a(b)(2),

10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(6) and TS 3.6.1.6. Under the IWL program, accessible concrete surfaces are subject to visual inspections to detect deterioration and distress. Tendon wires and anchorage hardware surfaces are inspected for loss of material, cracking, and mechanical damage. The tendon corrosion protection medium is tested for the pH, presence of free water, and soluble ion concentration. Individual wires are removed from selected sample tendons and tested for yield strength, ultimate tensile strength, and elongation.

Turkey Point has recently completed the Second 10-Year Inspection Interval (9/9/08 thru 9/9/18), which included the 40th Year Surveillance (2012) and the 45th Year Surveillance (2017) and was performed pursuant to the 2001 Edition thru the 2003 Addenda of Section XI of the ASME Code. The most recent 45th Year Surveillance consisted of a visual inspection of Unit 3 and a physical inspection of Unit 4 since Turkey Point exercised the option allowed by IWL-2421(b) for dual unit sites utilizing the same pre-stressing system. The scope of the Second Interval IWL examinations included Examination Category L-A, Concrete, that includes examination of all accessible surface areas and suspect areas, and Examination Category L-B, Unbonded Post-Tensioning System. The submittal stated that the inspection reports for both surveillances (40th and 45th Year) concluded that the containment structure had experienced no abnormal degradation of the post-tensioning systems. Measured tendon forces were all within acceptance limits and tendon test wires had acceptable results. Visual examinations of the concrete found no significant issues. Some loss of corrosion medium (grease) was detected for a number of tendons. No active corrosion was found on tendon ends and anchorage components. All indications were documented and will continue to be monitored for evidence of degradation.

In Section 3.2.3 of the Enclosure to the submittal, the licensee stated that the Turkey Point Containment Leak Rate Testing Program also includes requirements for visual inspection of accessible interior and exterior surfaces of the containment structure in accordance with several TS requirements to identify deterioration that may affect the structural integrity or leak-tightness of the containment. The Program currently requires these examinations prior to initiating a Type A test and during two other refueling outages before the next Type A test. If the interval for the Type A test is extended to 15 years, NEI 94-01, Revision 3-A, requires that a general visual examination of accessible interior and exterior surfaces be conducted prior to each Type A test and during at least three other outages before the next Type A test. Examinations performed under ASME IWE/IWL Programs may be credited for the subject visual inspections of the containment.

Based on the above, the NRC staff finds that the licensee has an adequate containment inspection program in place at Turkey Point as demonstrated by the implementation of overlapping inspection activities performed as part of the IWE/IWL programs and activities developed to support renewal of the original operating license. These programs periodically examine, monitor and manage structural deterioration, and aging degradation of the containment pressure boundary such that the primary containment can perform its intended function as a leak-tight barrier.

3.4.3.3 FPL Evaluation of NRC Information Notices In submittal Section 3.3 of Enclosure 1 to the submittal, the licensee reviewed several NRC Information Notices (INs) related to containment corrosion that may be applicable to the Turkey Point containment.

The NRC issued IN 92-20, Inadequate Local Leak Rate Testing, to alert licensees to problems with local leak rate testing of two-ply stainless-steel bellows used on piping penetrations at some plants. The licensee stated in the submittal that Turkey Point piping and ventilation penetrations are of the rigid welded type and are solidly anchored to the containment wall, thus precluding any requirement for expansion bellows.

The NRC issued IN 2011-15, Steel Containment Degradation and Associated License Renewal Aging Management Issues, dated August 1, 2011, to describe the mechanisms that can lead to degradation of coatings and pitting of containment liner plates due to long term exposure to water and moisture. The operating experience described in IN 2011-15 relates to containment liner corrosion that results from the liner plates being in contact with objects and materials that are lodged between or embedded in the containment concrete. Liner locations that are in contact with objects made of an organic material are susceptible to accelerated corrosion because organic materials can trap water that combined with oxygen will promote carbon steel corrosion. At Turkey Point, there has been no operating experience of liner corrosion attributed to the inaccessible (concrete) side of the liner.

The NRC issued IN 2014-07, Degradation of Leak Chase Channel Systems for Floor Welds of Metal Containment Shell and Concrete Containment Metallic Liner, dated May 5, 2014, to inform licensees of issues concerning degradation of floor weld leak chase channel systems of steel containment shell and concrete containment metallic liner that could affect leak-tightness and aging management of containment structures. The IN describes operating experience that is concerned about the omission of Code-required exams that were masked by other components and were therefore not included in the IWE database.

The submittal stated that Turkey Point has an air chase system inside containment structures similar to the leak chase system discussed in IN 2014-07. Walk-downs for accessible air chase test connection condition were conducted during 2014 (Unit 4) and 2015 (Unit 3) refueling outages. Further, the submittal stated the test connection (grouted pipe cap) condition was determined to be satisfactory or indeterminate (inaccessible), and there has been no evidence of moisture intrusion through the accessible air chase system test connections to inaccessible portions of the containment liner plate. Lastly, the submittal stated the IWE inspection plan will be updated to formally include general visual inspection of 100 percent of the accessible air chase system test connections at the containment floor-level interfaces along with the opening of any identified loose or degraded test connections for internal inspection.

3.4.3.4 Containment Inspection Program Conclusion Based on the review of information in the submittal, the NRC staff finds that the licensee effectively manages existing containment inspection programs of IWE and IWL to the requirements of

ASME Code,Section XI and the conditions in 10 CFR Part 50.55a, and responsively addresses industry events for applicability to Turkey Point. Therefore, the NRC staff concludes that the periodic visual inspection programs performed as part of the containment leakage rate testing and the overlapping inspection activities performed as part of the Containment lnservice Inspection Program and Containment Coatings Inspection and Assessment Program, support the licensees request to extend containment leakage rate test frequency.

3.5 Overall Evaluation of the Proposed Extension of ILRT and LLRT Test Intervals The NRC staff reviewed the Type A, Type B and Type C leakage test results related to the licensees proposal to extend 10 CFR Part 50, Appendix J test intervals in Section 3.1.1 of to the submittal. The ILRT results provided indicate that the previous two consecutive Type A tests at Turkey Point Unit 3 and 4 were successful with containment performance leakage rates less than the maximum allowable containment leakage rate contained in TS 6.8.4.h. Therefore, the NRC staff finds that the performance history of Type A tests supports extending the current ILRT interval on a permanent basis to 15 years as permitted by NEI 94-01, Revision 3-A and the conditions and limitations of NEI 94-01, Revision 2-A.

The NRC staff reviewed the local leak rate summaries contained in Tables 3.1.2-1 and 3.1.2-2 of Enclosure 1 to the submittal and notes that the aggregate results of the As-Found Minimum Pathway and As-Left Maximum Pathway for all the recent (i.e., since Unit 3 refueling in 2009)

Type B and C tests are less than the Type B and Type C test TS limit of 0.60 La contained in TS 6.8.4.h. The NRC staff reviewed the corrective actions identified in Section 3.1.2 of to the submittal taken for the valves that failed the leakage test. The NRC staff concludes that adequate corrective action for the failed valves has been performed. Therefore, the NRC staff finds that the licensee is effectively implementing the Type B and Type C leakage rate test program, as required by 10 CFR Part 50, Appendix J, Option B. Accordingly, the NRC staff finds that the performance history of Type B tests and Type C tests supports extending the current Type C test interval to 75 months as permitted by NEI 94-01, Revision 3-A.

3.6 Technical Specification Change As discussed in Section 1.1 of this SE, the proposed changes would revise TS 6.8.4.h, by replacing the reference to RG 1.163 with a reference to NEI 94-01, Revision 3-A. The first two deviations or exemptions from RG 1.163 to implement the performance-based leakage testing program in accordance with Option B of 10 CFR Part 50, Appendix J will be removed and third will be renumbered. The NRC staff reviewed the proposed administrative changes to the TS to assess whether the proposed content and format changes would have a significant effect on safety. The NRC staff found that the proposed replacements, renumbering, and revisions, will not have a substantive affect on the successful implementation of the Containment Leakage Rate Testing Program and are therefore acceptable.

3.7 Conclusion Based on the NRC staff review of the licensees submittal dated January 27, 2020, and the regulatory and technical evaluations above, the NRC staff finds that there is reasonable assurance that the licensee has addressed the NRC conditions to demonstrate acceptability of adopting NEI 94-01, Revision 3-A and the conditions and limitations specified in NEI 94-01, Revision 2-A, as the 10 CFR Part 50, Appendix J, Option B implementation documents.

The NRC staff finds that the licensee adequately implemented its Containment Leakage Rate Testing Program (i.e., Type A, B, and C leakage tests), for the Turkey Point containment. The results of past ILRTs and recent LLRTs demonstrate acceptable performance of the Turkey Point containment and demonstrate that the structural and leak-tight integrity of the containment structure is adequately maintained. The NRC staff also finds that the structural and leak-tight integrity of the Turkey Point containment will continue to be monitored and maintained if Turkey Point adopts NEI 94-01, Revision 3-A and the conditions and limitations specified in NEI 94-01, Revision 2-A, as the 10 CFR Part 50, Appendix J, Option B implementation documents.

Accordingly, the NRC staff determined that there is reasonable assurance that the structural and leak-tight integrity for the Turkey Point containment will continue to be maintained, without undue risk to public health and safety, if the current Type A test intervals are extended to 15 years and if the current Type C test intervals are extended to 75-months.

The NRC staff concludes that it is acceptable for Turkey Point to (i) revise TS 6.8.4.h, to adopt NEI 94-01, Revision 3-A and the conditions and limitations specified in NEI 94-01, Revision 2-A as the 10 CFR Part 50, Appendix J, Option B implementation documents; (ii) extend on a permanent basis the Type A test interval up to 15 years; and (iii) extend the Type C test intervals up to 75-months.

4.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 REFERENCES

5.1 Letter from Florida Power & Light Company to U.S. Nuclear Regulatory Commission, License Amendment Request 268. Request to Extend Containment Leakage Rate Test Frequency, Docket Nos. 50-250 and 50-251, Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41, dated January 27, 2020 (ADAMS Accession No. ML20034D803).

5.2 Nuclear Energy Institute (NEI) TR NEI 94-01, Revision 3-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, dated July 31, 2012, (ADAMS Accession No. ML12221A202).

5.3 Nuclear Energy Institute Topical Report 94-01, Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, November 19, 2008, (ADAMS Accession No. ML100620847).

5.4 U.S. Nuclear Regulatory Commission, Regulatory Guide 1.163, Performance-Based Containment Leak-Rate Testing Program, dated September 30, 1995, (ADAMS Accession No. ML003740058).

5.5 U.S. Nuclear Regulatory Commission, NRC Staff Safety Evaluation, Final Safety Evaluation for Nuclear Energy Institute Topical Report (TR) 94-01, Revision 2, Industry Guideline For Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, and Electric Power Research Institute (EPRI) Report No. 1009325, Revision 2, August 2007, Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals, dated June 25, 2008, (ADAMS Accession No. ML081140105).

5.6 Nuclear Energy Institute Topical Report NEI 94-01, Revision 2, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, and Electric Power Research Institute Report No. 1009325, Revision 2, August 2007, Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals, dated August 31, 2007, (ADAMS Accession No. ML072970206).

5.7 Letter from S. Bahadur (NRC) to B. Bradley (NEI), Final Safety Evaluation of Nuclear Energy Institute (NEI) Report 94-01, Revision 3, Industry Guideline for Implementing Performance- Based Option of 10 CFR Part 50, Appendix J (TAC No. ME2164), dated June 8, 2012, (ADAMS Accession No. ML121030286).

5.8 U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2008-27, Staff Position on Extension of the Containment Type A Test Interval Beyond 15 Years Under Option B of Appendix J to 10 CFR Part 50, dated December 8, 2008, (ADAMS Accession No. ML080020394).

Principal Contributors: SMehta, NRR RHernandez, NRR RPettis, NRR

ML21032A020 *by memorandum **by e-mail OFFICE DORL/LPL2-2/PM** DORL/LPL2-2/LA** DSS/SPCB/BC** DEX/ESEB/BC**

NAME EBrown BAbeywickrama BWittick JCollacino DATE 01/14/2021 01/21/2021 08/10/2020 12/01/2020 OFFICE DRA/APLB/BC** DSS/STSB/BC** OGC-NLO** NRR/DORL/LPL2-2/BC**

NAME KHsueh VCusamano AGhoshNaber UShoop DATE 08/07/2020 01/29/2021 02/19/2021 02/26/2021