Text

Submittal of Fifth 10 Year Interval Inservice Inspection (ISI) Program Plan
	ML15062A055
Person / Time
Site:	Turkey Point
Issue date:	03/11/2015
From:	Kiley M; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2015-040
	Download: ML15062A055 (147)
	v • d • e

0FPL. February 11, 2015 L-2015-040 10 CFR 50.55a(g)

U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-00001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Fifth 10 Year Interval Insetvice Inspection (ISI) Program Plan The Fifth 10-Year Inservice Inspection Interval for Turkey Point Unit 3 begins on February 22, 2014 and ends on February 21, 2024, and for Unit 4 begins on April 15, 2014 and ends on April 14, 2024.

Pursuant to 10 CFR 50.55a(g)(4)(ii) the ISI Program Plan for Turkey Point Units 3 and 4 is based on the requirements of Section XI of the ASME Boiler and Pressure Vessel Code, 2007 Edition with Addenda though 2008.

Florida Power & Light Company (FPL) is hereby submitting the Fifth 10 Year ISI Program Plan for Turkey Point Units 3 and 4. The program is provided in the Enclosure. The planned Relief Requests for the Fifth 10 Year ISI Interval will be submitted under different correspondence at a later date.

If you have any questions please contact Mitch Guth at (305) 246-6698.

Since rl4

ý Michael Kiley Vice President Turkey Point Nuclear Plant SM Enclosure cc: Regional Administrator, Region II, USNRC 1404-7 Senior Resident Inspector, USNRC, Turkey Point Plant K' Florida Power & Light Company 9760 S.W. 344m Street Homestead, FL 33035

Enclosure L-2015-040 Turkey Point Units 3 and 4 Fifth 10 Year Inservice Inspection Interval Program Plan Submittal

Florida Power and Light Company Nuclear Engineering Department Component, Support & Inspections Group Code & Inspections Section 700 Universe Blvd.

Juno Beach, Florida 33408 Fifth Inservice Inspection Interval Program Plan for Turkey Point Nuclear Power Plants Units 3 and 4 P.O. Box 4332 Florida City, Florida 33032 Commercial Service Dates:

Unit 3 - December 14, 1972 Unit 4 - September 7, 1973 USNRC Docket Numbers:

Unit 3 250 Unit 4 251 Document Number: 5th Interval-ISI-PTN-3/4-Program Plan Rev. 0 Prepared by: Dp-4-4 R, jo'ýý

\ V Reviewed by:

Reviewed by:

Mupasgr -Engineering Fleet Programs Approved by:

Manager - Engineering Fleet Programs

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Record of Revision Reason for Revision Fifth 10-Year Inspection Interval Program Plan as required by 10CFR50.55a(g)(4) 2 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 hIInterval-ISI-PTN-3/4-Program Plan January 21, 2015 List of Effective Pages Section Page/s Date Program Text 1-60 January 21, 2014 Appendix A A1-A2 January 21, 2014 Relief Request 1 44 pages Relief Request 2 1 page January 21, 2014 Relief Request 3 1 page Appendix B B1-B36 January 21, 2014 3 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Table of Contents Cover Page .......................................................................................................................................... 1 Record of Revision ............................................................................................................................... 2 List of Effective Pages ......................................................................................................................... 3 Table of Contents ................................................................................................................................. 4 List of Tables ........................................................................................................................................ 8 Abbreviations ....................................................................................................................................... 9 A bs tra ct .............................................................................................................................................. 13 1.0 Introduction ............................................................................................................................ 14 1.1 ISI Program Plan Development ............................................................................. 14 1.2 Other ISI Program s ............................................................................................... 14 1.2.1 Inspection Testing Program (IST) .......................................................... 14 1.2.2 Steam Generator (SG) Eddy Current Testing (ET) Program ................... 14 1.2.3 Snubber Program .................................................................................... 14 1.2.4 Pressure Test Program ............................................................................. 15 1.2.5 Repair and Replacement Program ........................................................... 15 1.2.6 Metal Containment Inservice Inspection Program (IWE) ......................... 15 1.2.7 Concrete Containment Inservice Inspection Program (IWL) ................... 15 1.3 Construction Perm it ............................................................................................... 15 1.4 Com m ercial Service Dates ................................................................................... 15 1.5 Background ................................................................................................................ 15 1.5.1 Preservice Inspection ............................................................................... 16 1.5.2 First Inservice Inspection Interval ............................................................. 16 1.5.3 Second Inservice Inspection Interval ...................................................... 16 1.5.4 Third Inservice Inspection Interval .......................................................... 16 1.5.5 Fourth Inservice Inspection Interval ........................................................ 16 1.5.6 Fifth Inservice Inspection Interval ............................................................ 17 1.6 Applicable Editions and Addenda to Section Xl ................................................... 17 1.6.1 10CFR50.55a Code of Federal Regulations Conditions ......................... 18 1.7 System Classification ............................................................................................. 20 1.7.1 System Classifications ............................................................................. 20 1.7.2 Optional Construction ............................................................................... 20 1.7.3 Containm ent Penetrations ...................................................................... 20 1.7.4 Class MC Com ponents .......................................................................... 20 1.7.5 Class CC Com ponents ............................................................................. 21 1.8 Inspection Program Plan ...................................................................................... 21 1.9 Regulatory Guides ................................................................................................. 21 1.10 ASM E Section XI Code Cases ............................................................................ 22 1.11 Branch Technical Position MEB 3-1 ..................................................................... 24 1.12 Plant Life Extension ............................................................................................... 24 1.12.1 Licensing Renewal Com m itment Docum ents .......................................... 24 1.13 Successive Exam inations ...................................................................................... 25 4 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.14 NDE Exam inations and Personnel Qualification/Certification ............................... 25 1.14.1 Alternative Examinations (IWA-4250(b)(2) and IWA-4521) ...................... 25 1.14.2 Certification and recertification (IWA-2314) ............................................... 25 1.14.3 Appendix VIII Requirements ...................................................................... 26 2.0 Risk Informed (RI) Requirements ...................................................................................... 26 3.0 Development of Class 1 Exam ination Plan ...................................................................... 27 3.1 Class 1 Code Exem ptions ................................................................................... 27 3.2 Com ponent Exam ination Basis ............................................................................. 28 3.2.1 Category B-A .......................................................................................... 28 3.2.2 Category B-B .......................................................................................... 29 3.2.3 Category B-D ........................................................................................... 30 3.2.4 Category B-F .......................................................................................... 31 3.2.5 Category B-G-1 ........................................................................................ 32 3.2.6 Category B-G-2 ......................................................................................... 33 3.2.7 Category B-J ............................................................................................. 34 3.2.8 Category B-K .......................................................................................... 35 3.2.9 Category B-L-2 ........................................................................................ 36 3.2.10 Category B-M-2 ........................................................................................ 36 3.2.11 Category B-N-1 ........................................................................................ 37 3.2.12 Category B-N-2 ........................................................................................ 37 3.2.13 Category B-N-3 ........................................................................................ 37 3.2.14 Category B-O ........................................................................................... 38 3.2.15 Category B-P .......................................................................................... 38 3.2.16 Category B-Q ........................................................................................... 38 4.0 Development of Class 2 Examaination Plan ................................................................... 38 4.1 Class 2 Code Exem ptions ................................................................................... 39 4.1.1 IW C-1221 ................................................................................................ 39 4.1.2 IWC-1222 ................................................................................................. 40 4.1.3 IWC-1223 ................................................................................................. 41 4.2 Com ponent Exam ination Basis ............................................................................. 41 4.2.1 Category C-A ........................................................................................... 42 4.2.2 Category C-B ........................................................................................... 42 4.2.3 Category C-C ........................................................................................... 43 4.2.4 Category C-D ........................................................................................... 44 4.2.5 Category C-F-1 ........................................................................................ 44 4.2.6 Category C-F-2 ........................................................................................ 45 4.2.7 Category C-F-3 ........................................................................................ 45 4.2.8 Category C-F-4 ........................................................................................ 45 4.2.9 Category C-H ........................................................................................... 46 5 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 5.0 Development of Class 3 Examination Plan ..................................................................... 46 5.1 Class 3 Code Exemptions ................................................................................... 46 5.1.1 IW D-1220 ............................................................................................... . . 46 5.1.2 IW D -5222(c) ............................................................................................ 47 5.2 Component Examination Basis ............................................................................. 47 5.2.1 C ategory D -A ........................................................................................... 48 5.2.2 C ategory D -B ........................................................................................... 48 6.0 IWE Metal Containment Requirements ............................................................................. 49 7.0 Development of Component Supports Examination Plan ............................................... 49 7.1 Code Exemptions for Supports ............................................................................. 49 7.2 Support Examination basis .................................................................................... 49 7.2.1 C ategory F-A .......................................................................................... 49 7.2.2 Item Num bers .......................................................................................... 50 7 .3 S n u b b e rs ................................................................ ................................................... 50 8.0 IWL Concrete Containment Requirements ...................................................................... 50 9.0 Augmented and Other Programs ...................................................................................... 51 9 .1 C la ss 1 ...................................................................................................................... 51 9.1.1 Reactor Coolant Pump Flywheels ........................................................... 51 9.1.2 Management Thermal Fatique (MRP-146) ............................................ 51 9.1.3 Code Case N-729 Alternative Examintion Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds, Section Xl, Division 1 ................................... 51 9.1.4 Code Case N-722 Additional Examinations for PWR Pressure-Retaining Welds on Class 1 Components Fabricated with Alloy 600/82/182 materials, Section Xl, Division 1 ......................................... 52 9.1.5 Westinghouse technical Bulletin TB-07-02 Rev. 2, "Reactor Vessel Head Adapter Thermal Sleeve Wear"................................................... 52 9.1.6 WCAP-1 6913-P - Operability Assessment and Plant Applicability Evaluation for Pressurizer Heater Sleeve Leakage in Westinghouse Designed Pressurizers ............................................................................ 52 9.1.7 Pressurizer Surge Line AMP (Plant Life Extension) ............................... 52 9 .2 C la ss 2 ...................................................................................................................... 53 9.2.1 NRC Bulletin 79-13 .................................................................................. 53 9.2.2 Assessment of RHR Mixing Tee Thermal Fatigue in PWR Plants (MR P -192) ............................................................................................. .. 53 6 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 10.0 Evaluation/Acceptance Criteria ......................................................................................... 53 10.1 Supplem ental Exam inations ................................................................................. 53 10.2 Additional Exam inations ......................................................................................... 54 10.3 Successive Inspections for Com ponents ............................................................ 54 10.3.1 Class 1 Com ponents [IW B-2420(b)] ........................................................... 54 10.3.2 Class 2 Com ponents [IW C-2420(b)] .......................................................... 54 10.3.3 Class 3 Com ponents [IW D-2420(b)] .......................................................... 54 10.3.4 Com ponent Supports [IW F-2420(b)] ........................................................ 54 11.0 Repair/Replacem ent Activities ........................................................................................... 55 12.0 Relief Requests ...................................................................................................................... 55 13.0 Boundary Classifications .................................................................................................... 55 14.0 Addition of W elds, Com ponents and Com ponent Supports ............................................. 56 15.0 Records .................................................................................................................................. 56 15.1 General ...................................................................................................................... 56 15.2 Nondestructive Exam inations ............................................................................... 56 15.3 Reports ....................................................................................................................... 57 15.4 Inservice Inspection Sum m ary Report .................................................................. 57 15.5 NIS-2 or NIS-2A Reports ...................................................................................... 57 16.0 References ............................................................................................................................. 57 7 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Appendix A - Relief Requests ...................................................................................................... Al Relief Request No. 1 Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal ..................................................................... 44 pages Relief Request No. 2 Alternative Examinations for Regenerative Heat Exchanger .............. 1 page Relief Request No. 3 Examination of Snubber Attachment Hardware ................................. 1 page Appendix B - Class 1, 2 and 3 Component and Component Support ISI Examination Summary T a b le s ........................................................................................................................ B1 List of Tables Table 1A Fifth Inservice Interval Dates - Unit 3 .................................................................... 17 Table 1B Fifth Inservice Interval Dates - Unit 4 .................................................................... 17 Table 2 USNRC Regulatory Guides ................................................................................. 21 Table 3 Applicable Code Cases ........................................................................................ 22 Table 4 Listing of Class 1 Valves by Group - Unit 3 ........................................................ 36 Table 5 Listing of Class 1 Valves by Group - Unit 4 ........................................................ 37 Table 6A Listing of Class 2 Exempt Components - Unit 3 .................................................... 40 Table 6B Listing of Class 2 Exempt Components - Unit 4 .................................................... 40 Table 7A Listing of Class 3 Exempt Components - Unit 3 .................................................... 47 Table 7B Listing of Class 3 Exempt Components - Unit 4 .................................................... 47 Table 8 Units 3/4 Boundary Classification Drawings ........................................................ 55 Table 9 R elief R equests .................................................................................................... A2 Table 10 Unit 3 - Class 1, 2 and 3 Component and Component Support ISI Examination S um m ary T able .................................................................................................... . . B3 Table 11 Unit 4 - Class 1, 2 and 3 Component and Component Support ISI Examination S um m ary T able .................................................................................................... B20 8 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Abbreviations ANII Authorized Nuclear Inservice Inspector ANSI American Nuclear Standard Institute ASME American Society of Mechanical Engineers BC Branch Connection B & PV Boiler & Pressure Vessel CCW Component Cooling Water CFR Code of Federal Regulations CH Charging System CHR Containment Heat Removal CPS Code Programs Section CRDM Control Rod Drive Mechanism CRS Code Required Surface CSI Component Support and Inspections CTMT Containment CS Containment Spray CV Control Valve CVCS Chemical and Volume Control System CW Clockwise ECCS Emergency Core Cooling System ECT Eddy Current Testing ENG Nuclear Engineering 9 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Abbreviations FPL Florida Power & Light Company FPS Fuel Pool System FSAR Final Safety Analysis Report FW Feedwater System HPSI High Pressure Safety Injection HS High Stress HX Heat Exchanger ID Identification IE Inspection and Enforcement ISI Inservice Inspection IST Inservice Testing JPN Juno Nuclear Engineering LER License Event Report LS Long Seam MOV Motor Operated Valve MRP Material Reliability Program MSIV Main Steam Isolation Valve MS Main Steam System MT Magnetic Particle Testing N/A Not Applicable NDE Nondestructive Examination NPS Nominal Pipe Size 10 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Abbreviations PDS Program Plan Boundary Drawings P&ID Piping and Instrumentation Diagram POV Pneumatic Operated Valve PSI Preservice Inspection PT Liquid Penetrant Testing PTN Plant Turkey Nuclear PWR Pressure Water PZR Pressurizer QA Quality Assurance QC Quality Control Qp Quality Procedure RCS Reactor Coolant System RCP Reactor Coolant Pump RGX Regenerative Heat Exchanger RHR Residual Heat Removal RI-ISI Risk Informed Inservice inspection RPV Reactor Pressure Vessel SD Structural Discontinuity SG Steam Generator SGBD Steam Generator Blowdown SRP Standard Review Plan SI Safety Injection 11 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Abbreviations T Thickness of Component, Pipe, etc.

TE Terminal End USNRC United States Nuclear Regulatory Commission UT Ultrasonic Testing VT Visual Testing 12 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Abstract This document describes the Class 1, 2, and 3 Inservice Inspection (ISI) Plan Fifth 10-Year Inservice Inspection Interval for Turkey Point Nuclear Power Plant Units 3 and 4.

This Program Plan was developed and prepared to meet the requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section Xl, 2007 Edition with Addenda through 2008, and 10CFR50.55a for Class 1, 2, and 3 systems. This Program Plan is subject to the conditions of 10CFR50.55a(b)(2), except design and access provisions and preservice examination requirements. This Plan identifies those components and/or systems and their supports that are subject to examination and testing.

Where applicable, ASME Code Cases are incorporated. The Code Cases used are either approved through publication in 10CFR50.55a, NRC Regulatory Guide 1.147, or are included in a Relief Request.

Other alternatives to the Code requirements have been included as relief requests, or they reference specific NRC regulations. Areas where Code compliance is not possible are also included as relief requests, along with proposed alternatives.

The ISI Programs for Containment, Inservice Pressure Tests, IWL, and Snubber Examinations are covered under separate plant documents. General requirements for these programs are included for completeness.

Additional requirements for augmented examinations are addressed. The ISI Program does not require these examinations; however, due to the nature of the augmented requirements, these programs have been included and administered at the request of the plant.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.0 Introduction Turkey Point Units 3 and 4 are three-loop Westinghouse Pressurized Water Nuclear Power Plants, Florida Power and Light Company (FPL) is the Owner of Record.

1.1 ISI Program Plan Development This document details the Inservice Inspection Plan of Class 1, 2, and 3 components for the fifth 10-Year Inservice Inspection Interval for Turkey Point Nuclear Power Plant Units 3 and 4.

The schedule of examinations is located in the 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule. The isometrics used for locations of welds during examinations are located at the Turkey Point Nuclear site. The schedule and isometrics are separate controlled documents.

Inservice examination of component and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 10CFR50.55a 12 months prior to the start of the 120-month inspection interval. These requirements are subject to the limitations and modifications listed within the 10CFR50.55a.

This Program Plan reflects the Inservice Inspection requirements of ASME Section Xl, 2007 Edition with Addenda through 2008 as modified by 10CFR50.55a.

1.2 Other ISI Programs This document does not address every aspect of Inservice Inspection. The following details the examination and testing requirements of those parts covered by other documents.

1.2.1 Inservice Testing Program (IST)

The program for Inservice Testing of Class 1, Class 2, and Class 3 Pumps and Valves is covered by the Turkey Point Inservice Testing (IST) Program, which is submitted and approved separately.

1.2.2 Steam Generator (SG) Eddy Current Testing (ET) Program The Steam Generator (SG) Eddy Current Testing (ET) Program is governed by the requirements of Turkey Point Technical Specifications, Section 3/4.4.5 and NEI 97-06. This program is administered separately.

1.2.3 Snubber Program The program for the examination and testing of safety-related snubbers is addressed by Turkey Point plant procedures.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 h Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.2.4 Pressure Test Program The program for Inservice System Pressure Testing of ASME Code Class 1, Class 2, and Class 3 components and systems is addressed in a separate document.

1.2.5 Repair and Replacement Program The Repair and Replacement Program, 0-ADM-5.32, for ASME Code Class 1, 2, and 3 component and systems, Class MC and CC are addressed by Turkey Point Plant procedures.

1.2.6 Metal Containment Inservice Inspection Program (IWE)

The Metal Containment Inservice Inspection Program, 2nd Interval-IWE-PTN-3/4-Program Plan, controls the examination of Containment Building under Subsection IWE and is administered separately.

1.2.7 Concrete Containment Inservice Inspection Program (IWL)

The Concrete Containment Inservice Inspection Program, 12-1SI/IWL-PTN-3/4, controls the examination of Containment Building under Subsection IWL and is administered separately.

1.3 Construction Permit The Construction permit for Turkey Point Nuclear Power Plant Units 3 & 4 was issued on April 27, 1967.

1.4 Commercial Service Dates The Operating Licenses for Turkey Point Nuclear Power Plants were issued on July 19, 1972 for Unit 3 and April 10, 1973 for Unit 4.

The Commercial Service Dates for Turkey Point Nuclear Power Plants are December 14, 1972 for Unit 3 and September 7, 1973 for Unit 4.

1.5 Background Vessels, piping, pumps and valves were built and installed in accordance to the rules of ASME Section VIII and ANSI Standard B31.1 for those systems classified as Class 1, 2, and 3.

Turkey Point Units 3 and 4 have been examined to the requirements of different Editions and Addenda of Section XI. The applicable Edition of Section Xl was mandated by changes to 10 CFR 50.55a at 10-year intervals or earlier.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 tr Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.5.1 Preservice Inspection The Preservice Inspection was conducted in accordance with the 1970 Edition with Addenda through Winter 1970 Addenda of the ASME Boiler and Pressure Vessel (B&PV) Code,Section XI.

1.5.2 First Inservice Inspection Interval During the first 10-year Inservice Inspection Interval, the first two periods were conducted in accordance with the 1970 Edition with Addenda through Winter 1970 Addenda of the ASME Boiler and Pressure Vessel (B&PV) Code, Section Xl. The last period was conducted in accordance with the 1974 Edition with Addenda through Summer 1975 of ASME B&PV Code, Section Xl.

The first 10-year interval for Turkey Point Unit 3 began on December 13, 1972 and ended on February 21, 1984. The first interval for Turkey Point Unit 4 began on September 7, 1973 and ended on April 14, 1984. An extension of the first interval was granted by the USNRC on March 1, 1984.

1.5.3 Second Inservice Inspection Interval The second 10-Year Inservice Inspection Interval for both units was conducted in accordance with the 1980 Edition through Winter 1981 Addenda of Section XI. Turkey Point Unit 3 second interval ran from February 22, 1984 to February 21, 1994. Turkey Point Unit 4 second interval began on April 15, 1984 and ended on April 14, 1994.

1.5.4 Third Inservice inspection Interval The third 10-year Inservice Inspection Interval for both units was conducted in accordance with the 1989 Edition of Section XI. Turkey Point Unit 3 third interval began on February 22, 1994 and ended on February 21, 2004. Turkey Point Unit 4 third interval began on April 15, 1994 and ended on April 14, 2004.

1.5.5 Fourth Inservice inspection Interval The fourth 10-year Inservice Inspection Interval for both units was conducted in accordance with ASME Section Xl, 1998 Edition with Addenda through 2000.

Turkey Point Unit 3 fourth interval began on February 22, 2004 and ends on February 21, 2014. Turkey Point Unit 4 third interval began on April 15, 2004 and ends on April 14, 2014.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.5.6 Fifth Inservice Inspection Interval The fifth 10-year Inservice Inspection Interval for both units will be conducted in accordance with ASME Section Xl, 2007 Edition with Addenda through 2008 as modified by 10CFR50.55a.

The fifth 10-Year Inservice Inspection Interval is divided into three successive Inspection periods as determined by calendar years of plant service within the interval. The dates of the fifth 10-year Inservice Inspection Interval and Periods are as follows:

Table 1A - Unit 3 Fifth Inservice Inspection Interval Period Start End 5 th Interval February 22, 2014 February 21, 2024 1 st Period February 22, 2014 February 21, 2017 2 nd Period February 22, 2017 February 21, 2021 3 rd Period February 22, 2021 February 21, 2024 Table 1B - Unit 4 Fifth Inservice Inspection Interval Period Start End 5 th Interval April 15, 2014 April 14, 2024 1 st Period April 15, 2014 April 14, 2017 2 nd Period April 15, 2017 April 14,2011 3 rd Period April 15, 2021 April 14, 2024 1.6 Applicable Editions and Addenda to Section Xl In accordance with 10 CFR 50.55a(b)(2), the Inservice Inspection Requirements for the fifth Inservice Inspection interval applicable to Class 1, 2, and 3 components at Turkey Point Units 3 and 4 are based on ASME Section Xl, 2007 Edition with Addenda through 2008.

Portions of the ISI Program Plan are based on other Editions and Addenda of Section XI, Relief Requests, the Code of Federal Regulations, Regulatory Guides, and Plant Technical Specifications and commitments. Where this has occurred, it is documented within this Program Plan.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.6.1 10CFR50.55a Code of Federal Regulations Conditions The following mandatory and optional Code of Federal Regulations conditions are included in 10CFR50.55a as of December 5, 2014. Only those 10CFR50.55a conditions applicable to the 2007 Edition through 2008 Addenda of Section Xl nondestructive examination requirements for Class 1, 2, and 3 components and component supports are listed. The conditions for concrete and metal containment components are listed for completeness only and are not applicable to this Program Plan. These conditions were reviewed for inclusion in the ISI Program Plan and dispositioned as follows:

1.6.1.1 Turkey Point Units 3 and 4 will not utilize the option in 10CFR50.55a(b)(2)(ii), to examine Class 1 piping perASME Section Xl, 1974 Edition with the Summer 1975 Addenda. Turkey Point will have a Risk-Informed Inservice Inspection (RI-ISI) application for Class 1 piping, this condition is not applicable.

1.6.1.2 The Turkey Point design includes a concrete containment subject to ASME Section Xl, Subsection IWL requirements. Therefore the mandatory conditions in 10CFR50.55a(b)(2)(viii) apply to Turkey Point Units 3 and 4. Examination of concrete containment components is addressed under the Concrete Containment ISI Program, 12-1SI/IWL-PTN-3/4.

1.6.1.3 The Turkey Point design includes a metal shell (or liner) subject to ASME Section Xl, Subsection IWE requirements. Therefore the mandatory conditions in 10CFR50.55a(b)(2)(ix) apply to Turkey Point Units 3 and 4. In addition, they will implement the optional conditions for the maximum direct examination distance for remote visual examinations presented in 10CFR50.55a(b)(2)(ix)(B). The examination of metal containment components is addressed under Containment Building Metallic Liner Inservice Inspection Program, 2nd Interval-IWE-PTN-3/4-Program Plan.

1.6.1.4 As required by 10CFR50.55a(b)(2)(x), Turkey Point will apply the station 1 OCFR50 Appendix B Quality Assurance Program of NQA-1 to Section Xl activities.

1.6.1.5 As allowed by 10CFR50.55a(b)(2)(xiv), for Appendix VIII Qualified Personnel Turkey Point will use the annual practice requirements in VII-4240 of Section X1 Appendix VII in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training (when deemed appropriate) as discussed in 10CFR50.55a(b)(2)(xiv). When utilizing this option, the annual practice requirements will be performed on material or welds that contain cracks, or by analyzing prerecorded data from material or welds that contain cracks. All training will be completed no earlier than 6 months prior to performing ultrasonic examinations.

1.6.1.6 As required by 10CFR50.55a(b)(2)(xviii)(A), Level I and II nondestructive examination personnel at Turkey Point will be recertified on a 3-year interval in lieu of the 5-year interval specified in IWA-2314(a) and IWA-2314(b) of the 2007 Edition through 2008 Addenda.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.6.1.7 As required by 10CFR50.55a(b)(2)(xix), Turkey Point will not apply the provisions in IWA-4520(b)(2) and IWA-4521 of the 2007 Edition through 2008 Addenda which allow the substitution of ultrasonic examination for radiographic examination specified in the Construction Code.

1.6.1.8 As required by 10CFR50.55a(b)(2)(xx)(B), Turkey Point will apply IWA-4540(a)(2) of the 2002 Addenda when performing system leakage tests after repair and replacement activities involving welding or brazing on a pressure retaining boundary.

1.6.1.9 As required by 10CFR50.55a(b)(2)(xxi)(A), the provisions of Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels, Items Nos. B3.120 and B3.140 of Inspection Program B in the 1998 Edition will be applied by Turkey Point Units 3 and 4. As allowed by 10CFR50.55a(b)(2)(xxi)(A), a visual examination with enhanced magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1, 2001 Edition with the 2003 Addenda may be performed in place of an ultrasonic examination.

1.6.1.10 Implementation of IWA-2220, "Surface Examination" that allows the use of an ultrasonic examination method to perform a surface examination, is prohibited by 10CFR50.55a(b)(2)(xxii).

1.6.1.11 1 OCFR50.55a(b)(2)(xxvii) modifies the requirements of IWA-5241 (f) and requires insulation removal from 17-4 PH or 410 stainless steel studs or bolts aged at a temperature below 11 00°F or those having a Rockwell Method C hardness value above 30, and from A-286 stainless steel studs or bolts preloaded to 100,000 pounds per square inch or higher. These requirements will be implemented in accordance with the PTN Bolted Joint Program.

1.6.1.12 As required by 10CFR50.55a(b)(2)(xxviii), Turkey Point will use the stated conditions when implementing Equation 2 in ASME Section Xl, Appendix A-4300(b)(1).

1.6.1.13 As required by 10CFR50.55a(b)(2)(xxix), Turkey Point 3 and 4 will submit a relief request to apply a Risk-Informed Inservice Inspection Programs during the Fifth Interval.

1.6.1.14 As allowed by 10CFR50.55a(g)(6)(ii)(B), Turkey Point acknowledges that their Containment ISI Program Plan does not have to be submitted to the NRC for approval. The Program elements will be maintained on site for audit.

1.6.1.15 Turkey Point will comply with the mandatory augmented examination criteria listed in 10CFR50.55a(g)(6)(ii)(D) regarding Reactor Vessel Head inspections.

1.6.1.16 Turkey Point will comply with the mandatory augmented examination criteria listed in 10CFR50.55a(g)(6)(ii)(E) regarding visual inspections of reactor coolant pressure boundaries.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.6.1.17 Turkey Point will comply with the mandatory augmented examination criteria listed in 10CFR50.55a(g)(6)(ii)(F) regarding examination requirements for Class 1 piping and nozzle dissimilar-metal butt welds. However, Turkey Point does not have piping fabricated with UNS N06082 or UNS W86182 weld filler material. Therefore, although mandated, these criteria do not apply to Turkey Point.

1.7 System Classification System safety classifications, design and fabrication requirements meet the intent of 10CFR50.2(v) and Regulatory Guide 1.26, as identified within the Turkey Point Units 3 and 4 Updated Final Safety Analysis Report (UFSAR).

Water, steam and radioactive containing components (other than turbines and condensers) are designated Quality Group A, B, C, or D in accordance with their importance to safety.

1.7.1 System Classifications Class 1 system boundaries are developed based on 10CFR50.2(v), and the Turkey Point Units 3 and 4 FSAR. Class 2 and 3 system boundaries are developed based on Regulatory Guide 1.26 and the Turkey Point Units 3 and 4 FSAR.

System Quality Group classification interfaces between components of different quality groups are designated on various system piping and instrument diagrams (P&IDs) (see Section 13).

1.7.2 Optional Construction Optional construction of a component within a system boundary to a classification higher than the minimum class established in the component design specification does not affect the overall system classification by which the applicable rules of Section Xl are determined.

1.7.3 Containment Penetrations Portions of piping penetrating the containment vessel which are required to be constructed to Class 1 or 2 rules for piping, and which may differ from the classification of the balance of the piping system, may not affect the overall system classification that determines the applicable rules of Section Xl.

1.7.4 Class MC Components 10CFR50.55a was amended, effective November 22, 1999, to address the requirements of ISI of metal containment buildings. The Metal Containment Inservice Inspection Program, as addressed in the 2 nd Interval-IWE-PTN-3/4-Program Plan defines the classification of the areas to be examined.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.7.5 Class CC Components 10CFR50.55a was amended, effective November 22, 1999, to address the requirements of ISI of concrete containment buildings. The Concrete Containment Inservice Inspection Program, as addressed in the 12-ISI/IWL-PTN-3/4, defines the classification of the areas to be examined.

1.8 Inspection Program Plan Examinations for Class 1, 2, and 3 components and their supports are scheduled in accordance with the Inservice Inspection Program. This incorporates the criteria of IWB-2411, IWC-2411, IWD-2411, IWF-2410 and Tables IWB-2411-1, IWC-2411-1, IWD-241 1-1 and IWF-241 0-1 for the examination of Class 1, 2, and 3 components and their supports, respectively. Examinations are scheduled based upon previous 10-Year intervals, to the extent practical and within the limits of IWB-2420(a), IWC-2420(a),

IWD-2420(a) and IWF-2420(a).

In order to be consistent in determining percentages, FPL chooses to multiply the number of examination areas by the minimum or maximum percentages of the Inspection Program and rounding to the nearest whole number. This will be the number FPL uses for determining how many welds/components/supports will be examined each period.

The total numbers of Turkey Point Units 3 and 4 Class 1, 2 and 3 components and supports subject to examination at the start of the fifth interval are shown in the Summary Tables in Appendix B. The listing of these components and supports and their relevant ISI related details are maintained and updated on an ongoing basis in the Turkey Point Units 3 and 4 ISI database.

The 5 th Interval Turkey Point ISI database provides the data for the Inservice Inspection Schedule Tables for examinations of the major components for PTN 3 and 4 located in 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule, respectively. The 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule include tables that have descriptions of each component subject to examination, the required Code references, and any other pertinent information that is useful for determining examination requirements. The information and summary tables located in the 5 Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule satisfy the requirements of IWA-2420(b)(1) through (6) respectively.

1.9 Regulatory Guides The Regulatory Guides determined to be applicable to Turkey Point Units 3 and 4 for purposes of this ISI Program Plan are listed below:

Table 2: USNRC Regulatory Guides 1.26 Quality Group Classifications 1.147 Section Xl Code Case Acceptability 1.193 ASME Code Cases Not Approved for Use 21 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.10 ASME Section Xl Code Cases Section Xl Code Cases applicable to the ISI Plan are shown below. Each of the Code Cases has been approved or conditionally approved and listed in USNRC Regulatory Guide 1.147, or are the subject of a relief request. When Code Cases are approved for use through a relief request, and are later added to Regulatory Guide 1.147, FPL may continue to use them in accordance with the Regulatory Guide.

Table 3: Applicable Code Cases Number Description Repair Welding Using Automatic or Machine Gas Tungsten-Arc Welding N-432-1 (GTAW) Temper Bead Technique, Section Xl, Division 1 (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Rotation of Snubbers and Pressure Retaining Items for the Purpose of N-508-4 Testing or Preventive Maintenance,Section XI, Division 1 (approved with conditions in Reg. Guide 1.147, Rev. 17)

Evaluation Criteria For Temporary Acceptance of Flaws in Moderate Energy N-513-3 Class 2 and 3 Piping,Section XI Division 1, (Approved with conditions in Regulatory Guide 1.147, Rev. 17)

Alternative Requirements For Successive Inspections of Class 1 and 2 N-526 Vessels,Section XI, Division 1 (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Alternative Requirements to Repair and Replacement Documentation N-532-5 Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,Section XI, Division 1 (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Alternative Requirements for Wall Thickness Restoration of Class 2 and High N-561-2 Energy Class 3 Carbon Steel Piping, Section Xl, Division 1 (Approved with conditions in Reg. Guide 1.147, Rev. 17)

Alternative Requirements for Wall Thickness Restoration of Class 3 N-562-2 Moderate Energy Carbon Steel Piping, Section Xl, Division 1 (Approved with conditions in Reg. Guide 1.147, Rev. 17)

Alternative Examination Requirements for Classes 1, 2, and 3 Piping N-586-1 Component and Supports, Section Xl, Division 1 (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

N-597-2 Requirements for Analytical Evaluation of Pipe Wall Thinning (Approved with conditions in Regulatory Guide 1.147, Rev. 17)

N-600 Transfer of Qualifications Between Owners,Section XI, Division 1 (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Ultrasonic Examination of Penetration Nozzles in Vessels, Examination N-613-1 Category B-D, Item Nos. B3.10 and B3.90, reactor Nozzle-to-Vessel Welds, Figs. IWB-2500-7(a), (b), and (c), Section Xl, Division 1, (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Alternative Calibration Block Material (Approved with conditions in Regulatory.

Guide 1.147, Rev. 17) 22 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Table 3: Applicable Code Cases Number Description Alternative Requirements for Inner Radius Examination of Class 1 Reactor N-648-1 Vessel Nozzles, Section Xl, Division 1 (Approved with condition in Regulatory Guide 1.147. Rev. 17)

Alternate Examination Requirements for IWE-5240 Visual Examination, Section Xl, Division 1 (approved without conditions in Reg. Guide 1.147, Rev. 16)

Ferritic and Dissimilar Metal Welding Using SMAW Temper Bead Technique N-651 Without Removing the Weld Bead Crown for the First Layer Section Xl, Division 1 (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Alternative Requirements for Wall Thickness Restoration of Classes 2 and 3 N-661-2 Carbon Steel Piping for Raw Water Service, Section Xl, Division 1 (approved with conditions in Reg. Guide 1.147, Rev. 17)

Alternative Examination Requirements to Table IWB-2500-1 and Table IWC-N-706-1 2500-1 for PWR Stainless Steel Residual and Regenerative Heat Exchangers (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Additional Examinations for PWR Pressure Retaining Welds in Class 1 N-722-1 components Fabricated With Alloy 600/82/182 Materials, Section Xl, Division 1 (Mandated with conditions in 10CFR50.55a(g)(6)(ii)(D))

Alternative Examination requirements for PWR reactor Vessel Upper Heads N-729-1 With Nozzles Having Pressure-Retaining Partial-Penetration Welds, Section Xl, Division 1 (Mandated with conditions in 10CFR50.55a(g)(6)(ii)(E))

Alternative Class 1 System Leakage Test Pressure Requirements, Section Xl, Division 1 (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Mitigation of Flaws in NPS 2 (DN 50) and Smaller Vessels and Piping By Use N-733 of a Mechanical Connection Modification (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

Successive Inspections of Class 1 and 2 Piping Welds (Approved without conditions in Regulatory Guide 1.147, Rev. 17)

N-751 Pressure Testing of Containment Penetration Piping (Approved with conditions in Regulatory Guide 1.147, Rev. 17)

Alternative to Inspection Interval Scheduling Requirements of IWA-2430, N-765 Section Xl, Division 1 (approved without conditions in Reg. Guide 1.147, Rev. 17)

Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation N-770-1 Activities (Mandated with conditions in 10CFR50.55a(g)(6)(ii)(F)) However, Turkey Point does not have piping fabricated with UNS N06082 or UNS W86182 weld filler material. Therefore, although mandated, this Code Case does not apply to Turkey Point.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 1.11 Branch Technical Position MEB 3-1 Branch Technical Position MEB 3-1 required FPL to determine where piping failure in fluid systems outside of the containment would have an adverse effect on other components and equipment. FPL completed a detailed engineering analysis of the Residual Heat Removal, Chemical Volume Control, Main Steam, Main Feedwater, Auxiliary Feedwater, and Steam Generator Blowdown systems in 1973. At that time, modifications to the plant were made to eliminate areas of concern. Based on this analysis, augmented ISI examinations on these systems are not required. (Ref. 16.38) 1.12 Plant Life Extension The purpose of the Renewed License Program (EN-AA-1 06) is to define the roles and responsibilities for the implementation of the License Renewal process and the actions that need to be completed for each unit after the Renewed Operating License is issued to include the post approval inspections and operation in the Period of Extended Operation (PEO).

The ISI Program Plan will implement the FPL commitment to manage the effects of aging for systems/structures/components within the scope of license renewal. The Section Xl Plan is credited as an aging management program for license renewal. As such, changes to the Section Xl Program Plan shall consider License Renewal requirements described in the Turkey Point Units 3 and 4 Design Basis Document, 5610-000-DBD-001, "Selected Licensing and Issues (SLI)",Section XVIII.

1.12.1 Licensing Renewal Commitment Documents PTN-ENG-LRAM-00-0027, ASME Section Xl, Subsection IWF Inservice Inspection Program Plan - License Renewal Basis Document, has been credited as a License Renewal commitment for performing the inspections as required by this document.

PTN-ENG-LRAM-00-0044, ASME Section Xl, Subsection IWB, IWC and IWD Inservice Inspection Program Plan - License Renewal Basis Document, has been credited as a License Renewal commitment for performing the inspections as required by this document.

PTN-ENG-LRNS-01-0019, RAI 3.2.4 A VT-1 visual examination will be implemented in addition to the Code required VT-3 visual examination for the reactor vessel core support lugs. This commitment is to be implemented in the fifth ISI interval during the period of extended operation.

PTN-ENG-LRAM-00-0055, Report to Site Engineering any new flaws identified in the pressurizer surge line in order to assess their impact on the Environmental Assisted Fatigue (EAF) evaluation.

PTN-ENG-LRAM-00-0041, Reactor Vessel internals Inspection Program

- License Renewal Basis Document, has been credited as a License Renewal commitment for performing the inspections as required by this document. This is a fifth and sixth interval commitment. This inspection 24 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 will correspond with ASME Section Xl reactor vessel inspections.

PTN-ENG-LR-00-0030 - A combination of volumetric inspections and destructive testing on a sample of small bore Class 1 piping and nozzles was performed at Turkey Point Units 3 and 4 during the fourth interval to verify that cracking is not an aging effect requiring management during the period of extended operation. A one-time volumetric (ultrasonic) examination was performed on five (5) 3 inch full penetration butt welds in each unit to look for evidence of cracking due to thermal and mechanical loading or intergranular stress corrosion. In addition, seven (7) small bore socket welds in each unit underwent destructive testing to look for evidence of inservice cracking. For each socket weld that was destructively examined, the NRC allowed equivalent credit to be taken for volumetrically examining two socket welds. The results of the ultrasonic examinations and destructive testing of the small bore butt and socket welds confirmed that there was no inservice cracking in the sample welds. Therefore, it was confirmed that inservice cracking in small bore piping at Turkey Point is not an aging issue and as such does not require additional management during the period of extended operation. No further action is required.

PTN-ENG-LRAM-00-0037, "Reactor Vessel Integrity Program - License Renewal Basis Document."

1.13 Successive Examinations The sequence of component examinations will be modified in accordance with the requirements of ASME Section Xl, IWB-2420(a), IWC-2420(a), IWD-2420(a) and IWF-2420(a). This allows FPL to alter the sequence of examinations to allow the examination of several components in an area during one outage instead of over several outages. This will reduce costs and radiation exposure. The percentage requirements of IWB-241 1, IWC-241 1, IWD-241 1, and IWF-2410 will be satisfied. The examination schedule is designed to optimize the performance of work within the plant to reduce radiation dose, eliminate interference with other work, and reduce costs.

1.14 NDE Examinations and Personnel Qualification/Certification All NDE will be performed in accordance with the requirements of ASME Section Xl, 2007 Edition with Addenda through 2008 with the following modifications as required by 10CFR50.55a.

1.14.1 Alternative Examinations (IWA-4520(b)(2) and IWA-4521)

Turkey Point Units 3 and 4 will not apply the provisions in IWA-4520(b)(2) and IWA-4521 of the 2007 Edition through 2008 Addenda which allow the substitution of ultrasonic examination for radiographic examination specified in the Construction Code. (Reference 10CFR50.55a(b)(2)(xix)).

1.14.2 Certification and Recertification (IWA-2314)

Level I and II nondestructive examination personnel and personnel qualified 25 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 under the American Society for Nondestructive Testing Central Certification Program and ANSI/ASNT CP-1 89 shall be recertified on a 3-year interval in lieu of the 5-year interval specified in IWA-2314(a) and IWA-2314(b) (Reference 10 CFR 50.55a(b)(2)(xviii)(A)).

1.14.3 Appendix VIII Requirements 1.14.3.1 10CFR50.55a(b)(2)(xiv) requires that all personnel qualified for performing ultrasonic (UT) examinations in accordance with Appendix VIII shall receive additional annual hands-on training. This requirement consists of at least eight hours of hands on training on samples containing cracks no earlier than six months prior to performing examinations at a licensee's facility. Turkey Point will comply with these additional training requirements for personnel performing Section Xl Appendix VIII, UT examinations.

1.14.3.2 In September 1999, 10CFR50.55a incorporated an expedited implementation schedule for ASME Section Xl, Appendix VIII. FPL implemented the requirements in accordance with the expedited schedule within the third 10-year interval for Turkey Point Units 3 and 4. For the fifth 10-year interval, FPL will implement the requirements of ASME Section Xl, 2007 Edition with Addenda through 2008 as modified by 1 OCFR50.55a and relief request, when approved.

2.0 Risk-Informed (RI) ISI Requirements 2.1 During the third and fourth 10-year intervals, Turkey Point Units 3 and 4 implemented a Risk-Informed selection criterion for Examination Category B-F and B-J piping welds.

This alternative to the requirements of Section Xl was submitted to the NRC during the third 10-year interval in letters dated January 19, 2000 and July 8, 2002. The alternative was authorized by letters dated November 30, 2000 and August 1, 2003 for the remainder of the third ISI interval ending February 21, 2004 for PTN-3 and April 14, 2004 for PTN-4. This alternative to the requirements of Section Xl was resubmitted to the NRC during the fourth 10-year interval as Relief Request #3 for Unit 3 by SE dated December 9, 2008 (TAC No. MD7740) and Relief Request #4 for Unit 4 by SE dated December 9, 2008 (TAC No. MD8875).

2.2 During the third and fourth 10-year intervals, the RI-ISI application was developed and implemented in accordance with the RI-ISI methodology of WCAP 14572, Rev. 1-NP-A, Addenda 1. This is typically referred to as the Westinghouse RI-ISI approach. During the fifth 10-year interval, Turkey Point Units 3 and 4 intends to convert their RI-ISI application from the Westinghouse RI-ISI approach to the EPRI RI-ISI approach that is in accordance with EPRI Topical Report No. TR-1 12657 and ASME Section Xl, Nonmandatory Appendix R. The RI-ISI application will also be expanded to include the examination of Class 2 piping welds currently addressed by ASME Section Xl, Examination Categories C-F-1 and C-F-2. Once the RI-ISI conversion to the EPRI approach is completed, the proposed alternative will be submitted via relief request for approval by the NRC. Until that time, Turkey Point Units 3 and 4 will implement the criteria of ASME Section Xl, Examination Categories B-F, B-J, C-F-1 and C-F-2 for the examination of Class 1 and 2 piping welds. Examination Category B-F vessel butt 26 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 welds fabricated with UNS N06082 or UNS W86182 weld filler material with or without application of listed mitigation activities in accordance with Code Case N-770-1, as mandated with conditions in 10CFR50.55a(g)(6)(ii)(F) does not apply. Turkey Point does not have piping fabricated with UNS N06082 or UNS W86182 weld filler material.

Therefore, although mandated, this Code Case does not apply to Turkey Point.

3.0 Development of the Class 1 Examination Plan Plant controlled isometric, P&IDs, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.

Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.

3.1 Class 1 Code Exemptions IWB-1 220 - Components Exempt from Examination The following components 1 or parts of components are exempted from the volumetric and surface examination requirements of IWB-2500:

(a) components that are connected to the reactor coolant system and part of the reactor coolant pressure boundary, and that are of such a size and shape so that upon postulated rupture the resulting flow of coolant from the reactor coolant system under normal plant operating conditions is within the capacity of makeup systems which are operable from on-site emergency power. The emergency core cooling systems are excluded from the calculation of makeup capacity; (b) (1) components and piping segments NPS 1 (DN 25) and smaller, except for steam generator tubing; (2) components and piping segments which have one inlet and one outlet, both of which are NPS 1 (DN 25) and smaller; (3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 1 (DN 25) pipe.

(c) reactor vessel head connections and associated piping, NPS 2 (DN 50) and smaller, made inaccessible by control rod drive penetrations.

(d) welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

Note 1: The exemptions from examination in IWC-1220 may be applied to those components permitted to be Class 2 in lieu of Class 1 by the regulatory authority having jurisdiction at the plant site.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Note 2: For heat exchangers, the shell side and tube side may be considered separate components.

3.2 Component Examination Basis This section describes each Examination Category. The required percentage of examinations and any limitations for each Examination Category is described. All other requirements are found in ASME Section Xl, 2007 Edition with Addenda through 2008.

The Summary Tables located in 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule satisfy the requirements of IWA-2420(b)(1) through (6) respectively.

A narrative discussion of Class 1 components subject to examination and testing are described in detail below:

3.2.1 Category B-A, Pressure Retaining Welds in Reactor Vessel ASME Section XI, Appendix VIII requirements are implemented as required.

Items B1.10-Shell Welds B1.11-Circumferential B1I.12-Longitudinal Examine essentially 100% of all longitudinal and circumferential shell welds (does not include shell-to-flange weld).

There are no longitudinal shell welds on the reactor vessel at Turkey Point Units 3&4.

Items Bl.20-Bottom Head Weld B1.21 -Circumferential B1i.22-Meridional Examine essentially 100% of the accessible length of the circumferential head weld shell weld. There are no meridional head welds at Turkey Point Units 3 &

4.

Items Bl.20-Top Head Weld B1.21-Circumferential B1i.22-Meridional Not applicable to Turkey Point. The replacement reactor heads that were installed in Fall 2004 for Unit 3 (Cycle 21) and Spring 2005 (Cycle 22) for Unit 4 are both a one piece forging.

Item Bl.30-Shell-to-Flange Weld Examine essentially 100% of the shell-to-flange weld.

Code Table Note 3 - The shell-to-flange weld examination may be performed during the first and third inspection periods, in which case 50% of the shell-to-flange weld shall be examined by the end of the first period, and the remainder by the end of the third period. During the first period, the examination need only be performed from the flange face, provided this same portion is examined from the shell during the third period.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Alternatively, FPL may defer the examination to the end of the interval per Code Table Note 5, provided the conditions identified in Note 5 are met.

Item B1.40-Head-to-Flange Weld Examine essentially 100% of the head to flange weld.

Not applicable to Turkey Point. The replacement reactor heads that were installed in Fall 2004 for Unit 3 (Cycle 21) and Spring 2005 (Cycle 22) for Unit 4 are both a one piece forging and do not contain a head to flange weld.

Items Bl.50-Repair Welds B1i.51-Beltline Region There are no repair welds in the beltline region of Turkey Point Units 3 and 4 Reactor Pressure Vessels.

3.2.2 Category B-B, Pressure Retaining welds in vessels other than Reactor Vessels All examinations are performed from the outside surface of the components.

Pressurizer:

Item B2. 10-Shell-to-Head B2. 11 -Circumferential B2.12-Longitudinal Examine 100% of both shell to head welds and 1 ft. on one intersecting longitudinal weld at each circumferential weld.

Pressurizer:

Items B2.20-Head Welds B2.21 -Circumferential B2.22-Meridional There are no circumferential or meridional head welds in the pressurizer at Turkey Point Units 3 and 4.

Steam Generators (Primary Side)

Items B2.30-Head Welds B2.31 -Circumferential B2.32-Meridional There are no circumferential or meridional head welds in the Turkey Point Units 3 and 4 steam generators.

Steam Generators (Primary Side)

Item B2.40-Tubesheet to Head Welds 29 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Examine 100% of one weld on one vessel. The examinations are limited to one vessel among the group of vessels performing a similar function (Reference Note 1 Table IWB-2500-1 and Figure IWB-2500-20(d)).

Heat Exchangers (Primary Side) - Head:

Item B2.50-Head Welds B2.51 -Circumferential B2.52-Meridional An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger is being submitted to the NRC during the fifth 10-year interval as Relief Request #2 for Units 3 and 4.

Heat Exchangers (Primary Side) - Shell:

Item B2.60-Tubesheet-to-Head Welds B2.70-Longitudinal Welds B2.80-Tubesheet-to-Shell Welds An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger is being submitted to the NRC during the fifth 10-year interval as Relief Request #2 for Units 3 and 4.

There are no longitudinal welds in the Turkey Point Units 3 and 4 Regenerative Heat Exchanger.

3.2.3 Category B-D, Full Penetration Welds of Nozzle in Vessels (Plan B)

Examination category B-D, Item Numbers B3.120 and B3.140, will be examined in accordance with the requirements of ASME Section Xl, 1998 Edition (Reference 10CFR50.55a(b)(2)(xxi)(A)).

Reactor Vessel:

Item B3.90-Nozzle-to-Vessel Welds B3.100-Nozzle Inside Radius Section Examine all nozzles during the interval. In place of the UT examination required by Table IWB-2500-1, FPL may implement the alternative requirements of Code Case N-648-1 as modified by NRC Reg. Guide 1.147.A visual examination with enhanced magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1 with limiting assumptions on the flaw aspect ratio. The provisions of Table IWB-2500-1 for this examination category continue to apply except that, in place of the examination volumes, the surfaces to be examined are the external surfaces shown in the figures applicable to this table.

Pressurizer:

Item B3.110-Nozzle-to-Vessel Welds B3.120-Nozzle Inside Radius Sections Examine all nozzles during the interval. The inside radius sections are required to be examined by 10CFR50.55a(b)(2)(xxi)(A). A visual examination with enhanced magnification that has a resolution sensitivity to detect a 1-mil width 30 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1 may be performed in place of an ultrasonic examination (Reference 10CFR50.55a(b)(2)(xxi)(A)).

Steam Generators:

Item B3.130-Nozzle-to-Vessel Welds B3.140-Nozzle Inside Radius Sections Examine all nozzles during the interval. The inside radius sections are required to be examined by 10CFR50.55a(b)(2)(xxi)(A). A visual examination with enhanced magnification that has a resolution sensitivity to detect a 1 -mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1 may be performed in place of an ultrasonic examination (Reference 10CFR50.55a(b)(2)(xxi)(A)).

Heat Exchangers (Primary Side):

Item B3.150-Nozzle-to-Vessel Welds B3.160-Nozzle Inside Radius Sections An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger is being submitted to the NRC during the fifth 10-year interval as Relief Request #2 for Units 3 and 4.

3.2.4 Category B-F, Pressure Retaining Dissimilar Metal Welds Reactor Vessel:

Item B5.10-NPS 4 (DN 100) or Larger Nozzle-to-Safe End Butt Welds B5.20-Less Than NPS 4 (DN 100) Nozzle-to-Safe End Butt Welds B5.30-Nozzle-to-Safe End Socket Welds Examine 100% of the Examination Category B-F, Item No. B5.10 welds during the interval. Item Nos. B5.20 and B5.30 are not applicable to Turkey Point Units 3 and 4.

Pressurizer:

Item B5.40-NPS 4 (DN 100) or Larger Nozzle-to-Safe End Butt Welds B5.50-Less Than NPS 4 (DN 100) Nozzle-to-Safe End Butt Welds B5.60-Nozzle-to-Safe End Socket Welds Examine 100% of the Examination Category B-F, Item No. B5.40 welds during the interval. Item Nos. B5.50 and B5.60 are not applicable to Turkey Point Units 3 and 4.

Steam Generator:

Item B5.70-NPS 4 (DN 100) or Larger Nozzle-to-Safe End Butt Welds B5.80-Less Than NPS 4 (DN 100) Nozzle-to-Safe End Butt Welds 85.90-Nozzle-to-Safe End Socket Welds Examine 100% of the Examination Category B-F, Item No. B5.70 welds during the interval. Item Nos. B5.80 and B5.90 are not applicable to Turkey Point Units 3 and 4.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Heat Exchangers:

Item B5.100-NPS 4 (DN 100) or Larger Nozzle-to-Safe End Butt Welds B5.1 10-Less Than NPS 4 (DN 100) Nozzle-to-Safe End Butt Welds B5.120-Nozzle-to-Safe End Socket Welds Not applicable to Turkey Point Units 3 and 4.

3.2.5 Category B-G Pressure Retaining Bolting, Greater Than 2 in. (50 mm) in Diameter For heat exchangers, piping, pumps, and valves, volumetric examination of bolting for heat exchangers, pumps, or valves may be conducted on one heat exchanger, one pump, or one valve among a group of heat exchangers, pumps, or valves that are similar in design, type, and function. In addition, when the component to be examined contains a group of bolted connections of similar design and size, such as flanged connections, the examination may be conducted on one bolted connection among the group For heat exchangers, piping, pumps, and valves, visual examinations are limited to components selected for examination under B-B (vessels other than RPV),

B-J (piping), B-L-2 (pump casings), and B-M-2 (valve bodies exceeding NPS 4).

Reactor Vessel:

Item B6.10-Closure Head Nuts Item B6.20-Closure Studs Item B6.40-Threads in Flange Item B6.50-Closure Washers, Bushings Examine 100% of the bolting each interval.

Pressurizer:

Item B6.60-Bolts and Studs B6.70-Flange Surface, when connection disassembled B6.80-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 and 4.

Steam Generators:

Item B6.90-Bolts and Studs B6.100-Flange Surface, when connection disassembled B6.1 10-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 and 4.

Heat Exchangers:

Item B6.120-Bolts and Studs B6.130-Flange Surface, when connection disassembled B6.140-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 and 4.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Piping:

Item B6.150-Bolts and Studs B6.160-Flange Surface, when connection disassembled B6.170-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 and 4 Pumps:

Item B6.180-Bolts and Studs B6.190-Flange Surface, when connection disassembled B6.200-Nuts, Bushings, Washers Examine 100% of the above items of one Reactor Coolant Pump during the interval.

Valves:

Item B6.210-Bolts and Studs B6.220-Flange Surface, when connection disassembled B6.230-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 and 4 3.2.6 Category B-G-2, Pressure Retaining Bolting, 2 in. (50 mm) and Less in Diameter For heat exchangers, piping, pumps, and valves, examinations are limited to components selected for examination under B-B (vessels other than RPV), B-J (piping), B-L-2 (pump casings), and B-M-2 (valve bodies exceeding NPS 4), if disassembled.

Reactor Vessel:

Item B7.10-Bolts, Studs, and Nuts Not applicable to Turkey Point Units 3 and 4.

Pressurizer:

Item B7.20-Bolts, Studs, and Nuts Examine 100% of the bolting each interval.

Steam Generators:

Item B7.30-Bolts, Studs, and Nuts Examine 100% of the bolting each interval on the steam generator selected for examination under Examination Category B-B.

Heat Exchangers:

Item B7.40-Bolts, Studs, and Nuts Not applicable to Turkey Point Units 3 and 4.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Piping:

Item B7.50-Bolts, Studs, and Nuts Examine 100% of the bolting each interval.

Pumps:

Item B7.60-Bolts, Studs, and Nuts Not applicable to Turkey Point Units 3 and 4.

Valves:

Item B7.70-Bolts, Studs, and Nuts Examine 100% of the bolting on one of each group of valves each interval.

3.2.7 Category B-J, Pressure Retaining Welds in Piping Item B9.10-Piping NPS 4 or larger Item B9.11-Circumferential welds Item B9.20-Piping Less than NPS 4 Item B9.21-Circumferential welds other than PWR high pressure safety injection systems Item 89.22-Circumferential welds of PWR high pressure safety injection systems Item B9.30-Branch pipe connection welds Item B9.31-Piping NPS 4 or larger Item 89.32-Piping less than NPS 4 Item 89.40-Socket welds Examinations shall include the following:

(a) All terminal ends in each pipe or branch run connected to vessels.

(b) All terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed either of the following limits under loads associated with specific seismic events and operational conditions:

(1) primary plus secondary stress intensity range of 2.4 Sm for ferritic steel and austenitic steel (2) cumulative usage factor U of 0.4 (c) All dissimilar metal welds not covered under Examination Category B-F.

(d) Additional piping welds so that the total number of circumferential butt welds (or branch connection or socket welds) selected for examination equals 25% of the circumferential butt welds (or branch connection or socket welds) in the reactor coolant piping system. This total does not include welds exempted by IWB-1220 or welds in Item No. B9.22. For PWRs, these additional welds may be located as follows:

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 (1) one hot-leg and one cold-leg in one reactor coolant loop (2) one branch, representative of an essentially symmetrical piping configuration among each group of branch runs that are connected to a loop and that perform similar system functions (3) each piping and branch run exclusive of the categories of loop and runs that are part of system piping in (1) and (2) above A 10% sample of PWR high pressure safety injection system circumferential welds in piping > NPS 1 1/2 and < NPS 4 shall be selected for examination. This sample shall be selected from locations determined by the Owner as most likely to be subject to thermal fatigue. Thermal fatigue may be caused by conditions such as valve leakage or turbulent effects.

3.2.8 Category B-K, Welded Attachments for Vessels, Piping, Pumps, and Valves For piping, pumps, and valves, a sample of 10% of the welded attachments will be examined. Each welded attachment will receive a surface examination of 100% of required areas of each welded attachment. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, Inservice Inspection, or testing. Examinations performed as a result of support deformation cannot be credited under the requirements of the Inspection Program.

Pressure Vessels:

Item B10.10-Welded Attachments For multiple vessels of similar design, function and service, only one of the welded attachments of only one of the multiple components requires examination. For single vessels, only one welded attachment shall be selected for examination. The attachment selected for examination on one of the multiple vessels or the single vessel, as applicable, shall be an attachment under continuous load during normal system operation, or an attachment subject to a potential intermittent load (seismic, water hammer, etc.) during normal system operation ifan attachment under continuous load does not exist.

An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger is being submitted to the NRC during the fifth 10-year interval as Relief Request #2 for Units 3 and 4.

Piping:

Item B10.20-Welded Attachments Examine 10% of the welded attachments associated with the component supports selected for examination under IWF-251 0.

Pumps:

Item B10.30-Welded Attachments Examine 10% of the welded attachments associated with the component 35 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 supports selected for examination under IWF-2510.

Valves:

Item B10.40-Welded Attachments Not applicable to Turkey Point Units 3 and 4.

3.2.9 Category B-L-2, Pump Casing Pumps:

Item B12.20-Pump Casing Examination of the internal surfaces of one of the three reactor coolant pumps when disassembled for maintenance. Pump to be identified when pump is disassembled.

3.2.10 Category B-M-2, Valve Bodies Valves that are of the same size, constructional design, and manufacturing method, and that perform similar functions in the system are grouped together.

Valves:

Item B12.50-Valve Body, Exceeding NPS 4 (DN 100)

Examine at least one valve of each group of valves once per interval when disassembled for maintenance, repair, or volumetric examination.

Table 4 Unit 3 Class 1 Valve Grouping Group Num Zone Znue Valve Number Type Size Number Number 3-036 MOV-3-750 Gate Isol 14" 3-036 MOV-3-751 Gate Isol 14" 3-037 3-875A Check 10" 3-038 3-875B Check 10" 3-039 3-875C Check 10',

2 3-037 3-875D Check 10" 3-038 3-875E Check 10",

3-039 3-875F Check 10",

3-037 3-876A Check 8" 3-038 3-876B Check 8" 3 3-039 3-876C Check 8" 3-038 3-876D Check 8" 1 3-039 3-876E Check 8" 36 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Table 5 Unit 4 Class 1 Valve Grouping Group Num Zone Znue Valve Number Type Size Number Number 4-036 MOV-4-750 Gate Isol 14" 4-036 MOV-4-751 Gate Isol 14" 4-037 4-875A Check 10" 4-038 4-875B Check 10" 4-039 4-875C Check 10" 2 4037 4-875D Check 10" 4-038 4-875E Check 10" 4-039 4-875F Check 10" 4-037 4-876A Check 8" 4-038 4-876B Check 8" 3 4-039 4-876C Check 8" 4-038 4-876D Check 8" 4-039 4-876E Check 8" 3.2.11 Category B-N-I, Interior of Reactor Vessel Reactor Vessel:

Item B1 3.10-Vessel Interior Examine accessible areas once each inspection period above and below the reactor core made accessible for examination by removal of components during normal refueling.

3.2.12 Category B-N-2, Welded Core Support Structures and Interior Attachments to Reactor Vessels Reactor Vessel (PWR):

Item B13.50-Interior Attachments within Beltline Region There are no interior attachments within the beltline region of the Turkey Point Units 3 and 4 Reactor Pressure Vessels.

Item B1 3.60-Interior Attachments Beyond Beltline Region Examine interior attachments beyond the beltline region once per interval.

These examinations may be deferred until the end of the interval.

3.2.13 Category B-N-3, Removable Core Support Structures Item B13.70-Core Support Structure Examine accessible surfaces of core support structures once per interval. The structure shall be removed from the vessel. These examinations may be deferred until the end of the interval.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 3.2.14 Category B-O, Pressure Retaining Welds in Control Rod Housings Reactor Vessel (PWR):

Item B14.20-Welds in Control Rod Drive (CRD) Housings Item B14.21-Welds in In-Core Instrumentation (ICI) Nozzle Housings >NPS 2 (DN 50)

Examine 10% of the peripheral housing welds.

Item No. B14.21, Welds in In-Core Instrumentation (ICI) Nozzle Housings Not applicable to Turkey Point Units 3 and 4.

3.2.15 Category B-P, All Pressure Retaining Components The system leakage test shall be conducted prior to plant startup following each refueling outage.

For insulated components in systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connections for VT-2 visual examination. Insulation removal and VT-2 visual examination of insulated bolted connections may be deferred until the system is depressurized. When corrosion-resistant bolting material with a chromium content of at least 10%, such as SA-564 Grade 630 H1100, SA-453 Grade 660, SB-637 Type 718 or SB-637 Type 750 is used, it is permissible to perform the VT-2 examination without insulation removal (IWA-5241 (f)).

10CFR50.55a(b)(2)(xxvii) modifies the requirements of IWA-5241(f) and requires insulation removal from 17-4 PH or 410 stainless steel studs or bolts aged at a temperature below 1100°F or those having a Rockwell Method C hardness value above 30, and from A-286 stainless steel studs or bolts preloaded to 100,000 pounds per square inch or higher.

Item B15.10-Pressure Retaining Components (IWB-5222(a)

Item B 15.20-Pressure Retaining Components (IWB-5222(b)

Perform VT-2 visual examination in association with system leakage test each refueling outage for Item B15.10 and once per interval for Item B15.20.

3.2.16 Category B-Q, Steam Generator Tubing Item: B16.20-Steam Generator Tubing in U-Tube Design The extent and frequency of examination is governed in accordance with the Turkey point Units 3 and 4 Plant Technical Specifications.

4.0 Development of the Class 2 Examination Plan Plant controlled isometric, P&IDs, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.

4.1 Class 2 Code Exemptions The following Class 2 exemption criteria are applicable. Article IWC-1220 of ASME Section Xl, 2007 Edition with Addenda through 2008 lists those piping and components exempt from examination.

IWC-1 220 - Components Exempt from Examination The following components (or parts of components) are exempted from the volumetric and surface examination requirements of IWC-2500; 4.1.1 IWC-1221, Components within RHR, ECC, and CHR Systems or Portions of Systems1 (a) For systems, except high pressure safety injection systems in pressurized water reactor plants:

(1) components and piping segments NPS 4 (DN 100) and smaller.

(2) components and piping segments which have one inlet and one outlet, both of which are NPS 4 (DN100) and smaller.

(3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 1-1/2 (DN 40) pipe.

(b) For high pressure safety injection systems in pressurized water reactor plants:

(1) components and piping segments NPS 1-1/2 (DN40) and smaller.

(2) components and piping segments which have one inlet and one outlet, both of which are NPS 1-1/2 (DN40) and smaller.

(3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 1-1/2 (DN 40) pipe.

(c) Vessels, piping, pumps, valves, other components, and component connections of any size in statically pressurized, passive (i.e. no pumps) safety injection systems 3 of pressurized water reactor plants.

(d) Piping and other components of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-IS I-PTN-3/4-Program Plan January 21, 2015 Table 6A Unit 3 Class 2 Exempt Components Component/Piping System Exemption Criteria Accumulator Tank 3T299A and piping to Valve IWC-1221(c) 3-875D Accumulator Tank 3T299B and piping to Valve IWC-1 221(c) 3-875E Accumulator Tank 3T299C and piping to Valve IWC-1 221(c) 3-875F Containment Spray from Valve MOV-3-880A IWC-1221(d) to spray headers inside containment Containment Spray from Valve MOV-3-880B W-21(d to spray headers inside containment Table 6B Unit 4 Class 2 Exempt Components Component/Piping System Exemption Criteria Accumulator Tank 4T299A and piping to Valve IWC-1 221 (c) 3-875D Accumulator Tank 4T299B and piping to Valve IWC-1 221 (c) 3-875E Accumulator Tank 4T299C and piping to Valve IWC-1221(c) 3-875F Containment Spray from Valve MOV-4-880A IWC-1221(d) to spray headers inside containment Containment Spray from Valve MOV-4-880A IWC-1221(d) to spray headers inside containment II 4.1.2 IWC-1222, Components within Systems or Portions of Systems Other Than RHR, ECC, and CHR Systems1 (a) For systems, except auxiliary feedwater systems in pressurized water reactor plants:

(1) components and piping segments NPS 4 (DN100) and smaller.

(2) components and piping segments which are NPS 4 (DN 100) and smaller.

(3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 1-1/2 (DN 40) pipe.

(b) For auxiliary feedwater systems in pressurized water reactor plants:

(1) components and piping segments NPS 1-1/2 (DN40) and smaller.

(2) components and piping segments which have one inlet and one 40 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 outlet, both of which are NPS 1-1/2 (DN 40) and smaller.

(3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 1-1/2 (DN 40) pipe (c) Vessels, piping, pumps, valves, other components, and component connections of any size in systems or portions of systems that operate (when the system function is required) at a pressure equal to or less than 275 psig (1900 kPa) and at a temperature equal to or less than 2000 F (930 C).

(d) Piping and other components of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions.

4.1.3 IWC-1 223, Inaccessible Welds Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

Note 1: RHR, ECC, and CHR systems are the Residual Heat Removal, Emergency Core Cooling, and Containment Heat Removal Systems, respectively.

Note 2: For heat exchangers, the shell side and tube side may be considered separate components.

Note 3: Statically pressurized, passive safety injection systems of pressurized water reactor plants are typically called:

(a) accumulator tank and associated system.

(b) safety injection tank and associated system.

(c) core flooding tank and associated system.

The following Class 2 systems are exempt from surface and volumetric requirements for reasons other than size:

4.2 Component Examination Basis This section describes each Examination Category. The required percentage of examinations and any limitations for each Examination Category is described. All other requirements are found in ASME Section Xl, 2007 Edition with Addenda through 2008.

The Summary Tables located in 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule satisfy the requirements of IWA-2420(b)(1) through (6) respectively.

A narrative discussion of Class 2 components subject to examination and testing are described in detail as follows:

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 4.2.1 Category C-A, Pressure Retaining Welds in Pressure Vessels Item C1.10-Shell Circumferential Welds Examine 100% of cylindrical-shell-to-conical-shell-junction welds and shell- (or head) to-flange welds. The examinations may be limited to one vessel or distributed among a group of vessels.

Item C1.20-Head Circumferential Welds Examine 100% of head-to-shell welds. The examinations may be limited to one vessel or distributed among a group of vessels.

Item Cl.30-Tubesheet-to-Shell Welds Examine 100% of tubesheet-to-shell welds. The examinations may be limited to one vessel or distributed among a group of vessels.

4.2.2 Category C-B, Pressure Retaining Nozzle Welds in Vessels Items C2.10-Nozzles in Vessels < 1/2/ inch (13mm) Nominal Thickness C2.1 1-Nozzle-to-Shell (Nozzle-to-Head or Nozzle-to-Nozzle) Weld Not applicable to Turkey Point Units 3 and 4.

Items C2.20-Nozzles Without Reinforcing Plate in Vessels > 1/2 Inch (13 mm)

Nominal Thickness C2.21-Nozzle-to-Shell (Nozzle-to-Head or Nozzle-to-Nozzle) Weld C2.22-Nozzle Inside Radius Section Applicable to Nozzle-to-Shell (Head) weld for nozzles greater than NPS 4 (Reference General Note-Figures IWC-2500-4). Nozzle Inner Radius requirement applies to nozzles greater than NPS 12 (Reference Figures IWC-2500-4(a), (b), (c) and (d)). Examine nozzles at terminal ends of piping runs.

The examination may be limited to one vessel or distributed among the vessels.

Items C2.30-Nozzles With Reinforcing Plate in Vessels > 1/2/ in. (13 mm)

Nominal Thickness C2.31-Reinforcing Plate Welds to Nozzle and Vessel Examine nozzles at terminal ends of piping runs. The examination may be limited to one vessel or distributed among the vessels.

C2.32-Nozzle-to-Shell (Nozzle-to-Head or Nozzle-to-Nozzle) Welds When Inside of Vessel is Accessible Not applicable to Turkey Point Units 3 and 4.

C2.33-Nozzle-to-Shell (Nozzle-to-Head or Nozzle-to-Nozzle) Welds When Inside of Vessel is Inaccessible 42 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Applicable to Nozzle-to-Shell (Nozzle-to-Head or Nozzle-to-Nozzle) weld for nozzles greater than NPS 4 (Reference General Note-Figures IWC-2500-4).

Examine telltale hole in reinforcing plates once each period. The examination may be limited to one vessel or distributed among the vessels. This examination will be performed during the pressure test of the system.

4.2.3 Category C-C, Welded Attachments for Vessels, Piping, Pumps, and Valves For piping, pumps, and valves, a sample of 10% of the welded attachments will be examined. Each welded attachment will receive a surface examination of 100% of required areas of each welded attachment. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, Inservice Inspection, or testing. Examinations performed as a result of support deformation cannot be credited under the requirements of the Inspection Program.

Pressure Vessels:

Item C3.10-Welded Attachments For multiple vessels of similar design, function and service, only one of the welded attachments of only one of the multiple components requires examination. For single vessels, only one welded attachment shall be selected for examination. The attachment selected for examination on one of the multiple vessels or the single vessel, as applicable, shall be an attachment under continuous load during normal system operation, or an attachment subject to a potential intermittent load (seismic, water hammer, etc.) during normal system operation if an attachment under continuous load does not exist.

Examine one of the welded attachments on one of the Residual Heat Exchangers.

Piping:

Item C3.20-Welded Attachments Examine 10% of the welded attachments associated with the component supports selected for examination under IWF-251 0.

Pumps:

Item C3.30-Welded Attachments Not applicable to Turkey Point Units 3 and 4.

Valves:

Item C3.40-Welded Attachments Not applicable to Turkey Point Units 3 and 4.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 4.2.4 Category C-D, Pressure Retaining Bolting > 2 in. (50 mm) in Diameter Pressure Vessels:

Item C4.10-Bolts and Studs Not applicable to Turkey Point Units 3 and 4.

Piping:

Item C4.20-Bolts and Studs Not applicable to Turkey Point Units 3 and 4.

Pumps:

Item C4.30-Bolts and Studs Not applicable to Turkey Point Units 3 and 4.

Valves:

Item C4.40-Bolts and Studs Not applicable to Turkey Point Units 3 and 4.

4.2.5 Category C-F-i, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping Item C5.10-Piping welds > 3/8 in. (10 mm) nominal wall thickness for piping greater NPS 4 (DN 100).

C5.11-Circumferential Weld Item C5.20-Piping welds > 1/5 in. (5 mm) nominal wall thickness for piping >

NPS 2 (DN 50) and < NPS 4 (DN 100)

C5.21-Circumferential Weld Item C5.30-Socket Welds Item C5.40-Pipe branch connections of branch piping > NPS 2 (DN 50)

C5.41-Circumferential Welds Examine 7.5%, but not less than 28 welds, of all dissimilar metal, austenitic stainless steel or high alloy welds not exempted by IWC-1 220. The welds to be examined shall be distributed among the systems in a manner such that a representative sample of each system and size is selected. Welds that are not exempted by IWC-1 220, but are not required to be nondestructively examined per Category C-F-1 are listed as C-F-3 within the 5th Interval ISI-PTN-3/4-Program Plan. The weld population of C-F-1 and C-F-3 are added together and multiplied by 7.5% to determine the number of required examinations.

Longitudinal welds are examined in accordance with Notes 5 and 6 in Table IWC-2500-1 for this examination category.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 4.2.6 Category C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping Item C5.50-Piping welds > 3/8 in. (10 mm) nominal wall thickness for piping >

NPS 4 (DN 100)

C5.51-Circumferential Weld Item C5.60-Piping welds > 1/5in. (5 mm) nominal wall thickness for piping >

NPS 2 (DN 50) and < NPS 4 (DN 100)

C5.61-Circumferential Weld Item C5.70-Socket Welds Item C5.80-Pipe branch connections of branch piping > NPS 2 (DN 50)

C5.81-Circumferential Weld Examine 7.5%, but not less than 28 welds, of all dissimilar metal, austenitic stainless steel or high alloy welds not exempted by IWC-1 220. The welds to be examined shall be distributed among the systems in a manner such that a representative sample of each system and size is selected. Welds that are not exempted by IWC-1 220, but are not required to be nondestructively examined per Category C-F-2 are listed as C-F-4 within the 5th Interval ISI-PTN-3/4-Program Plan and Schedule. The weld population of C-F-2 and C-F-4 are added together and multiplied by 7.5% to determine the number of required examinations.

Longitudinal welds are examined in accordance with Notes 6 and 7 in Table IWC-2500-1 for this examination category.

4.2.7 Category C-F-3 Those welds in Examination Category C-F-1 that are in piping < 3/8 in. thick for piping > NPS 4 or piping < 1/5 in. thick for piping > NPS 2 and < NPS 4 are excluded from examination per Table IWB-2500-1. These welds that are not exempt, but are excluded by the requirements of Examination Category C-F-1 are counted as part of the selection criteria. These welds have been given the Examination Category of C-F-3 and are for counting purposes only. No examinations are required.

4.2.8 Category C-F-4 Those welds in Examination Category C-F-2 that are in piping < 3/8 in. thick for piping > NPS 4 or piping < 1/5 in. thick for piping > NPS 2 and < NPS 4 are excluded from examination per Table WB-2500-1. These welds that are not exempt, but are excluded by the requirements of Examination Category C-F-2 are counted as part of the selection criteria. These welds have been given the Examination Category of C-F-4 and are for counting purposes only. No examinations are required.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 4.2.9 Category C-H, All Pressure Retaining Components Item C7. 10-Pressure Retaining Components The pressure retaining components within the Class 2 system boundaries are subjected to system leakage tests in accordance with IWC-5220 and visually examined per IWA-5240.

5.0 Development of the Class 3 Examination Plan Plant controlled isometric, P&IDs, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.

Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.

In accordance with IWD-1210, the examination requirements of Subsection IWD apply to those pressure retaining components and their welded attachments on Class 3 systems in support of the following functions:

(a) reactor shutdown (b) emergency core cooling (c) containment heat removal (d) atmosphere cleanup (e) reactor residual heat removal (f) residual heat removal from spent fuel storage pool 5.1 Class 3 Code Exemptions The following Class 3 exemption criteria are applicable. Article IWD-1220 of ASME Section Xl, 2007 Edition with Addenda through 2008 lists those piping and components exempt from examination.

5.1.1 IWD-1 220 - Components Exempt from Examination The following components or portions of components are exempted from the VT-1 visual examination requirements of IWD-2500:

(a) components and piping segments NPS 4 (DN100) and smaller.

(b) components and piping segments which have one inlet and one outlet, both of which are NPS 4 (DN 100) and smaller.

(c) components 1 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4 (DN 100) pipe.

(d) components that operate at a pressure of 275 psig (1900kPa) or less and at a temperature of 2000 F (950 C) or less in systems (or portions of systems) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 (e) welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

Note 1: For heat exchangers, the shell side and tube side may be considered separate components.

The following Class 3 systems are exempt from the surface and volumetric requirements other than size:

Table 7A Unit 3 Class 3 Exempt Components Component/Piping System Exemption Criteria From Spent Fuel Pool through Pump 3P212A and 3P212B through Spent Fuel Pool Heat Exchanger IWD-1220(d) 3E208A and 3E208B back to spent fuel pool Note: Unit 3 Emergency diesel lines are exempt due to size Table 7B Unit 4 Class 3 Exempt Components Component/Piping System Exemption Criteria From Spent Fuel Pool through Pump 4P212A and 4P212B through Spent Fuel Pool Heat Exchanger IWD-1220(d) 4E208A and 4E208B back to spent fuel pool Radiator lines from the Unit 4 Emergency Diesels IWD-1220(d) to the radiators 5.1.2 IWD-5222(c) System Leakage Test Exclusions (c) The following portions of system are excluded from system leakage test examination requirements:

(1) items outside the boundaries of IWD-5222(a)

(2) items outside the boundaries of IWD-5222(b)

(3) open-ended discharge piping that is not periodically pressurized to conditions described in IWD-5221 (4) portions of systems that are associated with a spray header or are normally submerged in its process fluid such that the external surfaces of the pressure-retaining boundary are normally wetted during its pressurized conditions 5.2 Component Examination Basis This section describes each Examination Category. The required percentage of examinations and any limitations for each Examination Category is described. All other requirements are found in ASME Section Xl, 2007 Edition with Addenda through 2008.

The Summary Tables located in 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule satisfy the requirements of IWA-2420(b)(1) through (6) respectively.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 A narrative discussion of Class 3 components subject to examination and testing are described in detail below:

5.2.1 Category D-A, Welded Attachments for Vessels, Piping, Pumps, and Valves Each welded attachment will receive a visual (VT-1) examination of 100% of required areas of each welded attachment. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, Inservice Inspection, or testing. Examinations performed as a result of support deformation cannot be credited under the requirements of the Inspection Program.

Pressure Vessels:

Item D 1.10-Welded Attachments For multiple vessels of similar design, function and service, only one of the welded attachments of only one of the multiple components requires examination. For single vessels, only one welded attachment shall be selected for examination. The attachment selected for examination on one of the multiple vessels or the single vessel, as applicable, shall be an attachment under continuous load during normal system operation, or an attachment subject to a potential intermittent load (seismic, water hammer, etc.) during normal system operation if an attachment under continuous load does not exist.

Piping:

Item Dl.20-Welded Attachments The percentage sample shall be proportional to the total number of nonexempt welded attachments connected to the piping in each system subject to examination. Examine 10% of the welded attachments.

Pumps:

Item Dl.30-Welded Attachments Not applicable to Turkey Point Units 3 and 4.

Valves:

Item D1.40-Welded Attachments Not applicable to Turkey Point Units 3 and 4.

5.2.2 Category D-B, All Pressure Retaining Components Item D2. 10-Pressure Retaining Components A system leakage test (IWD-5220) shall be performed during each inspection period.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 6.0 IWE Metal Containment Requirements The requirements for Code Class MC (Metal Containment) are found in the Turkey Point Containment Building Metal Containment Inservice Inspection Program, which is administered separately (Reference paragraph 1.2.6). The 2nd Interval-IWE-PTN-3/4-Program Plan establishes the administrative, managerial, and implementation control for the IWE Containment Inspection Program Plan.

7.0 Development of Component Supports Examination Plan Plant controlled isometric, P&IDs, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.

Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.

7.1 Code Exemptions for Supports Under IWF-1 230, component supports exempt from the examination requirements of IWF-2000 are those connected to piping and other items exempted from volumetric, surface, or VT-1 or VT-3 visual examination by IWB-1 220, IWC-1 220, IWD-1 220, and IWE-1220. In addition, portions of supports that are inaccessible by being encased in concrete, buried underground, or encapsulated by guard pipe are also exempt from the examination requirements of IWF-2000.

7.2 Support Examination Basis This section describes Examination Category F-A. The required percentage of examinations and any limitations is described. All other requirements are found in ASME Section Xl, 2007 Edition with Addenda through 2008. The Summary Tables located in 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule satisfy the requirements of IWA-2420(b)(1) through (6) respectively.

A narrative discussion of F-A supports subject to examination and testing is described in detail below:

7.2.1 Category F-A, Supports Item F1.10-Class 1 Piping Supports Examine 25% of Class 1 piping supports. The total percentage sample shall be comprised of supports from each system (e.g., Main Steam, Feedwater, or RHR), where the individual sample sizes are proportional to the total number of nonexempt supports of each type and function within each system.

Item F1.20-Class 2 Piping Supports Examine 15% of Class 2 piping supports. The total percentage sample shall be comprised of supports from each system (e.g., Main Steam, Feedwater, or RHR), where the individual sample sizes are proportional to the total number of nonexempt supports of each type and function within each system.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Item F1.30-Class 3 Piping Supports Examine 10% of Class 3 piping supports. The total percentage sample shall be comprised of supports from each system (e.g., Main Steam, Feedwater, or RHR), where the individual sample sizes are proportional to the total number of nonexempt supports of each type and function within each system.

Item F1.40-Supports Other Than Piping Supports (Class 1, 2, 3, and MC)

Examine the supports of only one of the multiple components within a system of similar design, function, and service.

7.2.2 Item Numbers Item numbers will be categorized to identify support types by component support function.

A - Single Acting Restraints or Hangers B - Double Acting Restraints C - Spring Hangers and Supports D - Anchors P - Pumps S - Snubbers T - Tanks V - Vessels (includes Heat Exchangers)

W - Welded Stanchions Other codes may be used as necessary.

Several supports hold more than one classified line. These supports are counted only once and if scheduled for examination, will cover all of the applicable lines. The support will be counted once for credit.

7.3 Snubbers Snubbers are functionally tested under the Snubber Program, which is administered separately. The requirements for the snubber program are included in 0-OSP-1 05.1.

Visual, VT-3, examinations are performed on snubbers (pin-to-pin) as required by the OM Code, Subsection ISTD. Snubber attachment hardware (pin-to-pipe and pin-to-structure), including welded attachments, is also examined as part of the Snubber Program rather than under the ISI Program per ASME Section Xl, Subsection IWF.

This alternative is addressed in Relief Request #3. If welded attachments are present, they will be examined under the Class 1, 2, 3, F-A Examination Category, as applicable.

The welded attachments are tracked within the ISI program database.

8.0 IWL Concrete Containment Requirements The requirements for Code Class CC (Concrete Containment) are found in the Turkey Point Containment Building Concrete Containment Inservice Inspection Program, which is administered separately (Reference paragraph 1.2.7). 12-ISI/IWL-PTN-3/4 establishes the administrative, managerial, and implementation control for the IWL Containment Inspection Program Plan.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 9.0 Augmented and Other Programs This section identifies augmented inspection programs maintained within the ISI Program that are not required by ASME Section XI. However, due to the nature of the augmented requirements, these programs have been included within the ISI Program. These augmented programs satisfy NRC requirements, operating experience, engineering judgment, etc.

Augmented program revisions or deviations shall be governed by the referenced documents.

The following is the detailed description of the Turkey Point's Inservice Inspection Program Plan Basis for Augmented Examination of additional components/systems.

9.1 Class 1 9.1.1 Reactor Coolant Pump Flywheels As required by Plant Technical Specification 4.0.5, each Reactor Coolant Pump Flywheel shall be inspected at an interval not to exceed 20 years per the requirements of TSTF-421 and WCAP-15666. This examination shall be conducted by an in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle of one-half the outer radius, or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the disassembled flywheel. All RCP flywheels will be tracked for location and examination cycle in both Units 3 and 4 Inservice Inspection database by the RCP motor designation.

9.1.2 Management of Thermal Fatigue in Normally Stagnant Non-Isolable RCS Branch Lines (MRP-146)

This report provides needed guidelines and other good practice recommendations for evaluation and inspecting regions in normally stagnant PWR reactor coolant system branch lines where there may be potential for thermal fatigue cracking that could lead to leakage and forced plant outages.

Per the implementation protocol of the NEI 03-08 initiative, these guidelines are "needed" actions for PWR licensees.

9.1.3 Code Case N-729-1 -Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds, Section Xl, Division 1 10CFR50.55a(g)(6)(ii)(D) requires that Turkey Point augment the inservice inspection program by implementing ASME Code Case N-729-1 subject to the conditions specified in paragraphs 10CFR50.55a(g)(6)(ii)(D)(2) through (6).

For the replacement components installed during PTN 3/4-21, a base metal visual (BMV) examination is required every 3rd refueling outage or 5 years, whichever is less and a volumetric and/or surface examination is required of all nozzles not to exceed one (1) Inspection Interval (nominally 10 calendar years).

The first BMV examinations were performed in 2009 during cycles PTN3-24 and PTN4-25 and the first volumetric examinations were performed in 2014 during cycle PTN3-27 and PTN4-28. The next base metal visual (BMV) examination will be performed at a 5 year interval and the next volumetric examination will be performed at a 10 year interval. Reference FPL Engineering Evaluation PTN-ENG-SESJ-01-0058, Rev. 0.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 9.1.4 Code Case N-722 Additional Examinations for PWR Pressure Retaining Welds in Class 1 components Fabricated With Alloy 600/82/182 Materials, Section Xl, Division 1 10CFR50.55a(g)(6)(ii)(E) requires Turkey Point augment the inservice inspection program by implementing ASME Code Case N-722-1 subject to the conditions specified in paragraphs (g)(6)(ii)(E)(2) through (4). The inspection requirements of ASME Code Case N-722-1 do not apply to components with pressure retaining welds fabricated with Alloy 600/82/182 materials that have been mitigated by weld overlay or stress improvement.

9.1.5 Westinghouse Technical Bulletin TB-07-02 Rev. 2 As per Westinghouse Technical Bulletin TB-07-02, "Reactor Vessel Head Adapter Thermal Sleeve Wear", a visual examination is to be performed on the Reactor Head Thermal Sleeves where they protrude from the head adapter nozzle looking for wear. Turkey Point Units 3 and 4 are identified on Table 1 of TB-07-2 Rev. 1 as not having sufficient upper head cross flow to be susceptible to thermal sleeve wear. Plants that have replaced the reactor vessel closure head and are not susceptible to thermal sleeve wear have not accumulated sufficient operating time to sustain observable wear. A visual examination of the thermal sleeve adapter surface was performed in 2014 during cycles PTN3-27 and PTN4-28 in conjunction with the NRC required 10-year examination volumetric of the nozzle penetrations perASME Code Case N729-1. Although the Turkey Point heads are not susceptible to thermal sleeve wear, suggested guidance from Westinghouse to perform inspections after 120 months of service will be used.

9.1.6 WCAP-16913-P - Operability Assessment and Plant Applicability Evaluation for Pressurizer Heater Sleeve Leakage in Westinghouse Designed Pressurizers This report provides "needed" requirements necessary to address the potential for primary coolant leakage from pressurizer heater sleeves as the result of circumferentially oriented stress corrosion cracking, which could result in heater sleeve ejection if not detected before the cracks reach the critical flaw size.

Each PWR with stainless steel heater sleeves is required to conduct a visual inspection (VT-2 in accordance with IWA-2212 of Section Xl of the ASME Code) of the visible, without removal of insulation, portion of all heater sleeves and adjacent and nearby insulation for evidence of primary coolant leakage of all heater sleeves each refueling outage after January 1, 2010. Per the implementation protocol of the NEI 03-08 initiative, these guidelines are "needed" actions for PWR licensees.

9.1.7 Pressurizer Surge Line During the fifth interval the piping welds in the pressurizer surge line will undergo augmented examinations in order to meet license renewal aging management commitments. In accordance with Engineering Evaluation PTN-ENG-SECS-12-027, Aging Management Program PTN-ENG-LRAM 0055 and the NRC Safety Evaluation Report dated May 29, 2013 (ML13141A595 and TAC NOS. ME8717 AND ME8718), all of the piping 52 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 welds in the pressurizer surge line will undergo both volumetric and surface examinations during the interval. This includes five (5) piping welds in Turkey Point Unit 3 and seven (7) piping welds in Turkey Point Unit 4.

9.2 Class 2 9.2.1 NRC Bulletin 79-13 Augmented Feedwater Examinations, as a result of a continuation of NRC Bulletin 79-13, and NRC Informational Notice 93-20, Thermal Fatigue Cracking of Feedwater Piping to Steam Generators.

Turkey Point Units 3 and 4 will perform a continuous enhanced ultrasonic examination starting at the Feedwater Nozzle ramp and extending out to a point of 1 diameter on the elbow. Examinations will be performed in conjunction with the Code examination schedule as identified in the summary tables located in 5 th Interval-ISI-PTN-3-Schedule and 5 th Interval-ISI-PTN-4-Schedule..

9.2.2 Assessment of RHR Mixing Tee Thermal Fatigue in PWR Plants (MRP-192)

This report provides "good practice" recommendations for evaluation and inspecting all PWR RHR mixing tee welds within at least four internal pipe diameters downstream from the mixing tee junction point, including the mixing tee downstream weld where there may be potential for thermal fatigue cracking that could lead to leakage and forced plant outages. Per the implementation protocol of the NEI 03-08 initiative, these guidelines are "good practice" actions for PWR licensees. PTN performed examinations to satisfy the requirements during PTN3-24(March 2009) and PTN4-25(November 2009). The evaluation included in CR 2008-18112 (AR 450452450452 that future examinations will be performed every 7 years, Per AR 1669062, PM 043358 (WO 40123893) and PM 048453 (W04012389) has been initiated to schedule the exams.

10.0 Evaluation/Acceptance Criteria Florida Power and Light will perform non-destructive examinations using visual, surface (Penetrant and Magnetic Particle), and volumetric (Ultrasonic, Radiography, and Eddy Current) techniques. Other NDE techniques may be utilized when required.

During inservice inspections, NDE indications are evaluated against the acceptance standards of ASME Section XI. Components with indications that do not exceed the acceptance criteria will be considered acceptable for continued service. Additional examinations are not required.

Examinations that reveal indications shall be evaluated in accordance with article IWA-3000, IWB-3000, IWC-3000, IWD-3000 and IWF-3000, as applicable. Additional guidance for conditions identified during component support examinations, including minimum thread engagement acceptability, is located in engineering discipline standard STD-C-01 1.

10.1 Supplemental Examinations Examinations that detect flaws/conditions that require evaluation in accordance with the requirements of IWB-3100, IWC-3100 or IWF-3100, may be supplemented by other 53 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 examination methods and techniques within the limits specified by IWB-3200, IWC-3200 or IWF-3200.

10.2 Additional Examinations Examinations that reveal flaws or relevant conditions that exceed the referenced acceptance standard, shall be extended to include additional examinations during the current outage. The additional examination requirements of IWB-2430, IWC-2430, IWD-2430, or IWF-2430, (as applicable) shall be performed as determined by Nuclear Engineering.

10.3 Successive Inspections for Components Where components are accepted for continued service by analytical evaluation, IWB-2420(b), IWC-2420(b), IWD-2420(b) and IWF-2420(b), the area containing the flaws or component support shall be subsequently reexamined in accordance with the following; 10.3.1 Class 1 Components [IWB-2420(b)]

If a component is accepted for continued service in accordance with IWB-3132.3 or IWB-3142.4, the areas containing flaws or relevant conditions shall be reexamined during the next three inspection periods listed in the schedule of the Inspection Program of IWB-2400. Provided the flaws or relevant conditions remain essentially unchanged for three successive inspection periods, the component examination schedule will revert to the original schedule of successive inspections.

10.3.2 Class 2 Components [IWC-2420(b)]

If a component is accepted for continued service in accordance with IWC-3122.3 or IWC-3132.3, the areas containing flaws or relevant conditions shall be reexamined during the next inspection period of listed in the schedule of the Inspection Program of IWC-2400. Provided the flaws or relevant conditions remain essentially unchanged for the next inspection period, the inspection schedule will revert to the original schedule of successive inspections.

10.3.3 Class 3 Components [IWD-2420(b)]

If a component is accepted for continued service in accordance with IWD-3000, the areas containing flaws or relevant conditions shall be reexamined during the next inspection period of listed in the schedule of the Inspection Program of IWD-2400. Provided the flaws or relevant conditions remain essentially unchanged for the next inspection period, the inspection schedule will revert to the original schedule of successive inspections.

10.3.4 Component Supports [IWF-2420(b)]

If a component support is accepted for continued service in accordance with IWF-3112.2 or IWF-3122.2, the component support shall be reexamined during the next inspection period listed in the schedule of the Inspection Program of IWF-2410. Provided the examinations do not require additional corrective measures during the next inspection period, the inspection schedule will revert to the original schedule of successive inspections.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 11.0 Repair/Replacement Activities The requirements of ASME Section Xl, 2007 Edition with Addenda through 2008, ASME Section XI, 2001 Edition with Addenda through 2003 and the Repair and Replacement Program for Turkey Point Nuclear Plant shall be met for Class 1, 2, and 3 piping, Class MC, Class CC, and components and their supports, as applicable. Specific requirements for the repair, replacement, or modification of ISI components are detailed in 0-ADM-532, ASME Section Xl Repair/Replacement Program.

12.0 Relief Requests A relief request is required when there is situations where Code requirements cannot be met or where an alternative is desired. Relief Requests shall be prepared using the NEI guidance for the standard format for requests from commercial reactor licenses pursuant to 10CFR50.55a.

Relief requests will be reviewed for completeness, technical adequacy, and implementation.

Reviewers may be the site ISI Coordinators, the ISI Specialist, NDE personnel, and any other group the relief request may affect. Typical examples where relief requests are submitted are as follows:

12.1 For Class 1 and 2 weld examinations, relief is required if 90% or less of the Code required coverage were achieved (if unable to meet Code examination requirements).

12.2 The request for use of an alternative to a requirement listed within ASME Section Xl. An example is the use of a Code Case that has not been approved for use by the latest revision of NRC Reg. Guide 1.147.

13.0 Boundary Classifications The code required boundaries for all Class 1, 2, and 3 systems are denoted by a boxed-in letter (A, B, and C respectively) on Piping and Instrument Diagrams (P&IDs). The following list shows those P&IDs applicable to the Turkey Point ISI Program Plan. As a general rule, 5610 series drawings are common between units, 5613 series are for Unit 3 and 5614 series are for Unit 4.

Table 8: Units 3/4 Boundary Classification Drawings Drawing Number Sheet P & ID Title S~~~~Numbers P&I il 5613-M-3018 1 Condensate Storage System 5614-M-3018 1 Condensate Storage System 5613-M-3019 1 thru 2 Intake Cooling Water System 5614-M-3019 1 thru 2 Intake Cooling Water System 5614-M-3022 1 thru 6 Emergency Diesel and Oil System 5613-M-3030 1 thru 5 Component Cooling Water System 5614-M-3030 1 thru 4 Component Cooling Water System 5613-M-3033 1 Spent Fuel Pool Cooling System 5614-M-3033 1 Spent Fuel Pool Cooling System 5613-M-3036 1 Reactor Coolant System 5614-M-3036 1 Reactor Coolant System 5613-M-3041 1 thru 4 Reactor Coolant System 5614-M-3041 1 thru 4 Reactor Coolant System 55 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Table 8: Units 3/4 Boundary Classification Drawings Drawing Number Sheet P & ID Title Numbers P&I il 5610-M-3046 1 Chemical and Volume Control System 5613-M-3047 1 thru 3 CVCS - Charging, Letdown & RCP seal 5614-M-3047 1 thru 3 CVCS - Charging, Letdown & RCP Seal 5613-M-3050 1 Residual Heat Removal System 5614-M-3050 1 Residual Heat Removal System 5613-M-3056 1 Containment Emergency Filter System 5614-M-3056 1 Containment Emergency Filter System 5613-M-3062 1, 2 Safety Injection System 5614-M-3062 1, 2 Safety Injection System 5613-M-3064 1 Safety Injection Accumulator System (CTMT) 5614-M-3064 1 Safety Injection Accumulator System (CTMT) 5613-M-3068 1 Containment Spray System 5614-M-3068 1 Containment Spray System 5613-M-3072 1, 3 Main Steam System 5614-M-3072 1, 3 Main Steam System 5613-M-3074 3, 4 Feedwater System 5614-M-3074 3, 4 Feedwater System 5613-M-3075 1, 2 Auxiliary Feedwater System 5614-M-3075 1, 2 Auxiliary Feedwater System 5610-M-3075 1 Auxiliary Feedwater System - Turbine Drive for Auxiliary Feedwater Pumps 5610-M-3075 2 Auxiliary Feedwater System - Auxiliary Feedwater Pumps 14.0 Addition of Welds, Components, and Components Supports The rules for selection and scheduling of examinations for new welds shall be in accordance with paragraphs IWB-2411 (b), IWC-2411 (b), IWD-2411 (b) and IWF-241 0(c).

15.0 Records 15.1 General Records of Inservice Inspection Program Plan, Schedules, outage schedules, calibration standards, examination and test procedures, results of activities, final reports, certifications, and corrective actions will be developed and maintained in accordance with IWA-6000.

15.2 Nondestructive Examinations Completed NDE examination data packages shall be submitted to the ISI Program owner following completion of the inservice examination activity.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5t Interval-ISI-PTN-3/4-Program Plan January 21, 2015 15.3 Reports 15.3.1 Reports/documents will be generated for the following activities:

(a) Nondestructive examination activities performed on Class 1, 2, and 3 systems, components and their supports (b) Nondestructive examination activities performed on Class MC and CC systems (c) Snubber examinations and tests (d) System pressure tests (e) Repairs and replacements 15.3.2 The final reports shall contain, as a minimum, the information required to support submittal of the NIS-1 or OAR-1 (Code Case N-532-5 as modified by NRC Reg. Guide 1.147).

15.4 Inservice Inspection Summary Report FPL shall forward a summary report, NIS-1 or OAR-i, of the ISI activity to the Nuclear Regulatory Commission in accordance with IWA-6230 or Code Case N-532-5 (as modified by NRC Reg. Guide 1.147), as applicable.

15.5 NIS-2 or NIS-2A Reports NIS-2 forms, or ifCode Case N-532-5 is followed, a NIS-2A form, will be completed for each repair or replacement.

16.0 References The Inservice Inspection Program Plan for Class 1, 2, and 3 (or Quality Groups A, B, and C respectively) systems and components and supports, was developed after reviewing the following documents and procedures. Limitations of design, geometry, and materials of construction may have an impact on the implementation of some of these documents.

16.1 10 CFR 50.55(a) Code of Federal Regulations.

16.2 American Society of Mechanical Engineers (ASME) Section Xl Code, 2007 Edition with Addenda through 2008.

16.3 American Society of Mechanical Engineers (ASME) Section Xl Code, 1998 Edition.

16.4 USNRC Regulatory Guide 1.26 - Quality Group Classifications and standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants, Revision 3, dated February 1976.

16.5 USNRC Regulatory Guide 1.147 - Inservice Inspection Code Case Acceptability ASME Section XI.

16.6 USNRC Regulatory Guide 1.178 - An Approach for Plant-Specific Risk Informed Decision Making Inservice Inspection of Piping.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 16.7 USNRC Regulatory Guide 1.193 -ASME Code Cases Not Approved for Use.

16.8 USNRC Bulletin 88-11, Pressurizer Surge Line Thermal Stratification.

16.9 USNRC Bulletin 79-13, Cracking in Feedwater System Piping.

16.10 USNRC Information Notice 93-20, Thermal Fatigue Cracking of Feedwater Piping to Steam Generators, dated March 24, 1993.

16.11 Nondestructive Evaluation: Performance Demonstration Initiative (PDI) Comparison to ASME Section Xl, Appendix Viii 2007 Edition with 2008 Addendum and 10CFR50.55a, Year 2011. EPRI, Palo Alto, CA 2012 1026510.

16.12 Branch Technical Position MEB 3-1, High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment.

16.13 Branch Technical Position APCSB 3.1. Paragraph B.2c (4).

16.14 First, Second, Third, and Fourth Interval Inservice Inspection Long Term Programs, Plans, and Schedules for Turkey Point Units 3 & 4.

16.15 Turkey Point's Units 3 & 4 Update Final Safety Analysis Report.

16.16 Turkey Point Technical Specifications, Docket number 50-250 for Unit 3 and 50-251 for Unit 4.

16.17 STD-C-01 1, "Acceptance Criteria for As-Built Safety Related Piping and Pipe Supports,"

and Specification SPEC-M-004, "Maintenance Bolting Specification for St. Lucie Units 1 and 2 and Turkey Point Units 3 and 4."

16.18 Generic Aging Lessons Learned (GALL) Report.

16.19 Turkey Point Document- QI-11-PTN-4, "ASME Section Xl Tests."

16.20 Turkey Point Document- 0-OSP-105.1, "Visual Inspection, Removal and Reinstallation of Mechanical Shock Arrestors."

16.21 Turkey Point Document ADM-532, "ASME Section Xl Repair/Replacement Program."

16.22 Turkey Point Document ADM-523, "ASME Section XI Pressure Test for Quality Group A, B, C Systems/Components."

16.23 Engineering QI - ENG-QI 5.2, "Implementation of ASME Section Xl (Inservice Inspection)."

16.24 Turkey Point Units 3 & 4 Design Basis Document, 5610-000-DBD-001, "Selected Licensing and Issues (SL1)",Section XVIII, Latest Revision.

16.25 Procedure - EN-AA-1 06, "Renewed License Program' 58 of 60

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 16.26 Engineering Evaluation PTN-ENG-LRAM-00-0041, latest revision, "Reactor Vessel Integrity Program - License Renewal Basis Document."

16.27 Engineering Evaluation PTN-ENG-LRAM-00-0044, latest revision, "ASME Section Xl, Subsections IWB, IWC and IWD Inservice Inspection Program Plan - License Renewal Program Basis Document."

16.28 Engineering Evaluation PTN-ENG-LRAM-00-0027, latest revision, "ASME Section Xl, Subsection IWF Inservice Inspection Program Plan -License Renewal Program Basis Document."

16.29 Engineering Evaluation PTN-ENG-LRAM-00-0037, "Reactor Vessel Integrity Program -

License Renewal Basis Document."

16.30 Procedure - ER-SR-107, "Alloy 600 Management Program".

16.31 MRP-146- "Materials Reliability Program: Management of Thermal Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines (MRP-146, Revision 1)",

EPRI, Palo Alto, CA: 2011. 1022564.

16.32 Nuclear Energy Institute NEI 04-05, "Living Program Guidance to Maintain Risk-Informed Inservice Inspection Programs for Nuclear Plant Piping Systems", April 2004.

16.33 MRP-192 - "Materials Reliability Program: Assessment of RHR Mixing Tee Thermal Fatigue in PWR Plants (MRP-1 92, Revision 1)", EPRI, Palo Alto, CA: 2008. 1018395.

16.34 Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement Regarding Extension of Reactor Coolant Pump Motor Flywheel Examination for Westinghouse Plants Using the Consolidated Line Item Improvement Process, published October 22, 2003 (68 FR 60422).

16.35 Federal Register Notice: Notice of Opportunity of Comment on Model Safety Evaluation on Technical Specification Improvement Regarding Extension of Reactor Coolant Pump Motor Flywheel Examination for Westinghouse Plants Using the Consolidated Line Item Improvement Process, published June 24, 2003 (68 FR 37590).

16.36 Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-421, "Revision to RCP Flywheel Inspection Program (WCAP-15666)", Revision 0, November 2001.

16.37 WCAP 15666 - "Extension of Reactor Coolant Pump Motor Flywheel", dated July, 2001.

16.38 NRC letter dated May 5, 2003, from H. Berkow to R. Bryan (WOG) transmitting Safety Evaluation of WCAP-1 5666.

16.39 Letter to Mr. Angelo Giambusso of the Atomic Energy Commission, February 22, 1973, from Florida Power & Light and Letter to Dr. James Coughlin of Florida Power & Light, April 2, 1973, from Mr. Angelo Giambusso of the Atomic Energy Commission.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 16.40 WCAP-16913-P, Revision 1 "Operability Assessment and Plant Applicability Evaluation for Pressurizer Heater Sleeve Leakage in Westinghouse Designed Pressurizers" April 2009, PA-MSC-0316.

16.41 Turkey Point Document 2 nd Interval IWE-PTN-3/4-Program Plan, "ASME Section Xl, Subsection IWE, Containment Building Metal Containment Inservice Inspection Program for Turkey Point Units 3 and 4."

16.42 Turkey Point Document 12-1SI-IWL-PTN-3/4, "ASME Section Xl, Subsection IWL Interval 2, Concrete Containment Inservice Inspection Program for Turkey Point Units 3 and 4."

16.43 Procedure - ER-AA-1 18, "ASME Section Xl Inservice Inspection Program". Fleet Inservice Inspection Program.

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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Appendix A Relief Requests Al

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Table 9 Relief Requests Relief Request Description Status Number Safety Evaluation 1 Repair of Pressurizer Stainless Steel Heater Sleeve Approved Without Flaw Removal October 9, 2014 (18 Month Approval) 2 Alternative Examinations for Regenerative Heat In course of Exchanger preparation In course on of 3 Examination of Snubber Attachment Hardware prep preparation A2

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Relief Request No. 1 Unit 3 Only "REPAIR OF PRESSURIZER STAINLESS STEEL HEATER SLEEVE WITHOUT FLAW REMOVAL" Relief Request 1 has been approved by SER dated October 9, 2014 (18-Month Approval until Fall 2015)

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 9, 2014 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division Florida Power & Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT NUCLEAR GENERATING UNIT NO. 3 - SAFETY EVALUATION FOR RELIEF REQUEST NO. I FOR FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL - REPAIR OF PRESSURIZER STAINLESS STEEL HEATER SLEEVE WITHOUT FLAW REMOVAL (TAC NO. MF3834)

Dear Mr. Nazar:

By letter dated April 4, 2014, as supplemented by letters dated April 9, and April 14, 2014, Florida Power & Light Company (the licensee) submitted Relief Request No. 1 for the fifth 10-year inservice inspection interval of Turkey Point Nuclear Generating Unit No. 3 (Turkey Point 3). Pursuant to Title 10 of the Code of FederalRegulations (10 CFR),

Part 50, Section 55a(a)(3)(ii), the licensee requested the U.S. Nuclear Regulatory Commission (NRC) to authorize an alternative to the requirements of 10 CFR 50.55a(g)(4) because compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

During the Turkey Point 3 refueling outage that began in March 2014, the licensee observed evidence of leakage in the annulus between the outer surface of one heater sleeve and the pressurizer bottom head bore. The licensee requested NRC authorization of a proposed alternative to the American Society of Mechanical Engineers (ASME) Code,Section XI, 2007 Edition with Addenda through 2008, subparagraph IWB-3142.3, "Acceptance by Corrective Measures or Repair/Replacement Activity," which states that a component containing relevant conditions is acceptable for continued service if the relevant conditions are corrected by a repair/replacement activity or by corrective measures to the extent necessary to meet the acceptance standards of Table IWB-3410-1. The licensee's proposed alternative was to relocate the pressure boundary weld to the outside of the pressurizer bottom head shell and, thus, leave the flaw that caused the leakage in place. The licensee requested relief for one 18-month operating cycle.

The licensee requested the NRC to authorize the proposed alternative to support placing the pressurizer back in service for entry into Mode 4 from the Turkey Point 3 spring 2014 refueling outage. By electronic mail dated April 8, and April 10, 2014, the NRC staff requested additional information. During a conference call with the licensee on April 15, 2014, the NRC verbally authorized the licensee's use of Relief Request No. 1 for Turkey Point 3 for that unit's next 18-month operating cycle. The NRC staff's follow-up written safety evaluation is enclosed.

Relief Request 1 Al of A44

M. Nazar The NRC staff reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that complying with the requirements of subparagraph IWB-3142.3 would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety and that the licensee adequately addressed all regulatory requirements in 10 CFR 50.55a(a)(3)(ii). Accordingly, the NRC staff authorizes Relief Request No. 1 at Turkey Point 3 for that unit's current 18-month operating cycle.

All other ASME Code,Section XI requirements for which relief was not specifically requested and authorized in Relief Request No. 13 remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

If you have any questions regarding this issue, please contact the project manager, Ms. Audrey Klett, at (301) 415-0489 or by e-mail at Audrev.Klett(nrc.gov.

Sincerely, Lisa M. Regner, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-250

Enclosure:

Safety Evaluation cc w/encl.: Distribution via Listserv Relief Request 1 A2 of A44

, NUCLEAR REGULATORY UNITED STATESCOMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. 1 FOR THE FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-250

1.0 INTRODUCTION

By letter dated April 4, 2014,1 as supplemented by letters dated April 9, and April 14, 2014,2 Florida Power & Light Company (the licensee) submitted Relief Request No. 1 for the fifth 10-year inservice inspection (ISI) interval of Turkey Point Nuclear Generating Unit No. 3 (Turkey Point 3). Pursuant to Title 10 of the Code of FederalRegulations (10 CFR),

Part 50, Section 55a(a)(3)(ii), the licensee requested the U.S. Nuclear Regulatory Commission (NRC) to authorize an alternative to the requirements of 10 CFR 50.55a(g)(4) because compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

During the Turkey Point 3 refueling outage that began in March 2014, the licensee observed evidence of leakage in the annulus between the outer surface of one heater sleeve and the pressurizer bottom head bore at Heater Penetration No. 11. The licensee requested NRC authorization of a proposed alternative to the American Society of Mechanical Engineers (ASME) Code,Section XI, 2007 Edition with Addenda through 2008, subparaglraph IWB-3142.3, "Acceptance by Corrective Measures or Repair/Replacement Activity," which states that a component containing relevant conditions is acceptable for continued service if the relevant conditions are corrected by a repair/replacement activity or by corrective measures to the extent necessary to meet the acceptance standards of Table IWB-3410-1. The licensee's proposed alternative was to perform a "half-nozzle" repair that relocates the pressure boundary weld to the outside of the pressurizer bottom head shell and, thus, leave the flaw that caused the leakage in place, which was assumed to exist in the original J-groove weld attaching the heater sleeve to the pressurizer cladding. The licensee requested relief for one 18-month operating cycle.

1Agencywide Documents Access and Management System (ADAMS) Accession No. ML14098A036.

2 ADAMS Accession Nos. ML14101A366 and ML14106A603, respectively.

3As defined in the Preface to the ASME Code, Section X1, under "Organization of Section Xl," all references beginning with IWA- or IWB- are to parts of the ASME Code,Section XI. Numbers ending in units of 1000 refer to "Articles," units of 100 are "Subarticles," units of 10 are "Subsubarticles," units of 1 are "Paragraphs," and units of .1 are "Subparagraphs."

Relief Request 1 Enclosure A3 of A44

The licensee requested the NRC to authorize the proposed alternative to support placing the pressurizer back in service for entry into Mode 4 from the Turkey Point 3 spring 2014 refueling outage. By electronic mail (email) dated April 8, and April 10, 2014,4 the NRC staff sent the licensee requests for additional information (RAIs). By letters dated April 9 and April 14, 2014, the licensee responded to the NRC staff's requests. During a conference call with the licensee on April 15, 2014, the NRC verbally authorized the licensee's use of Relief Request No. I for Turkey Point 3 for that unit's 18-month operating cycle that began after the spring 2014 refueling outage.5

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(3)(ii), the licensee proposed an alternative to 10 CFR 50.55a(g)(4) - specifically to the ASME Code,Section XI, subparagraph IWB-3142.3.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. Pursuant to 10 CFR 50.55a(g)(4)(i) and 10 CFR 50.55a(g)(4)(ii), inservice examination of components and system pressure tests conducted during the first and subsequent 10-year inspection intervals must comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein.

Pursuant to 10 CFR 50.55(a)(3)(ii), alternatives to the requirements of 10 CFR 50.55a(g) may be used when authorized by the Director of the NRC Office of Nuclear Reactor Regulation if compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on its regulatory and technical evaluations in this safety evaluation, the NRC staff concludes that the regulatory authority exists to authorize the licensee's proposed alternative on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff reviewed and evaluated the licensee's request pursuant to 10 CFR 50.55a(a)(3)(ii).

The code of record for the fifth 10-year ISI interval is the 2007 Edition with Addenda through 2008 of the ASME Code,Section XI, subject to the limitations and modifications in 10 CFR 50.55a(b).

4 ADAMS Accession Nos. ML14099A191 and ML14120A152, respectively.

5 The memorandum documenting the verbal relief request is dated April 16, 2014, and is available in ADAMS under Accession No. ML14106A050.

Relief Request 1 A4 of A44

3.0 TECHNICAL EVALUATION

3.1 Licensee's Proposed Alternative ASME Code Components Affected and Applicable Code Edition and Addenda The components for which the licensee sought proposed alternatives are the pressurizer and pressurizer heater sleeve nozzle No. 11. The pressurizer heater sleeve is internally welded to the pressurizer lower head cladding. The components are examination category B-P, "All Pressure Retaining Components," Code Item No. B15.10. The stainless steel SA-213 TP316 sleeve has a 1.125-inch nominal outside diameter and a 0.095-inch wall thickness. The pressurizer lower head base material (carbon steel) is SA-216 Grade WCC. The cladding is austenitic stainless steel. The original construction code for the pressurizer is the ASME Code,Section III, 1965 Edition, including Addenda through summer 1965, Class A. The code of record for the fifth 10-year ISI interval is the 2007 Edition with Addenda through 2008 of the ASME Code,Section XI, subject to the limitations and modifications in 10 CFR 50.55a(b).

ASME Code Requirement for Which Relief is Requested The licensee requested relief from the requirements of the ASME Code,Section XI, IWB-3142.3, "Acceptance by corrective Measures of Repair/Replacement Activity," which states that a component containing relevant conditions is acceptable for continued service if the relevant conditions are corrected by a repair/replacement activity or by corrective measures to the extent necessary to meet the acceptance standards of Table IWB-3410-1.

In its letter dated April 4, 2014, the licensee stated that visual examination of the Turkey Point 3 pressurizer heater sleeve penetrations during the spring 2014 refueling outage revealed evidence of leakage in the annulus between the outer surface of the heater sleeve and the pressurizer lower head bore at Heater Penetration No. 11. The licensee stated that it performed manual nondestructive examination (NDE) from the sleeve bore using eddy current testing (ECT) after the heater was removed from the heater sleeve. The licensee stated that the ECT examination did not reveal a flaw in the sleeve. Therefore, the licensee concluded the most likely location of the flaw is in the partial penetration stainless steel weld between the heater sleeve and the stainless steel cladding on the inside of the pressurizer bottom head.

In its letter dated April 4, 2014, the licensee stated that removal of the flaw would constitute a hardship because removal of a flaw in the partial penetration weld would require the licensee to perform work from inside the pressurizer, which would result in high personnel radiation dose, personnel safety hazards, and potential foreign material generation. The licensee repaired Heater Sleeve No. 11 using the "half-nozzle" method, which relocated the pressure boundary weld to the outside of the pressurizer bottom head. The licensee requested a proposed alternative to the requirements of the ASME Code,Section XI, IWB-3142.3 to leave the presumed flaw in place in the original weld.

Duration of Proposed Alternative In its letter dated April 4, 2014, the licensee requested to apply the proposed alternative for one 18-month fuel cycle. In its letter dated April 4, 2014, the licensee also stated that during the next fuel cycle, it will perform additional analyses to justify the revised configuration with the Relief Request 1 A5 of A44

postulated flaw(s) remaining in place for the current inspection interval for Turkey Point 3, which expires on February 21, 2024.

In its letter dated April 4, 2014, the licensee stated that there are no known precedents for pressurizer stainless steel heater sleeve leakage requiring repair. The licensee stated that there is a precedent for evaluating flaw growth in carbon steel and low alloy steel base material caused by fatigue and that is exposed to reactor coolant in the pressurizer environment. The licensee stated that the evaluation for that precedent is, "ATTACHMENT (6) UNIT 1 PRESSURIZER HEATER SLEEVE AS-LEFT J-GROOVE WELD FLAW EVALUATION FOR IDTB [Internal Diameter Temper Bead) REPAIR - NON-PROPRIETARY," dated May 11, 2011,6 which was for the Calvert Cliffs Nuclear Power Plant (CCNPP), LLC.

3.2 NRC Staff's Evaluation 3.2.1 Evaluation of Compliance with ASME Code Requirements The heater sleeves fall under examination category B-P; therefore, per IWB-2500, Table IWB-2500-1, they are subject to a VT-2 visual examination each refueling outage during the system leakage test conducted prior to plant startup. The table refers to IWB-3522 for acceptance standards, which states:

A component whose visual examination (IWA-5240) detects any of the following relevant conditions shall meet IWB-3142 and IWA-5250 prior to continued service:

a) any through-wall or through-weld, pressure retaining material leakage from insulated and non-insulated components; b) leakage in excess of limits established by the Owner from mechanical connections (such as pipe caps, bolted connections, or compression fittings) or from components provided with leakage limiting devices (such as valve packing glands or pump seals);

c) areas of general corrosion of a component resulting from leakage; d) discoloration or accumulated residues on surfaces of components, insulation, or floor areas that may be evidence of borated water leakage; or e) leakages or flow test results from buried components in excess of limits established by the Owner.

6ADAMS Accession No. ML11132A183.

Relief Request 1 A6 of A44

IWB-3142. 1(b) states:

A component whose visual examination detects the relevant conditions described in the standards of Table IWB-3410-1 shall be unacceptable for continued service, unless such components meet the requirements of IWB-3142.2, IWB-3142.3, or IWB-3142.4.

The licensee chose the option of IWB-3142.3 for acceptance with corrective measures or repair/replacement activities, which states that a component containing relevant conditions is acceptable for continued service if the relevant conditions are corrected by a repair/replacement activity or by corrective measures to the extent necessary to meet the acceptance standards of Table IWB-3410-1. The licensee implemented the repair in the form of a half-nozzle repair.

However, the licensee proposed an alternative to the Code requirements because the repair, while it will stop leakage and restore the pressure boundary integrity, will not remove the defect that caused the leak, which is presumed to be in the J-groove weld because itwas not found in the tube.

3.2.2 Evaluation of Hardship Because the flaw causing the leak is assumed to be in the original J-groove weld, removing the defect that caused the leak would require removing the original J-groove weld, which would have to be performed from inside the pressurizer. In its letter dated April 4, 2014, the licensee stated that removing the heater sleeve-to-pressurizer weld requires accessing the internal surface of the pressurizer and removing the weld and remaining sleeve base material. Such an activity would result in high radiation exposure to the personnel involved, which is considered a hardship. The licensee also stated that grinding and/or machining within the components would also expose personnel to safety hazards and could introduce foreign material in the pressurizer that could later affect fuel performance.

The NRC staff concludes that removing the original weld would result in a hardship to the licensee because of the radiation exposure to personnel, personnel safety hazards, and foreign material risk. The benefit to be gained with respect to safety from removing the original J-groove weld does not compensate for the hardship because, based on experience with similar half-nozzle repairs on similar nozzle configurations, there has never been a case of unacceptable flaw growth into the vessel. Therefore, in this case, the NRC staff concludes that to comply with the ASME Code requirement would constitute a hardship without a compensating increase in safety.

3.2.3 Evaluation of Leak Tightness and Structural Integrity The licensee requested relief from the ASME Code requirements of IWB-3142.3, which essentially allow a component with flaws to be accepted for continued service if the component is repaired or replaced to correct or remove the flaws or if the flaws are reduced in size such that the flaws would meet the acceptance criteria of the ASME Code,Section XI, Table IWB-341 0-1. The licensee's proposed alternative is to repair the heater sleeve using the half nozzle technique in which the bottom portion of the original sleeve is replaced with a new sleeve, and the pressure-retaining weld is relocated to the outer surface of the vessel. In the half-nozzle method, the remnant of the original sleeve, including the original J-groove weld, remains installed, but the original J-groove weld is no longer part of the pressure boundary.

Relief Request 1 A7 of A44

However, it is possible that a flaw exists in the original J-groove weld, and this flaw could grow because of fatigue loads through the entire J-groove weld and the cladding beneath the J-groove weld into the carbon steel bottom head of the pressurizer. Therefore, the NRC staff evaluated the licensee's request for reasonable assurance that postulated flaws in the original J-groove weld will not grow into the carbon steel pressurizer bottom head to the extent that threatens structural integrity.

Establishment of Leakage Path in the OriginalJ-Groove Weld In its letter dated April 9, 2014, in response to the NRC's RAI No. 1, the licensee confirmed that it performed ECT on the entire heater sleeve bore and found no indications. By process of elimination, the licensee concluded that the flaw causing the leak is located in the J-groove weld because no through-wall cracking is present in the sleeve. However, this cannot be confirmed by NDE because ECT does not penetrate deep enough to detect flaws in the weld, and there is no qualified ultrasonic testing technique for inspecting J-groove welds. In its letter dated April 4, 2014, the licensee also stated that it performed a borescope examination of the original heater sleeve weld to the pressurizer, and it noted an area of discoloration around M.-inch in size along the reinforcing fillet weld face. However, the licensee did not identify any indication of cracking in the discolored region or in any other part of the weld that it viewed.

Based on the results of the licensee's ECT and visual examination of the heater sleeve and weld, the NRC staff concludes the leak path is most likely through the weld because the ECT examination detected no cracking in the sleeve itself.

Flaw Growth Assessment In its letter dated April 4, 2014, the licensee provided a qualitative evaluation of the likelihood of flaw propagation from the J-groove weld into the pressurizer bottom head shell material. The licensee's evaluation intended to demonstrate that there is a very low probability that such flaw propagation would occur during the one cycle duration of the proposed alternative. In its letter dated April 4, 2014, the licensee stated that the leak occurred since the last visual VT-2 inspection of the pressurizer bottom head performed in fall 2012 because no evidence of leakage was observed at that time. Therefore, the licensee concluded that the postulated flaw that caused the leakage must be confined to the J-groove weld because a crack through the weld alone would be sufficient to allow leakage, and additional time would have been required for the crack to grow into the cladding.

In its email dated April 8, 2014, in RAI No. 4, the NRC staff requested the licensee to address the possibility that the leakage may have required several cycles to reach the bottom head surface because of the roll expansion of the original sleeve into the bottom head. The NRC staff also asked whether this creates the possibility that the flaw causing the leakage may have had more time to grow into the cladding and the pressurizer bottom head. In its response dated April 9, 2014, the licensee stated that the purpose of the roll expansion of the pressurizer heater sleeve is to limit the loads on the existing internal weld, much like an interference fit of a nozzle.

The licensee further stated that while the roll expansion provides support for the nozzle, it is not expected to provide a watertight seal against the pressure and dilation stresses of the reactor coolant system (RCS). The licensee referred to industry operating experience (OE), including Relief Request 1 A8 of A44

Licensee Event Report (LER) 95-007-01 , which described similarly designed and installed pressurizer instrument nozzles with roll expansion that also exhibited leakage. The licensee stated that this OE, the Turkey Point 3 experience, and the interference fit penetrations in reactor vessel upper heads suggest that the breach of an inner diameter partial penetration pressure boundary weld will result in leakage. In its letter dated April 9, 2014, the licensee also stated that the pressurizer bottom head cladding was stress-relieved (i.e., post-weld heat treated) during fabrication, which would tend to reduce the crack growth rate through the cladding. The licensee also stated that several additional operating cycles would be needed for a crack to grow through the cladding, whereas leakage would begin as soon as the crack was through the J-groove weld. Finally, the licensee noted that its qualitative assessment already considers the possibility of crack growth by fatigue into the pressurizer bottom head shell.

The NRC staff reviewed the referenced industry OE and LER, which are for the same incident of leakage in stainless steel pressurizer instrument nozzles at the Surry Power Station, Unit 1 (Surry). The OE and LER do not quantify the amount of corrosion to the pressurizer shell but indicate that the corrosion was able to be machined out as part of the preparation of the nozzle bore for a new nozzle. Therefore, the NRC staff assumes the amount of corrosion associated with the Surry pressurizer instrument nozzle leak was not structurally significant, which indicates that the leaks had existed for one cycle or less. The NRC staff concludes that it is likely the leakage at Turkey Point 3 only required one cycle to reach the outside surface of the pressurizer bottom head based on experience with reactor pressure vessel (RPV) closure head nozzles with an interference fit. In such cases, 8 there was no significant corrosion or crack propagation into the vessel shell before leakage reached the surface. The NRC staff concluded the licensee's assumption that the flaw at Turkey Point 3 would not have grown significantly into the cladding is reasonable if leakage reached the surface in one cycle because the number of fatigue cycles occurring over one operating cycle is relatively small. Based on its review of the licensee's response to RAI No. 4 and other OE, the NRC staff concluded that it was highly probable that the leak had only existed for one cycle.

Assessment of Flaw Growth by Fatigue In its letter dated April 4, 2014, the licensee cited experience with previous fatigue flaw growth analyses for Combustion Engineering (CE) design pressurizers that were documented in WCAP-15973-P-A, 'Low-Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs," Revision 0, dated February 2005. This document contains proprietary information and is not publicly available. A public version of the Westinghouse document, WCAP-1 5973-NP-A, Revision 0, is available in ADAMS. " The licensee also referenced a public version of the AREVA, Inc. Calculation 32-9156231-000.6 These analyses were for CE design pressurizer heater sleeves that have significantly larger J-groove welds than the Turkey Point 3 design. Therefore, the initial flaw that was postulated in these analyses was significantly larger than the initial flaw postulated for the Turkey Point 3 J-groove weld. In its letter dated April 4, 2014, the licensee stated these fatigue crack growth analyses yielded 7ADAMS Legacy Accession No. 9603050016.

a See ADAMS Accession Nos. ML023400549, ML010090434, ML011350195, and ML031200697 for examples of LERs related to reactor vessel closure head penetration leakage where no significant wastage (i.e., loss of material from general corrosion or erosion) occurred.

9ADAMS Accession No. ML050700431.

Relief Request 1 A9 of A44

acceptable results for a significant length of time, providing ample assurance that flaw growth into the Turkey Point 3 pressurizer bottom head would be stable for at least one cycle.

The staff reviewed the proprietary and nonproprietary analyses for CCNPP-1 in which the postulated J-groove flaw was found to be acceptable for 35 years, as documented in the NRC's safety evaluation dated December 9, 2011 .o The CCNPP-1 pressurizer heater sleeves have a similar geometry to the Turkey Point 3 heater sleeve, in terms of thickness, diameter, the vessel shell thickness, but have a larger J-groove weld area. The operational transients causing fatigue cycles should be similar in number and severity to those experienced by the Turkey Point 3 heater sleeves. However, to confirm this, in its email dated April 8, 2014, RAI No. 3, Part (a)(i), the NRC staff requested the number of operating transients applicable over the life of the plant for the Turkey Point 3 heater sleeves and whether any of these transients have the potential to be more severe than the corresponding transients in CE design pressurizers. In its response dated April 9, 2014, the licensee stated that the transients for CE design pressurizers are generally similar to those for Westinghouse designs, such as Turkey Point 3, because both are pressurized-water reactors (PWRs), and the CE design closely followed the Westinghouse design in its implementation. The licensee further indicated that one of the key differences is that the CE design has many more heatup (HU) and cooldown (CD) transient cycles than the Westinghouse design (i.e., 500 versus 200 cycles), which makes the use of the CE design transients conservative for use in evaluating the Turkey Point 3 heater sleeve. The licensee also indicated that the CE generic evaluation reported one transient type (i.e., 500 cycles of HU and CD (HU/CD) with a change in temperature (AT) caused by insurges and outsurges assumed to occur during HUICD) that was applicable to the pressurizer heater sleeve and contributed to fatigue crack growth. For the Turkey Point 3 pressurizer, the AT for the surge during HU/CU was consistent with the larger surge AT from the generic CE evaluation.

In Table 1 of its letter dated April 9, 2014, the licensee listed all the cycles applicable to the Turkey Point 3 heater sleeve, including revised AT and flowrate values based on the updated fatigue design basis from the extended power uprate. Some types of cycles listed in Table I were not considered in the generic CE evaluation. Although the AT values for these cycles were less than the insurge/outsurge AT, the NRC staff was concerned that these cycles could contribute to fatigue crack growth because of the large numbers of cycles over the life of the plant for some types of cycles, such as 5-percent changes in plant loading and unloading.

Therefore, by email dated April 10, 2014, the NRC staff provided RAI No. 5 to the licensee. In its response dated April 14, 2014, the licensee stated that in the CE generic evaluation, only the HU/CD and operating basis earthquake (OBE) transients made a significant contribution to fatigue crack growth. Furthermore, because the CE generic evaluation assumed a much larger number of HU/CD cycles over the pressurizer design life than Turkey Point 3 (i.e., 500 versus 200 cycles), fatigue crack growth for Turkey Point 3 should be bounded for the life of the plant.

The licensee also stated that the current evaluation is only for one 18-month cycle; therefore, the number of cycles expected to be accrued is only a small fraction of the design life cycles.

The NRC staff concludes that for the HU/CD transients with insurge/outsurge, the fatigue crack growth for Turkey Point 3 should be bounded over the life of the plant because the number of cycles considered in the generic CE evaluation is 150-percent greater or 2 %times than that for Turkey Point 3. The staff also compared the Turkey Point 3 information to the CCNPP-1

'oADAMS Accession No. ML 13360526.

Relief Request 1 A10 of A44

analysis, in which plant loading and unloading had no contribution to fatigue crack growth.

Therefore, the NRC staff expects that plant loading and unloading would not significantly contribute to fatigue crack growth for Turkey Point 3. The NRC staff also understands that Turkey Point 3 operates as a base-loaded plant (i.e., the plant generally operates at 100-percent power rather than increasing or decreasing power level based on the grid demand).

Therefore, plant loading and unloading transients and steady-state fluctuation transients should occur much less frequently than the numbers of these transients that are included in the design basis cycles of Table 1 of the licensee's letter dated April 9, 2014. Furthermore, Footnote 6 to Table I indicates the maximum AT for the steady state fluctuation transient occurs at 15-percent power, which is not a power level at which base-loaded plants normally operate for any extended period. Based on its evaluation of the information the licensee provided in its RAI responses dated April 9, and April 14, 2014, the NRC staff concludes that transients other than HU/CD and OBE will not significantly contribute to fatigue crack growth.

In its email dated April 8, 2014, the NRC staff requested in RAI No. 3.a.ii that the licensee identify the key parameters in determining the driving force for crack growth and final flaw stability of the postulated flaw in the Turkey Point 3 heater sleeve assembly. The NRC staff also requested the licensee to demonstrate that these parameters are bounded by the corresponding parameters of the CCNPP-1 heater sleeve assembly and the generic CE heater sleeve assembly evaluation. In its letter dated April 9, 2014, the licensee compared the rates of temperature change for the limiting transients for the generic CE heater sleeve assembly evaluation to that allowed for the Turkey Point 3 pressurizer. The information provided demonstrated the rate of temperature change for the limiting transient (i.e., CD) is similar, but the numbers are conservatively high for the generic CE design.

Based on the information provided by the licensee in response to RAls 3.a.i and 3.a.ii, the NRC staff concludes that the types of operational transients - specifically the HU/CD transients coupled with insurge - that dominate fatigue crack growth are similar for both the generic CE design and Turkey Point 3. The NRC staff also expects that the severity of the transients would be similar based on the similar AT for the surge and HU/CD rates. With respect to geometry of the generic CE and Turkey Point 3 heater sleeve assemblies, the generic CE analysis and the licensee's submittals indicated that the heater sleeve outer diameter and thickness and pressurizer bottom head shell and cladding thickness are similar. The major difference is in the dimension of the J-groove weld, which is much larger in the generic CE and CCNPP-1 heater sleeves. In its qualitative evaluation, the licensee assumed the flaw was the size of the Turkey Point 3 J-groove weld dimension of 3/16 inch. Therefore, because the transients are relatively the same, the driving force should be similar, but the resulting applied stress intensity should be less for Turkey Point because of the smaller flaw dimension.

The licensee also stated that because the cladding was stress-relieved, the fatigue crack growth rates in the cladding should be reduced compared to those in the J-groove weld, which is not stress-relieved. The licensee therefore concluded that if 42 years of operation were required for a fatigue crack to grow through the 3/16-inch J-groove weld, greater than 18-months would be required for the crack to grow another 3/16 inch.

Relief Request 1 All of A44

Based on a comparison of the licensee's analysis to the generic and plant-specific CE plant pressurizer flaw analyses, the NRC staff concludes the following regarding the Turkey Point 3 pressurizer heater sleeve:

The controlling transients for fatigue crack growth are similar in severity, but a much larger number were assumed for the CE plants; therefore, fatigue crack growth for Turkey Point 3 should be bounded for plant life.

The driving force for crack growth should be less for Turkey Point 3 because of the smaller initial flaw size. The licensee's assumption that the initial flaw is limited to the J-groove weld is reasonable based on the design of the heater sleeve and relevant OE.

Because the Turkey Point 3 relief request is only for one 18-month cycle, fatigue crack growth over one cycle should be a small fraction of the expected amount for a 40-year life, which was found to be acceptable for the generic CE analysis, or for 35 years, which was found acceptable in the CCNPP-1 analysis.

Assessment of Flaw Growth by Stress Corrosion Cracking(SCC)

In its safety evaluation11 for WCAP-1 5973-P-A Rev 0, the NRC staff concluded that existing flaws in J-groove welds will not grow by SCC into the low-alloy steel material of the pressurizer bottom head provided that the licensee maintains low levels of oxygen (i.e., less than 10 parts per billion (ppb)) and halide (i.e., chloride and sulfate ion concentrations of less than 150 ppb) in the RCS chemistry for the previous two refueling cycles and maintains appropriate hydrogen overpressure on the RCS. In Section 3.1.1, "Chemistry Control Program," of its safety evaluation 12 for the License Renewal of the Turkey Point Nuclear Generating Unit Nos. 3 and 4, the NRC staff documents that Turkey Point 3 follows Revision 4 of the Electric Power Research 13 Institute (EPRI) Topical Report TR-105714, "EPRI Primary Water Chemistry Guidelines."

Following the EPRI guidelines will assure the conditions regarding contaminants and hydrogen will be met.

Based on OE in PWRs, which shows the resistance of carbon and low-alloy steels to SCC if good chemistry is maintained, and the conformance to the EPRI guidelines of Turkey Point 3, the NRC staff concludes that flaw growth caused by SCC into the pressurizer shell is extremely unlikely.

FinalFlaw Stability In its email dated April 8, 2014, the NRC staff requested in RAI 3.b that the licensee provide the material resistance to fracture (J-R) curve for the Turkey Point 3 pressurizer bottom head. The licensee instead provided the static initiation fracture toughness (K1c) curve for the SA-216, Grade WCC pressurizer bottom head material and compared the Kic value at the temperature at the end of CD of 70 degrees Fahrenheit (OF) to the K1c value used in WCAP-1 5973-P-A. The licensee stated that based on the Turkey Point 3 bottom head reference nil-ductility temperature (RTNDT) of 30 OF, the Kic at RTNDT plus 40 OF would be approximately 70 kilopound 1 ADAMS Accession No. ML050700431.

12 ADAMS Accession No. ML012320135.

13 This document contains proprietary information and is not publicly available.

Relief Request 1 A12 of A44

-11 -

per square inch square root inches (ksia/in). For normal and upset conditions, the ASME Code,Section XI, IWB-3612 formerly required a margin for the ratio of crack-arrest fracture toughness (Kia) to the applied stress intensity factor (K,) be greater than the square root of 10 (Ka/K, greater than q10). However, the more recent editions of the Code, such as the 2007 edition with 2008 addenda, allow K1,/K1 greater than q10 for normal and upset conditions.

The K, values are larger than K1. value for the same temperature minus the RTNDT value.

Because the applicable ASME Code Section XI edition for Turkey Point 3 is the 2007 edition through 2008 addenda, KI, would be used in linear elastic fracture mechanics (LEFM) evaluations for normal and upset conditions.

Ifthe applied stress intensity were the same for Turkey Point 3 as the generic CE analysis, the licensee's Kic value of 70 ksiqin would allow the IWB-3612 margins to be met for the most limiting transient evaluated by LEFM in the generic CE analysis. However, because both the generic CE analysis and the CCNPP-1 analysis used elastic-plastic fracture mechanics (EPFM) for acceptance of the final flaw in some cases, in its email dated April 10, 2014, the NRC staff requested in RAI 6 that the licensee provide the J-R curve for the Turkey Point 3 pressurizer bottom head material. In its letter dated April 14, 2014, the licensee responded to RAI 6 and indicated that a material-specific J-R curve was not available for the SA-216, Grade WCC material because there were no requirements for such toughness testing in the 1965 edition of the ASME Code,Section III to which the Turkey Point 3 pressurizer was constructed. The licensee indicated the J-R model used in the generic CE analysis was equally applicable to Turkey Point 3. The generic CE analysis used the J-R toughness model for typical RPV steel from Equation 17 in Revision 0 of NRC Regulatory Guide (RG) 1.161, "Evaluation of Reactor Pressure Vessels with Charpy Upper-Shelf Energy [USE] Less Than 50 Ft-Lb [foot-pounds],"14 modified by the use of a margin factor of 1.0 rather than 0.749. The NRC staff accepted the generic CE analysis because sensitivity studies performed by Westinghouse showed that the RG 1.161 acceptance criteriai 5 were still met even when the 0.749 factor was applied to the J-R curve, and with a structural factor of 9.0 on the applied J-integral value (JappIw).

The model proposed is applicable to a sulfur content of less than 0.01 8-percent and calculates the J-R curve based on a correlation with Charpy V-notch (CVN) USE. The licensee assumed a USE value of 70 ft-lb in lieu of plant-specific data for the Turkey Point 3 bottom head. To support its assumption, the licensee provided USE data for several heats of SA-216, Grade WCC material, including full CVN curves. The staff reviewed these curves and concluded the USE of these material heats is greater than 100 ft-lb. Therefore, the staff concludes the licensee's assumption of a USE of 70 ft-lbs for the Turkey Point 3 pressurizer bottom head is reasonable. The staff reviewed RG 1.161, and concluded that the J-R model used in the generic CE analysis is appropriate for the pressurizer bottom head material. Therefore, because the material resistance to fracture of the Turkey Point 3 material should be equal to or greater than the material resistance used in the generic heater sleeve analysis, the staff determined it to be acceptable.

With respect to the driving force for fracture for the final flaw, in its response to RAI 6, the licensee indicated that in the generic CE analysis, CD was limiting among the transients 14 ADAMS Accession No. ML003740038.

is Japplied is less than J0 .1, and AJappijd divided by aa (aJppjed/a) is less than BJnte, Voa at Japplied equal to Jm=a; where Jappuid is the driving force, Jo.1 is the material resistance at 0.1-inch crack extension, and Jmwtl is the material resistance curve.

Relief Request 1 A13 of A44

evaluated by LEFM and that CD coupled with insurge/outsurge was evaluated by EPFM. The licensee implied the same transients would be limiting for the Turkey Point 3 heater sleeve.

Given the similar severity of the CD transients for the generic CE analysis and Turkey Point 3, the NRC staff concludes that the driving force for final crack stability should be similar for both.

However, the NRC staff notes that based on the information provided on the driving force for fatigue crack growth and the material fracture toughness, it is highly unlikely a flaw would approach critical size in one operating cycle.

General CorrosionEvaluation The licensee performed a general corrosion evaluation of the exposed carbon steel in the penetration. Based on industry data and AREVA's experience, the licensee estimated a corrosion rate of exposed carbon steel the bore of the lower head 0.0018 inches per year with 10-percent shutdown time during the operating cycle, and 0.0026 inches per year with 20-percent shutdown time during the operating cycle. Corrosion rates are higher during plant shutdowns because of higher oxygen concentrations. The NRC staff checked the licensee's estimated rate against the rate equation in WCAP-1 5973-P-A, Revision 0 and found that the licensee's corrosion rate is slightly more conservative and is therefore acceptable.

NRC Staff Conclusion on Leak Tightness and StructuralIntegrity Based on its review of the licensee's evaluation of the potential for crack growth into the pressurizer shell and the licensee's corrosion assessment, the NRC staff concludes that there is reasonable assurance that unacceptable flaw growth caused by fatigue or SCC will not occur in one operating cycle. The NRC staffs conclusion is based on a comparison of the licensee's analysis to quantitative flaw analyses performed on similar postulated flaws in similar components and on OE that shows that flaws in remnant welds have not degraded structural integrity when half-nozzle repairs have been implemented.

4.0 REGULATORY COMMITMENTS In its letter dated April 4, 2014, the licensee included a regulatory commitment that it will perform a bare metal visual examination of the Turkey Point 3 pressurizer heater sleeve area during the next (i.e., Cycle 28) refueling outage. The NRC staff's conclusions in this safety evaluation did not rely on the licensee's commitment to perform a bare metal visual examination.

5.0 CONCLUSION

Based on its review of the licensee's submittals, the NRC staff concludes that the licensee's proposed alternative - Relief Request No. 1 - provides reasonable assurance that the leak tightness and structural integrity of the Turkey Point 3 pressurizer will be maintained over the 18-month duration of the operating cycle for which the licensee requested relief. The NRC staff also concludes that complying with the requirements of IWB-3142.3 would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The NRC staff, therefore, authorizes the licensee's requested alternative for the duration of the current 18-month operating cycle for Turkey Point 3.

Relief Request 1 A14 of A44

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: J. Poehler, NRR Date: October 9, 2014 Relief Request 1 A15 of A44

M. Nazar The NRC staff reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that complying with the requirements of subparagraph IWB-3142.3 would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety and that the licensee adequately addressed all regulatory requirements in 10 CFR 50.55a(a)(3)(ii). Accordingly, the NRC staff authorizes Relief Request No. 1 at Turkey Point 3 for that unit's current 18-month operating cycle.

All other ASME Code, Section Xl requirements for which relief was not specifically requested and authorized in Relief Request No. 13 remain applicable, including third-party, review by the Authorized Nuclear Inservice Inspector.

If you have any questions regarding this issue, please contact the project manager, Ms. Audrey Klett, at (301) 415-0489 or by e-mail at Audrev.Klett(nrc.aov.

Sincerely, IRAI Lisa M. Regner, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-250

Enclosure:

Safety Evaluation cc w/encl.: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-2 R/F RidsNrrDorlLpl2-2 RidsNrrLABClayton RidsAcrsAcnwMailCTR RidsRgn2MailCenter JJandovitz, OEDO RidsNrrPMTurkeyPoint RidsNrrDeEvib JPoehler, NRR ADAMS Ae~emRinn Nn ML14122A268 *Bv e-maiI, OFFICE LPLI I-2/PM LPLII-2/LA EVIB/BC* LPLII-2/BC (A)

NAME AKIett BClayton SRosenberg LRegner DATE 09/23/14 09/22/14 107/17/14 10/09/14 OFFICIAL RECORD COPY Relief Request 1 A16 of A44

0 10 CFR 50.55a L-2014-096 April 4, 2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Unit 3 Docket No. 50-250 Inservice Inspection Plan - Fifth Inspection Interval Unit 3 Relief Request No. 1 Pursuant to 10 CFR 50.55a(a)(3)(ii), Florida Power & Light Company (FPL) requests Nuclear Regulatory Commission (NRC) approval to use an alternative to the ASME Boiler and Pressure Vessel Code,Section XI, 2007 Edition, including Addenda through 2008. FPL determined pursuant to 10 CFR 50.55a(a)(3)(ii) that compliance with specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Turkey Point Unit 3 is currently in its refueling outage for Cycle 27. During a visual inspection of the pressurizer heater sleeve penetrations, an indication of leakage in the annulus between the outer surface of the heater sleeve and the lower head bore at heater penetration 11 was found.

Because of difficulties in assessing the flaw and removing it, FPL is hereby requesting the NRC to review and approve the attached alternative to support placing the pressurizer back in service (Mode 4). Entry into Mode 4 from the current Unit 3 refueling outage is currently scheduled for April 14, 2014.

Please contact Robert Tomonto, Licensing Manager, at 305-246-7327 if you have any questions or require any additional information about this submission.

Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant

Attachment:

Turkey Point Unit 3 Relief Request No. i for the 5 t" Inspection Interval cc: Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant Florida Power & Light Company 9760 SW 344 'h St., Florida City, FL 33035 Relief Request 1 A17 of A44

Proposed Alternative in Accordance with IOCFR 50.55a(a)(3)(ii)

Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety REPAIR OF PRESSURIZER STAINLESS STEEL HEATER SLEEVE WITHOUT FLAW REMOVAL

1. ASME Code Component Affected Turkey Point Unit 3 Components: Pressurizer and pressurizer heater sleeve (nozzle)

Code Class: ASME Section III 1965 Edition, including Addenda through Summer 1965, Class A Examination Category: B-P Code Item Number: B15.10

==

Description:==

Pressurizer heater sleeve internally welded to the pressurizer lower head cladding Size: 1.125" Nominal outside diameter, 0.095" wall thickness Material: Stainless steel SA-213 TP316 sleeve, austenitic stainless steel cladding, SA-216 Grade WCC lower head

2. Applicable Code Edition and Addenda

ASME B&PV Code Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components" 2007 Edition, including Addenda through 2008.

Relief Request 1 A18 of A44

3. Applicable Code Requirement

Pursuant to 10 CFR 50.55a (a)(3)(ii) Florida Power and Light (FPL) requests an alternative to the requirements of ASME B&PV Code, Section Xl, IWB-3142.3 "Acceptance by Corrective Measures or Repair/Replacement Activity. A component containing relevant conditions is acceptable for continued service if the relevant conditions are corrected by a repair/replacement activity or corrective measures to the extent necessary to meet the acceptance standards of Table IWB-341 0-1 ."

4. Reason for Request

FPL conducted visual examinations of the pressurizer heater sleeve penetrations during the current Turkey Point Unit 3 Refueling Outage. These examinations revealed evidence of leakage in the annulus between the outer surface of the heater sleeve and the lower head bore at heater penetration #11. There was no leakage observed at the other heater penetrations. Manual nondestructive examination (NDE) was conducted from the sleeve bore using the eddy current method after the heater was removed from the heater sleeve. The examination did not reveal any flaw in the sleeve. Therefore, the most likely location of the flaw is located in the stainless steel weld between the heater sleeve and the stainless steel cladding buildup.

The heater sleeve is roll expanded into the lower head bore and welded with a partial penetration weld to the stainless steel cladding buildup on the inside of the pressurizer lower head. The partial penetration weld joint does not extend into the lower head carbon steel base material.

The cladding is final stress relieved prior to welding the heater sleeve thereto. The cladding is approximately 3/8" thick and one layer of cladding of approximately 3/16" thick remains beneath the partial penetration weld. The heater is fillet welded to the bottom of the sleeve and extends upward through the two heater lateral support plates in the pressurizer.

To remove the heater sleeve-to-pressurizer weld requires accessing the internal surface of the pressurizer and removal of the weld and any remaining sleeve base metal. Such an activity results in high radiation exposure to the personnel involved which is considered a hardship. Grinding and/or machining within the components also exposes personnel to safety hazards as well as possible foreign material remaining in the pressurizer that could later affect fuel performance.

Relief Request 1 A19 of A44

FPL proposes to leave the upper portion of the existing heater sleeve and its weld to the pressurizer lower head cladding in service.

5. Proposed Alternative and Basis for Use PROPOSED ALTERNATIVE:

The original weld will not be corrected and the heater sleeve base material will be removed to approximately the mid wall of the pressurizer lower head. The heater sleeve will be repaired by relocating the pressure boundary weld from the inside surface of the pressurizer to the outside surface. The repair is in accordance with the Class 1 requirements of the ASME Boiler and Pressure Vessel Code Section III.

The "half-nozzle" method will be used for the repair to penetration #11. The heater is removed and the heater sleeve is severed below the pressurizer lower head. The remaining lower portion of the heater sleeve is removed by boring to approximately mid-wall of the lower head. The removed portion of the stainless steel sleeve will be replaced with a section (half-nozzle) of low carbon stainless steel which will then be welded to the outside surface of the pressurizer lower head using low carbon stainless steel weld filler. A new heater will be welded to the bottom of the replacement lower sleeve using low carbon stainless steel weld filler. The upper portion of the sleeve, including the partial penetration weld, will remain in place. (See Figure 1)

Heater sleeve welds on pressurizers with Alloy 600 material have been repaired by the industry using a similar "half-nozzle" technique. The half-nozzle method has been used at Calvert Cliffs Unit 1 and St. Lucie Unit 2.

The portion of the original heater weld to the pressurizer was examined with a borescope. An area of discoloration - Y2" along the reinforcing fillet weld face was noted. However, no indication of cracking was identified in the discolored region or any other part of the weld that was viewed.

The original heater sleeve remnant and weld will not receive any additional NDE. The new lower heater sleeve-to-lower head and heater/plug-to-lower heater sleeve pressure boundary welds, on the exterior surface of the pressurizer, will be examined in accordance with the applicable requirements of the ASME Boiler and Pressure Vessel Code Sections III and XI.

Relief Request 1 A20 of A44

BASIS FOR USE:

Since the heater sleeve material and sleeve-to-clad weld are generally not susceptible to a stress corrosion mechanism in the pressurizer environment it is presumed that the weld flaw(s) was the result of an original fabrication flaw that propagated from service.

Such service propagation could be a combination of thermal fatigue and/or SCC.

There has been no leakage at any other pressurizer heater sleeve location at Turkey Point unit 3 or unit 4. A review of industry operating experience (OE) from the 48 US PWRs with similar stainless steel heater sleeves welded to the interior clad surface, representing greater than 3800 heater sleeves and 23-42 years of service, has not identified a leak at this location. OE was identified at one US plant but the leak was at a location in the heater sleeve material outside of the pressurizer shell attributed to an anomaly in the tube adjacent to the weld. The greater than 3800 stainless steel pressurizer heater sleeves with 23-42 years of operating history represents greater than 100,000 sleeve years of service with occurrence of only this single leak in the weld.

This provides evidence of the excellent service history as well as the evidence of the lack of a generic condition.

The effects of propagation of any flaw(s) that remain in the original heater sleeve weld, by fatigue crack growth and stress corrosion cracking mechanisms are considered.

Postulated worst case flaws are assessed for flaw growth. The assessment concludes the structural integrity will not be adversely affected by postulated flaw(s) remaining in service for at least one fuel cycle.

Further characterization of the weld by NDE was not practical as discussed below. Due to its location in the inside of the lower pressurizer head, the original heater sleeve-to-pressurizer clad partial penetration weld is extremely difficult to access from the pressurizer manway, through the heater support plates and heaters, to perform NDE.

Also, if it was accessible, to fully characterize the flaw(s) causing leakage would require a volumetric examination method, such as an ultrasonic (UT) examination method.

However, the weld configuration around the sleeve outer diameter precludes UT coupling and control of the sound beam needed to perform flaw characterization and sizing, with reasonable confidence, of the measured flaw dimensions. If UT examination of the original partial penetration weld were attempted from the outside surface of the pressurizer lower head, the cladding interface would provide an acoustic mismatch that would severely limit this examination. This UT examination would also encounter scanning interferences due to adjacent heaters as well as the required long examination distances (i.e., metal paths) for interrogation of radial-axial oriented flaws at the opposite (inside) surface. These conditions would make accurate detection, characterization, and sizing of flaw(s) problematic.

Relief Request 1 A21 of A44

Currently, there is no qualified UT technique for examination of the original partial penetration weld or adjacent carbon steel pressurizer lower head material from either the inside or outside surface. Radiography of this area is also impractical because of the inability to position either a source or film inside the pressurizer. Additionally, other NDE methods, such as liquid penetrant, magnetic particle, and eddy current would not provide useful volumetric information needed for flaw characterization.

It is reasonable to assume that the existing flaw(s) is contained within the weld only, since eddy current examination did not reveal any indication in the heater sleeve, and has not progressed significantly into the cladding beneath the weld.

The cladding is subjected to post weld heat treatment (stress relief). As a result, the residual tensile stress state during normal operation is significantly less than the tensile stress state in the weld, which has not been stress relieved. During operation the cladding stress may even be compressive because the stainless steel coefficient of thermal expansion is greater than that of the carbon steel lower head. Therefore, the force driving a crack through the weld will be greatly diminished as the crack enters the cladding. For stress corrosion cracking (SCC), the reduced stress will lead to lower growth rates, and for cyclic loading (fatigue) the stresses will be alternating about a significantly lower mean stress, leading to reduced crack growth per cycle. Therefore is it reasonable to assume that the flaw that resulted in the leak through the 3/16" partial penetration weld after 42 years of service would take greater than one 18-month cycle to grow an additional 3/16" through the remaining layer of clad to reach the clad/carbon steel interface.

The current inspection performed at Turkey Point Unit 3 is a VT-2 exam every refueling outage, meeting the NEI-03-08 recommended inspection guidance and frequency provided by the PWR Owners Group. This examination is performed with the insulation in place. The Turkey Point Unit 3 pressurizer lower head is insulated with glass or mineral fiber insulation. At the time of the initial inspection the insulation configuration provided gaps around the leaking penetration and several other heater sleeve locations to permit examination of the base metal. A complete bare metal visual was performed at all 78 penetrations to determine the extent of condition.

The bottom of the pressurizer is visually inspected for leakage every outage, therefore the leak occurred since the last inspection. Since it took many years for the leakage to occur, there is no reason to believe that significant growth into the cladding would occur in only a few additional fuel cycles, especially due to its lower residual stress state and since the sleeve-to-cladding weld is no longer pressure retaining.

Relief Request 1 A22 of A44

Therefore, it is reasonable to assume that:

a) The existing flaw is completely contained within the pressurizer stainless steel cladding.

b) Crack growth from the cladding into the inside surface of the pressurizer lower head carbon steel base material will not occur over the next fuel cycle.

c) There are no flaw(s) driven by fatigue into the lower head carbon steel base material.

d) In the unlikely event that a, b, and c, are untrue, quantitative analysis of a similar configuration has demonstrated that a flaw starting at the cladding to base metal interface can grow for a significant length of time and remain stable with appropriate factors of safety.

Experience with fatigue flaw growth analysis in Combustion Engineering (CE) designed PWR pressurizers was performed by the PWROG in WCAP-1 5973-P-A Rev 0, as well as a plant specific analysis in NRC Accession MLI11132A1 83. The initial postulated flaw was significantly larger in the CE design since the pressure boundary J-groove weld prep is cut into the low alloy carbon steel lower head of the pressurizer, resulting in a significantly larger initial flaw than the Turkey Point Unit 3 original weld prep which remains in the stress relieved clad (Figure 1). These fatigue crack growth analyses yielded acceptable results for a significant length of time, providing ample assurance that a flaw growth into the ferritic steel head would be stable for at least one cycle.

The qualitative fracture mechanics assessment concludes that it is acceptable to allow postulated flaw(s) to remain in service and demonstrates the acceptability of the condition for at least one fuel cycle. Therefore the proposed alternative is being requested for acceptance in accordance with IWB-3142.3 for the next 18-month fuel cycle.

Corrosion of the exposed carbon steel in the half nozzle repair is also considered. The "half-nozzle" repair has a small radial gap between the heater sleeve remnant and the replacement lower heater sleeve and the bore in the pressurizer lower head and a small axial gap between the bottom of the heater sleeve remnant and the top of the replacement lower heater sleeve. As a result, primary coolant (borated water) will fill this crevice. Carbon steels used for reactor coolant systems components are clad with stainless steel to minimize corrosion resulting from exposure to borated primary coolant.

Since the crevice regions are not clad, the carbon steel is exposed to borated water.

Relief Request 1 A23 of A44

The carbon steel pressurizer lower head will not be significantly degraded by general corrosion as a result of the modification. Although some minor corrosion may occur in the crevice region on the carbon steel head the degradation will not proceed to the point that the structural integrity of the pressurizer will be adversely affected during its remaining service life, including the period of extended operation. Further, available laboratory data and field experience also indicate that continued propagation of cracks into carbon steel by a stress corrosion mechanism is unlikely.

For the carbon steel exposed to the primary coolant, galvanic corrosion, hydrogen embrittlement, SCC, and crevice corrosion are not expected to be a concern. Based on industry data and AREVA's experience, the corrosion rate of exposed carbon steel in the bore of the lower head is conservatively estimated to average 0.0018" per year with 10% shutdown time during the operating cycle and 0.0026" per year with 20% shutdown time during the operating cycle.

SCC of the stainless steel components (replacement heater sleeve and weld metals) is not likely because two of the three necessary synergistic elements of SCC (susceptible material and aggressive environment) are minimal or not present. Some residual stresses will likely be present adjacent to the weld in the replacement stainless steel items. However, this stress will likely not cause crack initiation or propagation because the other two necessary elements of SCC are minimal or not present.

Results of the stress analyses show that the structural integrity of the pressurizer will not be adversely affected for the remainder of its service life due to material loss in the lower head base material.

In conclusion, the ASME B & PV Code Section Xl requirement, IWB-3142.3, is to correct a component containing a flaw(s). The proposed alternative is to relocate the pressure boundary weld to the outside surface of the pressurizer and not correct the item(s) containing the flaw(s) but show by qualitative assessment that the material and the presence of the postulated worst case flaw(s) will not be detrimental to the pressure retaining function of the pressurizer for one fuel cycle.

6. Duration of Proposed Alternative Relief is requested for 18-month fuel cycle. During the next fuel cycle additional analyses will be performed to justify the revised configuration with the postulated flaw(s) remaining in place for the current inspection interval for Turkey Point Unit 3 which expires on February 21, 2024.

Relief Request 1 A24 of A44

7. Commitment FPL will perform a bare metal visual examination of the Unit 3 pressurizer heater sleeve area during the next Cycle 28 refueling outage.

8. Precedents There are no known precedents for pressurizer stainless steel heater sleeve leakage requiring repair. The modified configuration is similar to various half-nozzle repairs performed by the industry for Alloy 600 items that have experienced leakage that have typically been caused by primary water SCC. However, there is a precedent for evaluating flaw growth in carbon steel and low alloy steel base material due to fatigue that is exposed to reactor coolant in the pressurizer environment. An evaluation has been submitted to the NRC as follows:

"ATTACHMENT (6) UNIT 1 PRESSURIZER HEATER SLEEVE AS-LEFT J-GROOVE WELD FLAW EVALUATION FOR IDTB REPAIR - NON-PROPRIETARY," Calvert Cliffs Nuclear Power Plant, LLC May 11, 2011, NRC Accession ML11132A183.

Relief Request 1 A25 of A44

0.11 Inches - Approximate Axial Gap Between Upper Sleeve Remnant &

Lower Replacement Heater Sleeve Figure 1 Penetration #11 Final Configuration Relief Request 1 A26 of A44

0FRL.

10 CFR 50.55a L-2014-100 April 9, 2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Unit 3 Docket No. 50-250 Inservice Inspection Plan - Fifth Inspection Interval Unit 3 Relief Request No. 1 - Response to Request for Additional Information

References:

1) Florida Power & Light Company letter L-2014-096, "lnservice Inspection Plan - Fifth Inspection Interval Unit 3 Relief Request No. 1", dated April 4, 2014

2) Email to Florida Power & Light Company, "Request for Additional Information Turkey Point Unit 3 Fifth Inspection Interval Relief Request No. 1 Revision 0 Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal Docket No. 50-250", dated April 8, 2014 Pursuant to 10 CFR 50.55a(a)(3)(ii), Florida Power & Light Company (FPL) requested Nuclear Regulatory Commission (NRC) approval to use an alternative to a certain requirement in the ASME Boiler and Pressure Vessel Code,Section XI, in Reference 1. A NRC request for additional information (RAI) was forwarded to FPL in Reference 2. Attached is the FPL response to the Reference 2 RAI.

Please contact Robert Tomonto, Licensing Manager, at 305-246-7327 if you have any questions or require any additional information about this submission.

Very truly yours Michael Kiley Pýý ýL I- I at-it iý-'p LA Y Site Vice President Turkey Point Nuclear Plant

Attachment:

Response to Request for Additional Information Concerning Turkey Point Unit 3 Relief Request No. 1 for the 5 th Inspection Interval cc: Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant Florida Power & Light Company 9760 SW 344e SL, Florida City, FL 33035 Relief Request 1 A27 of A44

By email dated April 8, 2014, the Nuclear Requlatory Commission (NRC) staff forwarded to the Florida Power & Light Company (FPL) a request for additional information (RAI) concerning FPL's request for relief from a certain provision of the ASME Boiler and Pressure Vessel Code. FPL submitted the request for relief by letter L-2014-096 dated April 4, 2014. The FPL response to the NRC RAI follows.

NRC RAI By letter dated April 4, 2014, Florida Power & Light company (FPL, the licensee) requested approval to use an alternative to the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code), Section Xl, 2007 Edition, including Addenda through 2008. During the Turkey Point, Unit 3 refueling outage, the licensee observed evidence of leakage in the annulus between the outer surface of one heater sleeve and the pressurizer bottom head bore. The licensee specifically requested relief from the requirements of the ASME Code, Section Xl, IWB-3142.3, "Acceptance by Corrective Measures or Repair/Replacement Activity," which states that a component containing relevant conditions is acceptable for continued service if the relevant conditions are corrected by a repair/ replacement activity or by corrective measures to the extent necessary to meet the acceptance standards of Table IWB-3410-1. The licensee stated that it had determined that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, therefore requested relief pursuant to 10 CFR 50.55a(a)(3)(ii). The licensee proposed to perform a "half-nozzle" repair which relocates the pressure boundary weld to the outside of the pressurizer bottom head shell and thus leaves the flaw that caused the leakage in place, which is assumed to exist in the original J-groove weld attaching the heater sleeve to the pressurizer cladding. The licensee requested relief for one 18-month operating cycles. The licensee's relief request is supported by a qualitative assessment of the potential for the growth of an assumed flaw in the original J-groove weld into the pressurizer bottom head shell. In support of its qualitative assessment the licensee cited experience with previous fatigue flaw growth analyses for Combustion Engineering (CE) -design pressurizers that are documented in References 1 and 2.

The staff requires the following addition information to complete its review of the relief request:

NRC RAI 1

1. Under "Reason for Request," the relief request states manual nondestructive examination (NDE) was conducted from the sleeve bore using the eddy current Relief Request 1 A28 of A44

method after the heater was removed from the heater sleeve, and that the examination did not reveal any flaw in the sleeve, the licensee stated that therefore, the most likely location of the flaw is located in the stainless steel weld between the heater sleeve and the stainless steel cladding buildup.

Confirm that the entire length of the original pressurizer heater sleeve bore was examined with eddy current testing.

FPL Response to RAI 1 As part of the removal of the heater, the heater sleeve end connection and a few inches of the sleeve were removed, leaving approximately 4 Y4" of the heater sleeve that protruded from the pressurizer shell. The remaining heater sleeve was approximately 9" long. The entire length of the remaining sleeve was examined by the ECT method and no crack like indication was identified.

NRC RAI 2

2. Was the pressurizer shell bore visually examined after the lower portion of the original heater sleeve was removed, and if so was any corrosion or degradation of the carbon steel pressurizer bottom head noted in this area? If so describe the type and extent of degradation including the amount of material lost.

FPL Response to RAI 2 Upon completion of boring out the lower portion of the original heater sleeve, the carbon steel bore of the pressurizer was visually examined. There was no evidence of material loss due to corrosion identified.

NRC RAI 3

3. The qualitative flaw assessment relies on the assumption that the existing flaw is completely contained within the pressurizer stainless steel cladding, that crack growth from the cladding into the inside surface of the pressurizer lower head carbon steel material will not occur over the next fuel cycle, and that there are no flaw(s) existing driven by fatigue into the lower head carbon steel base material. However, the licensee stated that in the unlikely event that these assumptions are untrue, quantitative analysis of a similar configuration has demonstrated that a flaw starting Relief Request 1 A29 of A44

at the cladding to base metal interface can grow for a significant length of time and remain stable with appropriate factors of safety. To enable the staff to determine whether these quantitative analyses in Reference 1 and 2 would bound the Turkey Point 3 heater sleeve, the staff requires the following additional information:

a. To enable the staff to determine whether the driving force for crack growth and the stability determination of the final flaw in the Turkey Point, Unit 3 J-groove weld is bounded by the analyses in References 1 and 2:

i. Provide the number and type of operating transients applicable for the life of the plant to the pressurizer heater sleeve J-groove weld, similar to the information contained in Table 4-3 of Reference 2. Discuss whether any of the transients applicable to the Turkey Point, Unit 3 heater sleeve would be significantly more severe that the corresponding transients evaluated in the fatigue crack growth analyses documented in References 1 and 2.

ii. Identify the key parameters in determining the driving force for crack growth and final flaw stability of the postulated flaw in the Turkey Point, Unit 3 heater sleeve assembly, and demonstrate these parameters are bounded by the corresponding parameters of the CCNPP-1 heater sleeve assembly evaluated in Reference 1 and the generic heater sleeve assembly evaluated in Reference 2.

b. Demonstrate that the material resistance to fracture (J-R curve) of the Turkey Point, Unit 3 pressurizer bottom head is equal to or greater than the material resistance to fracture used in the crack stability evaluations in Reference 1 and 2.

FPL Response to RAI 3.a.i.

The transients for Combustion Engineering (CE) designs are generally similar to those for Westinghouse designs, since both are pressurized water reactors, and the CE design closely followed the Westinghouse design in its implementation. One of the key differences is that the CE design has many more heatup (HU) and cooldown (CD) transient cycles (500 versus 200) than the Westinghouse design. This makes the use of the CE design transients conservative for use in evaluating the Turkey Point plant.

The CE generic evaluation [Reference 1] reported that only two transients contribute to fatigue crack growth. They are 500 cycles of HU/CD and 200 cycles of operating basis earthquake (OBE). However, OBE is only applicable to the hot leg (i.e., it is not applicable to heater penetrations). The temperature changes (AT) are 320°F and 220'F Relief Request 1 A30 of A44

for insurge/outsurge in the HU/CD transients. The applicable transients for the Turkey Point pressurizer are identified in [Reference 3] for extended power uprate (EPU) conditions; they are listed here in Table 1. As shown in Table 1, the surge temperature change for HU/CD is 320°F with 200 cycles each, which is similar to the temperature change of the transients evaluated in [1].

Relief Request 1 A31 of A44

Table 1: Turkey Point Units 3 and 4 EPU Pressurizer Thot Comparisons [4]

EPU"1 Original Design 'W Trasint Ccls AT Surge Flow Rate Surge AT~(3) Surge Flow Rate Surge (OF) (gpm) (OF) (gpm)

Normal Conditions Plant Heatup 200 (1) 300 320 300 Plant Cooldown 200 (1) 300 320 300 Plant Loading @5%IMin 14500 101.6 159 125 375 Unit Unload @5%/Min 14500 48.0 204 125 435 Small Step Load Increase 2000 50.8 222 75 360 Small Step Load Decrease 2000 52.1 742 75 1245 Large Step Load Decrease (95%) 200 48.0 2794 135 7500 Steady-State Fluctuations Initial"8 ) 150000 100.1 325 75 3390 Random(a) 3000000 97.6 325 75 3390 Boron Concentration Equalization 29000 (2) (2) 75 400 Feedwater Cycling47 ) 2000 132.7 1350 Turbine Roll Test 10 (2) (2) -21 -377 Upset Conditions Loss of Load 80 48.0 10318 125 15000 Loss of Power 40 82.0 4406 125 3300 Partial Loss of Flow 80 105.8 895 170 4800 Reactor Trip from Full Power 400 98.1 693 135 300 Inadvertent Auxiliary Spray 10 103.7 465 125 450 OBE 50 (2) (2) 0 (1) This transient is unchanged or less severe than original transient (2) There is no insurge during this transient. Therefore, the surge nozzle and lower head/shell will experience only the pressurizer water temperature transient. This transient will not cause significant thermal shock loads.

(3) Used in thermal stress calculations (4) References 3 through 5 (5) References 10 through 12 (6) Steady-State fluctuations occur between 15% and 100% power per Table A.1-4 of Reference 3. The maximum AT at 15% power is listed here.

(7) Insurge assumed to occur at minimum THor. This transient may be grouped with the Large Step Load Decrease transient in component fatigue evaluations.

Relief Request 1 A32 of A44

FPL Response to RAI 3.a.ii.

As documented in the detailed flaw evaluation in reference 17 of [1], CD without insurge is used to calculate the maximum end of cooldown KI to compare with the KIC allowable for the stability evaluation. This transient cools down from 653°F to 200°F at 200°F/hr, then cools for 200°F to 120°F at 75°F/hr. HU/CD sequences with relatively large insurge/outsurge transients dominate fatigue crack growth. The temperature ranges are 320°F and 220°F for the HU/CD with insurge transients with 500 cycles.

Per reference 13 of [3], the pressurizer HU rate is limited to 100°F/hr and a maximum CD rate of 2000 F. This is similar to, or less severe than, the CD without insurge in [1].

As listed in Table 1, the HU/CD surge AT is 320°F [3] with 200 cycles each. This is also very similar to the transients evaluated in [1]. Therefore, the transients are similar, but the numbers are conservatively high for the CE design.

FPL Response to RAI 3.b.

The pressurizer head is fabricated from SA-216 Gr. WCC cast steel, and the ASME Code KIC curve is directly applicable to this material. Over the years, a great deal of fracture toughness information has been obtained regarding this material, and a figure has been prepared to summarize the data as compared to the ASME Code reference KIC curve; see Figure 1. The fracture toughness was determined for nine heats of material, whose results are plotted [Reference 4]. Sufficient Charpy information was also obtained on these heats of material, and the NUREG-0800 method was used to estimate RTNDT, which was found to be 10°F for each heat. Figure 1 shows that the KIC curve is clearly appropriate for this steel.

Per [1], the KIC allowable for the pressurizer lower head (heater sleeves) at end of cooldown is 25.0 ksi4in, with RTNDT = 300F. The end of cooldown is 700F, conservatively using the RTNDT of 30 0 F, T - RTNDT = 400 F. The KIC at 40°F from Figure 1 is approximately 70 ksi4in, which is much higher than the KIC = 25.0 ksi4in used in [1]. Therefore, it is conservative to compare the CE stability evaluation in [1] to the Turkey Point plant.

Relief Request 1 A33 of A44

Figure 1: A216 Gr. WCC Fracture Toughness, KIC [4]

140 172 TO1 0 IMtA:312 120 o a CT 0- Mal NA

-0 I o 67C, .00, 430 453 243! lI A12 IC1 .0 Greentio1 w..cI Wese

'U openi Poinis amesent Vail4 KI Diii ASIAI r2d K

K,, Curve .0 .- 0 40 alp Vt -N-N 0

-zSO -Iw 0 50 MD er~erature. *1 Fig. lO-Cuft* hm Ing birthvaild And invalid luighms 4aM lor 9 heats of A216 I CC Cradal ceiJ slaa Relief Request 1 A34 of A44

NRC RAI 4

4. FPL concluded the leak occurred since the last inspection, since no leakage was observed during the previous refueling outage. However, since the original heater sleeve was roll expanded into the pressurizer bottom head shell, discuss the possibility that throughwall cracking of the J-groove weld may have occurred in earlier fuel cycles, since the tight fit might delay boric acid leakage from reaching the outer surface of the bottom head. If so, revise the qualitative assessment of flaw growth accordingly since the original postulated weld flaw would have had additional cycles to grow into the cladding and pressurizer bottom head.

FPL Response to RAI 4 The roll expansion of the pressurizer heater sleeve is to limit the loads on the existing internal weld much like an interference fit of a nozzle. While the roll expansion provides support for the nozzle it is not expected to provide a water tight seal against the pressure and dilation stresses of the reactor coolant system (RCS). INPO OE7490 and LER 95-007-01 (Docket No. 50-280) describes similar designed and installed pressurizer instrument nozzles with roll expansion which also exhibited leakage. This OE, the Turkey Point experience, as well as the interference fit penetrations in reactor vessel upper heads, suggest that the breach of an ID partial penetration pressure boundary weld will result in leakage.

As stated in the relief request, the cladding is subject to a post weld stress relief. The stresses in the clad are significantly reduced, if not compressive. It is reasonable to assume that a flaw that progressed through the pressure boundary weld to produce the leak, would take additional cycles to progress through the layer of clad (3/16" minimum) that separates the existing pressure boundary weld and the carbon steel base metal.

However, the assessments in References 1 and 2 both consider fatigue crack growth extension into the ferritic base metal before assessing the flaw stability. Therefore, the qualitative assessment does consider the flaw has progressed beyond the point of leakage and into the ferritic base material.

References

1. WCAP-15973-P-A, Rev. 0, "Low-Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs" (ML050700433) (non-proprietary version available at ML050700431)

Relief Request 1 A35 of A44

2. Areva Calculation 32-9156231-000, "CCNPP-1 PZR Heater Sleeve As-Left J-Groove Weld Flaw Evaluation for IDTB Repair - Non-Proprietary,"

(ML11132A183)

3. Westinghouse Calculation Note, CN-SGDA-08-55, Rev. 2, "Evaluation of Pressurizer for EPU at Turkey Point Units 3 and 4 (NSSS Power 2652 MWt),"

December 7, 2011. (Westinghouse Proprietary Class 2)

4. Westinghouse Report, 72-1 E7-FCAST-R1, "Fracture Toughness and Crack Growth Rate Properties for A216 WCC Grade Cast Steel," April 7, 1972.

(Westinghouse Proprietary Class 2)

Relief Request 1 A36 of A44

C 10 CFR 50.55a L-2014-105 April 14, 2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Unit 3 Docket No. 50-250 Inservice Inspection Plan - Fifth Inspection Interval Unit 3 Relief Request No. 1 - Response to Follow-up Request for Additional Information

References:

1) Florida Power & Light Company letter L-2014-096 to the Nuclear Regulatory Commission, "Inservice Inspection Plan - Fifth Inspection Interval, Unit 3 Relief Request No. 1", dated April 4, 2014

2) Email to Florida Power & Light Company, "Request for Additional Information Turkey Point Unit 3 Fifth Inspection Interval Relief Request No. 1 Revision 0 Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal Docket No. 50-250", dated April 8, 2014

3) Florida Power & Light Company letter L-2014-100 to the Nuclear Regulatory Commission, "Inservice Inspection Plan - Fifth Inspection Interval, Unit 3 Relief Request No. 1 - Response to Request for Additional Information", dated April 9, 2014

4) Email to Florida Power & Light Company, "Follow-up Request for Additional Information Turkey Point Unit 3 Fifth Inspection Interval Relief Request No. 1 Revision 0 Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal Docket No. 50-250", dated April 10, 2014 Pursuant to 10 CFR 50.55a(a)(3)(ii), Florida Power & Light Company (FPL) requested Nuclear Regulatory Commission (NRC) approval to use an alternative to a certain requirement in the ASME Boiler and Pressure Vessel Code,Section XI, in Reference 1.

A NRC request. for additional information (RAI) was forwarded to FPL in Reference 2.

FPL responded to the Reference 2 RAI via Reference 3. A follow-up RAI was forwarded to FPL by the NRC in Reference 4. Attached is the FPL response to the Florida Power & Light Company 9760 SW 344 '" St.. Florida City, FL 33035 Relief Request 1 A37 of A44

Florida Power & Light Company L-2014-105 Page 2 of 2 Reference 4 RAI.

Please contact Robert Tomonto, Licensing Manager, at 305-246-7327 if you have any questions or require any additional information about this submission.

Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant

Attachment:

Response to Follow-up Request for Additional Information Concerning Turkey Point Unit 3 Relief Request No. 1 for the 5 th Inspection Interval cc: Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant Relief Request 1 A38 of A44

By email dated April 10, 2014, the Nuclear Requlatory Commission (NRC) staff forwarded to the Florida Power & Light Company (FPL) a follow-up request for additional information (RAI) concerning FPL's request for relief from a certain provision of the ASME Boiler and Pressure Vessel Code. FPL submitted the request for relief by letter L-2014-096 dated April 4, 2014 and responded to an initial April 8, 2014 RAI on April 9, 2014 (FPL letter L-2014-100). The FPL response to the April 10, 2014 RAI follows.

NRC RAI RAI 5 (Follow up to RAI 3a)

The response to Request for Additional Information (RAI) 3a in FPL's April 9, 2014 letter emphasizes that heatup and cooldown transients with insurge/outsurge transients dominate fatigue crack growth in the generic evaluation for Combustion Engineering (CE) designed pressurizers (Ref. 1, 2). In Table 1 of the RAI response, transients were listed that were not considered in the generic CE evaluation. Some of these transients have very large numbers of cycles over the life of the plant, such as plant loading at 5%

per minute, plant unloading at 5% per minute, and steady state fluctuations (initial and random). The temperature range for some of these cycles, although less than that of the insurge/outsurge during heatup and cooldown, is around 100 degrees F for some of these transients.

Would any of the transients listed in Table 1 that were not considered in the generic CE evaluation be expected to contribute significantly to fatigue crack growth? If not, provide an explanation for why these transients would not be expected to be significant contributors to fatigue crack growth. If any of the other transients would contribute significantly to fatigue crack growth, provide justification that fatigue crack growth for the Turkey Point, Unit 3 pressurizer would remain bounded by the generic evaluation.

FPL Response to RA1 5 Table 1 in the response to RAI-3.a. lists design transients for the Turkey Point Unit 3 and 4 pressurizers. The transients and cycles are generally similar between Westinghouse and Combustion Engineering (CE) designs, except that there are 500 heatup/cooldown (HU/CD) cycles in the CE design, and only 200 in the Westinghouse design. This makes use of the CE design calculation conservative for this application.

The CE evaluation in References 1 and 2 reviewed the pressurizer transients of the participating CE plants, and concluded that only HU/CD and operating basis earthquake (OBE) made any meaningful contribution to fatigue crack growth. The purpose of the pressurizer is to maintain system pressure while accounting for expansion and contraction of the system volume which occurs as the temperature changes. Most of the action in the pressurizer occurs as it experiences insurges and outsurges, with the Relief Request 1 A39 of A44

accompanying temperature changes in the bottom head and surge nozzle. It is also important to note that the transient cycles listed in the table in the response to RAI-3.a.

are for the design life of the plant, and the relief request is for only one operating cycle.

RAI 6 (Follow up to RAI 3b)

In response to RAI 3, Item b, FPL provided a graph of fracture toughness (Kic) versus temperature for the Turkey Point, Unit 3 pressurizer bottom head material. However, both of the heater sleeve flaw evaluations referenced in the relief request (Ref. 1, 2) used elastic-plastic fracture mechanics (EPFM) techniques to demonstrate stability of the final flaw, because the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code), Section Xl linear elastic fracture mechanics (LEFM) acceptance criteria were not met. This is specifically noted in Section 6.3.3.2 of Reference 3. Also in Reference 2, EPFM was used as the basis for accepting the final flaws.

Therefore, the staff requests that FPL (1) provide the material resistance (J-R) curve for the Turkey Point, Unit 3 pressurizer bottom head material (2) justify the use of the J-R curve in this application if it is not based on test data, and (3) demonstrate that the J-R curve is bounded by (i.e., provides equivalent or greater resistance to fracture) the J-R curve used in Refs 1 and 2.

FPL Response to RAI 6 The SA-216 Gr. WCC cast steel has a minimum yield strength less than 50 ksi, therefore, the ASME Code reference toughness curves apply directly to them. To further demonstrate this, additional fracture toughness tests were completed on materials of the same time period [4], and those were provided in the previous RAI response. This demonstrates that these materials are similar in behavior to those used in the previous evaluations, and the fracture toughness models used in those evaluations are equally applicable here.

The results summary sections of [1 and 3] listed stability results using the linear elastic fracture mechanics method (LEFM, K, versus Klc) for the transients, except insurge/outsurge. The end of cooldown (CD) is limiting among these transients. The elastic-plastic fracture mechanics method (EPFM, Japplied and J-R curves) was used to evaluate stability for insurge/outsurge transients. Per Figure 6-16 of [3], the limiting event for stability is 320°F CD in-surge.

There are no J-integral fracture resistance (J-R) curve data available for the pressurizer head SA-216 Gr. WCC cast steel materials, as this type of fracture toughness testing was not required in the 1965 ASME Section III Code. The material J-R curve used for Relief Request 1 A40 of A44

the evaluations in [1 and 3] was for typical reactor pressure vessel steel. The J-R curve was determined from Equation 17 of Regulatory Guide (RG) 1.161 (Ref. 5), without the margin factor (MF) of 0.749. As noted in Section 6.3.3.2.2 of [3], an MF of 1.0 was used since Japplied was conservatively multiplied by a factor of 3.0 in order to address the recommended safety factor (SF) of 1.15 and 1.25 for Levels A and B, respectively.

Furthermore, a lower bound Charpy upper shelf energy (CVNUSE) value of 70 ft-lbs [3]

was used in lieu of unavailable plant-specific Charpy tests of the pressurizer plate. This value is consistent with Branch Technical Position (BTP 5-2), Fracture Toughness Requirements, for pressure vessel materials.

The relevant input data used calculating Japplied and JMaterial are:

cy = 43.74 ksi, Material Yield Strength at Temperature @ 610-F CVNUSE = 70 ft-lb, Upper Shelf Energy from Charpy test The model for the J-R curve in equation 17 of [5] is:

JR = (MF) {CI(Aa)C2 exp[C3 (Aa)C4])

For high toughness materials, where the sulfur level is below 0.018%, the constants for this equation are provided in [5] as:

CI = exp[-2.44 + 1.13 In(CVN) - 0.00277 77 C2 = 0.077 + 0.116 InC1 C3 = -0.0182 - 0.00921nC1 C4 = -0.409 From this discussion and the preceding equation, it is shown that the J-R curve equation is primarily a function of the CVNUSE. For the J-R calculations shown in [3], the Charpy upper shelf energy was 70 ft-lb.

There are no plant specific data available for the SA-216 Gr. WCC cast steel used in the Turkey Point pressurizer heads. However, a number of heats of the same type of material were tested in [4], and full Charpy curves were obtained on three of them.

These Charpy curves, shown in Figure 1 through Figure 3, demonstrate that the upper shelf Charpy energy is at least 100 ft-lb for each heat. Tests also demonstrate that the sulfur level for these materials is typically less than 0.018 weight percent. Therefore, the Regulatory Guide equations used in [3] for the previous evaluation are directly applicable.

Relief Request 1 A41 of A44

Based on these evaluations, the model used in [1 and 3] is more limiting than a similar model based on the material of the Turkey Point Pressurizer head.

.0 a

S 4

ot

" -50 0 so NO M 20 250 Temperature, OF Figure 1: Temperature Dependence of the Charpy "V" Notch Impact Properties of SA-216 Gr. WCC, Heat 4312. (Sulfur content = 0.013 wt. %) [4]

Relief Request 1 A42 of A44

140 130 120 110 100 a, Ca Temperature, IF Figure 2: Temperature Dependence of the Charpy "V" Notch impact properties of SA-216 Gr. WCC, Heat 4394. (Sulfur content = 0.011 wt. %)

I E 50 Temperature, 'F Figure 3: Temperature Dependence of the Charpy "V" Notch impact properties of SA-216 Gr. WCC, Heat 4547. (Sulfur content = 0.010 wt. %)

Relief Request I A43 of A44

References

1. WCAP-1 5973-P-A, Rev. 0, "Low-Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs" (ML050700433) (non-proprietary version available at ML050700431)

2. Areva Calculation 32-9156231-000, "CCNPP-1 PZR Heater Sleeve As-Left J-Groove Weld Flaw Evaluation for IDTB Repair - Non-Proprietary,"

(ML11132A183)

3. Calculation CN-CI-02-71, Rev 1, "Summary of Fatigue Crack Growth Evaluation Associated with Small Diameter Nozzles in CEOG Plants." (ADAMS Accession No. ML041540237)

4. Westinghouse Report, 72-1 E7-FCAST-R1, "Fracture Toughness and Crack Growth Rate Properties for A216 WCC Grade Cast Steel," April 7, 1972.

(Westinghouse Proprietary Class 2)

5. US NRC Regulatory Guide 1.161, Rev. 0, "Evaluation of Reactor Pressure Vessels with Charpy Upper-Shelf Energy Less Than 50 Ft-Lb," June 1995.

Relief Request 1 A44 of A44

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Relief Request No. 2 "ALTERNATIVE EXAMINATIONS FOR REGENERATIVE HEAT EXCHANGER"

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Relief Request No. 3 "EXAMINATION OF SNUBBER ATTACHMENT HARDWARE"

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 Appendix B Class 1,2 and 3 Component and Component Support ISI Examination Summary Tables B1

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 APPENDIX B INSERVICE INSPECTION EXAMINATION

SUMMARY

TABLES The total numbers of Turkey Point Units 3 and 4 Class 1, 2 and 3 components and supports subject to examination at the start of the Fifth Interval are shown in the Summary Tables in Appendix B. The complete list of these components and supports and their relevant ISI related details is maintained and updated on an ongoing basis in the Turkey Point Units 3 and 4 ISI database.

B.1 Summary Tables for ASME Section XI Inservice Inspection Examinations The Class 1, 2 and 3 components and component supports requiring examination per ASME Section Xl are shown in Tables 10 and 11 for Turkey Point Units 3 and 4, respectively. ASME Section Xl Inservice Inspection Summary Tables 10 and 11 provides the following information:

B.1.1 Examination Category This column lists the Examination Category as identified in ASME Section Xl, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

B.1.2 Item Number This column lists the Code Item No. as defined in ASME Section Xl, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

B.1.3 Description of Components Examined This column lists a description of the components examined as identified in ASME Section Xl, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

B.1.4 Number of Components This column lists the total population of components potentially subject to examination.

The number of components actually examined during the inspection interval will be based upon the Code requirements for the subject Item Number.

B.1.5 Examination Method(s)

The column lists the examination method(s) required byASME Section Xl, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

B.1.6 Request Number(s)

This column provides a listing of applicable Relief Requests. If a request number is identified, see the corresponding Relief Request in Appendix A of this ISI Program Plan.

B2

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Relief Category Number Description of Components Examined Components Method(s) Number(s)

Shell Welds 81.11 Circumferential 3 Volumetric B1.12 Longitudinal 0 Volumetric B-A Pressure Head Welds Retaining 81.21 Circumferential 1 Volumetric Welds in 81.22 Meridional 0 Volumetric Reactor Vessel 81.30 Shell-to Flange Weld 1 Volumetric 81.40 Head-to-Flange Weld 0 Volumetric and Surface 81.50 Repair Welds in the Beltline Region 0 Volumetric B3

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Categoy Number Description of Components Examined Components Method(s) Number s Pressurizer Shell to Head Welds B2.11 Circumferential 2 Volumetric B2.12 Longitudinal 2 Volumetric Pressurizer Head Welds B2.21 Circumferential 0 Volumetric B2.22 Meridional 0 Volumetric B-B Steam Generator (Primary Side) Head Welds Pressure 82.31 Circumferential 0 Volumetric Retaining B2.32 Meridional 0 Volumetric Welds in Vessels Other B2.40 Tubesheet to Head Weld 3 Volumetric than Reactor Vessels Heat Exchangers (Primary Side) Head Welds B2.51 Circumferential 6 Volumetric 2 B2.52 Meridional 0 Volumetric Heat Exchangers (Primary Side) Shell 82.60 Tubesheet-to-Head Welds 0 Volumetric B2.70 Longitudinal Welds 0 Volumetric B2.80 Tubesheet-to-Sheet Welds 6 Volumetric 2 B4

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B3.90 Nozzle-to-Vessel Welds 6 Volumetric B3.100 Nozzle Inside Radius Section (Examined with B3.90) 6 Volumetric Pressurizer B3. 110 Nozzle-to-Vessel Welds 0 Volumetric B-D B3.120 Nozzle Inside Radius Section 6 Volumetric Full (See Note 1)

Penetration Steam Generator (Primary Side)

Welded B3.130 Nozzle-to-Vessel Welds 0 Volumetric Nozzles in B3.140 Nozzle Inside Radius Section 6 Volumetric Vessels (See Note 1)

Heat Exchangers (Primary Side)

B3. 150 Nozzle-to-Vessel Welds 12 Volumetric 2 B3.160 Nozzle Inside Radius Section 12 Volumetric 2 B5

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination I Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B5.10 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 6 Volumetric and Surface B5.20 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface B5.30 Nozzle-to-Safe End Socket Welds 0 Surface Pressurizer B5.40 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 6 Volumetric B-F and Surface Pressure B5.50 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface Retaining B5.60 Nozzle-to-Safe End Socket Welds 0 Surface Dissimilar Metal Welds Steam Generator In Vessel B5.70 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 6 Volumetric Nozzles and Surface B5.80 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface B5.90 Nozzle-to-Safe End Socket Welds 0 Surface Heat Exchangers B5.100 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 0 Volumetric and Surface B5.110 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface B5.120 Nozzle-to-Safe End Socket Welds 0 Surface B6

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination 1 Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B6.10 Closure Head Nuts 58 VT-1 Visual B6.20 Closure Studs 58 Volumetric or Surface B6.40 Threads In Flange 58 Volumetric B6.50 Closure Washers, Bushings 116 VT-1 Visual B-G-1 Pressurizer Pressure B6.60 Bolts and Studs -0 Volumetric Retaining B6.70 Flange Surface, when connection disassembled 0 VT-I Visual Bolting B6.80 Nuts, Bushings, and Washers 0 VT-1 Visual Greater Than 2 in. In Steam Generator Diameter B6.90 Bolts and Studs 0 Volumetric B6.100 Flange Surface, when connection disassembled 0 VT-i Visual B6.110 Nuts, Bushings, and Washers 0 VT-1 Visual Heat Exchangers B6.120 Bolts and Studs 0 Volumetric B6.130 Flange Surface, when connection disassembled 0 VT-I Visual B6.140 Nuts, Bushings, and Washers 0 VT-i Visual B7

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Piping B6.150 Bolts and Studs 0 Volumetric B6.160 Flange Surface, when connection disassembled 0 VT-1 Visual B6.170 Nuts, Bushings, and Washers 0 VT-1 Visual B-G-1 Pressure Pumps Retaining B6.180 Bolts and Studs 3 (sets) Volumetric Bolting or Surface Greater Than B6.190 Flange Surface, when connection disassembled 3 (sets) VT-1 Visual 2 in. In B6.200 Nuts, Bushings, and Washers 3 (sets) VT-1 Visual Diameter (cont'd) Valves B6.210 Bolts and Studs 0 Volumetric B6.220 Flange Surface, when connection disassembled 0 VT-1 Visual B6.230 Nuts, Bushings, and Washers 0 VT-1 Visual B8

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B7.10 Bolts, Studs and Nuts 0 VT-1 Visual Pressurizer B7.20 Bolts, Studs and Nuts 1 (set) VT-1 Visual Steam Generator B7.30 Bolts, Studs and Nuts 6 (sets) VT-1 Visual B-G-2 Pressure Heat Exchangers Retaining B7.40 Bolts, Studs and Nuts 0 VT-1 Visual Bolting, 2 in and Less Pipina In B7.50 Bolts, Studs and Nuts 9 (sets) VT-1 Visual Diameter B Pumps 87.60 Bolts, Studs and Nuts 0 VT-1 Visual Valves B7.70 Bolts, Studs and Nuts 13 (sets) VT-1 Visual B9

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination 1 Request Category Number Description of Components Examined Component Method(s) Number(s)

NPS 4 or Larger B9.11 Circumferential Welds 205 Surface and Volumetric Less Than NPS 4 B9.21 Circumferential welds other than PWR high pressure 127 Surface B-J safety injection systems Pressure B9.22 Circumferential welds of PWR high pressure safety 0 Volumetric Retaining injection systems Welds in Piping Branch Pipe Connection Welds B9.31 NPS 4 or Larger 7 Surface and Volumetric B9.32 Less Than NPS 4 17 Surface B9.40 Socket Welds 399 Surface B-K Welded Pressure Vessels B-KcWents Attachments B10.10 Welded Attachments Ppn 9 Surface 2 For Class 1 Ppn ForsCls B10.20 Welded Attachments 25 Surface Vessels, Pumps Piping, B10.30 Welded Attachments 3 Sets Surface Pumps, and Vle Valves B10.40 Valves Welded Attachments 0 Surface B10

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

B-L-2 Pumps Pump B12.20 Pump Casing V'-3 Visual Casings B-M-2 Valves Valve Body B12.50 Valves Exceeding NPS 4, Valve Internal Surfaces 13 VT-3 Visual B-N-1 Reactor Vessel Interior of B13.10 Vessel Interior 9 V'-3 Visual Reactor Vessel B-N-2 Reactor Vessel (BWR)

Welded Core B13.20 Interior Attachments Within Beltline Region N/A VT-I Visual Support B13.30 Interior Attachments Beyond Beltline Region N/A VT-3 Visual Structures B13.40 Core Support Structure N/A VT-3 Visual And Interior Attachments Reactor Vessel (PWR) to Reactor B13.50 Interior Attachments Within Beltline Region 0 VT-1 Visual Vessels B13.60 Interior Attachments Beyond Beltline Region 1 VT-3 Visual Bli

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number s B-N-3 Removable Reactor Vessel (PWR)

Core Support B13.70 Core Support Structure 30 VT-3 Visual Structures 11 _ _

Reactor Vessel (BWR)

B14.10 Welds in Control Rod Drive (CRD) Housing N/A Volumetric B-O or Surface Pressure Reactor Vessel (PWR)

Retaining B14.20 Welds in Control Rod Drive (CRD) Housing 24 peripheral Volumetric Welds in housing welds or Surface Control Rod Housing B14.21 Welds in In-Core Instrumentation Nozzle (ICI) 0 Volumetric I Housings > NPS 2 or Surface B-P B15.10 Pressure Retaining Components [IWB-5222(a)] Class 1 VT Visual All Pressure Pressure Retaining Boundary Components B15.20 Pressure Retaining Components [IWB-5222(b)] Boundary VT Visual B12

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISl EXAMINATION

SUMMARY

Examination Item f Number of Examination Request Category Number Description of Components Examined j Components Method(s) Number(s)

B-Q B16.10 Steam Generator Tubing in Straight Tube Design N/A Volumetric Steam Generator B16.20 Steam Generator Tubing in U-Tube Design 3 Steam Volumetric Tubing Generators C-A C1.10 Shell Circumferential Welds 11 Volumetric Pressure Retaining C1.20 Head Circumferential Welds 5 Volumetric Welds In Pressure C1.30 Tubesheet-to-Shell Weld 3 Volumetric Vessels B13

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number s)

Nozzles in Vessels < 1/2 in. Nominal Thickness C2.11 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 0 Surface Weld Nozzles Without Reinforcing Plate in Vessels > % in.

Nominal Thickness C2.21 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 6 Volumetric Weld And Surface C-B C2.22 Nozzle Inside Radius Section 6 Volumetric Pressure Retaining Nozzles With Reinforcing Plate in Vessels > 1 in.

Nozzle Welds Nominal In Vessels Thickness C2,31 Reinforcing Plate Welds to Nozzle and Vessel 8 Surface C2.32 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 0 Volumetric Welds (When Inside of Vessel is Accessible)

C2.33 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 4 VT-2 Visual Welds (When Inside of Vessel is Inaccessible)

B14

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

C-C Pressure Vessels Welded C3.10 Welded Attachments 4 Surface Attachments Pipina for C3.20 Welded Attachments 89 Surface Class 2 Pumps Vessels, C3.30 Welded Attachments 0 Surface Piping, Valves Pumps, and C3.40 Welded Attachments 0 Surface Valves C-D Pressure Vessels Pressure C4.10 Bolts and Studs 0 Volumetric Retaining Piping Bolting C4.20 Bolts and Studs 0 Volumetric Greater Pumps than 2 C4.30 Bolts and Studs 0 Volumetric In. In Diameter Valves C4.40 Bolts and Studs 0 Volumetric B15

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Piping Welds > 318 in. Nominal Wall Thickness for PiDina > NPS 4 C5.11 Circumferential Weld 202 Surface and Volumetric C-F-1 Piping Welds > 115 in. Nominal Wall Thickness for Pressure Piping > NPS 2 And < NPS 4 Retaining C5.21 Circumferential Weld 138 Surface and Welds in Volumetric Austenitic C5.30 Socket Welds 108 Surface Stainless Steel Or High Alloy Piping Branch Connections of Branch Piping Piping > NPS 2 C5.41 Circumferential Weld 4 Surface B16

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Piping Welds > 3/8 in. Nominal Wall Thickness for Piping > NPS 4 C5.51 Circumferential Weld 303 Surface and Volumetric C-F-2 Piping Welds > 1/5 in. Nominal Wall Thickness for PreFs2 Piping > NPS 2 And < NPS 4 Pressure C5.61 Circumferential Weld 58 Surface and Retaining Volumetric Welds in C5.70 Socket Welds 0 Surface Carbon or Low Alloy Steel Piping Branch Connections of Branch Piping Piping > NPS 2 C5.81 Circumferential Weld 21 Surface B17

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

C-H Class 2 AllPressure C7.10 Pressure Retaining Components Pressure VT-2 Visual Retaining Boundary Components Pressure Vessels DA D1.10 Welded Attachments VT-i Visual T1Vsa D-AD117 Welded Attachments P~n FrCass D1.20 Welded Attachments 98 For Class 311 VT-1 Visual Vessels, Pumps Piping, D1.30 Welded Attachments 0 VT-1 Visual Pumps And Valves Valves D1.40 Welded Attachments 0 VT-1 Visual B18

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 10 TURKEY POINT UNIT 3 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Class 3 D-B D2.10 Pressure Retaining Components Pressure VT-2 Visual All Pressure Boundary Retaining Components F1.10 Class 1 Piping Supports 156 VT-3 Visual 3 F1.20 Class 2 Piping Supports 255 VT-3 Visual 3 F-A Supports (See Note 2) F1.30 Class 3 Piping Supports 287 VT-3 Visual 3 F1.40 Supports Other Than Piping Supports 45 VT-3 Visual 3 (Class 1, 2, 3 and MC)'

Notes:

1. In accordance with 1 OCFR50.55a(b)(2)(xxi)(A), the 1998 Edition of ASME Section XI without Addenda must be applied for Examination Category B-D, Item Numbers B3.120 and B3.140. Although the 1999 Addenda eliminated Item Numbers B3.120 and B3.140, these Code Item Numbers are applicable and are reflected in the Turkey Point ISI Program Plan for the fifth interval.

2. The examination and testing of snubbers, including attachment hardware, shall be conducted in accordance with the Snubber Testing Program as documented in Turkey Point Procedure 0-OSP-1 05.1.

B19

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Relief Description of Components Examined Components Method(s) Request Category Number It Numberso Shell Welds B13.11 Circumferential 3 Volumetric B1,12 Longitudinal 0 Volumetric B-A Pressure Head Welds Retaining 81.21 Circumferential 1 Volumetric Welds in 81.22 Meridional Volumetric Reactor 0 Vessel B13.30 Shell-to Flange Weld Volumetric 81.40 Head-to-Flange Weld 1 Volumetric 0 and Surface 81.50 Repair Welds in the Beltline Region Volumetric 0

B20

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Pressurizer Shell to Head Welds B2.11 Circumferential 2 Volumetric B2.12 Longitudinal 2 Volumetric Pressurizer Head Welds B2.21 Circumferential 0 Volumetric B2.22 Meridional 0 Volumetric B-B Steam Generator (Primary Side) Head Welds Pressure B2.31 Circumferential 0 Volumetric Retaining B2.32 Meridional 0 Volumetric Welds in Vessels Other B2.40 Tubesheet to Head Weld 3 Volumetric than Reactor Vessels Heat Exchangers (Primary Side) Head Welds B2.51 Circumferential 6 Volumetric 2 B2.52 Meridional 0 Volumetric Heat Exchangers (Primary Side) Shell B2.60 Tubesheet-to-Head Welds 0 Volumetric B2.70 Longitudinal Welds 0 Volumetric B2.80 Tubesheet-to-Sheet Welds 6 Volumetric 2 B21

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination 1 Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B3.90 Nozzle-to-Vessel Welds 6 Volumetric B3.100 Nozzle Inside Radius Section (Examined with B3.90) 6 Volumetric Pressurizer B3. 110 Nozzle-to-Vessel Welds 0 Volumetric B-D B3.120 Nozzle Inside Radius Section 6 Volumetric Full (See Note 1)

Penetration Steam Generator (Primary Side)

Welded B3.130 Nozzle-to-Vessel Welds 0 Volumetric Nozzles in B3.140 Nozzle Inside Radius Section 6 Volumetric Vessels (See Note 1)

Heat Exchangers (Primary Side)

B3.150 Nozzle-to-Vessel Welds 12 Volumetric 2 B3.160 Nozzle Inside Radius Section 12 Volumetric 2 B22

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 t Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B5.10 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 6 Volumetric and Surface B5.20 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface B5.30 Nozzle-to-Safe End Socket Welds 0 Surface Pressurizer B5.40 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 6 Volumetric B-F and Surface Pressure B5.50 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface Retaining B5.60 Nozzle-to-Safe End Socket Welds 0 Surface Dissimilar Metal Welds Steam Generator In Vessel B5.70 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 6 Volumetric Nozzles and Surface B5.80 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface B5.90 Nozzle-to-Safe End Socket Welds 0 Surface Heat Exchangers B5.100 NPS 4 or Larger, Nozzle-to-Safe End Butt Welds 0 Volumetric and Surface B5.110 Less than NPS 4 Nozzle-to-Safe End Butt Welds 0 Surface B5.120 Nozzle-to-Safe End Socket Welds 0 Surface B23

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B6.10 Closure Head Nuts 58 VT-1 Visual B6.20 Closure Studs 58 Volumetric or Surface B6.40 Threads In Flange 58 Volumetric B6.50 Closure Washers, Bushings 116 Volumetric VT-1 Visual B-G-1 Pressurizer Pressure B6.60 Bolts and Studs 0 Retaining B6.70 Flange Surface, when connection disassembled 0 Volumetric Retaing B6.80 Nuts, Bushings, and Washers 0 VT-1 Visual Bolting VT-i Visual Greater Than 2 in. In Steam Generator Diameter B6.90 Bolts and Studs 0 Diameter B6.100 Flange Surface, when connection disassembled 0 Volumetric B6.110 Nuts, Bushings, and Washers 0 VT-1 Visual VT-1 Visual Heat Exchangers B6.120 Bolts and Studs 0 B6.130 Flange Surface, when connection disassembled 0 Volumetric B6.140 Nuts, Bushings, and Washers 0 VT-I Visual I'VT-I Visual B24

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Pipingi B6.150 Bolts and Studs 0 Volumetric B6.160 Flange Surface, when connection disassembled 0 VT-1 Visual B6.170 Nuts, Bushings, and Washers 0 VT-I Visual B-G-1 Pressure Pumps Retaining B6.180 Bolts and Studs 3 (sets) Volumetric Bolting or Surface Greater Than B6.190 Flange Surface, when connection disassembled 3 (sets) VT-1 Visual 2 in. In B6.200 Nuts, Bushings, and Washers 3 (sets) VT-1 Visual Diameter (cont'd) Valves B6.210 Bolts and Studs 0 Volumetric B6.220 Flange Surface, when connection disassembled 0 VT-1 Visual B6.230 Nuts, Bushings, and Washers 0 VT-1 Visual B25

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015

'I--

TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination I Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Reactor Vessel B7.10 Bolts, Studs and Nuts 0 VT-i Visual Pressurizer B7.20 Bolts, Studs and Nuts 1 (set) VT-1 Visual Steam Generator B7.30 Bolts, Studs and Nuts 6 (sets) VT-1 Visual B-G-2 Pressure Heat Exchangers Retaining B7.40 Bolts, Studs and Nuts 0 VT-I Visual Bolting, 2 in and Less Piping In B7.50 Bolts, Studs and Nuts 9 (sets) VI-I Visual Diameter Pumps 87.60 Bolts, Studs and Nuts 0 VT-1 Visual Valves 87.70 Bolts, Studs and Nuts 13 (sets) VT-1 Visual B26

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request ategory Number Description of Components Examined Components Method s Number(s)

NPS 4 or Larger B9.11 Circumferential Welds 219 Surface and Volumetric NPS 4 Less Than B9.21 Circumferential welds other than PWR high pressure 135 Surface B-J safety injection systems Pressure B9.22 Circumferential welds of PWR high pressure safety 0 Volumetric Retaining injection systems Welds in Piping Branch Pipe Connection Welds B9.31 NPS 4 or Larger 7 Surface and Volumetric B9.32 Less Than NPS 4 17 Surface B9.40 Socket Welds 421 Surface B-K Welded Pressure Vessels B-KcWents B10.10 Welded Attachments 9 Surface 2 Attachments Pipina For Class 1 B10.20 Welded Attachments 26 Surface Vessels, Pumps Piping, B10.30 Welded Attachments 3 Sets Surface Pumps, and Vle Vavs Valves B10.40 Welded Attachments VWlded A 0 Surface B27

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method s) Number(s)

B-L-2 Pumps Pump B12.20 Pump Casing 3 VT-3 Visual Casings B-M-2 Valves Valve Body B12.50 Valves Exceeding NPS 4, Valve Internal Surfaces 13 VT-3 Visual B-N-1 Reactor Vessel Interior of B13.10 Vessel Interior 9 VT-3 Visual Reactor Vessel B-N-2 Reactor Vessel (BWR)

Welded Core B13.20 Interior Attachments Within Beltline Region N/A VT-1 Visual Support B13.30 Interior Attachments Beyond Beltline Region N/A VT-3 Visual Structures B13.40 Core Support Structure N/A VT-3 Visual And Interior Attachments Reactor Vessel (PWR) to Reactor B1 3.50 Interior Attachments Within Beltline Region 0 VT-1 Visual

. Vessels B13.60 Interior Attachments Beyond Beltline Region 1 VT-3 Visual B28

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

B-N-3 Removable Reactor Vessel (PWR)

Core Support B13.70 Core Support Structure 30 VT-3 Visual Structures Reactor Vessel (BWR)

B14.10 Welds in Control Rod Drive (CRD) Housing N/A Volumetric B-O or Surface Pressure Reactor Vessel (PWR)

Retaining B14.20 Welds in Control Rod Drive (CRD) Housing 24 peripheral Volumetric Welds in housing welds or Surface Control Rod Housing B14.21 Welds in In-Core Instrumentation Nozzle (ICI) 0 Volumetric Housings > NPS 2 or Surface B-P B15.10 Pressure Retaining Components [IWB-5222(a)] Class 1 VT Visual All Pressure Retaining I resu ry Components B15.20 Pressure Retaining Components [IWB-5222(b)] Boundary VT Visual B29

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISl EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number s B-Q B16.10 Steam Generator Tubing in Straight Tube Design N/A Volumetric Steam Generator B16.20 Steam Generator Tubing in U-Tube Design 3 Steam Volumetric Tubing Generators C-A Peu C1.10 Shell Circumferential Welds 11 Pressure Volumetric Retaining C1.20 Head Circumferential Welds 5 Volumetric Welds In Pressure C1.30 Tubesheet-to-Shell Weld 3 Volumetric Vessels B30

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

Nozzles in Vessels < 1/%in. Nominal Thickness C2.11 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 0 Surface Weld Nozzles Without Reinforcing Plate in Vessels > 1/2 in.

Nominal Thickness C2.21 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 7 Volumetric Weld And Surface C-B C2.22 Nozzle Inside Radius Section 7 Volumetric Pressure Retaining Nozzles With Reinforcing Plate in Vessels > % in.

Nozzle Welds Nominal In Vessels Thickness C2.31 Reinforcing Plate Welds to Nozzle and Vessel 6 Surface C2.32 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 0 Volumetric Welds (When Inside of Vessel is Accessible)

C2.33 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) 3 VT-2 Visual Welds (When Inside of Vessel is Inaccessible)

B31

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

C-C Pressure Vessels Welded C3.10 Welded Attachments 4 Surface Attachments Piping for C3.20 Welded Attachments 72 Surface Class 2 Pumps Vessels, C3.30 Welded Attachments 0 Surface Piping, Valves Pumps, and C3.40 Welded Attachments 0 Surface Valves C-D Pressure Vessels Pressure C4.10 Bolts and Studs 0 Volumetric Retaining Piping Bolting C4.20 Bolts and Studs 0 Volumetric Greater Pumps than 2 C4.30 Bolts and Studs 0 Volumetric In. In Diameter C4.40 Valves Bolts and Studs 0- Volumetric B32

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s Piping Welds > 318 in. Nominal Wall Thickness for Piping > NPS 4 C5.11 Circumferential Weld 209 Surface and Volumetric C-F-1 Piping Welds > 1/5 in. Nominal Wall Thickness for Pressure Piping > NPS 2 And < NPS 4 Retaining C5.21 Circumferential Weld 143 Surface and Welds in Volumetric Austenitic C5.30 Socket Welds 110 Surface Stainless Steel Or High Alloy Piping Branch Connections of Branch Piping Piping > NPS 2 C5.41 Circumferential Weld 6 Surface B33

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number s Piping Welds > 3/8 in. Nominal Wall Thickness for Piping > NPS 4 C5.51 Circumferential Weld 266 Surface and Volumetric Piping Welds > 1/5 in. Nominal Wall Thickness for C-F-2 Piping > NPS 2 And < NPS 4 Pressure C5.61 Circumferential Weld 54 Surface and Retaining Volumetric Welds in C5.70 Socket Welds 0 Surface Carbon or Low Alloy Steel Piping Branch Connections of Branch Piping Piping > NPS 2 C5.81 Circumferential Weld 21 Surface B34

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Number of Examination Request Category Number Description of Components Examined Components Method(s) Number(s)

C-H Class 2 All Pressure C7.10 Pressure Retaining Components Pressure VT-2 Visual Retaining Boundary Components BoT-disa Pressure Vessels D-A D1.10 Welded Attachments 7 VT-1 Visual Welded AttachmentsPinc FrCass D1.20 Welded Attachments 99 For Class 3 VT-1 Visual Vessels, Pumps Piping, D1.30 Welded Attachments 0 VT-1 Visual Pumps And Valves Valves Dl1.40 Welded Attachments 0 VT-I Visual B35

Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 5 th Interval-ISI-PTN-3/4-Program Plan January 21, 2015 TABLE 11 TURKEY POINT UNIT 4 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item 1 Number of Examination Request Category Number Description of Components Examined Components Method(s) Numberys Class 3 D-B D2.10 Pressure Retaining Components Pressure VT-2 Visual All Pressure Boundary Retaining Components F1.10 Class 1 Piping Supports 159 VT-3 Visual 3 F1.20 Class 2 Piping Supports 247 VT-3 Visual 3 F-A Supports29V-3Vsa3 (See Note 2) F1.30 Class 3 Piping Supports 292 VT-3 Visual 3 F1.40 Supports Other Than Piping Supports 42 VT-3 Visual 3 (Class 1, 2, 3 and MC)'

Notes:

1. In accordance with 10CFR50.55a(b)(2)(xxi)(A), the 1998 Edition of ASME Section XI without Addenda must be applied for Examination Category B-D, Item Numbers B3.120 and B3.140. Although the 1999 Addenda eliminated Item Numbers B3.120 and B3.140, these Code Item Numbers are applicable and are reflected in the Turkey Point ISI Program Plan for the fifth interval.

2. The examination and testing of snubbers, including attachment hardware, shall be conducted in accordance with the Snubber Testing Program as documented in Turkey Point Procedure 0-OSP-105.1.

B36

L-2015-040, Submittal of Fifth 10 Year Interval Inservice Inspection (ISI) Program Plan

Text

SUBJECT:

Dear Mr. Nazar:

Enclosure:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

5.0 CONCLUSION

Enclosure:

Attachment:

2. Applicable Code Edition and Addenda

3. Applicable Code Requirement

4. Reason for Request

References:

Attachment:

References:

Attachment:

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