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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

April 1, 2019

L-2019-072 10 CFR 54.21 (b)

Turkey Point Units 3 and 4 Subsequent License Renewal Application First Annual Update

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. ML 18037A812)

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. ML 1811 3A 1 34)

Florida Power & Light Company (FPL) submitted a subsequent license renewal application (SLRA) for Turkey Point Units 3 and 4 (PTN 3 and 4) to the NRC on January 30 , 2018 (Reference 1) and SLRA Revision 1 on April 10, 2018 (Reference 2) .

The License Renewal Rule , 10 CFR 54.21 (b), requires that each year following submittal of an LRA, and at least 3 months before scheduled completion of the NRC review, an update to the LRA must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA including the Updated Final Safety Analysis Report Supplement.

In accordance with the License Renewa l Rule , FPL has performed the annual review of PTN 3 and 4 CLB changes since submittal of SLRA Revision 1 to determine whether any sections of the SLRA were materially affected by these changes. As a result of th is annual review, FPL identified four changes to the PTN 3 and 4 CLB materially affecting SLRA content. A description of these changes and the corresponding affected SLRA content revisions are provided in Attachments 1 and 2.

If you have any questions, or need additional information , please contact me at 561 -691 -2294.

Florida Power & Light Company

700 Universe Boulevard , Juno Beach, FL 33408

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2019-072 Page 2 of 2

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

Executed on April 1, 2019 .

William Maher Senior Licensing Director Florida Power & Light Company

WDM/RFO

Attachments :

Attachment 1 - Current Licensing Basis (CLB) Changes Affecting the SLRA Attachment 2 - Affected SLRA Content Revisions

cc:

Senior Resident Inspector, USNRC, Turkey Point Nuclear Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Nuclear 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 CLB Changes Affecting the SLRA L-2019-072 Attachment 1 Page 1 of 2

CURRENT LICENSING BASIS (CLB) CHANGES AFFECTING THE SLRA

Screening Document and PTN 3 and 4 CLB Aging Management

Change ltem 1 Review (AMR) Document Affected

Change 1 EC 288059 relocated a code boundary Screening Document: break from valve 3-502 in Unit 3 and 4-502 in Unit FPLCORP020-REPT-002 4 to the reactor vessel (RV) flange downstream of the inner 0-! irJg and the internal restricting orifice . AMR Document:

FPLCORP020-REPT-032 The SLRA is updated to discuss this boundary relocation . Change 2 Additional SR/NNS boundaries were Screening Document: added at valves 3-50-868 , 3-50-869, 4-50-868, FPLCORP020-REPT-008 and 4-50-869 for tie in of the ICW Supplemental Cooling System. AMR Document:

FPLCORP020-REPT-039 The SLRA is updated because the SLRA currently does not include discussion of this boundary in the Intake Cooling Water system. The SLRA is updated to add this new SR/NNS boundary and a new boundary drawing is listed. Change 3 EC 283021 re-routed the Units 3 and Screening Document: 4 condenser SJAE exhausts to the plant vent None stack where the exhaust will be monitored by the plant vent stack SPING (RAD-6304) . SJAE AMR Document: exhaust piping was not previously part of LR; None however, the combined U3 and U4 SJAE headers tie into ductwork that is in the scope of SLR (561 O-M-3060 SH1 ).

The SLRA is updated to discuss this new LR boundary.

SLRA Content Affected

Section 2.3.1.1.1

Section 2.3.3.1

Section 2.3.3 .11.1

1 Excludes change determinations where the SLRA was unaffected although a Screening Document or AMR Document was affected .

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 CLB Changes Affecting the SLRA L-2019-072 Attachment 1 Page 2 of 2

CURRENT LICENSING BASIS (CLB) CHANGES AFFECTING THE SLRA

Screening Document and PTN 3 and 4 CLB Aging Management

Change Item 1 Review (AMR) Document Affected

Change 4 EC 271017 replaced a portion of the Screening Document: 14-inch feedwater piping downstream of FCV-4- FPLCORP020-REPT-013 498 with chrome-moly piping.

AMR Document: The SLRA is updated because the SLRA FPLCORP020-REPT-031 currently does not include low-alloy steel in the Feedwater and Blowdown Summary of Aging Management Evaluation Table , or the list of materials of construction for the Feedwater and Blowdown components . The SLRA is updated to add chrome moly (low-alloy steel) to Table 3.4.2-2 and Section 3.4.2.1.2

SLRA Content Affected

Table 3.4.2-2

Section 3.4.2.1.2

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Affected SLRA Content Revisions L-2019-072 Attachment 2 Page 1 of 3

As a result of four PTN current licensing basis (CLB) changes affecting the SLRA during the SLRA first annual update period , SLRA Sections 2.3.1.1.1, 2.3.3.1,

. 2.3.3.11 .1, 3.4.2 .1.2 and Table 3.4.2-2 are amended as indicated by the following text deletion (strikethrough) and text addition (red underlined font) revisions:

2.3.1.1

[Change 1]

Reactor Coolant and Connected Piping

2.3.1 .1.1 Reactor Coolant Piping

Boundary

Reactor coolant piping boundaries for SLR are included in the RCS SLR boundary drawings listed in Section 2.3.1, Reactor Coolant System. Note that one Class 1 code boundary has been relocated from valve *-502 in Unit 3 and 4 to the reactor vessel (RV) flange downstream of the inner 0-ring and the internal restricting orifice. This change also relocates the SLR boundary to the RV flange for each unit.

[Change 2]

2.3.3.1 Intake Cooling Water

Boundary

The SLR boundaries are reflected on the SLRBDs listed below. The boundaries have been extended beyond the boundaries identified in the original Turkey Point license renewal effort to support changes associated with NFPA 805.

Turkey Point Common 5610-M-3019, Sheet 1

Turkey Point Unit 3 5613-M-3019 , Sheet1 5613-M-3019, Sheet2

Turkey Point Unit 4 5614-M-3019, Sheet1 5614-M-3019, Sheet2

The subsequent license renewal boundaries of the ICW system begin with the ICW pumps at the intake structure. For the ICW piping and components that are associated with heat removal from the CCW heat exchangers , the subsequent license renewal boundary ends at the discharge structure. For the ICW piping and components associated with heat removal from the TPCW heat exchangers, the safety-related pressure boundary ends at the downstream side of POV-*-4882, POV-*-4883 , *-50-315,

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Affected SLRA Content Revisions L-2019-072 Attachment 2 Page 2 of 3

and *-50-335. For the ICW piping and components associated with the addition of the ICW Supplemental Cooling system, the safety-related boundary ends at the upstream side of new valves *-50-868 and *-50-869. The nonsafety-related piping and the TPCW heat exchangers provide seismic support/anchorage for the upstream safety­related portion of the system. For NFPA 805, this piping must maintain a pressure boundary downstream to valve *-50-401 to provide isolation of ICW in the event of spurious operation of POV-*-4882 or POV-*-4883, and thus these piping and components are included in the scope of subsequent license renewal.

[Change 3]

2.3.3.11 .1 Auxiliary Building and Electrical Equipment Room Ventilation

Boundary

SLR boundaries are reflected on the SLRBDs listed below. There are no significant differences between the current boundaries and those identified as part of the original Turkey Point license renewal effort.

Turkey Point Common 5610-M-3060 , Sheet1 5610-M-3060, Sheet3

The subsequent license renewal boundary for auxiliary build ing ventilation begins at the inlet to the auxiliary building supply fans V10 and V11 , and includes system ductwork in the auxiliary building that provides supply air to safety-related rooms . The license renewal boundary continues through ductwork to the auxiliary building exhaust fans V8A and V8B, and ends at the fan exhaust ductwork located outside the auxiliary building . Note that a SLR boundary has been added on the common ductwork header upstream of the auxiliary building exhaust fans V8A and V8B to accommodate the addition of exhaust piping from the discharge of the Unit 3 and Unit 4 steam jet air ejectors (SJAEs). Note that the plant vent stack is only considered within the scope of subsequent license renewal as a nonsafety-related structure that could affect safety­related functions and is included with non-containment structures in Section 2.4.2.12.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Affected SLRA Content Revisions L-2019-072 Attachment 2 Page 3 of 3

[Change 4)

Table 3.4.2-2: Feedwater and Slowdown - Summary of Aging Management Evaluation

Component Type

Piping

Piping

Piping

f.iQing (insulated) Piping and ID.P.i.llil comoonents

3.4.2.1.2

Intended Material Environment Function

Pressure Low-allo~ Treated boundarv steel water {int) Pressure Low-allo~ Treated boundarv steel water lint\ Pressure Low-allo~ Treated boundarv steel water lint) Pressure Low-allo~ Air - outdoor boundarv steel {ext) Pressure Low-allo~ Treated boundart steel water (int}

Feedwater and Blowdown

Materials

Aging Effect Aging Management Program Requiring

Management Loss of Water Chemistrv One-Time material lnsoection Wall thinning - Flow-Accelerated Corrosion erosion Wall thinning - Flow-Accelerated Corrosion FAC Loss of External Surfaces Monitoring material of Mechanical Comoonents Cumulative TLAA - Section 4.3.2, Metal fatigue Fatigue of Piping Components damaae

The materials of construction for the Feedwater and Blowdown components are:

• Carbon steel

• Coating

• Copper alloy

• Stainless steel

• Low-allo)l steel

NUREG-2191 Table 1 Notes Item Item

VIII.D1 .SP-74 3.4-1, 014 A

VIII.D1 .S-408 3.4-1, 060 A

VIII.D1 .S-16 3.4-1, 005 A

VIII.H.S-402a 3.4-1, 063 A

VIII.D1 .S-11 3.4-1, 001 A