L-2006-181, Response to Request for Additional Information (RAI) Regarding Third 10-Year Inservice Inspection Interval Relief Requests 1A, 14A, 15A

Response to Request for Additional Information (RAI) Regarding Third 10-Year Inservice Inspection Interval Relief Requests 1A, 14A, 15A

ML061990015
Person / Time
Site:	Turkey Point
Issue date:	07/14/2006
From:	Jones T Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2006-181
Download: ML061990015 (71)

Text

4JUL 14 200S L-2006-1 81 i=PL 10 CFR 50.36 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

Turkey Point Units 3 and 4 Docket No. 50-250 and 50-251 Response to Request for Additional Information (RAI)

Regarding Third 10-year Inservice Inspection Interval Relief Requests 1A. 14A, 15A By letter L-2006-050 dated February 20, 2006, Florida Power & Light Company (FPL) requested relief from certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section Xl, due to limitations that were identified during the third 10-year Inservice Inspection (ISI) Interval at Turkey Point Units 3 and 4. On June 16, 2006, the NRC Staff requested additional information needed to complete their review of Relief Requests 1A, 14A, and 15A.

Attachment I provides NRC's RAI questions and FPL's responses. Attachments 2, 3 and 4 provide the revised Relief Requests 1A, 14A, and 15A, respectively. Revision bars are included in the relief requests to identify the changes that resulted from the response to NRC's RAI questions. The attached Relief Requests 1A, 14A, and 15A supercede those submitted in FPL's letter L-2006-050, dated February 20, 2006.

Please contact Walter Parker at (305) 246-6632, ifthere are any questions.

Very truly yours, Terry 0.-Joe Vice President Turkey Point Nuclear Plant SM Attachments cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Aq[)q7 an FPL Group company

L-2006-181 Attachment 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION TURKEY POINT UNITS 3 AND 4 RELIEF REQUEST NOS. 1A. 14A. AND 15A DOCKET NOS. 50-250 AND 50-251 General:

1. Relief Requests 1A, 14A and 15A Indicate that the third 10-year Inservice Inspection (ISI) Interval ended February 21, 2004, for Unit 3 and April 14, 2004, for Unit 4. By letter dated October 20, 2004, the NRC authorized extension of the third 10-year Interval to February 21, 2005, for Unit 3 and to April 14, 2005, for Unit 4. Please Indicate the proper end dates for the Unit 3 and Unit 4 third 10-year ISI Intervals.

FPL Response to Question 1:

For both Turkey Point Units 3 and 4 the third 10-year Inservice Inspection Interval included 1 year extension.

Specifically, for Unit 3, the interval began on February 22, 1994 and ended February 21, 2005. Respectively, for Unit 4, the interval began on April 15, 1994 and ended April 14, 2005. These dates are referenced in attached Relief Requests 1A, 14A, and 15A.

The one year extension to 2005 was based on the provision of ASME Section XI, 1989 Edition, IWA 2430, No Addenda. FPL and NRC discussed this extension in a telecon and subsequently, FPL notified the Staff by letters L-2002-125, dated June 26, 2002, and L-2003-158, dated June 20, 2003 for Units 3 and 4, respectively.

For clarification, the above referenced October 20, 2004 NRC letter did not directly authorize the extension of the Third 10-year Inservice Inspection interval. Rather, it simply provided the approval of Relief Request 34, Alternative Through-Wall Sizing Requirements For Implementation of Appendix VIII, Supplement 10" and Relief Request 35 "Alternative Ultrasonic Examination For The Reactor Flange-To-Upper Shell Welds Using PDI Demonstrated Techniques". It was the FPL notification letter noted above that documented the Third 10-year Inservice Inspection Interval extension. Itshould be noted that the extension of the Third 10-year Inservice Inspection Interval will not result in an extension of the Fourth 10-year Inservice Inspection Interval for either unit.

Relief Request 1A:

2. In Florida Power and Light Company (FPL) letter dated February 20, 2006, It Is stated the objective of Relief Request 1A Is to resubmit the previously approved Relief Request No.1. The request also states that this revision submits the examination volume coverage obtained during the third 10-year ISI Interval Inspection. In comparing Relief Request 1 with Relief Request 1 A, the upper shell-to-flange weld Is Included In both requests. Welds 3-DO-A, 3-DO-B, 3-DO-C, 4-DO-A, 4-DO-B, 4-DO-C are Included In Relief Request 1, but they are not Included In relief request 1A. Relief Request 1A contains additional examinations that had limited coverage, welds 3-WR-9 and 4-WR-9 and the 1-inch annular surface of flange surrounding each reactor vessel stud hole.

Does Relief Request 1A supersede Relief Request 1, or is it in addition to Relief Request 1? If Relief Request 1A Is to supersede Relief Request 1, was essentially full coverage obtained on welds 3-DO-A, 3-DO-B, 3-DO-C, 4-DO-A, 4-DO-B, 4-DO-C? If relief request 1A Is to be in addition to relief request 1, is the request for relief with regard to welds 3-WR-18 and 4-WR-18 any different than the request for relief made under Relief Request I (other than 71 percent coverage was obtained vs. 68 percent projected)?

FPL Response to Question 2:

Relief Request 1A supersedes Relief Request 1. Greater than 90 percent coverage was obtained for welds 3-DO-A, 3-DO-B, 3-DO-C, 4-DO-A, 4-DO-B, 4-DO-C outlet nozzles for Unit 3 and Unit 4.

The request for relief for the WR-18 weld in Relief Request 1A is the same as in Relief Request 1.

L-2006-181 Attachment 1

3. Relief Request IA states that the examination of the Figure 1 IWB-2500-12 A-B-C-D-E-F-G-H volume is limited when scanning the carbon steel base material surrounding the stud holes due to the sealing surfaces configuration. Please explain how the sealing surfaces configuration limits access to the required examination volume, and whether any alternate scanning angles can be used to achieve coverage in this area.

FPL Response to Question 3:

As shown in Figure 3 of the Relief Request 1A, there is a step down groove (sealing surface) where the o-ring fits on the vessel in the area that is limited. This area has uneven surfaces that do not allow for examination to be performed. This examination is performed by scanning a 0-degree transducer around the stud holes on the RPV Flange. The smallest diameter transducer (1/2") allowed by the procedure was used for the examination.

Alternate scanning angles would not achieve any additional coverage.

Relief Request 14A

4. FPL letter dated February 20, 2006 states the objective of Relief Requests 14A and 15A is to resubmit the previously approved Relief Request 14 and 15 for Class I and 2 vessel Inside radius, vessel welds, and piping welds that did not receive code required volume. In comparing Relief Request 14 and Relief Request 14A, there are 4 components (29"-RCS-1305-3, 8"-SI-2309-22, 8"-SI-2309-24, and 6"-BDA-2301-

8) that are listed In Relief Request 14 but not in Relief Request 14A. Please explain why the 4 components are not Included in Relief Request 14A.

FPL Response to Question 4:

Welds 8"-SI-2309-22 and 8"-2309-24 were removed in Relief Request 14A because two additional welds with no limitations in the C-F-1 category were examined during the interval. As a result, the welds with the worst case limitations were moved to augmented status.

Removal of welds 6"-BDA-2301-8 and 29"-RCS-1305-3 was in error. They will be added back into Relief Request 14A.

5. In Relief Request 14, component 3-SRGN-01-IR is listed under examination category B-D, item No.

B3.120, which is applicable to the Pressurizer. In Relief Request 14A, component 3-SRGN-01-IR is listed as applicable to examination category B-D, item No. B3.140. Please explain this change in classification of component 3-SRGN-01-IR.

FPL Response to Question 5:

This is a typographical error. The examination category is B-D, Item No. B3.120.

6. Table 1 Identifies the applicable code requirement for component "Spray Nozzle-SP-03-1-IR" as examination category B-D, item No. B3.140, which is applicable to steam generators. Please clarify whether this is a pressurizer spray nozzle or If it is applicable to steam generators.

FPL Response to Question 6:

This is a typographical error. This is the Pressurizer Spray Nozzle. The examination category is B-D, Item No.

B3.120.

L-2006-181 Attachment 1

7. Table 1 of Relief Request 14A Indicates 66-percent coverage from the elbow side for component 31"-

RCS-1302-10 was achieved. Relief Request 14 Indicates 75-percent coverage from the elbow side for component 31 "-RCS-1302-10 was achieved. Please explain the difference in coverage reported between the FPL August 8, 1996, letter and the February 20, 2006, letter.

FPL Response to Question 7:

When calculating the coverage for weld 31"-RCS-1 303-10, it was noticed that the CRV coverage was less than the previously calculated volume for weld 31 "-RCS-1302-10 with the same configuration. Upon further evaluation, it was determined that the weld scanned in 1998 had the CRV calculated with the rules from PDI and the weld scanned in 1994 had the original CRV calculated with the rules prior to PDI. The original calculation for weld 31"-RCS-1302-10 as presented in Relief Request 14 is correct based on the techniques in place at the time of the examination.

8. Describe any flaws or relevant Indications Identified adjacent to the areas that could not be examined.

FPL Response to Question 8:

There were no relevant indications or flaws identified adjacent to the areas that could not be examined.

Relief Request 15A:

9. Describe any flaws or relevant Indications Identified adjacent to the areas that could not be examined.

FPL Response to Question 9:

There were no relevant indications or flaws identified adjacent to the areas that could not be examined.

L-2006-181 Attachment 2 Page 1 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 1A (Revised) Rev 1 Relief Request In Accordance with 10 CFR50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1. ASME Code Component(s) Affected Class 1 pressure retaining welds in the reactor pressure vessel (RPV).

2. Applicable Code Edition and Addenda The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components, Section Xl, 1989 Edition, No Addenda.

3. Aopplicable Code Requirement Exam Item No.. Examination Requirements Cat.

B-A B1.21 Essentially 100% volumetric examination of all circumferential head welds.

B-A B1.30 Essentially 100% volumetric examination of the shell to flange weld.

B-G-1 B6.40 Essentially 100% volumetric examination of the 1 inch annular surface of flange surrounding each stud hole.

As defined by 10CFR50.55a(g)(6)(ii)(A)(2) and ASME Code Case N-460, essentially 100%

means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.

4. Impracticality of Compliance Due to the configuration of the Reactor Vessel, it is impractical to meet the examination coverage requirements of the ASME Code, Section Xl, 1989 Edition, No Addenda, as clarified by Code Case N-460. Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii). These areas were found during the 3rd 10-year inservice inspection interval.

When examined, the welds or surfaces listed within this request did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments.

These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume.

Described below, coupled with figures, are details of the examination limitations by weld or examination description. The accompanying figures graphically depict the extent of the limitations.

RPV Lower Head Ring-to-Bottom Head Weld (3-WR-9 and 4-WR-9)

L-2006-1 81 Attachment 2 Page 2 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 1A (Revised) Rev 1 Examination Category B-A, Item B13.21 The examination of the Figure IWB-2500-3 A-B-C-D volume is limited due to the proximity of the instrumentation tubes. Access to approximately 17% of the examination volume is restricted. The remaining 83% of the examination volume was examined with techniques which have been qualified by demonstration in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section XI, Appendix VIII, using the Performance Demonstration Initiative Protocol. This weld was examined from both sides of the weld, scanning both parallel and perpendicular to the weld. The ultrasonic examination identified no recordable indications.

The mechanized scanning of the lower head ring-to-lower head welds 3-WR-9 and 4-WR-9 are limited due to interference from the instrumentation tubes. Figure 1 provides an illustration of the weld volume limitation due to the instrumentation tubes.

RPV Upper Shell-to-Flange Weld (3-WR-18 and 4-WR-18)

Examination Category B-A, Item B13.30 The examination of the Figure IWB-2500-4 A-B-C-D volume is limited due to the Keyways and Irradiation Slots. Access to approximately 29% of the examination volume is restricted. The remaining 71% of the examination volume was examined with ASME Code acceptable techniques. Additionally, the mechanized techniques employed for examination from the RPV inside surface have also been qualified by demonstration in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section Xl, Appendix VIII, using the Performance Demonstration Initiative Protocol.

This weld was examined from both sides of the weld, scanning both parallel and perpendicular. The ultrasonic examination did not reveal any recordable or reportable flaws in accordance with the ASME Code Section Xl, 1989 Edition, No Addenda.

The upper shell-to-flange weld 3-WR-18 and 4-WR-18 is examined from the shell side and from the flange seal surface. The examination performed from the flange seal surface was not limited by configuration. Figure 2 shows the inside surface scan limitations and the location of the areas of incomplete coverage to the mechanized scanning due to the presence of the keyways and Irradiation slots.

RPV Threads in Flange (3-Lig-1 thru 58 and 4-Lig-1 thru 58)

Examination Category B-G-1, Item B6.40 The examination of the Figure IWB-2500-12 A-B-C-D-E-F-G-H volume is limited when scanning the carbon steel base material surrounding the stud holes due to the sealing surfaces configuration. Access to approximately 15.33% of the examination volume is restricted. The remaining 84.67% of the examination volume was examined with ASME Code acceptable techniques. The ultrasonic examination did not reveal any recordable or reportable flaws in accordance with the ASME Code Section Xl, 1989 Edition, No Addenda.

The manual scanning of the 1 inch annulus surface around the RPV flange stud hole 3-Lig 1- 58 and 4-Ligl thru 58 is performed from the RPV flange surface. Figure 3 provides an illustration of the RPV flange surface limitation due to interference from the sealing surface configuration. There is a step-down groove on the flange surface where the 0-ring fits. This causes an unparallel surface to perform the 0-degree examination.

L-2006-181 Attachment 2 Page 3 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 1A (Revised) Rev 1

5. Burden Caused by Compliance It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments.

Examinations are performed to the maximum extent possible. The Ultrasonic (UT) techniques for each weld or surface were reviewed to determine if additional coverage could be achieved. For the welds or surfaces listed above, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant.

6. Proposed Alternative and Basis for Use Proposed Alternative

1) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1.

2) Conduct ultrasonic examinations to the maximum extent possible.

Basis FPL performed inservice examinations of selected welds and surfaces in accordance with the requirements of 10CFR50.55a, plant technical specifications, and the 1989 Edition, No Addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl. When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

FPL performed mechanized ultrasonic examinations of the reactor vessel during the Unit 3 October 2004 and Unit 4 April 2005 refueling outage.

10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.

By letter dated July 22, 2004, and supplemented August 19, 2004, FPL submitted relief request

1. 35 to the U.S. Nuclear Regulatory Commission (NRC). The purpose of the relief request was to obtain permission to implement an alternative from certain provisions of the ASME Code, Section Xl, 1989 Edition, No Addenda, contained in the 3rd 10-year interval inservice inspection (ISI) program. FPL proposed supplementing the ASME Section Xl, 1989 Edition, No Addenda, Appendix I examination from the flange surface with the examination from the reactor vessel inside surface using procedures, equipment, and personnel qualified by demonstration to perform remote mechanized examination of the reactor vessel flange-to-shell weld from the inside surface in accordance with ASME Code 1995 Edition, 1996 Addenda,Section XI, Appendix VII, Supplements 4 and 6, in lieu of Section V, Article 4 requirements. The NRC authorized the proposed alternative by letter dated October 20, 2004 (TAC NO. MC3891). The accessible areas of the shell weld were examined with personnel, equipment and procedures that were qualified by demonstration in accordance with Supplements 4 and 6 of the 1995 Edition, 1996 Addenda of the ASME Code, Section Xl, Appendix VIII, using the Performance Demonstration Initiative (PDI) protocol. These examinations were performed from both sides of the welds, scanning both parallel and perpendicular to the weld to the maximum extent possible. The examinations

L-2006-181 Attachment 2 Page 4 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER IA (Revised) Rev 1 performed utilizing demonstrated and qualified techniques provided an equivalent or better examination than the requirements of the 1989 Edition, No Addenda, of ASME Section Xl.

FPL performed ultrasonic examinations of the remaining reactor vessel welds in accordance with the requirements of 10 CFR 50.55a, plant technical specifications, and the 1989 Edition, No Addenda, of ASME Section Xl to the maximum extent possible. Additionally, the mechanized techniques employed for examination from the RPV inside surface have also been demonstrated in accordance with Supplements 4 & 6 of the 1995 Edition, 1996 Addenda of the ASME Code Section Xl, Appendix VIII, using the Performance Demonstration Initiative Protocol.

NRC letter dated March 31, 1995 (TAC NO. M87725 and M87726) approved the initial submittal of relief request #1. The previous submittal of the relief request was based upon the techniques utilized and the limitations encountered during the examination during the 2'r 10-year inservice inspection interval and detailed the anticipated examination volume coverage for the examinations performed during the 3 rd 10-year inservice inspection interval examinations. This revision submits the examination volume coverage obtained during the 3 rd 10-year inservice inspection interval inspection.

In addition to the required ultrasonic examination, the interior of the reactor vessel, including welded attachments, received a visual examination in accordance with Table IWB-2500-1, Examination Categories B-N-i, B-N-2 and B-N-3. The visual examinations revealed no relevant indications.

The subject welds were examined in the 2nd interval during the 10-year reactor vessel examination. These examinations did not reveal any recordable or reportable flaws during the previous examination.

The extent of examination volume achieved ultrasonically, the alternate scans performed, and the system pressure tests provide assurance of an acceptable level of quality and safety.

7. Duration of Proposed Alternative Third Inservice Inspection Interval Unit 3 - February 22, 1994 thru February 21, 2005 (This includes a 1 year extension per ASME Section Xl, 1989 Edition, IWA 2430, No Addenda)

Unit 4 - April 15, 1994 thru April 14, 2005 (This includes a 1 year extension per ASME Section Xl, 1989 Edition, IWA 2430, No Addenda)

L-2006-181 Attachment 2 Page 5 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 1A (Revised) Rev 1

8. References 10CFR50.55a ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, No Addenda ASME Section V, "Rules For Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, No Addenda ASME Section Xl, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1" ASME Section Xl, "Rules For Inservice Inspection of Nuclear Power Plant Components," 1995 Edition, 1996 Addenda

L-2006-181 Attachment 2 Page 6 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 1A (Revised) Rev 1 Core stabliziflg Slug Rina Instrume ntationi tube RPV Lower Head Ring-to-Bottom Head Weld (3-WR-9 and 4-WR-9)

Figure 1

L-2006-181 Attachment 2 Page 7 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER IA (Revised) Rev I L'IRECTIONS :, 9, 4 ITi Parallel Scan DIRECTIONS I & 2 Limitation Missed Volume Perpendicular Scan Limitation Missed Volume Upper Shell to Flange Weld Volume Limitation Illustration Figure 2

L-2006-181 Attachment 2 Page 8 of 8 TURKEY POINT UNITS 3 AND 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 1A (Revised) Rev 1

/ /"'<

• 4. / /

ID \ '. \

Area of Interest ",..

RPV Flange Ligament Volume Limitation Illustration Figure 3

L-2006-181 Attachment 3 Page 1 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Relief Request In Accordance with 10 CFR50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1. ASME Code Component(s) Affected Class 1 inner radius in vessels Class 1 and 2 pressure retaining welds in vessel and piping

2. Applicable Code Edition and Addenda The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition, No Addenda.

3. Applicable Code Requirement rExam ItemNo. - Examination Requirements Cat.:

B-D B3.120 Essentially 100% volumetric examination of the nozzle inner I radius.

B-F B5.70 Essentially 100% volumetric and surface examination of Circumferential welds for >4" nominal pipe size.

B-J B9.11 Essentially 100% volumetric and surface examination of Circumferential welds for >4" nominal pipe size.

B-J B9.31 Essentially 100% volumetric and surface examination of branch pipe connections NPS 4 or larger.

Cl1.10 C-A C1.20 Essentially 100% volumetric examination of the weld length.

C-F-1 C5.11 Essentially 100% volumetric and surface examination of Circumferential welds for >4N nominal pipe size.

C-F-1 C5.21 Essentially 100% volumetric and surface examination of Circumferential welds for > 1/5" nominal pipe size.

C-F-2 C5.51 Essentially 100% volumetric and surface examination of Circumferential welds for >4" nominal pipe size.

As defined by ASME Code Case N-460, essentially 100% means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.

L-2006-181 Attachment 3 Page 2 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 14A (Revised) Rev 1

4. Impracticality of Compliance Due to the configuration of the welds included within this relief request, it is impractical to meet the examination coverage requirements of the ASME Code, Section Xl, 1989 Edition, No Addenda, as clarified by Code Case N-460. Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii). These areas were found during the 3rd 10-year inservice inspection interval.

When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site.

This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

When examined, the welds listed within this request did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments. These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume.

The Table 1 summarizes the percent of coverage achieved and references specific figures that show the extent of coverage. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

Relief is requested from the ASME Boiler and Pressure Vessel Code required volume as identified in Figure IWB-2500-7, 8, and 10 and IWC-2500-1 and 7, as applicable.

5. Burden Caused By Compliance Examinations are performed to the maximum extent possible. The ultrasonic (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved. If practical, physical obstructions were removed. For the welds listed within Table 1, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications.

Radiography is impractical due to the amount of work being performed in the areas on a 24-hour basis.

This would result in numerous work-related stoppages and increased exposure due to the shutdown of and startup of other work in the areas. The water must be drained from systems where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined. There would be significant burden associated with the performance of weld or area modifications or radiography in order to increase the examination coverage.

6. Proposed Alternative and Basis for Use Proposed Alternative

1) Surface examination per category B-F, B-J, C-F-1 and C-F-2.

2) Conduct ultrasonic examinations to the maximum extent possible.

3) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1 and Category C-H, Table IWC-2500-1.

L-2006-181 Attachment 3 Page 3 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Basis FPL performed inservice examinations of selected welds in accordance with the requirements of 10CFR50.55a, plant technical specifications, and the 1989 Edition, no addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl. When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments. Configuration, permanent attachments and/or structural interferences prohibit 100% ultrasonic examination of Code required volume.

Additional ultrasonic techniques are employed where practical to achieve the code-required volume. The Table 1 summarizes the percent of coverage achieved and references specific figures that show the extent of coverage. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

For examinations performed prior to the expedited implementation of Appendix VIII, Supplements 2 and 3 (May 22, 2000), the ultrasonic testing (UT) techniques for each weld were reviewed to determine if additional coverage could have been achieved. FPL's procedures require the examiner to consider whether additional coverage is necessary and practical. Those alternate techniques were investigated at the time of discovery. The alternate techniques considered were extending the calibration distance and/or using additional beam angles or modes. This has often provided the additional coverage needed to avoid relief. Using additional UT techniques on the weld examination areas in this relief request would have provided little or no additional coverage. The coverage obtained was the maximum practical.

For examinations performed after the 10 CFR 50.55a required expedited implementation of Appendix VII, supplements 2 and 3 (May 22, 2000), the ultrasonic testing (UT) was performed utilizing personnel qualified and procedures demonstrated in accordance with the Performance Demonstration Initiative (PDI) program.

In the cases where austenitic materials were examined (Code Category B-J and C-F-i), the credited volumetric examination of the weld required volume (WRV) is limited when access can only be obtained from one side. It should be noted that the volumetric examination was performed through 100% of the Code WRV; however, the PDI Appendix VIII procedure used is not qualified for the detection of flaws on the far side of the single sided access examinations of austenitic piping welds. The techniques employed for the single sided examinations provided for a best effort examination. The coverage obtained was the maximum practical.

The required surface examinations were performed and were not limited. In all cases, 100 percent of the code required surface area was examined. These surface and volumetric examinations did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in accordance with the ASME Code Section Xl, 1989 Edition, No Addenda.

For Category B-F, the Class 1 dissimilar metal piping welds have carbon steel nozzles buttered with stainless steel and field welded to forged stainless steel or cast stainless steel components with stainless steel weld material. All dissimilar metal weld examinations were performed prior to the expedited implementation of Appendix VIII, Supplements 10 (November 22, 2002). The ultrasonic testing (UT) techniques for each weld were reviewed to determine if additional coverage could have been achieved.

FPL's procedures require the examiner to consider whether additional coverage is necessary and practical.

Those alternate techniques were investigated at the time of discovery. The alternate techniques considered were extending the calibration distance and/or using additional beam angles or modes. This has often provided the additional coverage needed to avoid relief. Using additional UT techniques on the weld examination areas in this relief request would have provided little or no additional coverage. The coverage obtained was the maximum practical.

L-2006-181 Attachment 3 Page 4 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 14A (Revised) Rev 1 FPL performed the examinations to the extent possible. Operations personnel and system engineers perform walk downs of every system on a periodic basis looking for leakage or other abnormal conditions.

Surface and volumetric examinations performed, along with the required system pressure tests, provide reasonable assurance of an acceptable level of quality and safety.

10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components, which are classified as ASME Code Class 1, Class 2, and Class 3, must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.

The extent of examination volume achieved ultrasonically and the alternate scans performed (reference Table 1) coupled with the system pressure tests provide assurance of an acceptable level of quality and safety.

7. Duration of Proposed Alternative Third Inservice Inspection Interval February 22, 1994 to February 21, 2005 (This includes a 1 year extension per ASME Section Xl, 1989 Edition, IWA 2430, No Addenda)

8. References 10 CFR 50.55a ASME Section XI, Rules For In-service Inspection of Nuclear Power Plant Components, 1989 Edition, No Addenda.

ASME Section XI, Division 1, Code Case N-460, Alternative Examination coverage for Class 1 and Class 2 Welds,Section XI, Division 1.

ASME Section Xl, Rules For In-service Inspection of Nuclear Power Plant Components, 1995 Edition, 1996 Addenda

L-2006-181 Attachment 3 Page 5 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev I Table 1

.ASME Codle:  :::nrn*ln er Applicable Code Requirement" :i, .

• r. *'

• ASM CodeYear Component ID of AplcaliCdgRqirm Impracticably of Compliance Component Exam and coverage Obtained ig.

Exam Category B-D Inservice examination limited by welded pads, Inlet Nozzle to 3-SGA-1-IRS 2003 Item No. 13.140 1 supports, insulation pins, and Inner Radius Inner Radius Fig. IWB-2500-7(D) 70% Coverage Achieved configuration.

Exam Category B-D Inservice examination limited by welded pads, Outlet Nozzle To 3-SGA-O-IRS 2003 Item No. 83.140 2 supports, insulation pins, and Inner Radius Inner Radius Fig. IWB-2500-7(D) 70% Coverage configuration.

Exam Category B-D Inservice examination limited by welded pads, Inlet Nozzle To 3-SGB-I-IRS 1994 Item No. B3.140 1 supports, insulation pins, and Inner Radius Inner Radius Fig. IWB-2500-7(D) configuration.

1_ 70% Coverage Achieved Exam Category B-D Item No. B3.140 Inservice examination limited by welded pads, Outlet Nozzle To 3-SGB-O-IRS 1994 Fig. IWB-2500-7(D) 2 supports, insulation pins, and Inner Radius Inner Radius 70% Coverage Achieved In Two Circumferential Directions configuration.

Examined 1994 Exam Category B-D Inservice examination limited by welded pads, Inlet Nozzle To 3-SGC-1-IRS 1998 Item No. B3.140 I supports, insulation pins, and Inner Radius Inner Radius Fig. IWB-2500-7(D) configuration.

70% Coverage Exam Category B-D Inservice examination limited by welded pads, Outlet Nozzle To 3-SGC-0-IRS 1998 Item No. 83.140 2 supports, insulation pins, and Inner Radius Inner Radius Fig. IWB-2500-7(D) 2 orsinulation p 70% Coverage Achieved configuration.

Exam Category B-D Spray Nozzle Spray Nozzle- 1995 Item No. 83.120 Inservice examination limited by configuration and I Inner Radius SP-03-1-IR Fig. IWB-2500-7(D) raised letters welded in the examination zone 70% Achieved

L-2006-181 Attachment 3 Page 6 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Table1 ASME Code' ID Yea Applicable Code Requirement component Component Exam and coverage Obtained Fg. Impracticably. of Compliance Exam Category B-D Surge Nozzle 3-SRGN-01-IR 1994 Item No. B3.120 4 Inservice examination limited by Pressurizer Heater Inner Radius Fig. IWB-2500-7(D) Penetrations.

I 55% Achieved Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, Elbow To SG 29"-RCS-1305-4 1994 Fig. IWB-2500-8 5 examination is limited from the Elbow due to weld Nozzle 43% From Elbow Side crown and Nozzle side due to taper.

2% From Nozzle Side Examined Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, Elbow To SG 29"-RCS-1 308-4 1998 Fig. IWB-2500-8 6 examination is limited from the Elbow due to weld Nozzle 47% From Elbow Side crown and Nozzle side due to taper.

0% From Nozzle Side Examined Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, SG Nozzle To 31"-RCS-1 302-5 1994 Fig. IWB-2500-8 7 examination is limited from the Elbow due to weld Elbow 75% From Elbow Side crown and Nozzle side due to taper.

0% From Nozzle Side Examined Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, SG Nozzle To 31"-RCS-1303-5 1998 Fig. IWB-2500-8 8 examination is limited from the Elbow due to weld 62% From Elbow Side crown and Nozzle side due to taper.

0% From Nozzle Side Examined Exam Category B-J Inservice examination limited by configuration, Elbow To Tee 4"-RC-1 304-18 1995 Item No. 1B9.11 9 examination is limited from Elbow and Tee side due to (4"- 20) Fig. IWB-2500-8radius.

82% CRV Achieved

L-2006-181 Attachment 3 Page 7 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Table 1 AsMECode ear Component of Applicable Code Requirement Component Exam and coverage Obtained Fig. Impracticably of Compliance Exam Category B-J Inservice examination limited by configuration, Tee To Tee 4"-RC-1304-20 Item No. B9.11 9 examination is limited from both sides of the Tee side (4"-120) 1995 Fig. IWB-2500-8 due to radius.

82% CRV Exam Category B-J Branch 4"-RC-1305-1 Item No. B9.11 Inservice examination limited by configuration, Connection To (4"--120) 1998 Fig. IWB-2500-8 10 examination is limited from Elbow due to weld crown Elbow 87% From Branch Conn. Side and Branch Connection side.

81% From Elbow Side Exam Category B-J 8"-RHR-1301-3 Item No. B9.11 Inservice examination limited by configuration, Elbow To Valve (8"--120) 1998 Fig. IWB-2500-8 11 examination is complete from Elbow side and limited 100% From Elbow Side from Valve side due to taper.

39% From Valve Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pipe To Tee 8"-RHR-1 304-8 1998 Fig. IWB-2500-8 12 examination is limited from Pipe side due to weld (8"-120) 67% From Pipe Side crown and Tee side due to radius.

55% From Tee Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pipe To Pipe 8"-RHR-1305-2A (8"-120) 1Fig. IWB-2500-8 70% From Upstream Pipe Side 13 examination weld from Pipe side dueistolimited crown.upstream and downstream 70% From Downstream Pipe Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pipe To Tee 8"-RHR-1305-3 1998 Fig. IWB-2500-8 14 examination is limited from Pipe side due to weld (8"-120) 67% From Pipe Side crown and Tee side due to radius.

99% From Tee Side I II

L-2006-181 Attachment 3 Page 8 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Table 1 Year ASME Code."', Comp n I. of Applicable Code'Requirement Cg Comp n ECmponem and coverage Obtained Fig. Impracticably of Compliance Exam Category B-J Item No. B9.1 1 Inservice examination limited by configuration, Elbow Eow to Branch ctioBrnh 10"-S1-1 302-1 10--140) 1994 Fig.

Fig.IWB-2500-8 Elbow 15 examination is complete from Elbow side and limited Connection (10"-1 40) 100% From Elbow Side 85% From Branch Connection from Branch Connection side due to taper.

Side Exam Category B-J 10"-SI-1 302-4 Item No. B9.11 Inservice examination limited by configuration, Elbow To Valve (10--140) 1994 Fig. IWB-2500-8 16 examination is limited from Elbow side due to weld 85% From Elbow Side crown and Valve side due to taper.

25% From Valve Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Elbow To Valve 1(0S11303-11 1998 Fig. IWB-2500-8 17 examination is complete from Elbow side and limited (10"-140) 100% From Elbow Side from Valve side due to taper.

4% From Valve Side Exam Category B-J Pipe To Branch 10"-S1-1303-15 Item No. B9.11 Inservice examination limited by configuration, Connection (10"-140) 1998 Fig. IWB-2500-8 18 examination is complete from Pipe side and limited 100% From Pipe Side from Branch Connection side due to taper.

66% From Branch Conn. Side Exam Category B-J Branch Item No. B9.11 Inservice examination limited by configuration, Connection To 12"-RCS-1301-1 1994 Fig. IWB-2500-8 19 examination is complete from Pipe side and limited Pipe (12"-140) 100% From Pipe Side 67% From Branch Connection from Branch Connection side due to taper.

Side

L-2006-181 Attachment 3 Page 9 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Table 1 ASME Codepne ASMECode ' Year Applical Cod Re....... .......

Component ID of ApplicabeCodeRquiremImpracticably Fig. of Compliance ponentExam and coverage Obtained n .

Exam Category B-J 14"-RHR-1301-6 Item No. B9.11 Inservice examination limited by configuration, Pipe To Valve (14"-140) 1998 Fig. IWB-2500-8 20 examination is limited from Pipe side due to weld 86% From Pipe Side crown and Valve side due to taper.

8% From Valve Side Exam Category B-J 10" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 27.5"-RCS-1306-4 1995 Fig. IWB-2500-1 0 21 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pump To Pipe 27.5"-RCS-1306-11 1994 Fig. IWB-2500-8 22 examination is complete from Pipe side and limited 0% From Pump Side from Pump side due to taper.

100% From Pipe Side Exam Category B-J 10" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 27.5-RCS-1307-2 1995 Fig. IWB-2500-10 21 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Pipe Side Exam Category B-J 10" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 27.5"-RCS-1 309-3 1995 Fig. IWB-2500-1 0 21 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pump To Pipe 27.5"-RCS-1309-11 1998 Fig. IWB-2500-8 23 examination is limited from Pump side due to taper 0% From Pump Side and Pipe side due to weld crown.

87% From Pipe Side I II

L-2006-181 Attachment 3 Page 10 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev I Table 1 ASMECodeYear oASMEonnt Component I o Applicable Code Requirement H Exam D and co eageO ed Fig. Impracticably of Compliance Exam Category B-J Item No. B9.31 Inservice examination limited by configuration, Elbow to Pipe 29"-RCS-1 305-3 1994 Fig. IWB-2500-10 23A examination is limited from Elbow side due to taper 69% From Elbow Side and limited on pipe side due to 18" Branch connection 93% From Pipe Side Exam Category B-J 12" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 29"-RCS-1 305-BC3 1995 Fig. IWB-2500-10 24 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J 14" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 29"-RCS-1 308-BC-1 1995 Fig. IWB-2500-10 25 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Elbow To Pump 31"-RCS-1 302-10 1994 Fig. IWB-2500-8 26 examination is limited from Elbow due to weld crown I 75% From Elbow Side and Pump side due to taper.

0% From Pump Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Elbow To Pump 31"-RCS-1 303-10 1998 Fig. IWB-2500-8 26 examination is limited from Elbow due to weld crown 56% From Elbow Side and Pump side due to taper.

0% From Pump Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pipe To Elbow 31"-RCS-1 303-7 1998 Fig. IWB-2500-8 27 examination is limited from Pipe and Elbow side due 79% From Pipe Side to weld crown.

52% From Elbow Side I I

L-2006-181 Attachment 3 Page 11 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Table -1 CofASMECodeyear ASMEnent ID Applicable Code Requirement Component Exam and coverage Obtained ig. Irta of'Copliane Exm atgoy -

Exam Category C-A Inservice examination limited by configuration, Item No. C1 .20 examination is limited from the Head and Shell side Head To Shell 3-RHE-Al 1997 Fig. IWC-2500-1 28 due to support integral attachment, welded 95% From Head Side attachments and nozzle reinforcement plate.

57% From Shell Side Exam Category C-A Inservice examination limited by configuration, Item No. C1 .10 examination is limited from the Shell and Flange side Shell To Flange 3-RHE-A.2 1997 Fig.

71% From IWC-2500-1 Shell Side 29 due detto support upr integral attachment, welded nerlatcmnwle 110% From Felan Side attachments and nozzle reinforcement plate.

100% From Flange Side Exam Category C-F-1 Inservice examination limited by configuration, Item No. C5.21 examination performed with Appendix VIII Flange To Elbow (3--80) 2001 Fig. IWC-2500-7(a) 30 demonstrated procedure, examination complete from 100% From Elbow Side Elbow side only and no exam performed from the 0% From Flange Side Flange side due to taper.

Exam Category C-F-1 Inservice examination limited by configuration, 3 - 4 Item No. C5.21 examination performed with Appendix VIII Pipe To Valve (3"-80) 2001 Fig. IWC-2500-7(a) 31 demonstrated procedure, examination complete from 100% From Pipe Side Pipe side and no exam performed from the Valve side 0% From Valve Side due to taper.

Exam Category C-F-1 Item No. C5.11 Inservice examination limited by configuration, Reducer To Pipe (8"--120) 1998 Fig. IWC-2500-7(a) 32 examination is limited from the Pipe side due to weld 62% From Pipe Side crown and Reducer side due to taper.

50% From Reducer Side Exam Category C-F-1 Item No. C5.11 Inservice examination limited by configuration, Valve To Pipe 10"-S1-2304-3 1998 Fig. IWC-2500-7(a) 33 examination is limited from the Pipe side due to weld (10"-140) 91% From Pipe Side crown and Valve side due to taper.

8% From Valve Side I II

L-2006-181 Attachment 3 Page 12 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 Table 1 Year' ASME Code Component ID of,- Applicable'Code Requirement Fig CompnentID ig.Impracticably of Compliance Component;Ea and coverage Obtained'.

Exam Category C-F-1 14-RHR-2301-1 Item No. C5.11 Inservice examination limited by configuration, Valve To Elbow (14"-40) 1995 Fig. IWC-2500-7(a) 34 examination is limited from the Valve side due to taper 84% From Valve Side and Elbow side due to weld crown.

94% From Elbow Side Exam Category C-F-2 Inservice examination limited by configuration, 6"-BDC-2303-6 Item No. C5.51 examination performed with Appendix VIII Valve to Pipe (6"-1 60) 2003 Fig. IWC-2500-7(a) 35 demonstrated procedure, examination complete from 0% From Valve Side Pipe side and no exam performed from the Valve side 100% From Pipe Side due to taper.

Exam Category C-F-2 6-BDA-2301-8 Item No. C5.51 Inservice examination limited by configuration, Pipe to Wye (6"-160) 1994 Fig. IWC-2500-7(a) 36 examination is complete from Pipe side and limited 50% From Wye Side from Wye side due to taper.

100% From Pipe Side

L-2006-1 81 Attachment 3 Page 13 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 14A (Revised) Rev 1 STEAM GENERATOR STEAMGENERATOR 3-SGA-I-IRS(TYPICAL)

TONOZZLE 3-SGB-I.IRS TRANSITIONAREA 3-SGC-1-IRS (r X 21 INSULATION BRAD(ETSATB80 135,225.270, AND 315DEGREES F igure 1 18 OFSCANLIMITED DUE TOCLOSEPROXIMITY OF GENERATOR SUPPORT LOCATED AT90 DEGREE STEAM GENERATOR (T X 2") INSULATION BRACKETS 3-SOA-O-IRS (TYPICAL)

LOCATED AT45, 90, 112. 1150. 3-SGB-O-IRS AND202 DGREES3-G0-R 18- OF SCAN LIMITED DUE TO GENERATOR SUPPORT LOCATION AT 180DEGREE Figure 2 9 NOZZLE TO STEAM GENERATOR TRANSITION AREA

L-2006-181 Affachment 3 Page 14 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 14A (Revised) Rev 1 MAN WAY SP- -

ORV-03-$1 -IR LETTERS RAISED IN Figure 3 F0 04-C>

Figure 4

• 121 c ' ,

PRESSURIZER SURGE NOZZLE 3-SRGN-01-IR

L-2006-181 Affachment 3 Page 15 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSER VICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev I 29"-RCS-1305-4 (TYPICAL)

ELBOW Figure 5 29"-RCS-1308-4 (TYPICAL)

NOZZLE ELBOW Figure 6

27 Page 16 of 3 UNIT 3 L-2006-18 1 Attachment TURKEy POINT Rev 1 INTERVAL I4A (Revised)

INSPECTION TIIIRD 10-YEAR INSERVICE REQUEST NUMBER RELIEF 31 "-RCS-1302 5 (TYPICAL)

Figure 7 31"-RCS-1303-5 (TYPICAL)

ELBOW NOZZLE Figure 8

L-2006-181 Attachment 3 Page 17 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev I 4"-RC-1304-18 FLoN .4"-RC-1304-20 TO P VIE Figure 9 VIEW.'

4-RC-1305-1 (TYPICAL)

Figure 10 BRANCH CONNECTION ELBOW 8"-RHR-1301-3 (TYPICAL)

VALVE Figure 11

L-2006-181 Attachment 3 Page 18 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 8"-RHR-1304-8 (TYPICAL)

PIPE AREA 1 AREA2 AREA 3 00 it 0 DC~l Figure 12 V4T-r I- X7 It OfII@

L-2006-181 Affachment 3 Page 19 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSER VICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 8"-RHR-1305-2A (TYPICAL)

Figure 13 8"-RHR-1305-3 (TYPICAL)

Figure 14 10"-SI-1302-1 (TYPICAL)

ELBOW BRANCH Figure 15 CONNECTION

L-2006-181 Affachment 3 Page 20 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 14A (Revised) Rev 1 10"-SI-1302-4 (TYPICAL)

Figure 16 10"-SI-1303-11 (TYPICAL)

Figure 17 10"-SI-1303-15 (TYPICAL)

Figure 18

L-2006-181 Attachment 3 Page 21 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 12"-RC-1301-1 (TYPICAL)

BRANCH PIPE CONNECTION Figure 19 14"-RHR-1301-6 (TYPICAL)

VALVE Figure 20 PIPE 27.5"-RCS-1306-4 (TYPICAL) 27.5"-RCS-1307-2 27.5"-RCS-1309-3 Figure 21

L-2006-181 Attachment 3 Page 22 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 14A (Revised) Rev 1 27.5"-RCS-1306-11 (TYPICAL)

PUMP CASTING Figure 22 27.5"-RCS-1309-11 (TYPICAL)

PUMP PIPE Figure 23

L-2006-181 Attachment 3 Page 23 of 27 TURKEY POINT UNIT 3 TIIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 297-RCS-1305-3 PIPE I Figure 23A 29"-RCS-1305-BC3 (TYPICAL)

MAIN LOOP PIPING BRANCH CONNECTION Figure 24 29"-RCS-1308-BC-1 (TYPICAL)

Figure 25

L-2006-181 Attachment 3 Page 24 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 31"-RCS-1302-10 (TYPICAL) 31"-RCS-1303-10 Figure 26 PUMP ELBOW 31"-RCS-1303-7 (TYPICAL)

Figure 27 3-RHE-AI Reinforcement I I Plate and Inlet &

Outlet nozzle I  !

Coverage without limitations Coverage with limitations Figure 28

Attachment 3 POINT UNIT 3 U-2006-181 TURKEY Page 25 of 27 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 3-RHE-A2 Reinforcement Plate and Inlet

& Outlet Nozzle Figure 29 3"-SI-2301-1 (TYPICAL)

Figure 30 ELBOW 3"-SI-2301-4 (TYPICAL)

Figure 31 VALVE PIPE

L-2006-181 Aftachment 3 Page 26 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 8"-SI-2303-1 (TYPICAL)

Figure 32 10"-SI-2304-3 (TYPICAL)

VALVE PIPE Figure 33 14"-RHR-2301-1 (TYPICAL)

Figure 34 VALVE ELBOW

L-2006-181 Attachment 3 Page 27 of 27 TURKEY POINT UNIT 3 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 14A (Revised) Rev 1 6"-BDC-2303-6 VALVE PIPE Figure 35 6"-BDA-2301-8 (TYPICAL)

WYE Figure 36

L-2006-181 Attachment 4 Page 1 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev 1 Relief Request In Accordance with 10 CFR50.55a(g)(5)(iii)

-- Inservice Inspection Impracticality--

1. ASME Code Component(s) Affected Class 1 inner radius in vessels Class 1 and 2 pressure retaining welds in vessel and piping

2. Applicable Code Edition and Addenda The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition, No Addenda.

3. Aollicable Code Reauirement

.Exa Item No.,  :,.,Examination Requirements, Cat.

B-D B3.120 Essentially 100% volumetric examination of the nozzle inner radius.

B-F B5.70 Essentially 100% volumetric and surface examination of Circumferential welds for >4" nominal pipe size.

B-J B9.11 Essentially 100% volumetric and surface examination of Circumferential welds for >4" nominal pipe size.

B-J B9.31 Essentially 100% volumetric and surface examination of branch pipe connections NPS 4 or larger.

C1.10 C-A C1.20 Essentially 100% volumetric examination of the weld length.

C-B C2.21 Essentially 100% volumetric and surface examination of the nozzle to vessel welds.

C-F-1 C5.11 Essentially 100% volumetric and surface examination of Circumferential welds for >4" nominal pipe size.

Essentially 100% volumetric and surface C-F-1 C5.21 examination of Circumferential welds for > 1/5" nominal pipe size.

As defined by ASME Code Case N-460, essentially 100% means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.

L-2006-181 Attachment 4 Page 2 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1

4. Impracticality of Compliance Due to the configuration of the welds included within this relief request, it is impractical to meet the examination coverage requirements of the ASME Code, Section Xl, 1989 Edition, No Addenda, as clarified by Code Case N-460. Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii). These areas were found during the 3rd 10-year inservice inspection interval.

When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

When examined, the welds listed within this request did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments. These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume.

The Table 1 summarizes the percent of coverage achieved and references specific figures that show the extent of coverage. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

Relief is requested from the ASME Boiler and Pressure Vessel Code required volume as identified in Figure IWB-2500-7 through 10 and IWC-2500 1, 4 and 7, as applicable.

5. Burden Caused By Compliance Examinations are performed to the maximum extent possible. The ultrasonic (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved. If practical, physical obstructions were removed. For the welds listed within Table 1, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant.

Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications.

Radiography is impractical due to the amount of work being performed in the areas on a 24-hour basis. This would result in numerous work-related stoppages and increased exposure due to the shutdown of and startup of other work in the areas. The water must be drained from systems where radiography is performed, increases the radiation dose rates over a much broader area than the weld being examined. There would be significant burden associated with the performance of weld or area modifications or radiography in order to increase the examination coverage.

6. Proposed Alternative and Basis for Use Proposed Alternative

1) Surface examination per category B-F, B-J, C-B, and C-F-1

2) Conduct ultrasonic examinations to the maximum extent possible.

3) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1 and Category C-H, Table IWC-2500-1.

L-2006-181 Attachment 4 Page 3 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 Basis FPL performed inservice examinations of selected welds in accordance with the requirements of 10CFR50.55a, plant technical specifications, and the 1989 Edition, no addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl. When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments. Configuration, permanent attachments and/or structural interferences prohibit 100% ultrasonic examination of Code required volume. Additional ultrasonic techniques are employed where practical to achieve the code-required volume. The Table 1 summarizes the percent of coverage achieved and references specific figures that show the extent of coverage. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

For examinations performed prior to the expedited implementation of Appendix VIII, Supplements 2 and 3 (May 22, 2000), the ultrasonic testing (UT) techniques for each weld were reviewed to determine ifadditional coverage could have been achieved. FPL's procedures require the examiner to consider whether additional coverage is necessary and practical. Those alternate techniques were investigated at the time of discovery. The alternate techniques considered were extending the calibration distance and/or using additional beam angles or modes. This has often provided the additional coverage needed to avoid relief. Using additional UT techniques on the weld examination areas in this relief request would have provided little or no additional coverage. The coverage obtained was the maximum practical.

For examinations performed after the 10 CFR 50.55a required expedited implementation of Appendix VII, supplements 2 and 3 (May 22, 2000), the ultrasonic testing (UT) was performed utilizing personnel qualified and procedures demonstrated in accordance with the Performance Demonstration Initiative (PDI) program. In the cases where austenitic materials were examined (Code Category B-J and C-F-1, the credited volumetric examination of the weld required volume (WRV) is limited when access can only be obtained from one side. It should be noted that the volumetric examination was performed through 100% of the Code WRV, however, the PDI Appendix ViII procedure used is not qualified for the detection of flaws on the far side of the single sided access examinations of austenitic piping welds. The techniques employed for the single sided examinations provided for a best effort examination. The coverage obtained was the maximum practical.

The required surface examinations were performed and were not limited. In all cases, 100 percent of the code required surface area was examined. These surface and volumetric examinations did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations in accordance with the ASME Code Section Xl, 1989 Edition, No Addenda.

For Category B-F, the Class 1 dissimilar metal piping welds have carbon steel nozzles buttered with stainless steel and field welded to forged stainless steel or cast stainless steel components with stainless steel weld material. All dissimilar metal weld examinations were performed prior to the expedited implementation of Appendix VIII, Supplements 10 (November 22, 2002). The ultrasonic testing (UT) techniques for each weld were reviewed to determine if additional coverage could have been achieved. FPL's procedures require the examiner to consider whether additional coverage is necessary and practical. Those alternate techniques were investigated at the time of discovery. The alternate techniques considered were extending the calibration distance and/or using additional beam angles or modes. This has often provided the additional coverage needed to avoid relief. Using

L-2006-181 Attachment 4 Page 4 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 additional UT techniques on the weld examination areas in this relief request would have provided little or no additional coverage. The coverage obtained was the maximum practical.

FPL performed the examinations to the extent possible. Operations personnel and system engineers perform walk downs of every system on a periodic basis looking for leakage or other abnormal conditions. Surface and volumetric examinations performed, along with the required system pressure tests; provide reasonable assurance of an acceptable level of quality and safety.

10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components, which are classified as ASME Code Class 1, Class 2, and Class 3, must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.

The extent of examination volume achieved ultrasonically and the alternate scans performed (see Table 1) coupled with the system pressure tests provide assurance of an acceptable level of quality and safety.

7. Duration of Proposed Alternative Third Inservice Inspection Interval April 15, 1994 to April 14, 2005 (This includes a 1 year extension per ASME Section Xl, 1989 Edition, IWA 2430, No Addenda)

8. References 10 CFR 50.55a ASME Section XI, Rules For In-service Inspection of Nuclear Power Plant Components, 1989 Edition, No Addenda.

ASME Section Xl, Division 1, Code Case N-460, Alternative Examination coverage for Class 1 and Class 2 Welds, Section Xl, Division 1.

ASME Section Xl, Rules For In-service Inspection of Nuclear Power Plant Components, 1995 Edition, 1996 Addenda

L-2006-181 Attachment 4 Page 5 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev I Table 1 ASMVE Code Component, Component I'D Angle Used Applicable Code Requirement, andcoverageObtained Fig., Impracticably of Compliance Exam Category B-D Inservice examination limited by welded pads, Inlet Nozzle Inner 4-SGA-1-IRS 1994 Item No. B3.140 1 supports, insulation pins, and Inner Radius Radius Fig. IWB -2500-7(D) 75% Coverage configuration.

Exam Category B-D Inservice examination limited by welded pads, Outlet Nozzle 4-SGA-O-IRS 1994 Item No. B3.140 2 supports, insulation pins, and Inner Radius Inner Radius Fig. IWB -2500-7(D) 75% Coverage configuration.

Exam Category B-D Inservice examination limited by welded pads, Inlet Nozzle Inner 4-SGB-1-IRS 1997 Item No. B3.140 1 supports, insulation pins, and Inner Radius Radius Fig. IWB -2500-7(D) configuration.

75% Coverage configuration.

Exam Category B-D Inservice examination limited by welded pads, Outlet Nozzle 4-SGB-O-IRS 1997 Item No. B3.140 2 supports, insulation pins, and Inner Radius Inner Radius Fig. IWB -2500-7(D) configuration.

75% Coverage configuration.

Exam Category B-D Inservice examination limited by welded pads, Inlet Nozzle Inner 4-SGC-1-IRS 2002 Item No. B3.140 1 supports, insulation pins, and Inner Radius Radius Fig. IWB -2500-7(D) configuration.

75% Coverage Achieved Exam Category B-D Inservice examination limited by welded pads, Outlet Nozzle 4-SGC-0-IRS 2002 Item No. B3.140 Inner Radius Fig. IWB -2500-7(D) 2 supports, insulation pins, and Inner Radius 75% Coverage Achieved configuration.

Exam Category B-D I Spray Nozzle SP041IR 2000 Item No. B3.120 Inservice examination limited by configuration and Inner Radius -- Fig. IWB-2500-7(D) raised letters welded in the examination zone 70% Achieved I I

L-2006-181 Attachment 4 Page 6 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 Table 1 A ECompoen Copnn 'DAngle Applicable Code Requirement UsedeandmcoveragenObtainedpFl. Impracticably of. Compliance Exam Category B-D Surge Nozzle 4-SRGN-01 -1 R 1996 Item No. B3.120 4 Inservice examination limited by Pressurizer Heater Inner Radius Fig. IWB-2500-7(D) Penetrations.

55% Achieved Exam Category B-F Safe-End To PZR 12"-RC-1401-9 Item No. B5.70 Inservice examination limited by configuration, Nozzle (12"-140) 1996 Fig. IWB-2500-8 5 examination is complete from Safe-end side and 100% From Safe-End Side limited from Nozzle side due to taper.

74% From Nozzle Side Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, Elbow To SG 29"-RCS-1 404-4 1994 Fig. IWB-2500-8 6 examination is limited from the Elbow side due to weld Nozzle 74% From Elbow Side crown and Nozzle side due to taper.

0% From Nozzle Side Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, Elbow To SG 29"-RCS-1 405-4 1997 Fig. IWB-2500-8 7 examination is limited from the Elbow side due to weld Nozzle 53% From Elbow Side crown and Nozzle side due to taper.

10% From Nozzle Side Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, SG Nozzle To 31"-RCS-1401-5 1994 Fig. IWB-2500-8 8 examination is limited from the Elbow side due to weld 0% From Nozzle Side crown and Nozzle side due to taper.

62% From Elbow Side Exam Category B-F Item No. B5.70 Inservice examination limited by configuration, SG Nozzle To 31"-RCS-1402-5 1997 Fig. IWB-2500-8 9 examination is limited from the Elbow side due to weld Elbow 8% From Nozzle Side crown and Nozzle side due to taper.

42% From Elbow Side

L-2006-181 Attachment 4 Page 7 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 Table 1 ASE Code. Angle . Applicable Code Requirement Impracticably of Compliance Component Used and coverage Obtained Fig.

Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Valve To Elbow 8-RHR-14016 1996 Fig. IWB-2500-8 10 examination is complete from Elbow side and limited (8"-120) 20% From Valve Side from Valve side due to taper.

100% From Elbow Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pipe To Tee 8"-RHR-1402-4 1996 Fig. IWB-2500-8 11 examination is complete from Pipe side and limited (8"120) 100% From Pipe Side from Tee side due to taper.

30% From Tee Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Tee To Tee 8"-RHR-1402-7 1996 60% FromFig. Upstream IWB-2500-8 12 Tee Sideradius. examination is limited from both sides of the tee due (8120) 20% From Downstream Tee Side Exam Category B-J 10"-S1-1401-14 Item No. B9.11 Inservice examination limited by configuration, Valve To Pipe (10"--140) 1994 Fig. IWB-2500-8 13 examination is complete from Pipe side and limited 26% From Valve Side from Valve side due to taper.

100% From Pipe Side Exam Category B-J 89.11 Item No. ItemNo.

9.11Inservice examination limited by configuration, Elbow To Branch 10"-S1-1401-18 Fig. IWB-2500-8 n examination i lite byc iguration, Connection (10"-140) 1994 100% From Elbow Side 14 examination is complete from Elbow side and limited 18% From Branch Connection from Branch Connection side due to taper.

Side

L-2006-181 Attachment 4 Page 8 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev I Table 1 ASME Code Component I 'Angle- Applicable'Code Requirement Fig. Impracticably of Compliance CompConopeent Used and coverage Obtained.'

Exam Category B-J 10-S1-1402-1 Item No. B9.11 Inservice examination limited by configuration, Valve To Elbow (10S-140) 1999 Fig. IWB-2500-8 15 examination is complete from Elbow side and limited 100% From Elbow Side from Valve side due to taper.

26% From Valve Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pipe To Valve 10%S1-1402-13 1997 Fig. IWB-2500-8 17 examination is complete from Pipe side and limited (10"-140) 100% From. Pipe Side from Valve side due to taper.

23% From Valve Side Exam Category B-J Elbow To Branch 10"-SI-1 402-17 Item No. B9.11 Inservice examination limited by configuration, Connection (10"-140) 1997 Fig. IWB-2500-8 18 examination is complete from Elbow side and limited 100% From Elbow Side from Branch Connection side due to taper.

23% From Branch Conn. Side Exam Category B-J 10"-S1-1402-4 Item No. B9.11 Inservice examination limited by configuration, Elbow To Tee (10"-140) 1999 Fig. IWB-2500-8 16 examination is complete from Elbow side and limited 100% From Elbow Side from Tee side due to radius.

11% From Tee Side Exam Category B-J Branch 12"-RC-1401-1 Item No. B9.11 Inservice examination limited by configuration, Connection To 12"-140) 1997 Fig. IWB-2500-8 19 examination is limited from Branch Connection and Pipe (12"-140) 36% From Branch Conn. Side Elbow side due to taper.

86% From Pipe Side Exam Category B-J Branch Item No. B9.11 Inservice examination limited by configuration, Connection To 14"-RHR-1401-1 1994 Fig. IWB-2500-8 20 examination is limited from Branch Connection and Elbow (14"-140) 70% From Branch Conn. Side Elbow side due to taper.

35% From Elbow Side

L-2006-181 Attachment 4 Page 9 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev I Table 1 ASME Code ,CompoentID Angle. Applicable Code Requirement' Component * -i. Used and coverage Obtained Fig. Impractcably of Complance Exam Category B-J 14"-RHR-1401-5 Item No. B9.1 1 Inservice examination limited by configuration, Pipe To Valve (14"-140) 1994 Fig. IWB-2500-8 21 examination is complete from Pipe side and limited 100% From Pipe Side from Valve side due to taper.

0% From Valve Side Exam Category B-J 14"-RHR-1401-6 Item No. B9.11 Inservice examination limited by configuration, Valve To Pipe (14"--140) 1994 Fig. IWB-2500-8 22 examination is complete from Pipe side and limited 0% From Valve Side from Valve side due to taper.

100% From Pipe Side Exam Category B-J 14"-RHR-1401-9 Item No. B9.11 Inservice examination limited by configuration, Elbow To Pipe (14"-140) 1994 Fig. IWB-2500-8 23 examination is limited from Pipe side and Elbow side 54% From Elbow Side due to weld crown.

53% From Pipe Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pump To Pipe 27.5"-RCS-1406-11 1997 Fig. IWB-2500-8 25 examination is complete from Pipe side and limited 0% From Pump Side from Pump side due to taper.

100% From Pipe Side Exam Category B-J 10" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 27.5"-RCS-1 406-18 1994 Fig. IWB-2500-1 0 24 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Pump To Pipe 27.5"-RCS-1407-11 1994 Fig. IWB-2500o8 26 examination is limited from Pump due to taper and 18% From Pump Side Pipe side due to instrumentation line.

1______ _ _41% From Pipe Side III

L-2006-181 Attachment 4 Page 10 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev I Table 1 ASME Codel C tlD Angle Applicable Code Requirement Component omponen Used ;and coverage Obtained Fig. Impracticably of Compliance Exam Category B-J Item No. B9.31 Inservice examination limited by configuration, 10" Branch 27.5"-RCS-1407-20 1994 Fig. IWB-2500-10 24 examination is complete from Branch Connection side Connection 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J 4" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 27.5"-RCS-1409-16 1994 Fig. IWB-2500-10 27 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J 10" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 27.5"-RCS-1409-17 1994 Fig. IWB-2500-10 24 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Exam Category B-J 14" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 29"-RCS-1404-18 1994 Fig. IWB-2500-10 28 examination is complete from Branch Connection side 100% From Branch Conn. Side and limited from Main Loop Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J 12" Branch Item No. B9.31 Inservice examination limited by configuration, Connection 29"-RCS-1 405-21 1994 Fig. IWB-2500-10 29 examination is limited from Branch and Main Loop 75% From Branch Conn. Side Piping side due to taper.

0% From Main Loop Piping Side Exam Category B-J Item No. 9.11 Inservice examination limited by configuration, Elbow To Pump 31"-RCS-1 401-10 1994 Fig. IWB-2500-8 31 examination is limited from the Elbow due to weld 57% From Elbow Side crown and taper and Pump side due to taper.

0% From Pump Side II

L-2006-181 Attachment 4 Page 11 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 Table 1 Amponent.e co ASME Code. " CmpnntI opnn o=: Use Angle .Apiaand Applicablecoverage ObtainedCdeRqimnt:,*Fg!,.

Code Requirement *,,.... ,:" *'

• Component Usd a oFig. Impracticably of Compliance Exam Category B-J Item No. B9.11 Inservice examination limited by configuration, Elbow To Pipe 31"-RCS-1401-8 1994 Fig. IWB-2500-8 30 examination is limited from Elbow due to taper and 64% From Elbow Side Pipe side due to weld crown.

88% From Pipe Side Exam Category C-A Inservice examination limited by configuration, Item No. Cl .20 examination is limited from the Head and Shell side Head To Shell 4-RHE-Al 1996 Fig. IWC-2500-1 79%eadromidedue 32 ex to to s integral support imtedrom theend weldedSellsd attachment, 79% From Head Side attachments and nozzle reinforcement plate.

52% From Shell Side Exam Category C-A Inservice examination limited by configuration, Item No. C1.10 examination is limited from the Shell and Flange side Shell To Flange 4-RHE-A2 1996 Fig. IWC-2500-1 33 due to support integral attachment, welded 57% From Shell Side attachments and nozzle reinforcement plate.

0% From Flange Side Exam Category C-A Item No. C2.21 Inservice examination limited by configuration, Nozzle To Shell 4-RHE-Al 1 1996 Fig. IWC-2500-4(a) 34 examination is limited from Nozzle side due to taper 99% From Nozzle Side and Shell side due to weld crown.

41% From Shell Side II Exam Category C-F-1 Inservice examination limited by configuration, Item No. C5.21 examination performed with Appendix VIII Flange To Elbow -3"-

10- 2002 Fig. IWC-2500-7(a) 35 demonstrated procedure, examination is complete F(3-80) 0% From Flange Side from Elbow side and limited from Flange side due to 100% From Elbow Side taper.

Examined 2002 Exam Category C-F-i Inservice examination limited by configuration, 8"-Sl-403-17Item No. C5.1 1 8"-SI-2403-17 To V2. C5.11 examination performed with Appendix VIII Pipe To Valve (8"-120) 2002 Fig. IWC-2500-7(a) 36 demonstrated procedure, examination complete from 100% From Pipe Side Pipe side and limited from Valve side due to taper.

0% From Valve Side

L-2006-181 Attachment 4 Page 12 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REOUEST NUMBER 15A (Revised) Rev 1 Table 1

"ýASME Code ComponentID Angle Applicable Code Requir'ement

• Component Componenten Used.

Usd . and coverage Obtained ..

adcvraeOtie .:.

Fig.  :", ..

Impracticably of Compliance, .* ..

Exam Category C-F-1 Inservice examination limited by configuration, Item No. C5.11 examination performed with Appendix VIII Pipe To Valve 8"-S24042 1999 Fig. IWC-2500-7(a) 37 demonstrated procedure, examination is complete (8"-120) 100% From Pipe Side from Pipe side and limited from Valve side due to 45% From Valve Side taper.

Exam Category C-F-1 Inservice examination limited by configuration, 8"-SI-2407 8 Item No. C5.11 examination performed with Appendix VIII Tee To Pipe (8"-120) 1999 Fig. IWC-2500-7(a) 38 demonstrated procedure, examination is complete 75% From Tee Side from Pipe side and limited from Tee side due to 100% From Pipe Side radius.

Exam Category C-F-1 10"-SI-2407-4 Item No. C5.11 Inservice examination limited by configuration, Pipe To Valve (1 "-1 40) 1999 Fig. IWC-2500-7(a) 39 examination is complete from Pipe side and limited 100% From Pipe Side from Valve side due to taper.

15% From Valve Side Exam Category C-F-1 10"-Sl-2407-5 Item No. C5.11 Inservice examination limited by configuration, Valve To Elbow 010"-140) 1999 Fig. IWC-2500-7(a) 40 examination is complete from Elbow side and limited 35% From Valve Side from Valve side due to taper.

100% From Elbow Side Exam Category C-F-1 12"-RHR-2402-15 Item No. C5.11 Inservice examination limited by configuration, Pipe To Flange (12"-40) 1996 Fig. IWC-2500-7(a) 41 examination is limited from Pipe side due to weld 27% From Pipe Side crown and Flange side due to taper.

70% From Flange Side Exam Category C-F-1 Item No. C5.1 1 Inservice examination limited by configuration, Tee To Tee 14"-RHR-2403-1 1996 Fig. IWC-2500-7(a) 42 examination is limited from the both sides of the Tee (14"-40) 78% From Upstream Tee Side 56% From Downstream Tee due to the radius.

Side

L-2006-181 Attachment 4 Page 13 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev I Table 1.

ASME.Code- ComponentID 'Angle' Applicable Code Requirement Fig. -,'- ,

Component Used and coverage Obtained Fig. Impracticably of Compliance Exam Category C-F-1 14"-RHR-2403-2 Item No. C5.11 Inservice examination limited by configuration, Tee To Pipe (14"-40) 1996 Fig. IWC-2500-7(a) 43 examination is complete from Pipe side and limited 78% From Tee Side from Tee side due to the radius.

100% From Pipe Side Exam Category C-F-1 14"-RHR-2403-4 Item No. C5.11 Inservice examination limited by configuration, Elbow To Valve (14"-40) 1996 Fig. From IWC-2500-7(a) 44 examination is limited from Elbow side due to weld 36% Elbow Side crown and Valve side due to taper.

73% From Valve Side I I

L-2006-181 Attachment 4 Page 14 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 STEAM GENERATOR TO NOZZLE TRANSITION AREA .(2- X 2-) INSULATION BRACKETS LOCATED AT 80, 135, 225. 270 AND 315 DEGREES 4-SGA-1-IRS (TYPICAL) 4-SGB-I-IRS 4-SGC-I-IRS Figure 1 (2 X 2-) INSULATION BRACKETS LOCATED AT 45, 90,112. 150 AND 202

,DEGREES 18 OF SCAN AREA IS LIMITED DUE TO CLOSE PROXIMITY OF STEAM GENERATOR SUPPORT LOCATED AT 180 DEGREES DŽ) 4-SGA-O-IRS (TYPICAL) 4-SGB-O-IRS z4-SGC-O-IRS NOZZLE TO STEAM GENERATOR TRANSITION AREA Figure 2

L-2006-181 Attachment 4 Page 15 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1

,UNIT 4 SPRAY NOZZLE SP-04-1-IR

'.MANWAY SP-04-1-IR Summary # 055400 Spray NozzlcicR Section Scan Limitation due to raised letters.

Inner diameter "3.5" Outer Diameter = 15" + 1/2" 15" 47.1" not scanned two directions total outside circumstance 31.8% area not scanned two directions Figure 3 70%CRV achieved 15%CRV achieved one direction 15%CRV not achieved at all

L-2006-181 Attachment 4 Page 16 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev I Figure 4 PRESSURIZER SURGE NOZZLE 4-SRGN-01-IR 12".RCS-1401-9 (TYPICAL)

Figure 5

L-2006-181 Attachment 4 Page 17 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev 1 29"-RCS-1404-4 (TYPICAL)

Figure 6 29"-RCS-1405-4 (TYPICAL)

NOZZLE ELBOW Figure 7

L-2006-181 Attachment 4 Page 18 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev I 31"-RCS-1401-5 (TYPICAL)

NOZZLE ELBOW Figure 8 31"-RCS-1402-5 (TYPICAL)

NOZZLE Figure 9

L-2006-181 Attachment 4 Page 19 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER ISA (Revised) Rev 1 8"-RHR-1401-6 (TYPICAL)

VALVE ELBOW Figure 10 8-RHR-1402-4 (TYPICAL)

Figure 11

L-2006-181 Attachment 4 Page 20 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 8"-RHR-1402-7 (TYPICAL)

AREA 2 TEE AREA I TEE AREA 3 AREA 4 0"

28.5" 19" 9.6" I

2 41 3 J4 j 1 15

.25.5" 17.25" 11.25" 3" Figure 12

L-2006-1 81 Attachment 4 Page 21 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 10"-SI-1401-14 (TYPICAL)

VALVE PIPE Figure 13 rxX/0 10'-SI-1401-18 (TYPICAL)

Figure 14 10"-SI-1402-1 (TYPICAL)

VALVE ELBOW Figure 15

L-2006-181 Aftachment 4 Page 22 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSER VICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER I1SA (Revised) Rev 1 10"-S1-1402-4 (TYPICAL)

Figure 16 10"-SI-1402-13 (TYPICAL)

Figure 17 10"-SI-1402-17 (TYPICAL)

Figure 18 ELBOW

L-2006-181 Attachment 4 Page 23 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev 1 12"-RC-1401-1 (TYPICAL)

Figure 19 14"-RHR-1401-1 (TYPICAL)

Figure 20 14"-RHR-1401-5 (TYPICAL)

PIPE VALVE Figure 21

L-2006-181 Attachment 4 Page 24 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev 1 14"-RHR-1401-6 (TYPICAL)

PIPE Figure 22 14"-RHR-1401-9 (TYPICAL)

Figure 23

\~ -

27.5"-RCS-1406-18 (TYPICAL) 27.5"-RCS-1407-20

27. 5"-RC S-I1409-17 MAIN LOOP PIPING BRANCH Figure 24 CONNECTION 27.5"-RCS-1406-11 (TYPICAL)

L-2006-181 Attachment 4 Page 25 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 Figure 25 27.5"-RCS-1407-11 (TYPICAL)

Figure 26 PUMP PIPE 27.5"-RCS-1409-16 (TYPICAL)

Figure 27 MAIN LOOP

L-2006-181 Attachment 4 Page 26 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev 1 29"-RCS-1404-18 (TYPICAL)

MAIN LOOP BRANCH PIPING CONNECTION Figure 28 29"-RCS-1405-21 (TYPICAL)

Figure 29 31"-RCS-1401-8 (TYPICAL)

Figure 30

L-2006-181 Attachment 4 Page 27 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 31"-RCS-1401-10 PUMP ELBOW Figure 31 4-RHE-A1 Reinforcement I I Plate and Inlet &

I Outlet nozzle I

Figure 32 Coverage without limitations Coverage with limitations 4-RHE-A2 Reinforcement Plate and Inlet tI &Outlet Figure 33 Nozzle I

L-2006-181 Attachment 4 Page 28 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev I 4-RHE-A1 I Figure 34 3"-SI-2401-1 (TYPICAL)

FLANGE Figure 35 8"-SI-2403-17 (TYPICAL)

VALVE Figure 36 PIPE

L-2006-181 Attachment 4 Page 29 of 32 TURKEYPOINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev I 8"-SI-2404-2 (TYPICAL)

Figure 37 VALVE

-,8"-SI-2407-8 (TYPICAL)

TEE TEE Figure 38 3"1 &I]

L-2006-181 Attachment 4 Page 30 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL I RELIEF REQUEST NUMBER 15A (Revised) Rev I 10"-SI-2407-4 (TYPICAL)

VALVE Figure 39 10"-SI-2407-5 (TYPICAL)

Figure 40 12"-RHR-2402-15 (TYPICAL)

FLANGE Figure 41 14"-RHR-2403-1 (TYPICAL)

/ 1

L-2006-181 Attachment 4 Page 31 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 Figure 42 14"-RHR-2403-2 (TYPICAL)

PIPE Figure 43

L-2006-181 Attachment 4 Page 32 of 32 TURKEY POINT UNIT 4 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER 15A (Revised) Rev 1 14"-RHR-2403-4 (TYPICAL)

Figure 44 VALVE ELBOW