L-2019-019, Subsequent License Renewal Application Safety Review - December 20, 2018 Public Meeting Action Item Responses

Subsequent License Renewal Application Safety Review - December 20, 2018 Public Meeting Action Item Responses

ML19035A195
Person / Time
Site:	Turkey Point
Issue date:	01/31/2019
From:	Maher W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2019-019
Download: ML19035A195 (43)

Text

L-2019-019 10 CFR 54.17 January 31, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Florida Power & Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review - December 20, 2018 Public Meeting Action Item Responses

References:

1. FPL Letter L-2018-004 to NRC dated January 30, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application (ADAMS Accession No.

ML18037A812)

2. FPL Letter L-2018-082 to NRC dated,April 10, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application - Revision 1 (ADAMS Accession No.

ML18113A134)

3. NRC Public Meeting Updated Agenda dated November 20, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application (ADAMS Accession No. ML18353A571)

4. FPL Letter L-2018-166 to NRC dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application - Safety Review Requests for Additional information (RAI) Set 3 Responses (ADAMS Accession No.

ML18296A024)

On April 10, 2018, Florida Power & Light Company (FPL) submitted to the NRC Revision 1 of the subsequent license renewal application (SLRA) for Turkey Point Units 3 and 4 (Reference 1), as well as supplemental information for the SLRA Environmental Report (ER) (Reference 2). On December 20, 2018, the NRC and FPL held a public meeting (teleconference) to discuss items associated with the safety review of the SLRA for Turkey Point Units 3 and 4 (Reference 3).

The purpose of this letter is to provide, as attachments to this letter, responses to the discussion topic action items assigned to FPL during the referenced public meeting.

These responses revise and supersede (or supplement) the corresponding RAI responses in Reference 4, and/or amend the SLRA (Reference 2). ;4021

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_F,_ori_da_P_ow_e_r_&_ug_h_tc_o_mp_a_ny_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ /Vf. (c 700 Universe Boulevard, Juno Beach, FL 33408

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2019-019 Page 2 of 2 If you have any questions, or need additional information, please contact me at 561-691-2294.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 31, 2019.

Sincerely, William Maher Senior Licensing Director Florida Power & Light Company WDM/RFO Attachments: 7 Public Meeting Action Item Responses (refer to Letter Attachment Index)

LETTER ATTACHMENT INDEX Attachment Action Item Response Attachment Action Item Response Set 3 RAI B.2.3.20-2 Fire Rated Assemblies 1 5 Response Revision AMR Revision SLRA Appendix B Set 3 RAI B.2.3.27-2 2 6 Revision Response Supplement Transmission Conductor Set3 RAI B.2.3.11-1 3 7 AMR and XI E1 AMP Response Revision Revisions Fire Protection AMP '

4 Revision cc:

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

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.20-2 L-2019-019 Attachment 1 Page 1 of 7 NRC RAI Letter Nos. ML18243A006 and ML18243A007 dated September 17, 2018 One-Time Inspection, GALL AMP XI.M32 RAI 8.2.3.20-2

Background:

SLRA Table 3.2.2-2, states that carbon steel piping exposed internally to treated borated water wm be managed for loss of material by the Water Chemistry and One -

Time Inspection programs.

The "scope of program" program element of GALL-SLR AMP XI.M32 states the following:

1. The program cannot be used for structures or components with known age-related degradation mechanisms as determined based on a review of plant-specific and industry OE for the prior operating period.

Periodic inspections are proposed in these cases for structures or components with known age- related degradation.

During the audit, the staff reviewed AR 01638881, which states, "[t]here is a long history of Containment Spray carbon steel piping corrosion at PTN [Turkey Point]." Additionally, the AR states that the Containment Spray System Piping Inspection program was developed to perform ultrasonic testing (UT) with a 54 month frequency. The staff also noted that the AR states "corrosion product buildup can occur within the Containment Spray headers have been documented in several AR. .. " the AR goes on to state that most of the corrosion is considered to be general boric acid corrosion and there is also a buildup of bimetallic weld transition from carbon to stainless steel.

Issue:

It is not clear to the staff how the One-Time Inspection program will be sufficient for managing age-related degradation of carbon steel piping in the containment spray system, when a history of loss of material is apparent. The One-Time Inspection program states that the program cannot be used for structures or components with known age-related degradation mechanisms as determined based o_n a review of plant-specific and industry OE for the prior operating period. The program states that periodic inspections are proposed in these cases.

Request:

State the basis for using the One-Time Inspection program for carbon steel piping in the containment spray system. Alternatively, provide the following:

1. Provide a periodic inspection program that will be used to monitor the loss of material for carbon steel.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.20-2 L-2019-019 Attachment 1 Page 2 of 7

2. Provide the inspection frequency that will be used to monitor wall thinning for

• carbon steel piping in the containment spray system.

3. Provide how bimetallic corrosion (galvanic corrosion) will be managed for the weld transition from carbon to stainless steel.

FPL Response:

This revised RAI response supersedes in its entirety the RAI responses provided in of Reference 1 as discussed during the November 15, 2018 NRC public meeting with FPL (Reference 2) and Attachment 11 of Reference 3 as discussed during the December 20, 2018 NRC public meeting with FPL (Reference 4).

The carbon steel piping in the containment spray system is located inside containment and is partially filled with stagnant borated water, due to leakage through MOV-3/4-880A/B, up to a maximum water elevation of the refueling water storage tank of 65 feet.

The most susceptible locations to loss of material due to generic, pitting, crevice, galvanic, or boric acid corrosion are inspected using ultrasonic thickness measurements in accordance with the existing Containment Spray System Piping Inspection AMP. The inspections consider the most susceptible locations due to the bimetallic (galvanic) couplings on the stainless steel elbows to carbon steel pipe (on the replaced elbows) and the carbon steel elbows to the stainless steel pipe (near the containment penetration). The existing program calculates loss of material rates based on the UT measurements and either increases or decreases frequencies of inspections or replaces carbon steel pipe with stainless steel pipe as necessary. The frequency of these inspections were initially set to occur every outage, but the current inspection frequency is every five outages based on an evaluation of the observed loss of material rates and past replacement of limiting carbon steel elbows with stainless steel elbows.

Based on the site-specified operating experience obtained through the implementation of the Containment Spray System Piping Inspection AMP during the current license renewal period of extended operation (PEO), PTN has committed to replace the subject carbon steel piping with stainless steel piping prior to entry into the SLR subsequent period of extended operation (SPEO). The scope of the project involves the replacement of the carbon steel piping from the stainless steel to carbon steel bimetallic weld for the four contain'ment spray piping headers (3A, 3B, 4A and 4B) at penetrations P-19A and P-19B to a plant elevation of 65 feet inside containment. This will eliminate the loss of material and long-term loss of material aging effects for the carbon steel containment spray piping that is currently exposed to an internal environment of treated borated water. Note that visual inspection of the remaining carbon steel containment spray piping above the 65 foot elevation inside containment would still be required to manage the aging effects of loss of material due to the potential exposure to borated water leakage on the external surfaces of the piping and exposure to an internal and external environment of indoor uncontrolled air.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.20-2 L-2019-019 Attachment 1 Page 3 of 7 The PTN SLRA is revised to capture this commitment and eliminate the carbon steel piping material exposed to an internal environment of treated borated water.

References:

1. FPL Letter L-2018-166 to NRC dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 3 Responses (ADAMS Accession No. ML18296A024)

2. NRC Public Meeting Agenda dated November 5, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application (ADAMS Accession No. ML18315A004)

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

4. NRC Public Meeting Updated Agenda dated November 20, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application (ADAMS Accession No.

ML18353A571)

Associated SLRA Revisions:

SLRA Table 3.2-1, Table 3.2.2-2, and Table 17-3 are amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. 8.2.3.20-2 L-2019-019 Attachment 1 Page 4 of 7 Revise SLRA Table 3.2-1 Item 90 as follows:

Table 3.2-1: Summary of Aging Management Evaluations for the Engineered Safety Features Further Item Aging Effect/ Aging Management Evaluation Number Component Mechanism Programs Recommended Discussion 3.2-1, 090 Steel components Long-term loss of AMP XI.M32, No Consistent with NUREG-2191.

exposed to treated material due to general "One-Time Inspection" The One-Time Inspection AMP water, treated borated corrosion will be used to manage long-water, raw water term loss of material in the steel containment spray piping and the pressurizer relief tank

- exposed to treated borated water. The pressurizer relief tank is coated and the containment spray piping is normally empty.

Revise SLRA Table 3.2.2-2 as follows:

Table 3.2.2-2: Containment Spray - Summary of Aging Management Evaluation Aging Effect Aging Component Intended Requiring Management NUREG- Table 1 Type Function Material Environment Management Program 2191 Item Item Notes

~ Press1:1re Carbon +reated ben!:J term less One +ime V.J\..E 434- 3.2 1,090 A B01:1ndary steel berated vmter of material Inspection

~

~ Press1:1re Carbon +reated boss of 'Nater Chemistry - - H, B01:1ndary steel berated 1.vater material One +ime

~ Inspection

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRG RAI No. B.2.3.20-2 L-2019-019 Attachment 1 Page 5 of 7 Revise SLRA Table 3.2.2-2 notes and plant specific notes as follows:

Notes for Table 3.2.2-2 A. Consistent with component, material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

H. Aging effect not in NU REG 2191 for this component, material, and environment combination.

Plant Specific Notes for Table 3.2.2 2

1. Aging effect for this component, material, and environment combination is not in NU REG 2191. This line item is specific to the carbon steel piping header for containment spray. This portion of piping is normally drained but is flooded during system testing. The \'\later Chemistry and One Time Inspection AMPs are used to manage this aging effect as these AMPs are used to manage loss of material in other portions of the treated borated 1Nater systems. Note that long term loss of material is addressed by GALL line item V.A.E 434 and is included in this AMR as 111ell.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.20-2 L-2019-019 Attachment 1 Page 6 of 7 Revise SLRA Table 17-3, List of SLR Commitments and Implementation Schedule, to add new commitment 55.

Aging Management Implementation Schedule NUREG-2191 No. Program or Activity Commitment Section (Section) 55 Not applicable Not applicable Replace a portion of the Prior to:

existing PTN Units 3 and 4 PTN3: 12/01/2024 containment spra)l s)lstem PTN4: 12/01/2024 carbon steel piping inside containment with stainless steel piping. The scope of project involves the replacement of the carbon steel piping from the stainless steel to carbon steel bimetallic weld for the four containment spra)l piping headers {3A 1 38 1 4A and 48} at penetrations P-19A and P-198 to a plant elevation of 65 feet inside containment.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.20-2 L-2019-019 Attachment 1 Page 7 of 7 Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to SLRA Appendix B L-2019-019 Attachment 2 Page 1 of 1 ASME Section XI lnservice Inspection, Subsections IWB, IWC, and IWD, GALL AMP XI.M1:

Discussion:

This response revises SLRA Appendix B.2.3.3 to correct the typographical error by changing the "PTN ASME Section XI, Subsection IWF AMP" to the "PTN ASME Section XI, Subsections IWB, IWC, and IWD AMP".

References:

None Associated SLRA Revisions:

SLRA Section B.2.3.3 ("Exceptions to NUREG-2191" paragraph) is amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revision.

NUREG-2191 recommends, as a preventive measure that can reduce the potential for SSC or IGSCC, using bolting material for the reactor head closure studs that have an actual measured yield strength limited to less than 1,034 megapascals (MPa) (150 kilo pounds per square inch (ksi)) (NUREG-1339). PTN closure stud bolting is considered high strength steel (Section 3.1.2.1.3), and PTN is taking exception to Element 2(d), Preventive Actions. The exception is acceptable because PTN meets all other program element requirements for reactor head closure stud bolting and will enhance the program so that replacement bolts are limited to a yield strength of 150 ksi. In addition, PTN performs volumetric inspection of high-strength bolting for cracking under the PTN ASME Section XI, Subsection§.

.J.WJ;: IWB, IWC, and IWD AMP.

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 1 of 16 NRC RAI Letter Nos. ML18243A006 and ML18243A007 dated September 17, 2018 Open Cycle Cooling Water System, GALL AMP XI.M20 Regulatory Basis:

Section 54.21 (a)(3) of 10 CFR requires an applicant to demonstrate that the effects of

. aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. As described in the SRP-SLR, an applicant may demonstrate compliance with 10 CFR 54.21 (a)(3) by referencing the GALL-SLR Report.

In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

RAI 8.2.3.11-1

Background:

The recommendations in Aging Management Program XI.M20, "Open-Cycle Cooling Water System" (OCCW) in Generic Aging Lessons Learned for Subsequent License Renewal (GALL- SLR) Report state that the scope of program addresses piping and piping components exposed to raw water in the OCCW system. Enercon Report FPLCORP020.:.REPT-082, Aging M.a1:1agement Program Basis Document - Open-Cycle Cooling Water System," Revision 1 shows that the only implementing document associated with piping inspections is SPEC-M-086, "Intake Cooling Water System Piping Inspection."

Issue:

The staff noted that SPEC-M-086 describes the scope of the inspection procedure to include selected piping with nominal diameters of 24 inches or larger and did not specify inspection requirements for piping with diameters less than 24 inches. Drawing 5614-M-3019, Revision 28, "Intake Cooling Water System," appears to include in-scope OCCW piping with diameters less than 24 inches.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 2 of 16 Request:

Discuss how the applicable aging effects (e.g., loss of material, flow blockage) for in-scope OCCW piping with diameters less than 24 inches are managed by the OCCW program. Describe the inspections that are performed on in-scope OCCW piping with diameters less than 24 inches and cite any relevant procedures that address inspections of this piping.

FPL Response:

This revised RAI response supersedes in its entirety the RAI responses provided in Attachment 34 of Reference 1 discussed during the November 15, 2018 NRC public meeting with FPL (Reference 2) and Attachment 12 of Reference 3 discussed during

,the December 20, 2018 NRC public meeting with FPL (Reference 4).

For the current license renewal period of extended operation, the scope of the Intake Cooling Water System Inspection Program for piping is limited to the following:

• Piping from the ICW pump discharge check valves to the component cooling water (CCW) b_asket strainers

• Piping from the ICW pump discharge check valves to the turbine plant cooling water (TPCW) baskets strainers For SLR, the Open-Cycle Cooling Water (OCCW) System AMP will replace the current Intake Cooling Water System Inspection Program. The scope of the OCCW System AMP for piping will be expanded to include:

• Piping from the ICW pump discharge flanges to the inlet flanges of the component cooling ~ater (CCW) heat exchangers

• Piping from the ICW pump discharge flanges to the turbine plant cooling water (TPCW) baskets strainers This expanded piping scope for the OCCW System AMP now includes gray cast iron piping with diameters greater than 20 inches. The aging effects of ICW piping outside the boundaries of the OCCW System AMP and exposed to an internal environment of raw water are managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP and the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP if the component is coated.

The OCCW System AMP will also include portions of the ICW pump casings exposed to raw water.

A number of AMR line items from Table 3.3.2-1 of the PTN SLRA are updated to reflect this scope of the PTN Open-Cycle Cooling Water System AMP.

Turkey Point Units 3 and 4 .

Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 3 of 16

References:

1. FPL Letter L-2018-166 to NRC dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 3 Responses (ADAMS Accession No. ML18296A024)

2. NRC Public Meeting Updated Agenda dated November 5, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application (ADAMS Accession No.

ML18315A004)

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

4. NRC Public Meeting Updated Agenda dated November 20, 2018, Telecon Between NRC and. FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application (ADAMS Accession No.

ML18353A571)

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 4 of 16 Associated SLRA Revisions:

SLRA Table 3.3.2-1 is amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions.

Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Flow element Pressure Ductile iron Raw water (int} Wall thinning lnsQection of Internal VII.C1 .A-409 3.3-1, 126 E, 4 bounda!Y - erosion Surfaces in Miscellaneous PiQing and Ducting ComQonents Flow element Pressure Stainless steel Raw water (int) Loss of material Gf)eR Gyele GeeliR§ VII.G~.A §4 d.d ~. Q4Q A boundary Flow blockage WateF System VII.C1.A-727 3.3-1, 134 lnsQection of Internal Surfaces in Miscellaneous PiQing and Ducting ComQonents Flow element Pressure Stainless steel Raw water (int) Wall thinning - Gf)eR Gyele GeeliR§ VII.C1 .A-409 3.3-1, 126 E, .'.14 boundary erosion 1,oJateF System lnsQection of Internal Surfaces in Miscellaneous PiQing

' and Ducting ComQonents

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 5 of 16 Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Flow element Throttle Stainless steel Raw water (int) Loss of material QpeR Gyele GeeliR§ VII.G~.A a4 a.a ~, G4G A Flow blockage WateF SysteFR VII.C1 .A-727 3.3-11 134 lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents Flow element Throttle Stainless steel Raw water (int) Wall thinning - Q13eR Gyele GeeliR§ VII.C1 .A-409 3.3-1, 126 E,~

erosion WateF SysteFR lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents Heat Pressure Stainless steel Raw water (int) Wall thinning - GpeR Gysle GeeliR§ VI I. C 1.A-409 3.3-1, 126 E,~

exchanger boundary erosion 1NateF SysteFR (channel lns~ection of Internal head) Surfaces in Miscellaneous Pi~ing and Ducting Com~onents

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 6 of 16 Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Heat Pressure Stainless steel Raw water (int) Wall thinning - G13eR Gysle GeeliR§ VII.C1 .A-409 3.3-1, 126 E,44 exchanger boundary erosion Water System (tubes) lnsQection of Internal Surfaces in Miscellaneous PiQing and Ducting ComQonents Heat Pressure Stainless steel Raw water (int) Wall thinning - G13eR Gysle GeeliR§ VII.C1 .A-409 3.3-1, 126 E,44 exchanger boundary erosion Water System

(+tubesheet) lnsQection of Internal Surfaces in Miscellaneous PiQing and Ducting ComQonents Nozzle Pressure Gray cast iron Raw water (int) Wall thinning - G13eR Gysle GeeliR§ VI I. C1.A-409 3.3-1, 126 E,44 boundary erosion \/\later System lnsQection of Internal Surfaces in Miscellaneous PiQing and Ducting ComQonents

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. 8.2.3.11-1 L-2019-019 Attachment 3 Page 7 of 16 Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Nozzle Pressure Nickel alloy Raw water (int) Wall thinning - G13eA Gyele GeeliA§ VII.C1.A-409 3.3-1, 126 E,~

boundary erosion Water System Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Orifice Pressure Stainless steel Raw water (int) Wall thinning - G13eA Gyele GeeliA§ VII.C1.A-409 3.3-1, 126 E,~

boundary erosion 'Nater System Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Piping Pressure Gra~ cast iron Raw water {int} Wall thinning - . Inspection of Internal VII.C1 .A-409 3.3-11126 E14 bounda!Y erosion Surfaces in Miscellaneous Piping and Ducting Components Piping Pressure Coating Raw water {int} Loss of Open-C~cle Cooling VII.C1.A-416 3.3-11138 E,3 bounda!Y coating or Water S~stem lining integrit~

'

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 8 of 16 Table 3.3.2-1: Intake Cooling Water- Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item 2191 Item \

Management Piping Pressure Copper alloy Raw water (int) Wall thinning - G13eA Gysle GeeliA§! VII.C1 .A-409 3.3-1, 126 E,44, boundary erosion 'Nater System ,

lns~ection of Internal

..

Surfaces in Miscellaneous Pi~ing and Ducting Com~onents Piping Pressure Ductile iron Raw water (int) Loss of material G13eA Gysle GeeliA§ VII.G~ .AP d.d ~. Q37 A boundary Flow blockage '.IIJater System 494 3.3-1. 134 lns~ection of Internal VII.C1.A-Surfaces in 727 Miscellaneous Pi~ing and Ducting Com~onents Piping Pressure Ductile iron Raw water (int) Wall thinning - G13eA Gysle GeeliA§ VI I. C 1.A-409 3.3-1, 126 E,44, boundary erosion 'Nater System lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 9 of 16 Table 3.3.2-1: Intake Cooling Water-Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Piping Pressure Gray cast iron Raw water (int) Wall thinning - Open-Cycle Cooling VI1.C1.A-409 3.3-1, 126 E, 1

{Note 5) boundary erosion Water System Piping Pressure Gray cast iron Raw water (int) Loss of Open-Cycle Cooling VII.C1.AP-194 3.3-1, 037 A (Note 5) boundary material Water System Flow blockage

~

Piping Pressure Nickel alloy Raw water (int) Wall thinning - QpeR Gysle GeeliRQ VII.C1 .A-409 3.3-1, 126 E,~

boundary erosion l,IIJateF System lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. 8.2.3.11-1 L-2019-019 Attachment 3 Page 10 of 16 Table 3.3.2-1: Intake Cooling Water- Summary of Aging Management Evaluation Component Intended Material Environment . Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Piping Pressure Stainless steel Raw water (int) Wall thinning - QpeR Gysle GeeliR§J VI I. C 1.A-409 3.3-1, 126 E,~

boundary erosion 'Nater System lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents

~ PressYre StaiRless steel Rav.' 1Nater (iRt) bess ef material QpeR Gysle CeeliR§J VII.G1.A 54 3.3 1,040 A 991:!Rdary J;:le*.v sleeka§le Water System Piping and Structural Ductile iron Raw water (int) Wall thinning - QpeR Gyele GeeliR§J VII.C1 .A-409 3.3-1, 126 E,~

piping integrity erosion Water System components (attached) lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents Pump casing Pressure Carbon steel Raw water (int) Loss of material IRspeetieR ef IRtemal VII.C1.A 727 3.31,134 A boundary Flow blockage SYrfaees iR VII.C1 .AP-194 3.3-11 037 MiseellaRee1:1s PipiR§J aRd DYGtiR§l CempeReRts O~en-C3£cle Cooling

- Water S3£stem

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 11 of 16 Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Pump casing Pressure Gray cast iron Raw water (ext) Loss of material external Sw=fases VII.G~.A 7'J.7 a.a~.~a4 e-2 boundary Monitoring of VII.C1 .AP-194 3.3-11 037 A Meshanisal Gon=i13onents Ogen-C)lcle Cooling Water S)lstem Pumg casing Pressure Stainless Raw water (ext} Loss of Ogen-C)lcle Cooling VII.C1 .AP-194 3.3-11 037 A bounda!Y steel material Water S)lstem Thermowell Pressure Stainless steel Raw water (int) Wall thinning - G13en Gyele Gaoling VII.C1 .A-409 3.3-1, 126 E,44 boundary erosion Water Systen=i lnsgection of Internal Surfaces in Miscellaneous Piging and Ducting Comgonents Tubing Pressure Nickel alloy Raw water (int) Wall thinning - G13en Gyele Gaoling VII.C1.A-409 3.3-1, 126 E,44 boundary erosion 'Nater Systen=i lnsgection of Internal Surfaces in Miscellaneous Piging and Ducting Comgonents

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 12 of 16 Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Tubing Pressure Stainless steel Raw water (int) Wall thinning - GpeR Gyele GeeliR§ VII.C1.A-409 3.3-1, 126 E,44, boundary erosion WateF System lnsQection of Internal Surfaces in Miscellaneous PiQing and Ducting ComQonents

+ooiRg PFeSSl:IFe StaiRless steel Rm.v wateF (iRt) bess ef mateFial QpeR Gyele GeeliR§ VII.G1.A 54 3.3 1,040 A 99!:IRElai:y i;'.lew l:lleeka§e WateF System Valve body Pressure Carbon steel Raw water (int) Wall thinning - QpeR Gyele GeeliR§ VII.C1 .A-409 3.3-1, 126 E,44, boundary erosion WateF System lnsQection of Internal Surfaces in Miscellaneous PiQing and Ducting ComQonents Valve bod~ Pressure Gra~ cast iron Raw water {int} Wall thinning - lnsQection of Internal VII.C1 .A-409 3.3-11126 E,4 bounda!Jl erosion Surfaces in Miscellaneous PiQing and Ducting

• ComQonents

~urkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 13 of 16 Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Valve body Pressure Copper alloy Raw water (int) Wall thinning - G13eR Gysle GeeliR§J VII.C1 .A-409 3.3-1,126 E,~

boundary erosion Water System lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents Valve body Pressure Ductile iron Raw water (int) Wall thinning: G13eR Gysle GeeliR§J VII.C1 .A-409 3.3-1, 126 E,~

boundary erosion 'Nater System lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents Valve body Pressure Nickel alloy Raw water (int) Wall thinning - G13eR Gysle GeeliR§J VII.C1.A-409 3.3-1, 126 E,~

boundary erosion Water System lns~ection of Internal Surfaces in

' Miscellaneous Pi~ing and Ducting Com~onents

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. 8.2.3.11-1 L-2019-019 Attachment 3 Page 14 of 16 Table 3.3.2-1: Intake Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Program Item Management 2191 Item Valve body Pressure Stainless steel Raw water (int) Wall thinning - Gj::ieA Gysle GeeliA§! VII.C1.A-409 3.3-1, 126 E.~

boundary erosion Water System lns~ection of Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents Notes for Table 3.3.2-1 A Consistent with component, material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect and AMP listed for NUREG-2191 line item.AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specificAMP.

Plant-Specific Notes for Table 3.3.2-1

1. The Open-Cycle Cooling Water System AMP is enhanced to manage the wall thinning due to erosion aging effect.

2. These pump casings have a raw water external environment and loss of material is managed by the

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 15 of 16 External Surfaces Monitoring of Mechanical Components AMP.

3. The Open-Cycle Cooling Water System AMP is enhanced to manage the loss of coating or lining integrity aging effect.

4.The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP is used to manage the wall thinning due to erosion aging effect.

5. The ICW system piping within the scope of the Open-Cycle Cooling Water System AMP includes the piping between the discharge flange of the ICW pumps to the inlet flange of the CCW heat exchangers and to the TPCW strainers.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revised Response to NRC RAI No. B.2.3.11-1 L-2019-019 Attachment 3 Page 16 of 16 Revise SLRA Section 17.2.2.11 to add the following text after the first paragraph as follows:

The Open-Cycle Cooling Water (OCCW) System AMP will include the following SSC scope:

(a) Portions of the ICW pump casings that are exposed to a raw water environment:

(b) Piping and piping components from the ICW pump discharge flanges to the inlet flanges of the component cooling water (CCW) heat exchangers: and (c) Piping and piping components from the ICW pump discharge flanges to the turbine plant cooling water (TPCW) baskets strainers.

Revise SLRA Section B.2.3.11 to add the following text after the first paragraph of "Program Description" as follows:

The Open-Cycle Cooling Water (OCCW) System AMP will include the following SSC scope:

a. Portions of the ICW pump casings that are exposed to a raw water environment:

b. Piping and piping components from the ICW pump discharge flanges to the inlet flanges of the component cooling water (CCW) heat exchangers: and

c. Piping and piping components from the ICW pump discharge flanges to the turbine plant cooling water (TPCW) baskets strainers.

Revise the third paragr~ph of SLRA Section B.2.3.11 "Program Description" as follows:

The PTN OCCW System AMP works in conjunction with other PTN AMPs as described in this paragraph. For buried OCCW system piping within the scope of this AMP, the aging effects on the external surfaces of the piping are managed by the PTN Buried and Underground Piping and Tanks AMP; however, the internal surfaces are managed by this AMP. The aging management of closed-cycle cooling water systems is described in the PTN Closed Treated Water Systems AMP and is not included as part of this AMP.

The PTN OCCW System AMP also manages the loss of coating integrity for internal coatings of piping within the scope of this AMP. This piping includes cement lined cast iron piping from the three (3) IC'A' pump discharge check valves to the component cooling water (CCVV) basket strainers and piping from the three (3) ICVV pump discharge check valves to the turbine plant cooling water (TPC'A') baskets strainers.

This AMP includes the guidance provided in the "scope of program" elements of the PTN Internal eCoatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP to manage loss of coating integrity.

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Protection AMP L-2019-019 Attachment 4 Page 1 of 4 Fire Protection, GALL AMP XI.M26 Regulatory Basis:

10 CFR 54.21 (a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

Background:

SLRA Section B.2.3.15, "Fire Protection," program, Enhancement No. 1 states, in part, that the fire damper inspection procedure(s) will be updated to state "the acceptance criteria for the fire damper inspections as no visual indications of cracks or corrosion that could affect the component intended function."

The GALL-SLR AMP XI.M26, "Fire Protection," "acceptance criteria" program element, states, in part, that the acceptance criteria include "no visual indications of cracks or corrosion of fire damper assemblies."

SLRA Section B.2.3.15 states that the Fire Protection program will be consistent with GALL SLR Report AMP XI.M26.

Issue:

The enhancement could allow degradation beyond that recommended in GALL SLR AMP XI.M26, which states the acceptance criteria to be "no visual indications of cracks or corrosion." The SLRA does not state a basis for this exception to AMP XI.M26. In particular: (a) the criteria being used to determine the threshold at which to take corrective action; and (b) the qualifications of individuals determining the potential impact on the intended function of the damper assembly are nofstated.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Protection AMP L-2019-019 Attachment 4 Page 2 of 4 FPL Discussion:

During a recent audit by the NRC Staff, FPL was requested to state the basis for the exception to AMP XI.M26 including at least the criteria being used to determine the threshold at which to take corrective action and the qualifications of individuals determining the potential impact on the intended function of the damper assembly.

No exceptions to NUREG-2191 AMP XI.M26 are being taken. The threshold for corrective action on fire dampers is updated as follows:

• Any visual indication of cracking or corrosion on a fire damper assembly will be documented and evaluated for repair/replacement in accordance with the Turkey Point Corrective Action Program.

The personnel responsible for inspecting fire damper assemblies and the personnel responsible for determining the potential adverse impact and appropriate corrective action are to be qualified per the NRG-approved fire protection program (NFPA 805).

The need for inspector qualification is currently listed in SLRA Table 17-3 (Commitment

19) and Section B.2.3.15 (Element 4 enhancement) but is clarified to also discuss the qualifications of the personnel evaluating inspection results for corrective action.

References:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Protection AMP L-2019-019 Attachment 4 Page 3 of 4 Associated SLRA Revisions:

SLRA Table 17-3 and Section B.2.3.15 are amended as indicated by the following text deletion (strikethrough text) and text addition (red underlined font) revisions.

Revise SLRA Table 17-3 (Commitment 19) as follows:

19 Fire Protection XI.M26 Continue the existing PTN Fire Protection AMP, including No later than 6 months (17.2.2.15) enhancement to: prior to the SPEO, Le.:

a) Inspect for corrosion and cracking on all in-scope fire dampers PTN3:

assemblies~ with an acceptance criteria of no visual indications 1/19/2032 of cracks or corrosion that could affect the components' PTN4:

intended function Any visual indication of cracking or corrosion on a fire damper assembly will be documented 10/10/2032 and evaluated for repair/replacement in accordance with the Turkey Point Corrective Action Program.;

b) Ensure that the personnel that inspect and the personnel that evaluate the condition of penetration seals, walls, ceilings, floors, doors, fire damper assemblies, and other fire barrier materials are qualified per the NRG-approved fire protection program (NFPA 805) to perform such inspections and qualified to determine appropriate corrective action, respectively; c) Document any degradation identified in the halon fire suppression system tests and include in the tr!:!nding analysis; d) Project identified degradation until the next scheduled inspection when practical; e) Evaluate trending inspection results against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) and the timing of subsequent inspections will maintain the components' intended functions throughout the SPEO. If any projected inspection results will not meet acceptance criteria prior to the next scheduled inspection, then inspection frequencies are adjusted as determined by the PTN corrective action program.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Protection AMP L-2019-019 Attachment 4 Page 4 of 4 Revise SLRA Section B.2.3.15 (enhancements table) as follows:

.

Element Affected Enhancement

3. Parameters Update the fire damper inspection procedure(s) to specify inspections for Monitored or Inspected corrosion and cracking on all in-scope fire damper assemblies, and state

6. Acceptance Criteria that an~ visual indication of cracking or corrosion on a fire dameer assembl~ will be documented and evaluated for reeair/reelacement in accordance with the Turke~ Point Corrective Action Program. tRe aGGeptaAGe GFiteFia feF U:ie fiFe EiaR'lpeF iAspeGtiOAS as AO vis1:1al iAEiisatiOAS of GFaGks OF GOFFOSiOA that G0!:119 affeGt the GOR'lpOAeAt iAteAEleEl fl:IAGtiOAS.

4. Detection of Aging Update the procedures that inspect penetration seals, walls, ceilings, Effects floors, doors, fire damper assemblies, and other fire barrier materials to state that the inspectors and evaluators are qualified per the NRG-approved fire protection program (NFPA 805) to perform such inspections and determine aeeroeriate corrective action 1 reseectivel~.

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Rated Assemblies AMR L-2019-019 Attachment 5 Page 1 of 6 Fire Rated Assemblies Aging Management Review Regulatory Basis:

10 CFR 54.21 (a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

Background:

SLRA Table 3.5.2-10, states that hardening, loss of strength, and shrinkage are managed for cementitious fireproofing material exposed to air indoor uncontrolled and air indoor controlled by the Fire Protection program. The line item cites generic note J and plant specific note 2, which states, "[c]omponent and material are different, but consistent with environment, aging effect and AMP listed for NUREG-2191 line item.

AMP is consistent with NUREG-2191 AMP description." SLRA Table 3.3-1, item 3.3-1, 057, as well as the SRP SLR, address hardening, loss of strength, and shrinkage for elastomeric fire barrier penetration seals, not cementitious materials, exposed to air, condensation.

Issue:

Cementitious fireproofing material aging effects, which include cracking and loss of material, consistent with GALL SLR Report items such as TP-36 and A-90, are not consistent with elastomeric material aging effects.

FPL Discussion:

During a recent audit by the NRC Staff, FPL was requested to state the basis for the aging effects currently identified in the SLRA along with the basis for the omission of loss of material and cracking.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Rated Assemblies AMR L-2019-019 Attachment 5 Page 2 of 6 The aging effects currently listed in the SLRA (hardening, loss of strength, and shrinkage) are applicable to fire barriers that employ elastomeric sealing materials. The cementitious fireproofing materials at Turkey Point (e.g., Albi-Duraspray and Monokote) are not elastomeric, and therefore, the aging effects of hardening, loss of strength, and shrinkage are not applicable to those materials.

The omitted aging effects identified in the 'Issue' discussion (loss of material and cracking) are appropriate for fire barriers at PTN that employ Thermo-lag, Flamemastic, Cerafiber, and cementitious fireproofing (e.g., Albi Duraspray and Monokote).

The line items for fire barriers in SLRA Table 3.5.2-10 are updated to align with the bases as stated above. Additionally, SLRA Table 3.5.2-10 Note 2 is no longer required and is to be deleted.

References:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Rated Assemblies AMR L-2019-019 Attachment 5 Page 3 of 6 Associated SLRA Revisions:

SLRA Table 3.5.2-10 is amended as indicated by the following text deletion (strikethrough text) and text addition (red underlined font) revisions.

Revise SLRA Table 3.5.2-10 as follows:

Table 3.5.2-10: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Component Intended Requiring Management NUREG- Table 1 Type Function Material Environment Management Program 2191 Item Item Notes Drip shields over Fire barrier Stainless Air - outdoor Loss of material Fire Protection III.B2.T-37b 3.5-1, 100 E Thermo-lag steel Cracking Electrical Fire barrier Thermo-lag Air- indoor l=laFEleAiAg Fire Protection VII.G.A ~9 J.J ~. Ga7 G fireproofing protection uncontrolled bess ef stFeAgtl:l

-- -- J.

Air-indoor Sl:lriAkage controlled Loss of material Air - outdoor Cracking Fire doors Fire barrier Carbon steel Air- indoor Loss of material Fire Protection VII.G.A-21 3.3-1, 059 A uncontrolled Air- indoor controlled Air - outdoor Fire doors Shelter, Carbon steel Air- indoor Loss of material Fire Protection VII.G.A-21 3.3-1, 059 A between Cable protection uncontrolled Spreading Room Fire barrier Air- indoor and AC Fan controlled Room

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Rated Assemblies AMR L-2019-019 Attachment 5 Page 4 of 6 Fire doors, Pressure Carbon steel Air-indoor Loss of material Fire Protection VII.G.A-21 3.3-1, 059 A Control Room boundary uncontrolled Shelter, Air-indoor protection controlled Fire barrier Air - outdoor Table 3.5.2-10: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Component Intended Requiring Aging NUREG- Table 1 Type Function Material Environment Management Managemen 2191 Item Item Notes

-

Fire retardant Fire barrier Flamemastic Air- indoor l=laFEleAiA§! Fire Protection VII.G.A ~9 J.J ~. Ga7 A coating uncontrolled bess ef stFeA§ltR -- -- 4 Air-indoor Sl=lFiAka§!e .

controlled Loss of material Cracking Fire sealed Fire barrier Cerafiber Air - outdoor l=laFEleAiA§! Fire Protection VII.G.A ~9 J.J ~. Ga7 A isolation joint bess ef stFeA§!tl=l Sl=lFiAka§!e

-- -- 4 Loss of material Cracking Fire sealed Flood barrier Elastomer, Air - outdoor Loss of sealing Structures III.A6.TP-7 3.5-1, 072 B isolation joint rubber and Monitoring other similar materials Penetration Fire barrier Galvanized Air-indoor None None VII.J.AP-2 3.3-1, 121 C seals steel controlled Penetration Fire barrier Galvanized Air- indoor None None 111.82.TP-8 3.5-1, 095 C seals steel uncontrolled

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Rated Assemblies AMR L-2019-019 Attachment 5 Page 5 of 6 Penetration Fire barrier Elastomer, Air-indoor Hardening Fire Protection VII.G.A-19 3.3-1, 057 A seals rubber, and uncontrolled Loss of strength other similar Air- indoor Shrinkage materials controlled Penetration Flood barrier Elastomer, Air - outdoor Loss of sealing Structures 111.A6.TP-7 3.5-1, 072 B seals (pipe rubber and Monitoring trench) other similar materials /

Table 3.5.2-1 O: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Component Intended Requiring Aging Management NUREG- Table 1 Type Function Material Environment Management Program 2191 Item Item Notes Seals and Fire barrier Elastomer, Air - outdoor Hardening Fire Protection VII.G.A-19 3.3-1, 057 A gaskets (doors, rubber, and Loss of strength manways, and other similar Shrinkage hatches) materials Seals and Flood barrier Elastomer, Air - outdoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, 072 B gaskets (doors, rubber and manways, and other similar hatches materials Structural steel Fire barrier Cementitious Air- indoor l=laFEleRiRg Fire Protection VII.G.A ~9 d.d ~. Ga7 j~

fireproofing fireproofing

'e.a. Monocote uncontrolled Loss of stFeRgth -- --

Air- indoor ShFiRkage Albi-Du rasoravl controlled Loss of material Cracking

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revision to Fire Rated Assemblies AMR L-2019-019 Attachment 5 Page 6 of 6 Notes for Table 3.5.2-10 A. Consistent with component, material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect, but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

J. Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant-Specific Notes for Table 3.5.2~10

1. The components that are exposed to indoor controlled air are assumed to experience the same aging effects as if the components were exposed to indoor uncontrolled air.

2. Component and material are different, but consistent 1.vith environment, aging effect and AMP listed for NU REG 2191 line item. AMP is consistent with NU REG 2191 AMP description.

Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response to NRC RAI No. B.2.3.27-2 L-2019-019 Attachment 6 Page 1 of 5 RAI Letter Nos. ML18243A006 and ML18243A007 dated September 17, 2018 Monitoring of Neutron-Absorbing Materials Other Than Boraflex, GALL AMP XI.M40 RAI 8.2.3.27-2

Background:

The Turkey Point UFSAR, Section 16.2.17, "Metamic Insert Surveillance Program,"

Revision 28, contains a description of the Metamic Insert Surveillance Program. This description includes items such as: criteria for the surveillance testing; test requirements; test frequency; acceptance criteria; and corrective actions, documentation and reporting based on test results. In addition, procedure O-OSP-034.3, "Metamic Insert Surveillance,"

Revision 1, contains a similar description of requirements for the program, and also references UFSAR Section 16.2.17 for these requirements. Surveillance Requirement (SR) 4.9.14.2 in Technical Specification (TS) 3/4.9.14, "Spent Fuel Storage," also references UFSAR Section 16.2 for the surveillance program requirements.

Issue:

The staff reviewed the proposed UFSAR supplement, and it appeared that significant details of the program would be removed from the UFSAR. It is unclear whether these changes will impact the implementing procedure for the Metamic insert surveillance program.

Request:

Clarify whether the Metamic insert surveillance program, TS 3/4.9.14, or SR 4.9.14.2, will be impacted by the proposed changes to the UFSAR.

FPL Supplemental Response:

This response supplements the RAI response provided in Attachment 36 of Reference 1 with additional clarifications discussed during the November 15, 2018 NRC public meeting with FPL (Reference 2) and Attachment 10 of Reference 3.

This RAI supplement corrects the submittal dates for the Metamic license amendment listed in Commitment 31 of SLRA Table 17-3.

References:

1. FPL Letter L-2018-166 to NRC dated October 16, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 3 Responses (ADAMS Accession No. ML18296A024)

2. NRC Public Meeting Agenda dated November 5, 2018, Telecon Between NRC and FPL to Discuss Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application (ADAMS Accession No. ML18315A004)

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response to NRC RAI No. B.2.3.27-2 L-2019-019 Attachment 6 Page 2 of 5

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

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response to NRC RAI No. B.2.3.27-2 L-2019-019 Attachment 6 Page 3 of 5 Associated SLRA Revisions:

SLRA Appendix A, Table 17-3 is amended as indicated by the following text deletion (strikethrough) and text addition. (red underlined font) revisions.

SLRA Table 17-3 is revised as follows:

Aging Management Program NUREG-2191 No. or Activity (Section) Section Commitment Implementation Schedule 31 Monitoring of Neutron- XI.M40 Continue the existing (previously only credited for Metamic Complete the initial Bora!

inserts) PTN Monitoring of Neutron-Absorbing Materials testing and inspections no later Absorbing Materials other than other than Boraflex AMP, including enhancement to: than 6 months prior to the SPEO, i.e.:

Boraflex (17.2.2.27) a) Inspect and test Metamic inserts on a frequency dependent on the condition of the neutron-absorbing PTN3: 1/19/2032 material and determined and justified with PTN-specific OE. For each Metamic insert, the maximum PTN4: 10/10/2032 interval between each inspection and between each coupon test is not to exceed 10 years, regardless of OE; Submit the license b) Compare observations and measurements from the periodic inspections and coupon testing to baseline amendment no later than 18 information or prior measurements and analyses for months [?rior to the SPE0 1 trending analysis, projecting future degradation, ahd i.e.:

projecting the future subcriticality margin of the SFP.

PTN3: 1/19/2031 This trending will also consider differences in exposure conditions, venting, spent fuel rack PTN4: 10/10/2031 differences, etc. for each Metamic insert or coupon.

c) Initiate corrective actions (e.g., add neutron-absorbing capacity with an alternate material, or apply other available options) to maintain the subcriticality margin if the results from measurements and analysis indicate that the 5 percent subcriticality margin cannot be maintained because of current or projected degradation of the neutron-absorbinq material.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response to NRC RAI No. B.2.3.27-2 L-2019-019 Attachment 6 Page 4 of 5 d) Manage aging effects associated with the Baral panels in the SFP cask area by monitoring for loss of material and changes in dimension that could result in loss of neutron-absorbing capability of the Baral panels. Monitor parameters associated with the physical condition of the Baral panels and include insitu gap formation, geometric changes as observed from coupons or in situ, and decreased boron-10 areal density, etc. The parameters monitored are directly related to determination of the loss of material or loss of neutron absorption capability of the Baral panels.

These parameters are monitored using coupon and/or direct in-situ testing of the Baral panels to identify their associated loss of material and degradation of neutron absorbing capacity. The frequency of the inspection and testing depends on the condition of the neutron-absorbing material and is determined with site-specific OE; however, the maximum interval between these inspections is not to exceed 10 years, regardless of OE. Compare the Baral inspection and testing measurements to baseline values for trending analysis and projecting future panel degradation and SFP subcriticality margins. The degradation trending must be based on samples that adequately represent the entire Baral panel population, and the trending must consider differences in sample exposure conditions, differences in spent fuel cask racks, and possibly other considerations. The new Baral panel surveillance acceptance criteria for the obtained inspection, testing, and analysis measurements must ensure that the 5 percent subcriticality margin for the SFP will be maintained, otherwise corrective actions need to be implemented.

el Submit a license amendment to revise SR 4.9.14.2 to reference UFSAR Section 17.2.2.27.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Supplemental Response to NRC RAI No. B.2.3.27-2 L-2019-019 Attachment 6 Page 5 of 5 Associated

Enclosures:

None

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revisions to Transmission Conductor AMR and XI.E1 AMP L-2019-019 Attachment 7 Page 1 of 2 NRC Audit Breakout Meeting Dated January 9, 2019 Discussion During a recent audit by the NRC Staff, FPL was requested to provide additional information in the SLRA:

1. A discussion on transmission conductor loss of material due to wind-induced abrasion

• from sand-blasting, and

2. Guidance information related to the inspection of cables coated with flame retardant material recently included in the program basis document for the PTN Electrical Insulation for Electrical Cables and Connections not Subject to 10 CFR 50.49 EQ Requirements (XI.E1) AMP.

FPL Response:

The following numbered items correspond to the numbered items above.

1. SLRA Section 3.6.2.2.3 has been amended to include a discussion on transmission conductor loss of material due to wind-induced abrasion from sand-blasting.

2. SLRA Section B.2.3.38 has been amended to include guidance information related to inspection of cables coated with flame retardant material.

References:

None Associated SLRA Revisions:

SLRA Sections 3.6.2.2.3 and B.2.3.38 are amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions.

Insert the following in SLRA Section 3.6.2.2.3 after the "Loss of Material 0Afear)" section on page 3.6-5 as follows:

Loss of Material Due to Wind Induced Abrasion (Sand Blasting)

Loss of material of transmission conductors and connections due to wind induced abrasion (sand blasting) could occur in desert areas, beaches or in locations where agricultural farming is prevalent. There are no industries within the 0-5-mile radius of Turkey Point, with approximately one-half of the total area within the 0-5 mile radius being formed by the coastal waters in Biscayne Bay. The coastal waters can be characterized as a shallow-bay with no beaches. A substantial proportion of the land area in the 0-5 mile radius is vacant. A section of agricultural land is located in the northwestern quarter of the 0-5 mile arc and is mostly used for truck crop farming. A review of plant-specific OE did not identify wind induced abrasion due to sand blasting or other contamination as an aging effect for transmission conductors and connections. Therefore, loss of material of transmission

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Revisions to Transmission Conductor AMR and XI.E1 AMP L-2019-019 Attachment 7 Page 2 of 2 conductors and connections due to wind induced abrasion (sand blasting) is not an aging effect requiring management at Turkey Point.

Hurricanes and other major wind events could cause foreign objects (such as siding and roofs) to get blown into transmission conductors and connections.

Although these types of atmospheric disturbances are considered infrequent weather events rather than equipment aging, a review of plant-specific OE did not identify any instances where these events caused damage to transmission conductors and connections. Additionally, the site performs a detailed inspection of the switchyard after a hurricane to look for transmission conductor and connection conductor damage.

Therefore, loss of material due to wind induced abrasion-sand blasting of transmission conductors and connections due hurricanes and other major wind events is not an aging effect requiring management at Turkey Point.

Insert the following in SLRA Section B.2.3.38 as a new fourth paragraph on page 8~275 as follows:

The inspection of the material condition of cable jackets in trays covered with fire retardant material will be performed by one or a combination of the following techniques:

• Use scaffolding, ladders or other means to facilitate cable jacket inspection (e.g., if the underside of the cable tray is completely covered with flamastic, inspect cable jackets from the topside of the cable tray through gaps in the flamastic, as applicable).

• Use nearby junction boxes, pull boxes, and terminal boxes to view cable jackets as representative samples of cables within the tray.

• Use the optical zoom feature on a digital camera (or other device used for viewing distant objects) to inspect cable jackets through gaps in the fire retardant material from the floor.

• Use the cable jackets of newer cables laid on top of fire retardant material as representative samples of cables within the tray. Note: newer cables will require additional evaluation to determine their applicability, if this technique is used.

Factors such as cable age and orientationwithin the tray require evaluation for suitability.

• Remove fire retardant material to inspect cable jackets if necessary.

Note: if an adverse localized environment is identified, the inspection techniques noted above can be used to inspect the inaccessible area.

Associated

Enclosures:

None