L-2013-113, Inservice Inspection Plan Submittal of Relief Request No. 12

Inservice Inspection Plan Submittal of Relief Request No. 12

ML13164A186
Person / Time
Site:	Turkey Point
Issue date:	05/24/2013
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2013-113
Download: ML13164A186 (30)

Text

KAY 2 ., 2013 L-2013-113 FPL. 10 CFR 50.55a U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 RE: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inservice Inspection Plan Submittal of Relief Request No. 12 Pursuant to 10 CFR 50.55a(a)(3)(ii), Florida Power and Light (FPL) requests relief from ASME Section Xl, section IWB-5200, subsection IWB-5222, paragraph (b), for the Class 1 pressure test boundaries subject to system pressurization identified in Table 1 and plant drawings of the attached Relief Request No 12. The relief is requested on the basis that hardship and unusual difficulty exists without compensating increase in the level of quality and safety. As discussed in the attached Relief Request, the use of the proposed alternative provides reasonable assurance of structural integrity or leak tightness of the subject components.

Due to the extended refueling outages for the extended power uprate (EPU) Turkey Point plant modifications, FPL is invoking the provision of ASME Code Section Xl, IWA-2430(d)1 to extend the Fourth 10-Year ISI interval by 1-year for both Turkey Point Units 3 and 4 to complete the required inservice inspections during the refueling outages for Cycle 27 and Cycle 28 for Units 3 and Units 4 respectively, and to credit those inspections/examinations to the Fourth 10-Year ISI Interval.

Accordingly, FPL requests the approval of the attached Relief Request No. 12 by February 1, 2014 to support the Unit 3 refueling outage for Cycle 27 currently scheduled in the Spring of 2014, and the Turkey Point Unit 4 refueling outage activities currently scheduled for Cycle 28 in the Fall of 2014.

If you have any questions or require additional information, please contact Robert Tomonto, Licensing Manager, at (305) 246-7327.

Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Power , Light Company 9760 S.W. 344 Street Homestead, FL 33035

L- 2013-113, Attachment Page 1 of 14 10 CFR 50.55a Relief Request Number 12 Proposed Alternative in Accordance with 10 CFR 50.55a (a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety

1. ASME Code Component(s) Affected:

The affected components associated with this relief request are the Turkey Point Units 3 and 4 Class 1 pressure retaining components within the identified system boundary listed in Table 1 and the attached plant drawings.

2. Applicable Code Edition and Addenda

The code of record for the Turkey Point Units 3 and Unit 4 for the Fourth 10-year Inservice Inspection (ISI) interval is the 1998 Edition with Addenda through 2000 of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV),Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components."

3. Applicable Code Requirement

The ASME B&PV Section XI 1998 Edition with Addenda through 2000, Table IWB-2500-1, Section IWB-5200 "System Test Requirements", subsection IWB-5222 "Boundaries",

paragraph (b), requires that "The pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the system boundary."

4. Basis for Hardship or Unusual Difficulty without Compensating Increase In level of Quality or Safety Turkey Point Units 3 and 4 request relief from IWB-5222(b) in accordance with 10 CFR 50.55a(a)(3)(ii) on the basis that hardship or unusual difficulty exists, without a compensating increase in the level of quality and safety. The attached Table 1 and plant drawings identify the Class 1 pressure retaining components that are associated with the requested relief.

The reason for the relief is discussed below.

Turkey Point Units 3 and 4 design of Class 1 vents and drains typically consist of a single isolation valve with a capped/blind flanged end that constitutes the Class I system boundary.

Many of these valves are not readily accessible due to their physical locations and radiation/contamination levels in the area. Pressurization of these locations for testing would be performed in Mode 3 and would involve opening these single isolation valves to pressurize to the extended Class 1 pressure retaining components within the system

L- 2013-113, Attachment Page 2 of 14 boundary. After performance of the required VT-2 visual examination, these single isolation valves would be closed, isolating a high temperature, pressurized volume of water between the isolation valve and the capped/blind flanged end. This results in an undesirable plant configuration that would be conducive to pressure lock or the initiation of system leakage from valve packing or capped/blind flanged ends.

In addition, the piping associated with the vents and drains will contain pressurized reactor coolant fluid between the valve and cap/blind flange. During the subsequent refueling outage, after depressurization of the reactor coolant system, the valve would need to be opened prior to cap/blind flange removal in order to release the pressurized slug of reactor coolant system fluid contained between the valve and cap/blind flange. This will need to be performed in order to eliminate a safety hazard.

Turkey Point Units No. 3 and 4 design also requires substantial effort to extend the Class 1 system boundary where check valves or non-redundant components serve as the first system isolation from the reactor coolant system. Such configurations may require check valve disassembly or other temporary configurations to achieve test pressures at upstream piping and valves. Since the Class 1 system pressure testing is performed in Mode 3, these temporary configurations could conflict with Technical Specification requirements and valve alignments. Establishing and restoring such temporary configurations could also result in an unwarranted increase in worker radiation exposures.

Relief is requested from fully pressurizing piping between the first and second isolation device on small bore size vent, drain, test, and fill lines in the Reactor Coolant System (RCS), which range in size from 0.5 inch to 2 inches. The configurations are either two small isolation valves in series, a valve and blind flange, or a valve and cap. In certain configurations, the piping between the two isolation boundaries will tee to a third valve that is also the second isolation boundary. The piping segments provide the design required double isolation barrier for the reactor coolant pressure boundary. The code required leakage test would be performed in Mode 3 at the normal operating temperature and pressure.

Leakage testing of these piping segments at nominal operating pressure in Mode 3 would require the opening of the inboard isolation valve at the normal operating RCS temperature and pressure conditions. In doing so, the design requirement for two primary coolant pressure boundary isolation devices would be violated. Additionally, opening of these valves introduces the potential risk for spills and personnel contamination. For configuration where blind flanges or caps are installed as the isolation device, opening of the inboard valve introduces the possibility of a personnel safety hazard if a flange or cap fails in the presence of inspection personnel.

A VT-2 visual examination is performed on these piping segments through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. This leakage test does not specifically pressurize past the first isolation valve. Also, this leakage test is considered successful when no external or visible leakage is identified. Since this type of test assures that the combined first and second isolation devices are effective in

L- 2013-113, Attachment Page 3 of 14 maintaining the reactor coolant pressure boundary at normal operating temperature and pressure, the increase in safety achieved from the code required leakage test (IWB-5222(b))

is not commensurate with the hardship of performing such code required leakage testing.

14-inch Residual Heat Removal (RHR) Motor Operated Valves (MOV)

Turkey Point Unit 3: This piping segment consists of approximately 26 feet of 14-inch piping between RHR inlet valves MOV-3-750 and MOV-3-751. Within this piping segment there is a 3/4 inch pipe branch with a 3/4 inch valve that branches off into a two 1/2 inch valves.

Turkey Point Unit 4: This piping segment consists of approximately 44 feet of 14 inch piping between RHR inlet valves MOV-4-750 and MOV-4-751. Within this piping segment there is a 1 inch pipe branch with a 1 inch valve that branches off into a 1 inch valve and a 1/2 inch valve. Also, within this 14-inch piping segment, there is a 3/4 inch vent valve.

MOV-3/4-750 and MOV-3/4-751 are interlocked to avoid over-pressurization of the RHR system. The interlock prevents manual opening of the valves with RCS pressure above the required pressure interlock setpoint.

A VT-2 visual examination is performed on these piping segments through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. This proposed system pressure test does not specifically pressurize past the first isolation valve.

It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. The leakage test is considered successful when no external or visible leakage is identified. This test will provide assurance that the combined first and second isolation devices are effective in maintaining the reactor coolant pressure boundary at normal operating temperature and pressure.

Based on the above, extension of the pressure retaining boundary during system leakage tests to Class 1 pressure retaining components within the system boundary represents a hardship and unusual difficulty that does not provide a compensating increase in the level of quality and safety.

Safety Injection Loops Low Head Check Valves 3-875A/B/C, 4-875A/BIC, and Upstream Piping These six piping segments consist of 10-in. piping spans connected to an 8-in. and 2-in.

piping span along with 3/4 inch and 1 inch connections with valves. Pressure testing in Mode 3 would require a pressure source be connected at each segment location. In so doing, the design requirement for two primary coolant pressure boundary isolation devices would be violated. For test locations located overhead and away from normal personnel access areas, ladders or scaffolding would have to be installed to provide access to the piping segment and to open the valve.

The piping segments are inspected using VT-2 visual examination as part of the Class 1 system inspection at the conclusion of each refueling outage. The proposed system

L- 2013-113, Attachment Page 4 of 14 pressure test will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. However, the pressure in the segment will be at least at the operating pressure of the emergency core cooling system accumulators, which are pressurized to between 600 psig and 660 psig.

The acceptance criteria will be that no external or visible leakage will be allowed for the test to be successful. Therefore, based on the above, the imposition of the ASME Code requirements on the plant would cause a significant burden that would not be compensated by an increase in the level of quality and safety. The proposed alternative provides reasonable assurance that the subject line segments' leakage integrity will be maintained.

Safety Injection Loops High Head Check Valves 3-874A/B, 4-874A/B, and Upstream Piping These two piping segments consist of a 2-in. piping span between two check valves oriented toward the RCS. Pressure testing of these piping segments at nominal operating pressure in MODE 3 would require a modification to allow pressurizing to the normal operating RCS temperature and pressure conditions.

A VT-2 visual examination is performed on these piping segments through the entire length as part of the Class 1 system inspection at the conclusion of each refueling outage. The proposed system pressure test will not specifically pressurize past the first isolation valve for this inspection. It is possible that the piping becomes pressurized due to minor leakage past the first isolation valve. The acceptance criteria will be that no external or visible leakage will be allowed for the test to be successful.

Based on the above, it has been determined that compliance with the ASME Code requirement to perform the system pressure test on the subject line segments would result in a hardship that would not be compensated by an increase in quality and safety. The proposed alternative provides reasonable assurance that the subject line segments' leakage integrity will be maintained.

5. Proposed Alternative and Basis for Use:

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(4), specifies that ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except for the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI to the extent practical within the limitations of design geometry and materials of construction of the components.

Paragraph 50.55a(a)(3) of 10 CFR Part 50 states, in part, that alternatives to the requirements of 10 CFR 50.55a(g) may be used when authorized by the NRC if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of quality and safety, or if (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

L- 2013-113, Attachment Page 5 of 14 FPL is requesting authorization of an alternative to the requirements of the ASME Code Section XI, IWB-5222(b) pursuant to 10 CFR 50.55a(a)(3)(ii).

The proposed alternative for this request relief uses leakage testing. The Class 1 system boundary will be maintained in a normal, operational alignment during leakage tests for the items identified within Table 1 constituting exceptions to the Code-required boundary of IWB-5222(b). The VT-2 visual examination will extend to the Class 1 pressure retaining components within the system boundary during the performance of each system leakage test required by Table IWB-2500-1 examination category B-P. Items within Table 1 will be visually examined for evidence of leakage during system leakage testing without being pressurized.

Based on the discussion provided in Section 4, it is concluded that compliance with the specified requirements would result in hardship or unusual difficulty without compensating increase in the level of quality and safety, while the proposed alternative provides reasonable assurance of structural integrity or leak tightness of the subject components.

6. Duration of Proposed Alternative:

Relief Request No. 12 is requested for Turkey Point Units 3 and 4 for the Fourth 10-Year ISI Interval. The Unit 3 Fourth 10-Year ISI Interval began February 22, 2004 to February 21, 2014 and the Unit 4 Fourth 10-Year Interval began April 15, 2004 to April 14, 2014.

Due to the extended refueling outages for the extended power uprate (EPU) Turkey Point plant modifications, FPL is invoking the provision of ASME Code Section XI, IWA-2430(d)1 to extend the Fourth 10-Year ISI interval by 1-year for both Turkey Point Units 3 and 4 to complete the required inservice inspections during the refueling outages for Cycle 27 and Cycle 28 for Units 3 and Units 4 respectively, and to credit those inspections/examinations to the Fourth 10-Year ISI Interval.

7. Precedent Similar relief has been granted for H.B Robinson Steam Electric Plant Unit No.2, Docket No.

50-261, TAC No. ME 8255, ML12181A26.

8. Attachments Plant Drawings referenced in Table 1

L-2013-113, Attachment Page 6 of 13 Table I Relief Request No. 12 Turkey Point Unit 3 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Class Diameter Schedule Length Category Drawing No. Boundary Exception(s)

Drain line below PZR safety A376 TP316 5613-M-3041 Valve 3-545 remains closed to avoid valve RV-3-551A (pipe piece 1 3/4 in. SMLS Sch. 160  ! 1 ft. B-P Sh. 2 pressurizing downstream Class 1 pipe between 3-545 and 3-545A) piece and valve 3-545A Drain line below PZR safety Valve 3-546 remains closed to avoid valve RV-3-51 (pipe piece 1 3/4 in. A3L6 TBSP316 2 ft. B-P 5613-M-3041 pressurizing downstream Class 1 pipe between 3-546 and 3-546A Sh. 2 piece and valves 3-546A and 3-585 and 3-585) _ _ _ _ ______ _ _ _ _ _ _ _ _ _ _ _ ____ ______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Drain line below PRZ safety A376 TP316 5613-M-3041 Valve 3-547 remains closed to avoid valve RV-3-551C (pipe piece 1 3/4 in. SMLS Sch. 160 _ 1 ft. B-P Sh. 2 pressurizing downstream Class 1 pipe between 3-547and 3-547A) piece and valve 3-547A RCS loop intermediate loop 2 in. A376TP316 <1ft.

"A" drain valve, liquid waste SMLS Sch. 160 5613-M-3041 Valve 3-508A remains closed to avoid pressurizing downstream Class 1 disposal valve. piping, and leak-off 3/4 in. A376 A36T16TP316 2ft Sh 1 piping and valves 3-508B and 3-542 SMLS Sch. 160 RCS loop intermediate loop A376 TP316 5613-M-3041 Valve 3-515A remains closed to avoid "B" drain valve and liquid 1 2 in. SMLS Sch. 160 *1 ft. B-P Sh. 1 pressurizing downstream Class 1 waste disposal piping piping and valve 3-515B.

RCS loop intermediate loop A376 TP316 5613-M-3041 Valve 3-505A remains closed to avoid "C" drain valve and liquid 1 2 in. SMLS Sch. 160 *1 ft. B-P Sh. 1 pressurizing downstream Class 1 waste disposal piping piping and valve 3-505B.

5613M3047Valve 3-300A remains closed to avoid inje3/4 drain RCP "A" seal injection in. A36 TP316 A376 1 ft. B-P 5613-M-3047 Vle330 pressurizing ean downstream lsdt vi pipe piece RCva"lseanbln draia3ngin SMLS Sch. 160 1f. BP Sh. 3 n fag and flange Valve 3-300C remains closed to avoid RCPt "Avale watebypndflass 1 3/4 in. A6 TP316 1 ft. B-P 5613-M-3047 pressurizing downstream pipe piece vent valve and blind flange SMLS Sch. 160 - Sh. 3 and flange

L-2013-113, Attachment Page 7 of 13 Table I Relief Request No. 12 Turkey Point Unit 3 Affected Class I Pressure Retaining Components Affected Line or Component Code Class Pipe Diameter Pipe Schedule Approx Length Exam Category Drawing No. Boundary Exception(s)

A376 TP316 5613-M-3047 Valve Vle330 3-300D remains ean closed lsdt to avoid vi drain RCP "B" alseal cinjection RCP t d 1 3/4 in. A7 6 ft. B-P pressurizing downstream pipe piece valve and cap SMLS Sch. 160 -P 563-M3 Sh.f.

and cap Valve 3-300F remains closed to avoid RCPt vBsale watebypndlas 1 3/4 in. A376 TP316 5613-M-3047 pressurizing downstream pipe piece Vent valve and blind flange. SMLS Sch. 160 -P Sh. 3 and flange A376P316Valve 3-300G remains closed to avoid drain A376 TP316 5613-M-3047 Vle33O ean lsdt vi RCP "C"alseal cinjection RCP t d 1 3/4 in. SMLS Sch_ 160 1 ft. B-P 563 3 pressurizing downstream pipe piece valve and cap SMhS Sh.and cap and cap Valve 3-300J remains closed to avoid RCPt C"ale watebypfas 1 3/4 in. A376 TP316 5613-M-3047 pressurizing downstream pipe piece Vent valve and blind flange. SMLS Sch. 160 -P Sh. 3 and flange 2 in. A376 TP316 139 ft. Valve CV-3-31 1 remains closed to Auxiliary spray line vent valve 1SMLS Sch. 160 5613-M-3047 avoid pressurizing downstream piping and upstream piping Sh. 2 up to check valve 3-313 and vent pipe 3/4 in A376 TP316 < 1 ft. and vent valve 3-120J 3/4in SMLS Sch. 160 -

3/4 in. A376 TP316 3 ft. Check valve 3-875A to remain closed 1 in SMLS Sch. 160 to avoid disassembly or other temporary configurations required to 2 in. A376 TP316 100 ft. achieve test pressures at upstream SMLS Sch. 160 piping and valves: 3-868A, 3-873D, 3-Safety injection loop cold leg 5613-M-3064 873A, 3-876A, 3-875D, 3-940A, 3-injection check valve 3-875A 1 8 in. A376 TP316 3 ft. B-P 884B, and 3-941J SMLS Sch. 120 Sh. 1 and upstream piping 10 in. A376 TP316 35 ft.

SMLS Sch. 140

L-2013-113, Attachment Paae 8 of 13 Table I Relief Request No. 12 Turkey Point Unit 3 Affected Class I Pressure Retaining Components Code Pipe Pipe Approx Exam Affected Line or Component Class Diameter Schedule Length Category Drawing No. Boundary Exception(s) 3/4 in. A376 TP316 1 in. SMLS Sch. 160 Check valve 3-875B to remain closed A376 TP316 to avoid disassembly or other Safety injection loop cold leg 2 in. SMLS Sch. 160 70 ft. temporary configurations required to valve 3-875B injectioncheck 15613-M-3064 achieve test pressures at upstream injection pipig3-875B 1 B-P Sh. 1 piping and valves 3-868B, 3-873E, 3-8nin.remp.A376TP316 10 ft. 873B 3-875E, 3-940B, 3-884D, 3-SMLS Sch. 120 941K, 3-941R, 3-941V, 3-876B and 3-876D A376 TP316 SMLS Sch. 140 3/4 in. A376 TP316 1 in. SMLS Sch. 160 Check valve 3-875C to remain closed 2 in. SMLSTP316 A376 Sch. 160 to avoid disassembly or other Safety injection loop cold leg A376 TP316 5613-M-3064 temporary configurations required to injection check valve 3-875C 1 8 in. 18 ft. B-P Sh. 1 achieve test pressures at upstream and upstream piping SMLS Sch. 120 piping and valves 3-868C, 3-873F, 3-873C, 3-940C, 3-884F, 3-875F, 3-876E, 3-942A, and 3-876C.

l~in.

10 in. A376 TP316 A36T36 41 ft.

SMLS Sch. 140 14 in. A376 TP316 26 ft. Valve MOV-3-750 to remain closed to Residual heat removal motor- SMLS Sch. 140 5613-M-3050 avoid pressuring downstream piping operated valve MOV-3-750 B-P Sh. 1 and valves, MOV-3-751, 3-750B, 3-and common suction piping 3/4 in. 1/2 in. A376 TP316 3 ft. 750C and 3-750D.

SMLS Sch. 160 Valve CV-3-310B to remain closed to A376 TP316 5613-M-3047 avessurizing dowream piping B13 of CV Downstream3 piping in. SL c.10 45 ft. B-P S.2avoid pressurizing downstream piping 310B SMLS Sch. 160 P Sh. 2 up to check valve 3-312B

L-2013-113, Attachment Page 9 of 13 I m I Table I Relief Request No. 12 Turkey Point Unit 3 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Drawing No. Boundary Exception(s)

Class Diameter Schedule Length Category A376 TP316 Check valves 3-874A and 3-874B to 2 in. SMLS Sch. 160 222 ft. remain closed to avoid disassembly or Safety Injection check valves 5613-M-3062 other temporary configurations 3-874A, 3-874B and B-P Sh. 1 required to achieve test pressures at upstream piping A376 TP316 upstream piping and valves MOV 3/4 in. SMLS Sch. 160 __1ft. 866A and B, 3-941C and D, and 3-957 Valve 3-568 remains closed to 1 3/4 in. <1 ft. B-P avoid pressurizing downstream valve and cap Pressurizer Spray line drain ____________________ SMLS Sch. 160 A376 TP316 B-P

_______ Sh. 2

_________ pieceMnd04a pipe piece 5613-M-3041Vav3-6re and capinclsdt Valve 3-569 remains closed to Purier Sr line ay drai 1 3/4 in. A_76. B-P Sh. 2 avoid pressurizing downstream valve and cap ____________________

SMLS Sch. 160 *t-M2

______ _______ _________ pipe piece and cap Regenerative Heat Exchanger 1/4 in. A376 TP316563M04 Valve 3-201A remains closed to outlet drain line and cap SMLS Sch. 160 < 1 ft. B-P 56.13--07 avoid pressurizing downstream

L-2013-113, Attachment Page 10 of 13 Table I Relief Request No.12 Turkey Point Unit 4 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Categor Drawing No. Boundary Exception(s)

Class Diameter Schedule Length Valve 4-545 remains closed to Drain line below PZR safety . A376 TP316 ft. B-P 5614-M-3041 avoid pressurizing downstream valve RV-4-551A (pipe piece 3/4 in. SMLS Sch. 160 Sh. 2 Class 1 pipe piece and valve 4-between 4-545 and 4-545A) 545A Drain line below PZR safety Valve 4-546 remains closed to valve RV-4-551B (pipe piece 1 3/4 in. A376 TP316 2 ft. B-P 5614-M-3041 avoid pressurizing downstream between 4-546, 4-546A, and SMLS Sch. 160 Sh. 2 Class 1 pipe piece and valves 4-4-585) 546A and 4-585 Valve 4-547 remains closed to Drain line below PRZ safety A376 TP316 1 ft. B-P 5614-M-3041 avoid pressurizing downstream valve RV-4-551C (pipe piece 3/4 in. SMLS Sch. 160 Sh. 2 Class 1 pipe piece and valve 4-between 4-547and 4-547A) 547A RCS loop intermediate loop 2 in. A376 TP316 _ 1 ft. Valve 4-508A remains closed to "A" drain valve, liquid waste 1SMLS Sch. 160 5614-M-3041 avoid pressurizing downstream disposal piping, and leak-off A376 TP316 Sh. 1 Class 1 piping and valves 4-508B valve 3/4 in. A376 SMLSTP316 Sch. 160 28 28tft. and 4-542 RCS loop intermediate loop A376 TP316 5614-M-3041 Valve 4-515A remains closed to "B" drain valve and liquid 1 2 in. SMLS Sch. 160 < 1 ft. B-P Sh. 1 avoid pressurizing downstream waste disposal piping Class 1 piping and valve 4-515B.

RCS loop intermediate loop A376 TP316 5614-M-3041 Valve 4-505A remains closed to "C" drain valve and liquid 1 2 in. SMLS Sch. 160 < 1 ft. B-P Sh. 1 avoid pressurizing downstream waste disposal piping Class 1 piping and valve 4-505B.

A376P316Valve 4-300A remains closed to injection drain A376 TP316 5614-M-3047 Vle430 ean lsdt RCP "A" RCP "a" seal sl injle d 3/4 in. SMLS Sch. 160 1 ft. B-P 564M3 avoid pressurizing downstream pipe piece and flange

L-2013-113, Attachment Page 11 of 13 Table I Relief Request No.12 Turkey Point Unit 4 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Categor Drawing No. Boundary Exception(s)

Class Diameter Schedule Length Valve 4-300C remains closed to A376 TP316 5614-M-3047 RCP valve vent blind bypass andwater "A"seal flange 1 3/4 in. SMLS Sch. 160 <1 ft. B-P Sh. 3 avoid pressurizing downstream pipe piece and flange A376P316Valve 4-300D remains closed to A376 TP316 5614-M-3047 Vle430 ean lsdt RCP "B" al RCP td drain seal cinjection 1 3/4 in. SMLS Sch 160 1 ft. B-P 561 3 avoid pressurizing downstream pipe piece and cap A376 P316Valve 4-300F remains closed to RCP "B" seal water bypass A376 TP316 5614-M-3047 avo p resr dostream ing Vent valve and blind flange. 3/4 in. SMLS Sch. 160 1 ft. B-P Sh. 3 avoid pressurizing downstream pipe piece and flange A376 P316Valve 4-300G remains closed to RCP "C" seal injection jc n3/4 drain in. A376 TP316 1 ft. B-P 5614-M-3047 Vle43O avoid pressurizing lsdt ean downstream RCPaC"veald dria1 34pn SMLS Sch. 160 - 514M30 Sh.f.

pipe piece and cap A376 P316Valve 4-300J remains closed to A376 5614-M-3047 RCP "C" seal Vent valve andwater blindbypass flange. 1 3/4 in. SMLS TP316 Sch. 160 _ 1 ft. B-P Sh. 3 avoid pressurizing downstream pipe piece and flange Piping downstream of CV A376 TP316 5614-M-3047 Valve CV-4-311 remains closed to 311 1 2 in. SMLS Sch. 160 142 ft. B-P Sh 2 avoid pressurizing downstream piping up to check valve 4-313.

Safety injection loop cold leg 3/4 in. A376 TP316 5614-M-3064 Check valve 4-875A to remain injection check valve 4-875A 1 in SMLS Sch. 160 <3 B-P Sh. 1 closed to avoid disassembly or and upstream piping other temporary configurations 2 in. A376 TP316 89 ft. required to achieve test pressures SMLS Sch. 160 at upstream piping and valves 4-868A, 4-868D, 4-873D, 4-873A, 8 in. A376 TP316 15 ft. 4-876A, 4-875D, 4-876E 4-940A, SMLS Sch. 120 4-884B, and 4-941J

L-2013-113, Attachment Page 12 of 13 Table 1 Relief Request No.12 Turkey Point Unit 4 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Categor Drawing No. Boundary Exception(s)

Class Diameter Schedule Length 10 in. A376 TP316 46 ft.

SMLS Sch. 140 3/4 in. A376 TP316 1 in. SMLS Sch. 160 Check valve 4-875B to remain closed to avoid disassembly or Safety injection loop cold leg 2 in. A376 TP316 SLSc.10 110 ft. other temporary configurations injection chec va leSMLS Sch. 160 5614-M-3064 required to achieve test pressures injection check valve 4-875B B-P Sh. 1 at upstream piping and valves and upstream piping A376 8 in. SMLSTP316 Sch. 120 21 ft. 4-868B, 4-875E, 4-868E, 4-940B, 4-873E, 4-884D, 4-873B, 4-941 K, 4-941 R, 4-941V, 4-876B and 4-A376 TP316 876D SMLS Sch. 140 3/4 in. A376 TP316 1 in. SMLS Sch. 160 2in. A376 TP316 Check valve 4-875C to remain SMLS Sch. 160 closed to avoid disassembly or other temporary configurations Safety injection loop cold leg A376 TP31 5614-M-3064 required to achieve test pressures injection check valve 4-875C 8 in. SMLS Sch. 120 5 B-P Sh. 1 at upstream piping and valves and upstream piping 4-868F, 4-868C, 4-873F, 4-873C, 4-940C, 4-941L, 4-884F, 4-875F, 4-876C A376 TP316 SMLS Sch. 140 14 in. A376 TP316 44 ft. Valve MOV-4-750 to remain closed opRaesduvalvhea rmoval5 operateduvalvheatemova m-750Sh. 1otB-P 5614-M-3050 1 t vi andrsuigdwsra piping valves, MOV-4-751, 4-and common suction piping 3/4 in. A376 TP316 750A, 4-750B, 4-750C and 4-1/2 in. SMLS Sch. 160 10 ft. 750D.

1 in.

L-2013-113, Attachment Paae 13 of 13 Table I Relief Request No.12 Turkey Point Unit 4 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Categorý Drawing No. Boundary Exception(s)

Class Diameter Schedule Length Valve CV-4-310B to remain closed Piping downstream of CV A376 TP316 5614-M-3047 to avoid pressurizing downstream 31 OB SMLS Sch. 160 Sh. 2 piping up to check valve 4-312B 2in. A376 TP316 140 ft Check valves 4-874A and 4-874B SMLS Sch. 160 to remain closed to avoid Safety Injection check valves 5614-M-3062 disassembly or other temporary 4-874A, 4-874B and 1 B-P Sh. 1 configurations required to achieve upstream piping 3/4 in. A376 TP316 test pressures at upstream piping 1 in. SMLS Sch. 160 and valves MOV-4-866A and B, 4-941C and D, and 4-957 Valve 4-568 remains closed to dostream Spray line drain Pressurizervleadcp1 A376 TP316 6 5614-M-3041 avo presring 3/4 in. c. 1 ft.

_<S B-P S.2avoid pressurizing downstream valve and cap SMLS Sch. 160 Sh. 2 pip piece docap Pressurizer Spray line drain 1 / n A376 TP316 *ftBP pipe piece Valve 4-569and 5614-M-3041aviprsuzngdwtem cap closed to remains valve and cap SMLS Sch. 160 Sh. 2 pp ic n a Valve 4-201A remains closed Regenerative Heat Exchanger 1 3/4 in. A376 TP316 1 ft. B-P 5614-M-3047 to avoid pressurizing outlet drain line and flange SMLS Sch. 160 Sh. 1 downstream pipe piece and flange