ML18341A024
| ML18341A024 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/25/2019 |
| From: | Eric Oesterle NRC/NRR/DMLR/MRPB |
| To: | Nazar M Florida Power & Light Co |
| Lois James | |
| References | |
| EPID L-2018-RNW-0002 | |
| Download: ML18341A024 (18) | |
Text
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January 25, 2019 Mr. Mano Nazaar President, Nuclear Division and Chief Nuclear Officer 700 Universe Blvd EX/JB Juno Beach, FL 33408
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNITS 3 AND 4 - REPORT FOR THE ON-SITE REGULATORY AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2018-RNW-0002)
Dear Mr. Nazar:
By letters dated January 30, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18037A812), as supplemented, Florida Power & Light Company (FPL) submitted an application for subsequent license renewal of Renewed Facility Operating License Nos. DPR-31 and DPR-41 for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point) to the U.S. Nuclear Regulatory Commission (NRC) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and part 54 of title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants.
The staff of the U.S. Nuclear Regulatory Commission (NRC) completed an on-site regulatory audit from August 27-31, 2018, in accordance with the on-site regulatory audit plan (ADAMS Accession No. ML18232A576). The audit report is enclosed.
If you have any questions, please contact by Mr. Bill Rogers, the audit manager by telephone at 301-415-2945 or by e-mail at Bill.Rogers@nrc.gov.
Sincerely,
/RA Bill Roger for/
Eric R. Oesterle, Branch Chief License Renewal Project Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Audit Report cc w/encl: Listserv
ML18341A024 OFFICE PM:MRPB:DMLR LA:MRPB:DMLR BC:MRPB:DMLR NAME BRogers SLent EOesterle (BRoger for)
DATE 1/23/2019 12/27/2018 1/25/2019
Audit Report On-Site Regulatory Audit Regarding the Turkey Point Nuclear Generating Units 3 and 4, Subsequent License Renewal Application August 27 - 31, 2018 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF MATERIALS AND LICENSE RENEWAL Docket Nos: 50-250 and 50-251 License No: DPR-31 and DPR-41 Licensee: Florida Power & Light Company Facility: Turkey Point Nuclear Generating Units 3 and 4 Location: Homestead, Florida Dates: August 27-31, 2018 Reviewers: B. Rogers, Project Manager, DMLR B. Wittick, Branch Chief, DE A. Buford, Structural Engineer, DE S. Cuadrado de Jesús, General Engineer, DE J. López, Structural Engineer, DE A. Prinaris, Structural Engineer, DE D. Hoang, Structural Engineer, DE A. Chereskin, Chemical Engineer, DMLR W. Holston, Sr. Mechanical Engineer, DMLR S. Jones, Sr. Reactor Systems Engineer, DSS
Report for the On-Site Regulatory Audit Regarding the Turkey Point Nuclear Generating Units 3 and 4, Subsequent License Renewal Application
- 1. Introduction The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted an in-office audit of Florida Power & Light Companys (FPLs or the applicants) (1) methodology to identify the systems, structures and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR) (Scoping and Screening Portion), and (2) aging management programs (AMPs), AMR items, Time-Limited Aging Analyses (TLAA) and associated bases and documentation as applicable (AMP and TLAA Portion).
This regulatory audit is a follow-up from the in-office regulatory conducted between June 18 -
July 13, 2018. The scope of this audit focuses on areas where the NRC staff needed to observe, walkdown, or verify site information in order to conclude the scoping and screening methodology audit, or AMP, AMR, and TLAA audit. The specific areas of focus during the audit are provided below:
- SLRA AMP B.2.3.33, 10 CFR Part 50, Appendix J
- SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis
- Scoping and Screening of Non-Safety Systems with Potential for Spatial Interactions
- 2. Audit Activities The following sections discuss the areas reviewed by the staff.
SLRA AMP B.2.2.3, Concrete Containment Unbonded Tendon Prestress; SLRA AMP B.2.3.31, American Society of Mechanical Engineers (ASME) Section XI, Subsection IWL; and SLRA TLAA 4.5, Concrete Containment Tendon Prestress Audit Activities. During its audit, the staff conducted walkdowns of areas external to the concrete containment structure. In addition, the staff interviewed the applicants staff and reviewed the 20th through the 45th year of tendon and concrete containment surveillances, onsite documentation provided by the applicant, action reports (ARs), and other relevant documents identified in the table below.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit.
Relevant Documents Reviewed Document Title Revision / Date PTN [Turkey Point]/BFSC-00-2001 30TH YEAR TENDON INSPECTION Revision (R)0, 06/19/2000 (TENDON Selection and Lift-Off Criteria)
PTN/PSC-01-TP-004-000 Precision Surveillance Corporation Revision 0, 11/07/2001 (PSC): TURKEY POINT NUCLEAR PLANT UNITS 3 & 4 30TH YEAR CONTAINMENT TENDON SURVEILLANCE PTN/PSC-TP-N981-500 PSC - 35TH YEAR CONTAINMENT Revision 1, 04/16/2007 TENDON SURVEILLANCE AT TURKEY POINT (Scope of Work)
PTN/PSC-TP-N981-501 PSC - 35TH YEAR CONTAINMENT Revision 1, 04/16/2007 TENDON SURVEILLANCE AT TURKEY POINT (Tendon Selection, Normalization, and Lift-Off Criteria)
PTN/PSC-TP-N981-502 PSC - 35TH YEAR CONTAINMENT Revision 1, 04/16/2007 TENDON SURVEILLANCE AT TURKEY POINT (Technical Requirements)
PTN/PSC-TP-N981-504 PSC - 35TH YEAR CONTAINMENT Revision 0, 12/08/2006 TENDON SURVEILLANCE AT TURKEY POINT (Engineering Evaluation)
PTN/PSC-TP-N981-508 PSC - 35TH YEAR CONTAINMENT Revision 0, 05/25/2007 TENDON SURVEILLANCE AT TURKEY POINT (Final Report)
PTN/PSC-TP-N1075-501 PSC - 40TH YEAR IWL Revision 0, 11/14/2011 CONTAINMENT TENDON SURVEILLANCE AT TURKEY POINT (Tendon Selection and Predicted Forces)
PTN/PSC-TP-N1075-502 PSC - 40TH YEAR IWL Revision 1, 02/16/2012 CONTAINMENT TENDON SURVEILLANCE AT TURKEY POINT (Technical Requirements)
PTN/PSC-TP-N1130-502 PSC - 45TH YEAR IWL Revision 0, 08/10/2016 CONTAINMENT TENDON SURVEILLANCE AT TURKEY POINT (Technical Requirements)
PTN/PSC-TP-N1130-505 PSC - 45TH YEAR IWL Revision 0, 08/10/2016 CONTAINMENT TENDON SURVEILLANCE AT TURKEY POINT (Tendon Walkdown Results)
PTN/PSC-TP-N1130-506 PSC - 45TH YEAR IWL R0, 02/17/2017 CONTAINMENT TENDON SURVEILLANCE AT TURKEY POINT (Unit 4 FCR Predicted Forces Summary)
REP-1130-300* PSC - 45TH YEAR IWL R1, 03/02/2017 CONTAINMENT TENDON SURVEILLANCE AT TURKEY POINT (Comparative Analysis of Methods Used to calculate Predicted Forces)
REP-1130-510* PSC - 45TH YR U3 & U4 TENDON R0, 06/27/2017 SURVEILLANCE AT TURKEY POINT (Final Report)
REP-1130-511* PSC - 45TH YR SURVEILLANCE AT TURKEY POINT (Regression R0, 06/27/2017 Analysis)
N1130_000 PSC - FPL TURKEY POINT R1, 08/10/2016 NUCLEAR PLANT UNITS 3 & 4 45TH YEAR CONTAINMENT BUILDING TENDON I2-ISI-IWL-PTN-3-4 SURVEILLANCE (Post Tensioning R1, 05/18/2016 System ISI Manual)
TURKEY POINT UNITS 3 AND 4 - ASME SECTION XI, SUBSECTION IWL, INTERVAL 2, CONCRETE CONTAINMENT ISI PROGRAM N/A DOCUMENTED in R4 IN N/A REQUEST 4 - LIST OF 45TH YEAR TENDON ARs C-SJ599-11 BECHTEL - TURKEY POINT R0, 12/14/1994 UNITS 3 & 4 (Containment Structure Final Analysis Results for All Load Combinations)
C-SJ539-05 BECHTEL - TURKEY POINT R0, 06/08/1992 UNITS 3 & 4 (Evaluation of the 15TH Year Tendon Surveillance Lift-Off Forces)
C-SJ539-02 BECHTEL - TURKEY POINT UNIT R5, 02/01/1993 3 (Determination of Lift-Off Forces for 20TH Year Tendon Surveillance)
C-SJ539-09 BECHTEL - TURKEY POINT R1, 01/16/1993 NUCLEAR PLANT UNITS 3 & 4 (Probable Cause for Low Lift Off Forces on Hoop Tendons)
C-SJ561-01 BECHTEL - TURKEY POINT R4, 12/08/1992 UNITS 3 & 4 (Determination of Lift-Off Forces for Unit 4 20TH Year Tendon Surveillance)
C-SJ561-03 BECHTEL - TURKEY POINT R1, 01/16/1993 UNITS 3 & 4 (Evaluation of the Unit 4 20TH Year Tendon Surveillance Low Lift-Off Forces)
PTN-BFJC-95-029 25TH YEAR TENDON R1, 09/19/1996 SURVEILLANCE (Random Tendon Selection)
PTN-BFJC-95-031 25TH YEAR TENDON R0, 08/30/1996 SURVEILLANCE (Predicted Lower and Upper Limits and Normalizing Factors)
AR 1920613 Issues Replacing Anodes, 11/14/2013 Containment Cathodic Protection AR 2216534 Containment Cathodic Protection 07/24/2017 System Non-Functional ML172277A837 Turkey Point Nuclear Generating 10/02/2017 Station - NRC Design Basis Assurance Inspection (Team)
Report Turkey Point Units 3 and 4 Updated Chapter 5, Structures and 8 R 29 FSAR Chapter 8, Electrical Systems AR 2184466 U3 Loss of Tendon Grease 02/08/2017 Exceeds 10% of Volume AR 1679310 Leakage from Tendon Ends in 08/19/2011 U3/U4 Tendon Gallery AR 1959317 Unusual Stains - U3 NE 04/18/2014 Containment Building Tendon Caps AR 2184350 U3, Grease Leakage from tendon 02/08/2017 End Caps AR 1786466 U3 Containment Tendon (Leaking 07/21/2012 Oil)
AR 2196366 U4, Containment Inspection 04/04/2017 Excessive Grease Leakage During the audit and review of the above documentation, the staff made the following observations and expressed concerns regarding corrosion of concrete containment tendons, tendon anchorages, and concrete containment reinforcing bars:
- Turkey Point currently uses grease as a corrosion protection medium for Turkey Point tendons. Staff review of Turkey Point operating experience (OE) and of PSC documents indicate that tendon end caps leaking grease is a reoccurring issue at Turkey Point. Documentation shows that at times replenished grease has been in excess of 10 percent of the total grease volume, which indicates that significant leakage is occurring (per the ASME Section XI, Subsection IWL Code).
It is not clear how tendons maintain a continuous corrosion protection medium and how the applicants ASME Section XI, Subsection IWL AMP will manage grease volume and potential excessive leakage to ensure that grease maintains its function in preventing corrosion of containment tendons during the subsequent period of extended operation.
- Tendon anchorages have revealed signs of corrosion and inspected tendons have shown that water seepage has occurred inside tendons (as indicated, for example, in PTN-PSC-01-TP-004 and AR 1679310). Although tendons were covered with a grease residue some corrosion was found in areas originally filled with grease which is an indication that grease volume is insufficient to protect against corrosion. It is not clear whether the end caps provide adequate protection against water intrusion within the anchorage and tendon sheathing.
- Turkey Point has used in the past a cathodic protection system for corrosion protection of embedded containment steel components (e.g., rebars) and tendon anchorages. The cathodic protection system, however, has been inoperative since 2009 (as indicated in PTN AR 1920613) having achieved its end of life. During the audit, the applicant stated that the cathodic protection system and its effectiveness is being re-evaluated (as indicated in PTN AR 02216534) for potential reactivation. In SLRA Section 2.4, the applicant stated that the cathodic protection system is not in scope and thus not credited for corrosion protection. Since documentation that the staff reviewed indicates that the cathodic protection system was used to prevent corrosion of rebar and tendon components and the system has been reviewed by Bechtel's Metallurgy and Quality Control Department and FPL's CSI (Component, Support & Inspections) corrosion specialists for corrosion protection (as noted in the Updated Final Safety Analysis Report (UFSAR)) it is not clear how the applicant plans to manage corrosion for these components without its contribution, or, if measures were (are) taken to replace the function of the cathodic protection system.
- Below ground level, horizontal tendons and their anchorages are serviceable through access enclosures that are external to containment. These enclosures are accessible and are normally covered with metal plates. The staff noted during the audit that these enclosures have previously been filled with water; lack of drainage of the vaults has resulted in submergence of tendon anchorages that can lead to their corrosion. In discussions with the applicant during the onsite audit (and indicated in the SLRA), the staff noted that these areas are not within the scope of license renewal. Chronic or periodic submergence of tendon anchorages can cause accelerated aging effects to tendon components as well as to local concrete containment reinforcement. It is not clear how these areas will be effectively age managed to prevent loss of functionality of the local reinforcement and tendon anchorages.
During the audit and review of the above onsite documentation the staff made the following observations and expressed concerns regarding the identification and documentation of Unit 3 and Unit 4 prestessed concrete containments as twin containments and the methodology used to document tendon relaxation in the SLRA through the subsequent period of extended operation.
SLRA AMP B.2.3.17 Outdoor and Large Atmospheric Metallic Storage Tanks Audit Activities. During its audit, the staff conducted walkdowns of the condensate storage tanks (CST), primary water storage tanks (PWST), refueling water storage tanks (RWST),
demineralized storage tank (DWST), Unit 3 and 4 diesel oil storage tanks (DOST) and the raw water tanks (RWT). In addition, the staff reviewed onsite documentation provided by the applicant.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit.
Relevant Documents Reviewed Document Title Revision / Date 5614-M-724 Emergency Diesel Generator Building Plan and Sections Revision 0 5614-M-731 Emergency Diesel Generators 4A & 4B Piping Sections Revision 0 5614-P-869 Diesel Oil System Revision 3 5614-P-867 Diesel Oil System Revision 2 5614-M-3022 Emergency Diesel Engine and Oil System EDG 4A Fuel Revision 7 System 5614-M-725 Emergency Diesel Generator 4A & 4B Piping Plans Revision 0 The staff made the following observations during walkdowns:
- During the walkdown of all of the cited tanks, the tank to concrete interface joint appeared to be sealed with either an elastomeric compound or an unknown hard material. Except in minor degraded areas, the interface joint is coated. In addition, in some locations there was evidence of a white residue, potentially comprised of salt deposits.
- During the walkdown of the CSTs the staff noted that: (a) although the tank base to concrete interface is above ground elevation, there is an approximately 1/2- inch deep depressed area that could accumulate moisture around the entire circumference of each tank; (b) on both tanks there is an approximately 3-inch long area where what appears to be sealant material is missing; (c) in some areas there is a greenish substance appearing to be a mold, indicating the pervasive presence of moisture; (d) on the southeast side of the Unit 3 tank, there are locations of heavy corrosion at the base although absent indications of severe loss of material; (e) the Unit 4 tank exhibited some moderate corrosion at the tank base to concrete interface; and (f) some areas of the sealant material have an uneven application and are depressed, which will accumulate moisture.
- During the walkdown of the PWSTs the staff noted that: (a) there are some locations where the ground slopes towards the tank to concrete interface; (b) the tank to concrete interface is essentially at ground elevation; (c) two anchor bolts on the northeast side of the Unit 3 tank and two on the west side of the Unit 4 tank exhibited minor corrosion; and (d) some areas of the sealant are damaged.
- During the walkdown of the RWSTs the staff noted that: (a) there are some locations where the ground slopes towards the tank to concrete interface; (b) the tank to concrete interface is essentially at ground elevation including some areas where the area is covered with stone and some sediment; (c) there is sporadic light corrosion at the tank base; and (d) on the west side of both tanks, the sealant is damaged.
- During the walkdown of the DWSTs the staff noted that: (a) the tank to concrete interface is approximately 12-inches above grade; and (b) in the north-north east quadrant there are indications of minor corrosion at the base in sparse locations.
- During the walkdown of the Unit 3 DOST the staff noted that: (a) the tank to concrete interface is approximately 3-inches above grade; and (b) there are locations of heavy surface corrosion at the base (approximately 15 percent of the circumference). There was no evidence of significant loss of material in the locations of heavy surface corrosion.
- During the walkdown of the Unit 4 DOST the staff noted that the manway enclosures, tank sample connections, and flame arrestors that penetrate the roof of the tank are sealed with an elastomeric compound.
- During the walkdown of the RWTs the staff noted that: (a) the tank to concrete interface is approximately 3-inches above grade, although there were some locations where the joint was covered by ground elevation stones and light sediment; and (b) there were some locations where the base exhibited moderate corrosion.
The staff made the following observation during the audit:
- The staff reviewed the above cited relevant documents and in conjunction with the walkdown of the 4A DOST, verified that with the exception of the manway enclosures, tank sample connections, and flame arrestors (all located on the top of the tank), all of the penetrations into the 4A DOST tank are located inside the attached emergency diesel generator building.
SLRA AMP B.2.3.33 10 CFR Part 50, Appendix J Audit Activities. During its audit, the staff conducted discussions with the applicants plant and fleet personnel regarding the implementation of 10 CFR Part 50, Appendix J testing. In addition, the staff reviewed onsite documentation provided by the applicant.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit.
RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date ER-AA-114 Appendix J Testing Program Revision 2 Attachment 12 Integrated Leak Rate Test 03/31/2005 PT4-28, Periodic Testing Turkey Point Nuclear Plant: 02/26/2015 Containment Leakage Rate Testing Types A, B and C (includes data from 4PT27 and 4PT28)
PT3-28, Periodic Testing Turkey Point Nuclear Plant: 02/23/2016 Containment Leakage Rate Testing Types A, B and C (includes data from 3PT27 and 3PT28)
During the audit the staff made the following observations:
- The staff reviewed fleet procedure ER-AA-114 and noted that Gray areas discussed in Section 5.2, Documentation Requirements are to resolve ONLY technical questions of how the containment system leakage testing will be performed.
- When Type B and Type C as-found/as-left local leakage rate test (LLRT) results are missed then the missing as-found and as-left LLRT quantities are counted as test penalties and incorporated as such into the integrated leakage rate test (ILRT) results.
SLRA AMP B.2.3.35, Structures Monitoring and SLRA AMP B.2.3.36, Inspection of Water Control Structures Associated with Nuclear Power Plants Audit Activities. During its audit, the staff conducted walkdowns of the Unit 3 and Unit 4 fuel handling buildings, CCW heat exchanger rooms, high safety injection pump rooms, auxiliary building, turbine buildings and the condenser pits, electrical manholes, common units AFW pump room, intake and discharge structures, the boundary (embankments) of the cooling canal, and yard structures. In addition, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. These activities were undertaken to assess the applicants operating experience and verify its Structures Monitoring Program effectiveness The table below lists the documents that were reviewed by the staff and were found relevant to the audit.
Document Title Revision / Date 0-ADM-561 Structures Monitoring Program Revision 7 EN-AA-206 Renewed License Process Revision 8 AR 1766347 Waste Gas Compressor Room (b) Concrete Ledge 05/11/2012 Delamination and Cracks (Auxiliary Building)
AR 1766352 South Wall Under Stairwell Concrete Delamination and 05/11/2012 Cracks (Auxiliary Building) 1110-0040-RPT-001 Review of Auxiliary Building and Fuel Handling Building Revision 0 Functionality Assessments and Apparent Cause Evaluation 1110-0040-RPT-002 Review of Fuel Handling Building with Crane Loading Revision 0 Conditions to Support Apparent Cause Evaluation 400149-CA-001 Unit 4 Fuel Handling Building West and North Wall Corrosion Revision 00A Condition Assessment Report 08/09/2018 200024-01 Unit 4 Fuel Handling Building Wall Evaluation Revision 00A 08/03/2018 AR 1800290 U-4 Spent Fuel Building Degraded Concrete 09/05/2012 AR 1800281 U-4 Spent Fuel Building Degraded Concrete 09/05/2012 CR 2263467-02 Unit 3 and 4 Fuel Handling Building Degraded Concrete 06/27/2017 AR 18822156 Concrete Spalling Noted in High-Safety injection Pump Room 11/10/2012 Trench AR 02237081 Unit 3 High-Safety Injection Pump Room Trench - Walkdown 11/20/2017 AR 1766607 NNS Pipe Supports, Conduit, and Conduit Supports, 05/12/2012 AR 1767712 U-3 Intake Structure (concrete spall and corroded rebar, 05/16/2012 corroded conduit supports)
AR 1793860 U-4 Auxiliary Bldg Degraded Concrete 09/28/2012 AR 2213207 Structures Monitoring Program Long Term Action Monitoring 12/08/2017 Inspection Requirements not being tracked AR 2239727 Major Gaps to Effectiveness - PTN Structures Monitoring 12/08/2017 Program SSMP-WKDN-001A Structures Monitoring Program Walkdown Report, Unit 3, Revision 1A Baseline SSMP-WKDN-001B Structures Monitoring Program Walkdown Report, Unit 4, Revision 1B Baseline
PTN-ENG-SECS-17-019 2017 PTN Structures Monitoring Program Report Revision 3 /
06/01/2018 FPLCORP020-REP-088 AMP Basis for Water Control Structures Program Revision 1 FPLCORP020-REPT- PTN Screening Results - Non-Containment Structures Revision 1 025 FPLCORP020-REPT- AMP Basis for Structures Monitoring Program Revision 1 107 SPEC-C-004 Engineering Maintenance Specification - Coating Revision 12 EC-282844 Turkey Point Cooling Canal System Sediment Removal Revision 2 EC-291348 Engineering Evaluation for Cooling Canal System Revision 0 AR 00597049 Concrete spalling east foundation wall of south condenser 01/14/2011 AR 01768157 Intake structure degraded steel and concrete 05/17/2012 AR 02010523 Concrete spalling on north side of Unit 4 Spent Fuel Pool 12/02/2014 AR 02036089 Unit 4 Spent Fuel Pool building concrete structures falling off 03/29/2015 on the top of Auxiliary building AR 01832119 Discharge structure corrosion on steel beam 12/12/2012 During walkdowns the staff made the following observations:
- During the walkdown of the Unit 4 fuel handling building the staff noted the following structural degradation in the exterior of the structure: (i) cracked concrete, (ii) delaminated and spalled concrete, and (iii) corroded uncovered rebar. The applicant identified the observed degradations in AR 1800281 and AR 1800290, and the conditions were evaluated as acceptable with deficiencies in the following reports: 400149-CA-001, 1110-0040-RPT-001 and 1110-0040-RPT-002. The staff notes that corrective action was transferred to AR 02010523 to be corrected under work order package (WOP) 40181604-01.
- During the walkdown of the auxiliary building the staff noted major cracks (no sign of water infiltration) and concrete delamination at the 2, 4 and 10 feet elevations of the structure. The applicant identified the observed degradations in AR 1766347 and AR 1766352, repairs were noted in most of the degraded areas, and the conditions were evaluated in AR 1766347 and report no. 1110-0040-RPT-001.
- During the walkdown of the cooling canal the staff noted the cooling canal boundary embankments are in good condition, with no signs of cracking, spalling or distortion. The water level to the top of the embankments varies from 3 to 7 feet on both sides of the embankments.
During the audit the staff made the following observations:
- The staff reviewed report number 400149-CA-001 and noted that the engineering assessment of the structure concluded that the west and north wall of Unit 4 fuel handling building currently have active corrosion with a medium to high corrosion rate, and attributed the on-ongoing degradation to the harsh environment present at the site where airborne chlorides are significant.
- The staff reviewed report number 1110-0040-RPT-001 and noted that the engineering assessment of the auxiliary building concluded that the degradation was caused by initial differential settlement due to its unique foundation design.
- The staff reviewed AR 1767712 and AR 0440745 and noted that engineering inspections have identified ongoing degradation due to corrosion in the Unit 3 intake concrete structure and conduit supports.
- The staff reviewed AR 1793860, where the applicant documented indications of concrete leaching on Turkey Point Unit 4 auxiliary building concrete east wall. The degradation was evaluated by the applicant and deemed not to affect the intended function of the structural component.
- The staff reviewed walkdown reports SSMP-WKDN-001A and SSMP-WKDN-001B and noted that most corrosion-related degradation in steel structures and components, and steel reinforcement in concrete structures can be attributed to the harsh environment present at the site where airborne chlorides are significant.
- The staff reviewed the 2017 walkdown report, PTN-ENG-SECS-17-019, and noted that the report did not provide quantitative criteria for identified degradation, and does not trend the degradation from the baseline inspection reports. (Report No. SSMP-WKDN-001A and SSMP-WKDN-001B). The document also did not appear to consistently disposition previous degradations between subsequent reports.
- The staff reviewed EN-AA-206 and verified that enhancements were implemented in the procedure to ensure that work orders are periodically reviewed using management-controlled systems to identify backlog (long-standing issues), and to ensure that significant item repairs are scheduled and performed.
- The staff reviewed 0-ADM-561 and verified that enhancements were implemented in Section 4.4 of the Structures Monitoring Program procedure to ensure that identified follow-up inspections are properly tracked, scheduled and performed using quality-controlled systems.
SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit.
RELEVANT DOCUMENTS REVIEWED Document Title Revision / Date AR 02276547 Unable to Locate Original Referenced Document for SLRA 08/18/2018 During the audit the staff made the following observation:
The staff reviewed AR 02276547 and was unable to verify the fatigue design requirements for containment penetrations other than piping penetrations (e.g. personnel airlocks, equipment hatch and/or personnel hatch, electrical penetrations, etc.). As described in AR 02276547, the applicant was unable to find the fatigue analysis referenced in UFSAR Section 16.3.5, Containment Liner Plate Fatigue, and described in UFSAR Appendix 5B, Section B.2.1. The staff notes that SLRA Section 4.6 references the analysis described in UFSAR Appendix 5B, Section B.2.1, to disposition the fatigue analysis of the containment liner and penetrations for Turkey Point. However, sufficient information was not available for the staff to evaluate the disposition associated with containment penetrations other than piping penetrations.
Scoping and Screening of Non-Safety Systems with Potential for Spatial Interactions Audit Activities. During its audit, the staff conducted walkdowns of the following areas to evaluate the potential for systems and components omitted from the scope of license renewal to have spatial interactions with safety-related systems, structures, and components:
- the emergency diesel generator and safety-related electrical distribution areas to evaluate the scoping of non-safety-related water systems with the potential to cause failure of the electrical equipment
- the areas of the turbine building containing safety-related electrical equipment to evaluate the scoping of non-safety-related power conversion systems with the potential to cause failure of the electrical equipment The table below lists the documents that were reviewed by the staff and were found relevant to the audit.
Relevant Documents Reviewed Document Title Revision / Date ER-AA-111 Flow-Accelerated Corrosion Program Revision 1 5613-M-3073, Sheet 3 Condensate System SLRA Piping and Instrumentation Diagram Revision 23 During walkdowns the staff made the following observations:
- Floor drains from the upper 480 Volt (V) enclosed switchgear rooms for both trains entered a common floor drain piping run that passed directly over one train of the vital 4 kilovolt (kV) switchgear in the enclosed room below the 480V switchgear rooms. Condensate from the 480V room air handling units was routed to the floor drains, and in-scope chilled water piping was also a potential source of water to the floor drains. The floor drain piping run had not been identified among the structures, systems, and components with the scope of license renewal. Although the water sources contained a limited inventory of water, the sensitivity of the indoor-rated switchgear to water and the potential for cross-train interaction increased the safety-significance.
- Sumps collecting air handling unit condensate within each of the 4 kV switchgear rooms (two trains in each Unit 3 and Unit 4) were drained by non-safety sump pumps with vertical discharge piping. Intermittent operation of the sump pump creates the potential to spray nearby safety-related 4kV switchgear if the discharge piping failed.
- In addition to the safety-related turbine-driven auxiliary feedwater pumps, the staff noted that safety-related breakers/controllers for motor-operated valves and associated wiring were located within outdoor-rated electrical cabinets in the general turbine building area below the operating deck. The SLRA stated that spatial protection was provided by including steam and power conversion system piping within the scope of license renewal. However, the staff identified that large diameter piping identified as feedwater heater bypass piping was not included within the scope of license renewal and was
located in the general turbine building area below the operating deck where failure of high energy piping could affect safety-related equipment. The applicants staff indicated that exclusion of the piping from the scope of license renewal for high-energy interaction potential was acceptable due to infrequent use consistent with the Turkey Point licensing basis for high-energy line break protection.