L-2022-035, Fifth Ten-Year Inservice Inspection Interval Relief Request No. 10 Part-II

Fifth Ten-Year Inservice Inspection Interval Relief Request No. 10 Part-II

ML22069B128
Person / Time
Site:	Turkey Point
Issue date:	03/10/2022
From:	Hess R Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22069B127	List: L-2022-035, Fifth Ten-Year Inservice Inspection Interval Relief Request No. 10 Part-II
References
L-2022-035
Download: ML22069B128 (42)

Text

March 10, 2022 L-2022-035 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Turkey Point Unit 3 Docket Nos. 50-250 Fifth Ten-Year Inservice Inspection Interval Relief Request No. 10 Part-II

References:

1. Florida Power & Light Company letter L-2021-183, Fifth Ten-year Inservice Inspection Interval Relief Request Number 10, September 30, 2021 (ADAMS Accession Nos.

ML21273A240, ML21273A241)

2. Florida Power & Light Company letter L-2021-197, Response to Request for Additional Information for ISI Relief Request No. 10 Dated October 15, 2021 (ADAMS Accession ML21288A544)

3. Florida Power & Light Company letter L-2021-207, Response to Request for Additional Information for ISI Relief Request No. 10 Dated October 25, 2021 (ADAMS Accession ML21298A201)

4. NRC, Verbal Authorization read by David Wrona, Chief of the Plant Licensing Branch II-2, Office of Nuclear Reactor Regulation, Relief Request No. 10 Use of ASME CODE CASE N-513-4 for extended period not to exceed six months, October 29, 2021 In Reference 1, Pursuant to 10 CFR 50.55a(z)(2), Florida Power & Light Company (FPL) requested Nuclear Regulatory Commission (NRC) for relief from the applicable American Society of Mechanical EngineersSection XI Code (ASME Code) requirements to repair a section of the degraded Unit 3 Intake Cooling Water (ICW) pipe spool by installing a proprietary repair device, with new pressure boundary material and without removing the sections of degraded piping, and to extend the use of Code Case N-513-4 for six months until final design is complete and repair is implemented. In References 2 and 3, FPL provided response to NRCs request for additional information to address the extension of ASME Code Case N-513-4 to demonstrate that structural integrity of the ICW discharge pipe spool piece will continue for the requested period of six months. In Reference 4, NRC authorized in the first part of the Relief Request 10, the use of relief with enhanced frequent periodic examinations of the flaw and leakage monitoring beyond what is required by ASME Code Case N-513-4 for the extended period of six months or until April 29, 2022.

The second part of the Relief Request No. 10, Part II is submitted herein in Enclosure 1 providing information on the design and installation of the proprietary device and requesting NRC for relief from the applicable ASME Code requirements to complete the repair of the degraded Unit 3 ICW spool piece. The proprietary design and installation information are provided in Enclosure 2.

L-2022-035 Page2 contains the associated Affidavits ce1iifying that the material provided in Enclosure 2 is proprietary in nature. Accordingly, FPL requests that the material in Enclosure 2, be withheld from public disclosure under the provisions of 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

The basis for the relief is that compliance with the specified ASME Code repairs would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

FPL is requesting approval prior to April 8, 2022, which is based on the planned schedule for completion of the proposed repair.

If you have any questions, please contact Robert J. Hess, Licensing Manager, at (305) 246-4112.

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Licensing Manager Turkey Point Nuclear Plant Enclosures cc: USNRC Regional Administrator, Region II, USNRC USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant USNRC Project Manager, Turkey Point Nuclear Plant

L-2022-035 Enclosure 1 TURKEY POINT UNIT 3 Relief Request No. 10 Part II

Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 In Accordance with 10 CFR 50.55a(z)(2)

--Hardship or Unusual difficulty without a compensating increase in the level of quality and Safety--

1.0 ASME CODE COMPONENT(S) AFFECTED The affected component is the Turkey Point Unit 3 Intake Cooling Water (ICW) discharge pipe spool piece.

The 24-inch diameter, 11 1/8-inch long cast iron bolted pipe spool piece is located outside of the Turkey Point Unit 3 containment. The location of interest is within the Component Cooling Water (CCW) Room, a location that houses the three CCW heat exchangers, three CCW pumps and associated large bore piping.

The Unit 3 ICW discharge bolted spool piece was fabricated in accordance with the American Standard for Cast-Iron Pipe Centrifugally Cast In Metal Molds, For Water Or Other Liquids, ANSI A21.6. The original design code of the Unit 3 ICW system has been reconciled to ANSI B31.1 1973 Edition including Addenda through Winter 1976 Addenda. For the purpose of this relief request, the safety significance and quality class of the code of record ANSI B31.1 1973, is considered equivalent to ASME Code Section III, Class 3 piping (References 2 and 3). Accordingly, this piping is subject to repair/replacement requirements of ASME Code,Section XI, IWA 4000.

The following design data pertains to this moderate energy Quality Group C, ASME Section XI Class 3, ICW discharge pressure boundary piping:

• Pipe Schedule: 24-inch Sch. STD (tnom = 0.73-inch)

• Design Pressure: 55 psig

• Operating Pressure: 25 psig

• Design Temperature: 120°F

• Material Specification: Cast Iron, ASA 21.6, Class 150, Cement Lined ASA 21.4 with .25 inches thickness.

The ICW System loop provides the cooling water to the safety related Component Cooling Water (CCW) Heat Exchangers. The ICW System also provides cooling water to the Turbine Plant Cooling Water (TPCW) Heat Exchangers. A separate ICW System is provided for each nuclear unit. The safety related function of the ICW System is to remove the heat load from the CCW System during accident conditions to support both reactor heat removal and containment heat removal requirements.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 2.0 APPLICABLE CODE EDITION AND ADDENDA The Turkey Point, Unit 3 applicable Code for the fifth 10-year Inservice inspection (ISI)

Interval is the ASME Code Section XI 2007 Edition with 2008 Addenda (Reference 1).

The Turkey Point Unit 3 Fifth ISI 10-Year interval started on February 22, 2014 and ends on February 21, 2024.

3.0 APPLICABLE CODE REQUIREMENTS IWA-4412, Defect Removal states:

Defect removal shall be accomplished in accordance with the requirements of IWA-4420 IWA-4420, Defect Removal Requirements and IWA-4421, General Requirements states:

Defects shall be removed or mitigated in accordance with the following requirements:

(a) Defect removal by mechanical processing, metal removed by mechanical means, e.g., grinding, machining, chipping, shall be in accordance with IWA-4462.

(b) Defect removal by thermal methods shall be in accordance with IWA-4461.

(c) Defect removal or mitigation by welding or brazing shall be in accordance with IWA-4411.

(d) Defect removal or mitigation by modification shall be in accordance with IWA-4340.

The use of IWA-4340, Mitigation of Defects By Modification, for the Turkey Point current ASME Section XI, 2007 Code Edition is prohibited by 10 CFR 50.55a(b)(2)(xxv) provision (A), which states:

(A) The use of the provision for mitigation of defects by modification in IWA-4340 of Section XI 2001 Edition through the 2010 Addenda is prohibited IWA-4150 partially states The Edition and Addenda of Section XI used for the Repair/Replacement Program shall correspond with the Edition and Addenda identified in the Inservice inspection program applicable to the inspection interval. Alternatively, later Editions and Addenda of Section XI, or specific provisions within an Edition or Addenda later than those specified in the Owners Inservice Inspection Program may be used. When provisions of later Editions and Addenda are used, all related requirements shall be met.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 Accordingly, the provisions for mitigation of defects by modification in IWA-4340 of XI 2013 Edition, it may be used based on the second provision of 10 CFR 50.55a(b)(2)(xxv),

provision (B) which partially states:

(B) Mitigation of defects by modification: Second provision. The provisions for mitigation of defects by modification in IWA-4340 of Section XI 2011 Edition through the 2017 Edition may be used subject to the following conditions:

(1) The use of the provisions in IWA-4340 to mitigate crack-like defects or those associated with flow accelerated corrosion are prohibited.

(2) The design of a modification that mitigates a defect shall incorporate a loss of material rate either 2 times the actual measured corrosion rate in that pipe location (established based on wall thickness measurements conducted at least twice in two prior consecutive or nonconsecutive refueling outage cycles in the 10 year period prior to installation of the modification), or 4 times the estimated maximum corrosion rate for the piping system.

(3) The licensee shall perform a wall thickness examination in the vicinity of the modification and relevant pipe base metal. Except as provided in paragraphs (b)(2)(xxv)(B)(3)(i) and (ii), the examination must be performed during each refueling outage cycle to detect propagation of the defect into the material credited for structural integrity of the item unless the examinations in the two refueling outage cycles subsequent to the installation of the modification are capable of validating the projected flaw growth. Where the projected flaw growth has been validated, the modification must be examined at half its expected life or once per interval, whichever is smaller.

The use of IWA-4340, Mitigation of Defects by Modification of the ASME Section XI, 2013 Edition (Reference 4), can be met for the proposed modification with the exception of three provisions (g) (i) and (l), which state:

(g) In addition to meeting IWA-4160, the Owner shall perform an examination during each of the next two re-fueling outages to detect propagation of the flaw into the material credited for structural integrity of the item and, for high energy items, shall perform an examination to validate the projected flaw growth of (d) above.

For all other items, validation of the projected flaw growth by examination shall be performed, if practicable. Projected or actual flaw growth into material credited for the structural integrity of the item shall be unacceptable. The examination used to validate flaw growth shall be the same method used to characterize the defect, or a volumetric examination in accordance with Mandatory Appendix I shall be performed.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 (i) If the flaw growth is validated in accordance with (g) or (h), the modification shall be examined in accordance with (g) once per interval, except as required by IWA-4160.

(l) A system pressure test of the modification in accordance with IWA-5000 shall be performed. New welds, brazed joints, and mechanical connections, made in the course of the repair/replacement activity, shall be subjected to the required test pressure. The acceptance criteria for leakage at mechanical connections shall be established by the Owner.

4.0 REASON FOR REQUEST During the surface preparation for metalizing/coatings application, a through wall flaw was discovered on a Class 3, 24-inch diameter, 11 1/8-inch long ICW safety related cast iron bolted pipe spool piece prior to the start of the Turkey Point Unit 3 refueling outage March 30, 2020.

The non-planar flaw was identified under the pipe coatings downstream of the ICW manual isolation valve 3-50-406 from the CCW heat exchangers (See attached drawing, Figure 1). The flawed pipe section is located in the Turkey Point Unit 3 CCW heat exchanger room, approximately 12 feet from where the piping turns underground and downstream of the last isolation valve, directing the water exiting the CCW heat exchangers (HXs) back to the discharge structure and the ultimate heat sink. It does not include any downstream valves or any other active components that could fail and prevent delivery of the ICW fluid back to the discharge location. The safety significance of this section of the pipe is considered low since the heat removal function is completed as the ICW fluid exits the CCW heat exchangers.

The subject ICW pipe has been confirmed as being an original installation in operation since the initial plant start up. The piping is made of cast iron material with a nominal wall thickness of 0.73 inch, has a design pressure of 55 pounds-per-square-inch gauge (psig), and a design temperature of 120 degrees Fahrenheit. The system operates at approximately 25 psig.

The flaw size is shaped like a crater with two small wall weep holes inside. The size of the flaw longitudinal OD is 9/16 inches with a diameter of 13/16 inches. The average measured leakage has been approximately 5 GPH with the subject ICW line pressurized.

Leakage has fluctuated between 0-10 GPH (depending on the system cleanliness and line up). Recent leakage changes were observed up to an average of 60 GPH. Increase in leakage was validated each time with NDE to confirm flaw size growth remains within predicted and evaluated flaw size degradation limits.

The piping degradation for the Unit 3 ICW discharge piping spool piece was characterized as a through-wall leak which may have been caused by internal corrosion of the piping due to localized degradation of the concrete liner in the cast iron piping.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 The degraded spool piece is part of the ICW system, and its safety function is to remove heat load from the CCW HXs during accident conditions to support both reactor heat removal and containment heat removal requirements.

Turkey Point performed a flaw evaluation in accordance with NRC-approved ASME Code Case N-513-4 when the through-wall leak was initially discovered. The ASME Code Case N-513-4 evaluation was performed to validate the structural integrity of the as found condition and justify continued system operation until a repair could be performed.

FPL determined that performing an ASME Code compliant repair/replacement on the degraded portion of ICW piping in accordance with ASME Code,Section XI, IWA-4000 represents a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The hardship involves the unusual configurations required to affect a repair and the materials in the ICW system that create both operational and repair risks. The degraded ICW piping is a cast iron spool piece with concrete lining which is un-isolable and would require the entire Turkey Point Unit 3 ICW system to be placed out of service for repairs.

The operational risks associated with the ASME Code-compliant repair options evaluated by FPL would require removing the CCW Heat Exchangers from service and providing temporary heat exchangers and temporary flow paths which could impact cooling of the Turkey Point spent fuel pool (SFP).

The repair risks associated with these options are related to the cast iron piping material and the likelihood of further damage caused by drilling and/or welding on the pipe.

Because of the cast iron material, drilling or welding could cause cracking of the piping which could increase the leak rate or cause further damage to the concrete lining making the system more susceptible to internal corrosion. In addition, if removed by drilling, the size of the flaw would necessitate a plug size which will limit the number of threads that can be cut into the pipe wall and therefore affect the ASME Code-required thread engagement and leak tightness of the plug.

In the first part of Relief Request No. 10, FPL proposed to increase the frequency of the compensatory measures (leak rate monitoring and wall thickness ultrasonic measurement) to extend the use of ASME Code Case N-513-4 beyond the allowed single operating cycle for a period not to exceed six months after approval (or April 29, 2022) to allow for the design of an alternative repair method.

On October 29, 2021, NRC verbally authorized only the proposed alternative for extending the use of ASME Code Case N-513-4 for a period not to exceed six months, or April 29, 2022, to allow for the design of the repair method to be established.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 The second part of the relief request is submitted herein to request relief from the applicable ASME Code requirements to complete the repair of the degraded Unit 3 ICW spool piece with unacceptable through wall leakage by installing a proprietary repair device, with new pressure boundary material and without removing the sections of degraded piping.

10 CFR 50.55a(z) authorizes the Director, Office of Nuclear Reactor Regulation, to approve alternatives to the requirements of paragraphs (b) through (h) of 10 CFR 50.55a.

The installation of replacement pressure retaining parts without first removing the degraded portions of the subject ICW discharge pipe spool piece does not comply with the requirements of IWA-4421. Thereby, relief is requested from the requirements of IWA-4421 to remove defects in accordance with IWA-4340 part (d) on the subject piping identified in this request, prior to performing repair/replacement activities. Relief is also requested from the related provision B condition 3 of 10 CFR 50.55a(b)(2)(xxv) regarding defect removal by mitigation by modification and from provisions (g), (i) and (l) of IWA-4340, 2013 Edition.

5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE The proposed alternative has been developed because other repair/replacement options that would fully comply with IWA-4421 create a hardship or unusual difficulty without a compensating increase in the level of quality and safety for reasons detailed in this request.

Proposed Alternative Turkey Point Nuclear Generating Station, Unit 3, is currently experiencing degradation and leakage in a Safety-Related intake cooling water discharge piping.

The area of degradation and leakage is at the bottom of the straight section of the spool piece. The Pipe Spool is 11-1/8 inches long with a 25.8 inches OD x 0.73 inches straight pipe section with integral flanged ends. The piping is located above ground in the Auxiliary Building downstream of and connected to adjacent Valve 3-50-406. The opposite end is connected to a flanged elbow. The spool piece is constructed of Grey Cast Iron, cement lined. The end flanges are approximately 32 inches OD and 1-7/8 inches in width.

In lieu of the requirement of IWA-4421 to remove the defective portion of the ICW component prior to performing repair/replacement activities, an IWA-4340 modification/repair is needed to be installed around the circumference of the degraded pipe spool without removal of the degraded area.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 The unacceptable localized through wall defect shall be corrected by installation of a proprietary pressure retaining Restoration Hardware Assembly (RHA) designed and manufactured by PMC Engineering Solutions, Inc. that fully restores the degraded pipe spool for the lifetime of the plant. The repair activities for the RHA installation can be started and completed during any plant mode. This repair is being classified as a permanent repair suitable for long term operation while maintaining ASME Code compliance of the piping system. The proprietary design and installation and engineering modification information for RHA is provided in Enclosure 2.

Modification Summary and Code Compliance:

• The degraded area will be restored by encapsulation using a 2-piece split RHA with interfacing gaskets at the circumferential edge faces of the Pipe Spool end flanges and the axial edges of the RHA. Additionally, bolts connecting the existing flanges will be replaced with high-strength, saltwater corrosion-resistant bolting that incorporates individual gaskets to prevent leakage through the flange bolt holes.

• The original fabrication and design requirements for the piping section were ANSI A21.6, Cast-Iron Pipe Centrifugally Cast In Metal Molds For Water or Other Liquids, however, PTN has reconciled the design requirements of all safety related piping to ASME B31.1, 1973 edition through 1976 addenda per FPL Standard CN-3.01, Piping and Support Analysis Requirements, Turkey Point Units 3 & 4. Therefore, this edition and addenda of B31.1 was conformed to for both design and fabrication, as the fabrication requirements meet or exceed ANSI A21.6.

• The restoration of the degraded ICW discharge piping Pipe Spool is not considered a modification under ASME Section XI Non-Mandatory Appendix W. The Restoration Hardware Assembly is a modification that uses a Specially Designed Component per ANSI B31.1 paragraph 104.7 (Pressure Design of Other Pressure-Containing Components). The Restoration Hardware Assembly does not employ the application of a simple clamping device to provide pressure integrity of a leaking and or defective pressure boundary. Instead, the RHA replaces the pipe portion of the defective spool piece with a new corrosion-resistant, gasketed pressure boundary that distributes all applied loads within the piping system by use of structural attachments, welds, and high-strength bolting.

• The RHA is designed to the original construction code (ANSI B31.1 1973 Ed.,

Winter 1976 Addenda) for the ICW system and are classified as Code Class 3, Seismic Category I components. It is also designed to withstand system design pressure and temperature.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1

• The proposed modification does not affect the hydraulic characteristics of the system process fluid flow to the ultimate heat sink (discharge canal). The designed RHA is qualified against all code-of-record design basis loads.

Therefore, no supports are impacted as a result of the RHA installation.

• The piping and components involved in this restoration include the subject 25.8 inches OD straight section of degraded spool pipe, the adjacent Pipe Spool flanges, the adjacent upstream flange connected to Valve 3-50-406, and the flange connected to the adjacent downstream elbow.

• Total pipe stresses (existing plus stresses due to RHA addition) remain within code allowable pipe stresses. (Reference 5, included in Attachment 1) Affected adjacent piping, elbow and valve 3-50-406 are adequate for the additional applied loads. RHA will be the new pressure boundary and the structural element. The Finite Element Analysis for the Restoration Hardware Assembly assumes that the defective straight pipe portion of the Spool Piece is not credited and does not contribute any structural integrity to the restored section of piping.

As such, the straight section portion of the pipe spool that contains the degradation does not have to be removed and is reclassified as non-pressure boundary, non-structural, sacrificial material after the restoration is complete.

• The existing Pipe Spool Flanges and the adjacent Valve and Elbow Flanges are integral structural pieces of the RHA. As mentioned, after the RHA is installed, the existing pipe between the Flanges of the Pipe Spool is considered to have completely wasted away, leaving only the Pipe Spool Flanges. The Pipe Spool Flanges will function as spacers between the Flange Bolting / Flange Gasket and adjacent Valve and Elbow Flanges.

• A metal loss limit of 1.5 inches of the existing spool piece flange is included in the justification for acceptability of the design. Volumetric examinations for the flange have not been performed due to the size of the bolted flange and related limitations using qualified NDE procedures and equipment. Metal loss due to corrosion is confirmed not to exceed the minimum flange thickness tolerance required for the remaining operating life of Unit 3. A conservative corrosion rate calculation (Reference 6, Included in Attachment 1) assumes 0.01 inches per year, which amounts to a flange total metal loss of 0.300 inches for 30 years (expected life of the RHA modification).

• The RHA is constructed from material that is highly resistant to salt water that will be coated on the interior surface to enhance corrosion resistance. The fabrication/assembly of the Restoration Hardware Assembly follows the welding guidelines for Code Class 3 components.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1

• One critical aspect of the RHA is the gasketing profile which consists of the outer edge surface (approximately 1 7/8 inches wide) of each 32 inches OD Pipe Spool flange. The outer edge surface will be gasketed at 360 degrees, circumferential direction. The RHA will be approximately 10.5 inches wide, spanning between the 2 end flanges and will have the longitudinal direction mating surfaces gasketed. To ensure equal compressive pressure is applied to the installed gaskets, craft members machined both of the 1-7/8-inch flange edge surfaces to accommodate a gasket seal between the perimeter edge of the pipe spool flange and the RHA assembly.

• Laser scanning has also been performed on the pipe flange edges where gasket seating will occur. The scanning activity verifies parallelism between the two flanges where the RHA will be fitted. Vendor mockup fabrication details have also been established following the as-left machining and laser scanning to allow for the final fabricated RHA installation and integrity hydro testing in the vendor shop prior to shipment to Turkey Point. The satisfactory mockup installation and pressure testing at the vendors facility minimizes any potential challenges upon site installation.

• Styrene Butadiene Rubber (SBR), will be installed at circumferential and longitudinal locations on the RHA. Thicknesses will be determined on site to attain proper compression following fastener tightening. All gasketed joint configurations are specifically designed to prevent undesirable gaps. No metal to metal contact is expected between the RHA and the existing pipe spool. This will also prevent the potential for galvanic corrosion.

• Existing Pipe Spool flange bolting will be replaced using salt-water resistant high-strength fasteners and gaskets of the same diameter but slightly longer than the existing bolts. Pipe spool flange bolting may be removed one at a time for re-installation of new bolting hardware in its place.

• The flange stud bolts at the location of every nut internal to the RHA will be fitted with gaskets. The selected gasket material is standard type for low pressure and temperature system conditions with strong anti-corrosion characteristics.

• ASTM A193/194 fasteners are applied on external portions of the RHA. High grade corrosive resistant fasteners are applied on the internal/inaccessible portion of the RHA. The Inservice Inspection program will continue with inspections for the externally applied fasteners. Installed fasteners/nuts shall be torqued per PMC Installation drawings.

• Following the installation of all internal fasteners to the RHA, coating will be applied on all internal surfaces of the newly installed flange bolting and pipe spool.

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Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1

• The RHA also uses structural clips/gusset plates at several bolt locations that are part of the bolted connection to the Spool Piece Flanges and transfer the applied loads to the RHA structure. Load Transfer Clips shall be installed with the prescribed gaskets and bolting. Weld details described in the PMC Installation drawings in the proprietary Enclosure 2.

• The installation involves welding the newly installed load transfer plates and load transfer gussets onto the new RHA. Load transfer clips that are bolted to the valve flange and the elbow flange and welded to the load transfer plates in the field will transfer forces and moments from the cast iron flanges to the newly installed RHA. Clips and respective gussets are installed around the exterior bolted connection extending up on to the RHA. Clips are configured such that they do not affect the gaskets when welded to the RHA.

• The fillet weld sizes detailed in the fabrication and installation drawings are sized to ensure long term structural strength along with minimizing the potential for RHA cylinder warpage from the effects of high temperatures during welding process. All placed welds will allow for a minimum 10% margin of strength should future degradation be identified. Fillet welds are external and not exposed to the seawater, and they are not a component that mitigates degradation.

• The welded attachment on the installed clips to gussets to the new RHA shall be visually examined per ASME Section XI, Class 3, VT-1 requirements (Ref.

ASME XI, Table IWD-2500 (D-A).

• Prior to installation of the modification/repair, the through wall leakage will be stopped with a non-structural housekeeping seal. Stopping the leakage is only necessary to enable installation of the RHA. The through wall leak location shall be leak arrested using site approved compound such as Belzona rapid curing compound. Once the RHA is installed, the seal will no longer be needed, but it will remain in place.

• The RHA will include ports located at prescribed RHA locations to allow for mockup pressure testing of the RHA at the fabrication facility and for the injection of Belzona (non-corrosive filler material). Following the injection process, the ports will be closed with code approved threaded plugs of equally qualified material resistive to effects of corrosion.

• As discussed previously, the RHA gaskets will provide for primary pressure integrity and leak tightness of the repair. An additional secondary back up pressure integrity and leak tightness will be provided by filling the internal interstitial encapsulated area of pipe spool with an approved sealant, Belzona, to 10

Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 assure all gasketed areas are backed up. The sealant will provide additional saltwater corrosion protection of the encapsulated surfaces of the Cast Iron Pipe spool flange surfaces. This injectable compound does not initiate corrosion to affected metallic hardware.

The proposed alternative includes installation of the RHA in accordance with IWA-4340, mitigation by modification. Use of the IWA-4340 in its original form (Turkey Point Unit 3 code of record is ASME Section XI, 2007 with 2008 addenda) is prohibited per 10 CFR 50.55a(b)(2)(xxv) provision A.

The provisions in IWA- 4340,Section XI, 2013 Edition can be used in accordance with the second provision of 10 CFR 50.55a(b)(2)(xxv)(B) which allows the use of IWA-4340 of Section XI, 2011 Edition through the 2017 Edition with three conditions.

The repair installing the RHA meets 10 CFR 50.55a(b)(2)(xxv)(B) conditions 1 and 2 as follows:

• Regarding condition 1, the use of the provisions in IWA-4340 is allowed since the defect is not a crack-like defect and it is not associated with flow accelerated corrosion.

• Regarding condition 2, the use of the provisions in IWA-4340 is allowed since the modification incorporates a loss of material at least 4 times the estimated maximum corrosion rate of the piping system. As discussed above, a total metal loss of 1.5 inches for the spool piece flange is included. The estimated maximum corrosion rate of .01 inches per year times 4 results in a total metal loss of 1.2 inches for 30 years (proposed life of the modification).

Relief is requested from the requirements of 10 CFR 50.55a(b)(2)(xxv)(B) condition 3.

• Condition 3 requires Turkey Point to perform wall thickness examinations in the vicinity of the modification and the relevant pipe base metal. The RHA is designed to fully encapsulate the flawed pipe spool piece, which will no longer be relied upon for structural integrity. Volumetric inspections of the wall thickness in the vicinity of the modification will not be possible without removing the RHA. The RHA design specifies a metal loss of 1.5 inches of flange thickness before structural integrity of the repair assembly is impacted. As discussed above, in lieu of the examinations specified in 10 CFR 50.55a(b)(2)(xxv)(B)(3), Turkey Point performed an analysis to determine a conservative corrosion rate of the spool pipe flange. This analysis resulted in a corrosion rate of 0.01 inches per year. If multiplied by 4 to comply with 10 CFR 50.55a(b)(2)(xxv)(B)(2), the resulting period in which structural integrity will not be impacted exceeds the proposed life of the modification. As such, the 11

Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 required examinations represent an unusual difficulty without compensating increase in the level of quality and safety.

Relief is also requested from IWA-4340 of the ASME Section XI 2013 Edition provisions (g), (i) and (l). Request for relief is based on the following:

• Regarding provision (g) and (i) of IWA-4340, 2013, the degraded area is located in the straight pipe of the spool piece and has already been monitored with volumetric examinations since March 2020. Turkey Point is unable to perform the required flange examinations during future outages to detect propagation of the flaw into the material credited for structural integrity (flange) as part of the RHA. Validation of the projected flaw growth into the flange during future outage is not practicable by examination without removal of the RHA. In lieu of the inspections specified in IWA-4340(g) and (i) Turkey Point performed an analysis to determine a conservative corrosion rate of the pipe spool flange and determined that the structural integrity will not be impacted for the proposed life of the modification.

• Regarding provision (l), a system pressure test in accordance with IWA-5000 cannot be performed on the installed RHA. The RHA will be hydrostatically tested at the vendor shop prior to shipment to Turkey Point. Following the installation of the RHA, in lieu of system leakage test, for this open ended portion of the discharge line beyond the last shutoff valve, confirmation of adequate flow during system operation (full flow test) with no leakage observed by a VT-2 qualified examiner at the welded and mechanical connections of the modification shall be an acceptable alternative. Similarly, future periodic tests will be conducted by subjecting the RHA to a full flow test with no acceptable leakage observed by a VT-2 qualified examiner at the welded and mechanical connections of the modification.

Basis for the Request The RHA is designed to fully encapsulate the flawed pipe spool piece, which will no longer be relied upon for structural integrity. Complying with IWA-4421 requirements to remove degraded portions of this piping prior to performing a repair/replacement activity or to mitigate the defect in accordance with certain provisions of IWA-4340 represent a hardship or unusual difficulty without a compensating increase in the level of quality and safety for the following reasons:

The ICW leak cannot be isolated to perform a Code repair option during a unit shutdown without both operational and logistical challenges. Attempting to perform this repair will result in an unusual plant configuration which presents a substantial risk to the SFP cooling system. Furthermore, the repair cannot be completed while operating, because of the support function of ICW for many systems required during power operation.

12

Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 The proposed alternative is to relocate the pressure boundary by restoring the affected portion of the piping system, with a Restoration Hardware Assembly including the spool piece flange which will have adequate material thickness for pressure retention and structural integrity rather than correcting the piping experiencing the wall loss. The design analysis demonstrates that the RHA will become the new pressure boundary and will transfer applicable loads to the flange bolting. The structural integrity of the piping system is demonstrated to be within acceptable stress limits. The calculation considered the additional weight imparted by the new RHA on the piping. The proposed repair demonstrates that the material and the presence of the postulated worst-case wall loss in the spool piece and flange will not be detrimental to the pressure retaining function or structural capability of the intake cooling water piping system.

The proposed alternative provides reasonable assurance of structural integrity because the Restoration Hardware Assembly will be designed, fabricated, inspected, and installed in accordance with the requirements of the current Code of Construction, ASME B31.1 1973 Edition including Addenda through Winter 1976 using all applicable design loads and load cases provided by and verified by FPL.

The proposed alternative provides reasonable assurance that the component/system will be operationally ready because the alternative will restore the pressure boundary and structural integrity of the degraded spool piece to the requirements of the current code of construction.

Based on the discussion above, it is requested that the NRC authorize this proposed alternative in accordance with 10 CFR 50.55a(z)(2) Hardship or Unusual Difficulty without compensating increase in level of Quality or Safety.

6.0 DURATION OF PROPOSED ALTERNATIVE The licensee requests approval of the proposed alternative for the remaining life of the plant, as supported by the RHA design documentation, or until such time that further repair/replacement activities are required for the affected portions of the ICW system piping, whichever occurs first.

7.0 PRECENDENT NextEra Energy, Turkey Point Nuclear Power Station Units 3 and 4, Relief Request 6, approved by NRC on November 6, 2020, Turkey Point Nuclear Generating Unit No. 3

- Approval of Alternative to Use ASME Code Section XI IWA-4340 -For Repairs of Component Cooling Water System Piping (EPID L-LLR-0040) Accession No.:

ML20287A551.

13

Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1

8.0 REFERENCES

1. American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code,Section XI, 2007 Edition including Addenda through 2008.

2. FPL Standard CN-3.01, Piping and Support Analysis Requirements, Turkey Point Units 3 & 4.

3. ASME/ANSI B31.1, 1973 Edition including Addenda through Winter 1976

4. American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 2013 Edition.

5. Structural Integrity Design Stress Report, Turkey Point Repaired ICW Piping Stress Model, File No. 2101264.30. (Included in Attachment 1)

6. Structural Integrity Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron, SIA Report No. 2101264.401, Rev 0 Project No.

2101264.00 (Included in Attachment 1) 14

Turkey Point, Unit 3 Fifth 10-Year Interval Updated Relief Request No. 10 Intake Cooling Water Pipe Spool Repairs for Through Wall Defect Location of Through Wall Leak L-2022-035, Enclosure 1, Figure 1 1

Turkey Point, Unit 3 Fifth 10-Year Interval Relief Request No. 10 Part II Intake Cooling Water Pipe Spool Repairs for Through Wall Defect L-2022-035, Enclosure 1 Attachment 1 References

1. Structural Integrity Design Stress Report, Turkey Point Repaired ICW Piping Stress Model, File No. 2101264.301. (Appendix A and B of this reference is not included, available upon request)

2. Structural Integrity Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron, SIA Report No. 2101264.401, Rev 0 Project No. 2101264.00 15

File No.: 2101264.301 Project No.: 2101264 Quality Program Type: Nuclear Commercial CALCULATION PACKAGE PROJECT NAME:

Turkey Point Repaired ICW Piping Stress Model CONTRACT NO.:

02434170 Amendment 001 CLIENT: PLANT:

NextEra Energy, Inc. Turkey Point Nuclear Plant, Unit 3 CALCULATION TITLE:

Analysis of Clamp Repair, Intake Cooling Water (ICW) Piping Project Manager Preparer(s) &

Document Affected Revision Description Approval Checker(s)

Revision Pages Signature & Date Signatures & Date 0 1 - 11 Initial Issue A A-11 B B-760 S.M. Parker, P.E.

1/21/2022 W.F. Weitze, P.E.

1/20/2022 Yanni Patten 1/21/2022

Table of Contents 1.0 OBJECTIVE ..............................................................................................................3 2.0 METHODOLOGY ......................................................................................................3 3.0 ASSUMPTIONS / DESIGN INPUTS ..........................................................................3 4.0 CALCULATIONS .......................................................................................................6 5.0 RESULTS OF ANALYSIS..........................................................................................6

6.0 CONCLUSION

S AND DISCUSSION .........................................................................9

7.0 REFERENCES

........................................................................................................11 PIPESTRESS INPUT FILE ......................................................................... A-1 PIPESTRESS OUTPUT .............................................................................. B-1 List of Tables Table 1. Maximum B31.1 Stress Results..............................................................................6 Table 2. Heat Exchanger (HX) Loads ...................................................................................7 Table 3. Pipe Support Load Evaluation ................................................................................8 List of Figures Figure 1. Location of Repair .................................................................................................4 Figure 2. PIPESTRESS Model Geometry.............................................................................5 File No.: 2101264.301 Page 2 of 11 Revision: 0 F0306-01R4

1.0 OBJECTIVE The objective of this calculation package is to document the analysis of the ICW piping repair, consisting of a clamp assembly that encapsulates a cast iron spool piece that is leaking [1].

2.0 METHODOLOGY The piping is analyzed to the 1977 Edition of the B31.1 piping Code [2b], as was done in the previous analysis of this piping [3, Attachment 1, p. 1]. Although the Code of Construction for this piping is the 1973 Edition of B31.1 with Addenda through Winter 1976 [2a] [8, Table 9.3-4], this edition/addenda combination is not available in the PIPESTRESS computer program [4].

The PIPESTRESS computer program [4] is used to perform the analysis. The final configuration PIPESTRESS input file from the previous analysis [3, Attachment 2] [5, file ] is modified to analyze the current repair.

3.0 ASSUMPTIONS / DESIGN INPUTS No assumptions are introduced in this calculation package.

The total weight of the repair is 1200 lbs [9]. Loads and stresses due to deadweight would increase if the actual weight were higher. For seismic loading, loads and stresses could either increase or decrease with higher weight, although overall loads would be expected to increase.

The repair will be applied between the valve 3-50-406 downstream flange face and the next flange face downstream of that valve [6]. Figure 1 shows this location, based on the stress isometric [7]. The endpoints of the repair, points 15 and 16 in Figure 1, correspond to points 150 and 160, respectively, in the PIPESTRESS model [3, Attachment 3, p. 1].

File No.: 2101264.301 Page 3 of 11 Revision: 0 F0306-01R4

Figure 1. Location of Repair The clamp assembly and underlying piping are modeled in PIPESTRESS as a rigid member with a lumped mass midway along its length. The existing piping between points 150 and 160 has the following section properties [5, file , line 187]:

Outside diameter = 25.8", thickness = 0.73", weight = 589 lb/ft The piping consists of two lengths of 0.1927 ft, making the weight of this segment of the piping 589*2*0.1927 = 227 lb. This is added to the 1200 lb clamp assembly to yield 1427 lb total lumped weight.

The resulting input file is named , is listed in Appendix A, and is plotted in Figure 2.

Point numbers 150, 155 (midpoint), and 160 are circled in the figure.

File No.: 2101264.301 Page 4 of 11 Revision: 0 F0306-01R4

Figure 2. PIPESTRESS Model Geometry File No.: 2101264.301 Page 5 of 11 Revision: 0 F0306-01R4

4.0 CALCULATIONS Piping analysis is performed using the PIPESTRESS program [4]. The following load cases are carried over from the previous analysis [5, file ]:

111: Thermal, ambient 112: Thermal, design 113: Thermal, normal 114: Thermal, maximum 1: Operating weight 11: OBE (operating basis earthquake) X 12: OBE Y 13: OBE Z 14: SSE (safe shutdown earthquake) X 15: SSE Y 16: SSE Z 31: OBE X + Y 32: OBE Y + Z 33: SSE X + Y 34: SSE Y + Z 41: Pressure + weight + (OBE X + Y) 42: Pressure + weight + (OBE Y + Z) 43: Pressure + weight + (SSE X + Y) 44: Pressure + weight + (SSE Y + Z)

Changes to the input file to model the repair are described in Section 3.0. Also, while running the analysis initially, PIPESTRESS produced an error message because, at point 5, restraints were added to a previously defined anchor, which is not currently permitted in this program. As a result, the restraints are commented out. This is done to clear the error message; and has no effect on results because the applied anchor is essentially rigid, and therefore any added restraint stiffness would have no effect.

In addition, the following changes are made on the TITL card to enhance program output:

HS=1 adds a table of the highest stress points for each load case.

1F=1 creates a file with extension PRZ that contains all output reports.

5.0 RESULTS OF ANALYSIS Table 1 provides the maximum stress results from the PIPESTRESS output file with extension MAX and allowable stress values from files with extensions PRL and PRC. As the table shows, all stress requirements are met.

Table 1. Maximum B31.1 Stress Results Load Load Max. calc. Allowable Condition Criterion combination case Point Component stress, psi stress, psi Ratio Normal Eq. 13 TE 114 135 elbow 4994 9000 0.555 Normal Eq. 11 P+W 1 2070 tangent 1811 6000 0.302 Upset Eq. 9 P+W+OBE 41 645 branch 2811 7200 0.390 Faulted Eq. 9 P+W+SSE 43 645 branch 5685 14400 0.395 General note: P = pressure, W = weight, TE = thermal expansion range, OBE = operating basis earthquake, SSE

= safe shutdown earthquake. For OBE and SSE, the X+Y and Y+Z cases are enveloped.

File No.: 2101264.301 Page 6 of 11 Revision: 0 F0306-01R4

Table 2 lists the heat exchanger (HX) loads for the load cases shown for the current analysis (file

) and the previous loads in the as-left condition [3, sh. 24 and 25].

Table 2. Heat Exchanger (HX) Loads HX Point Case FX, lb FY, lb FZ, lb MX, ft-lb MY, ft-lb MZ, ft-lb 3E207A 825 W (1) 56 1288 407 409 228 -2952 SSE X+Y (33) 2010 1773 6159 9120 2401 1691 SSE Y+Z (34) 862 1026 3158 3623 5263 2319 design pos 2066 3061 6566 9529 5491 0 design neg -1954 -485 -5752 -8711 -5035 -5271 design pos, previous 2038 3009 6423 9339 5478 0 design neg, previous -1932 -429 -5615 -8493 -4968 -5211 3E207B 2150 W (1) 7 454 -930 1423 -1835 -1782 SSE X+Y (33) 1331 403 1488 2891 5161 1886 SSE Y+Z (34) 931 749 2259 2605 3585 1640 design pos 1338 1203 1329 4314 3326 104 design neg -1324 -295 -3189 -1468 -6996 -3668 design pos, previous 1317 1209 1377 4268 3246 52 design neg, previous -1305 -289 -3185 -1468 -6786 -3640 3E207C 360 W (1) 0 935 510 -751 520 -3256 SSE X+Y (33) 2666 2926 6660 4704 21818 7962 SSE Y+Z (34) 875 1042 2964 3585 4876 2119 design pos 2666 3861 7170 3953 22338 4706 design neg -2666 -1991 -6150 -5455 -21298 -11218 design pos, previous 2635 3760 6911 3984 5048 5527 design neg, previous -2641 -1860 -6065 -5188 -436 -9899 General note; W = weight, SSE = safe shutdown earthquake.

Table 3 lists the pipe support loads for the load cases shown for the current analysis (file

) and the maximum loads that were previously qualified [3, sh. 27 to 30]. Combined loads that exceed the previously qualified value are italicized; if by more than 5%, they are bold italicized.

Table 4 contains the piping forces and moments in the region of the repair for the load cases shown, from output files with extensions PRL and PRC. Figure 3 correlates the original and current point numbering in that region [3, Attachment 3].

Appendix B contains the complete PIPESTRESS output in one file, .

File No.: 2101264.301 Page 7 of 11 Revision: 0 F0306-01R4

Table 3. Pipe Support Load Evaluation spt no. point function case max. qual. new penet. 75 Fx W (1) 700 912 SSE X+Y (33) 37232 25099 SSE Y+Z (34) 0 3659 design pos 37932 26011 design neg -36532 -24187 Fz W (1) 2192 2996 SSE X+Y (33) 8596 3267 SSE Y+Z (34) 0 3132 design pos 10788 6263 design neg -6404 -271 8045-H-172-8 280 Fy W (1) -6224 -6075 SSE X+Y (33) 657 815 SSE Y+Z (34) 0 677 design pos 0 0 design neg -6881 8045-H-172-11 320 Fy W (1) -5372 -5343 SSE X+Y (33) 3081 3236 SSE Y+Z (34) 0 1267 design pos 0 0 design neg -8453 8045-H-172-03 445 Fy W (1) -14567 -15360 SSE X+Y (33) 2776 2924 SSE Y+Z (34) 0 1714 design pos 0 0 design neg -17343 8045-H-172-02 475 Fy W (1) 6604 6942 SSE X+Y (33) 3757 4013 SSE Y+Z (34) 0 1395 design pos 10361 design neg 0 0 8045-H-172-01 525 Fy W (1) -19372 -17276 SSE X+Y (33) 6108 5456 SSE Y+Z (34) 0 3138 design pos 0 0 design neg -25480 -22732 8045-H-172-06 720 Fy W (1) -6243 -5598 SSE X+Y (33) 1526 1487 SSE Y+Z (34) 0 692 design pos 0 0 design neg -7769 -7085 8045-H-172-09 785 Fy W (1) -6219 -6216 SSE X+Y (33) 2348 2405 SSE Y+Z (34) 0 1433 design pos 0 0 design neg -8567 8045-H-172-04 990 Fy W (1) -11915 -7960 SSE X+Y (33) 5721 5068 SSE Y+Z (34) 0 1613 design pos 0 0 design neg -17636 -13028 8045-H-172-05 930 Fy W (1) -7473 -5992 SSE X+Y (33) 4920 5078 SSE Y+Z (34) 0 1835 design pos 0 0 design neg -12393 -11070 8045-H-172-07 2075 Fy W (1) -5353 -4431 SSE X+Y (33) 558 599 SSE Y+Z (34) 0 559 design pos 0 0 design neg -5911 -5030 8045-H-172-10 2115 Fy W (1) -4814 -4992 SSE X+Y (33) 1360 843 SSE Y+Z (34) 0 1180 design pos 0 0 design neg -6174 -6172 File No.: 2101264.301 Page 8 of 11 Revision: 0 F0306-01R4

Table 4. Piping Forces and Moments in Region of Repair case element point FX, lb FY, lb FZ, lb MX, ft-lb MY, ft-lb MZ, ft-lb W (1) elbow 135 -1623 -3697 -40 1557 -2897 -359 140 1623 2251 40 2720 361 2895 flange 140 -1623 -2251 -40 -2720 -361 -2895 145 1623 2193 40 3322 -78 2895 flange 145 -1623 -2193 -40 -3322 78 -2895 150 1623 2135 40 3908 -518 2895 repair 150 -1623 -1975 -40 -3908 518 -2895 155 1623 1975 40 4289 -831 2895 repair 155 -1623 -548 -40 -4289 831 -2895 160 1623 548 40 4394 -1143 2895 flange 160 -1623 -548 -40 -4394 1143 -2895 165 1623 490 40 4535 -1583 2895 flange 165 -1623 -490 -40 -4535 1583 -2895 170 1623 432 40 4660 -2023 2895 valve 170 -1623 -432 -40 -4660 2023 -2895 175 1623 411 40 4701 -2183 2895 valve 175 -1623 618 -40 -4701 2183 -2895 180 1623 -640 40 4639 -2344 2895 SSE X+Y (33) elbow 135 9364 571 595 609 17584 1604 140 9364 571 595 1222 3091 16169 flange 140 9092 447 507 1222 3091 16169 145 9092 447 507 1254 839 16169 flange 145 9071 437 502 1254 839 16169 150 9071 437 502 1290 2066 16169 repair 150 9000 406 483 1290 2066 16169 155 9000 406 483 1316 3764 16169 repair 155 8465 190 363 1316 3764 16169 160 8465 190 363 1333 5373 16169 flange 160 8454 186 361 1333 5373 16169 165 8454 186 361 1358 7643 16169 flange 165 8432 179 356 1358 7643 16169 170 8432 179 356 1382 9914 16169 valve 170 8416 174 353 1382 9914 16169 175 8416 174 353 1391 10743 16169 valve 175 7997 124 281 1391 10743 16169 180 7997 124 281 1395 11530 16169 SSE Y+Z (34) elbow 135 1214 391 457 525 2104 781 140 1214 391 457 653 1661 1830 flange 140 1134 338 432 653 1661 1830 145 1134 338 432 704 1781 1830 flange 145 1128 334 433 704 1781 1830 150 1128 334 433 756 1951 1830 repair 150 1110 321 439 756 1951 1830 155 1110 321 439 793 2090 1830 repair 155 993 233 584 793 2090 1830 160 993 233 584 804 2212 1830 flange 160 991 231 589 804 2212 1830 165 991 231 589 821 2400 1830 flange 165 987 228 597 821 2400 1830 170 987 228 597 841 2601 1830 valve 170 984 226 603 841 2601 1830 175 984 226 603 848 2678 1830 valve 175 918 201 780 848 2678 1830 180 918 201 780 846 2746 1830 File No.: 2101264.301 Page 9 of 11 Revision: 0 F0306-01R4

Figure 3. Original and Current Point Numbering

6.0 CONCLUSION

S AND DISCUSSION All required pipe stresses (Table 1) are less than allowable values and are therefore acceptable. Tables 2 and 3 present equipment and support loads (respectively) for evaluation by NextEra; load increases are noted in the tables.

Note that cast iron is a non-ductile material. The reduced allowable stress of 6 ksi (see Table 1) is indicative of that and is meant to limit the strains to where ductility is not an issue.

File No.: 2101264.301 Page 10 of 11 Revision: 0 F0306-01R4

7.0 REFERENCES

1. PMC Engineering Drawing No. 202111-M-0001, Revision P7, ,

SI File No. 2101264.205.

2. ANSI B31.1, , The American Society of Mechanical Engineers:

a. 1973 Edition

b. 1977 Edition with Addenda through Winter 1976

3. Calculation No. PTN-3FSM-92-029, Revision 0,

, SI File No. 2101264.201.

4. PIPESTRESS, Version 4.0.0, DST Computer Services S.A., October 2018.

5. Design Information Transmittal, Document No. AR 02347348, DIT 001,

, SI File No. 2101264.202.

6. Email from P. Manzon (PMC Engineering) to C. Figueroa (NextEra) dated 12/8/2021,

Subject:

RE:

Turkey Point Nuclear - Pipe Spool Restoration Clamp, SI File No. 2101264.208.

7. Drawing No. 5613-P-820-S, Revision 5,

, SI File No. 2101264.205.

8. Turkey Point Updated Final Safety Analysis Report (UFSAR), Revision C29, 04/06/2018, SI File No.

2101264.211.

9. Design Information Transmittal, Document No. AR 02347348, DIT 003,

, SI File No. 2101264.202.

File No.: 2101264.301 Page 11 of 11 Revision: 0 F0306-01R4

sparker@structint.com 10731 E. Easter Avenue, Suite 100, Centennial, CO 80112 l 303-542-1427 March 7, 2022 REPORT NO. 2101264.401 REVISION: 0 PROJECT NO. 2101264.00 Quality Program: Nuclear Commercial Gary Priolio Turkey Point Nuclear Plant 9760 SW 344 St.

Florida City Florida

Subject:

Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron Piping

1.0 INTRODUCTION

The present concern is for the general corrosion rate of ductile grey cast iron operating at a design temperature of up to 120°F (49°C) exposed to brackish water with no chemistry control for dissolved oxygen at the Turkey Point nuclear reactor.

2.0 CORROSION EVALUATION As is presented in Figure 1, the atmospheric general corrosion rate of both ductile iron and gray iron are lower than mild steel and even copper steel, steel with significant amounts of copper [1].

In the case of submerged exposure, the results of an extremely short-term testing of only 28 days, the general corrosion rate of ductile iron exposed to simulated seawater of 3.5% chloride at 86°F was 29 mils per year (mpy) [1]. From the standpoint of Corrosion of engineering alloys, the parabolic law is of significant importance. As per this law, the oxide growth on the base metal occurs with a continuing decreasing corrosion rate. The rate of the reaction, therefore, is inversely proportional to the corrosion film thickness or the weight of oxide formed. Most metals and engineering alloys corrode follow parabolic kinetics. The corrosion oxide growth process is usually governed by the diffusion of ions or electrons through the initially formed oxide scale.

Since general corrosion of steel and cast iron do follow parabolic kinetics, a longer-term general

© 2022 by Structural Integrity Associates, Inc. All rights reserved. No part of this document or the related files may be reproduced or transmitted in any form, without the prior written permission of Structural Integrity Associates, Inc.

MCG-007-00 08.21.20

March 7, 2022 Gary Priolio Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron Piping corrosion test would have yielded dramatically lower penetration rates as illustrated in Figures 2 and 3.

Figure 1. Results of Exposure of Steels and Cast Irons to General Corrosion by the Atmosphere 80 feet from the Ocean at Kure Beach, N. C. (Specimen size of 4 x 6 inches) [1]

Report No. 2101264.401 R0 PAGE l 2

March 7, 2022 Gary Priolio Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron Piping Figure 2. Sketch of Parabolic Kinetics for General Corrosion Figure 3. Sketch of the Corrosion Rate that Decreases with Time Report No. 2101264.401 R0 PAGE l 3

March 7, 2022 Gary Priolio Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron Piping The design temperature of 120°F (49°C) versus the test temperature of 86°F (30°C) would produce only a slight increase in general corrosion rate as based on carbon steel general corrosion tests exposed to the water (i.e., an open system), as shown in Figure 4 [2].

16 Fresh Water (Salinity 0) 14 Seawater (Salinity 35)

Dissolved Oxygen, ppm or Corrosion Rate, mpy Carbon Steel General Corrosion Rate 12 10 8

6 4

2 0

0 10 20 30 40 50 60 70 80 90 100 Temperature, C Figure 4. Effect of Temperature on the General Corrosion Rate of Carbon Steel in an Open System [2]

Finally, ductile iron is considered to have superior corrosion resistance compared to carbon steel 1 [1, 3]. If consideration is given to comparing ductile irons resistance relative to carbon steel in seawater, the long-term study discussed below is considered applicable to Turkey Point.

A very extensive and long-term study indicated that that the overall corrosion rates of carbon steel continuously immersed in quiescent seawater at many locations throughout the world for periods 1

Buried ductile iron piping does not necessarily require cathodic protection while buried carbon steel pipe typically does require cathodic protection.

Report No. 2101264.401 R0 PAGE l 4

March 7, 2022 Gary Priolio Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron Piping from less than one year to up to 40 years ranged from 0.8-14.6 mpy, where the average corrosion rate was 4 mpy [4]. It should be noted that the data curves below in Figure 5 2 were obtained at average temperatures lower than the 120°F (49°C) design temperature. Somewhat higher general corrosion rates would be anticipated at Turkey Points pipe spool piece.

The average of the corrosion rates in Figure 5 in the first five years is 5.5 mpy, very close to 5 mpy, which is the value most commonly used for the expected average rate of corrosion rate of steel continuously immersed in quiescent seawater under natural conditions in the industry [4].

The average of the corrosion rates for periods of > 5 to 10 years, > 10 to 20 years, and > 20 years are 2.8 mpy, 2.8 mpy, and 2.0 mpy, respectively, indicating that, as expected, the general corrosion rate decreases with time.

Figure 5. Average General Corrosion of Steel Continuously Immersed in Seawater [4]

2 Note the similarity between Figures 3 and 5 that demonstrate the reduction in general corrosion rates with time.

Report No. 2101264.401 R0 PAGE l 5

March 7, 2022 Gary Priolio Corrosion Assessment for Turkey Point Intake Cooling Water Ductile Grey Cast Iron Piping

3.0 CONCLUSION

The extremely short-term general corrosion test (e.g., 28 days) of ductile iron at a slightly lower exposure temperature of 86°F (30°C) versus 120°F (49°C) exposed to simulated seawater, resulted in a general corrosion rate of 29 mpy. However, it is expected that the long-term general corrosion rate of Turkey Points ductile cast iron pipe spool piece exposed to lower chloride containing brackish water even at a slightly higher temperature would be significantly lower than this short test value.

Therefore, based on the 5 mpy, which is the value most commonly used for the expected average rate of corrosion rate of steel continuously immersed in quiescent seawater and conservatively doubling that value, it is anticipated that the general corrosion rate of Turkey Points ductile grey cast iron to be conservatively 10 mpy.

4.0 REFERENCES

1. F. L. LaQue, The Corrosion Resistance of Ductile Iron, Corrosion, Volume 14, Number 10, National Association of Corrosion Engineers, Houston, TX, October, 1958, p. 55.

2. Effects of Marine Environments on Stress Corrosion Cracking of Austenitic Stainless Steels, EPRI, Palo Alto, CA: 2005. 1011820.

3. D. Dechant and C. Perry, External Corrosion Comparisons: Steel and Ductile-iron Pipe, January 4, 2005. https://www.nwpipe.com/app/uploads/2020/08/External-Corrosion-on-Steel-and-Ductile-Iron-2005.pdf

4. I. Matsushima, Carbon Steel - Corrosion by Seawater, Chapter 32, Uhligs Corrosion Handbook, Second Edition, R. W. Revie (ed), John Wiley & Sons, Inc. New York, NY, 2000, p. 545.

Prepared by: Verified by:

3/8/2022 3/8/2022 Barry Gordon Date Daniel Denis Date Associate Senior Consultant Approved by:

3/8/2022 Stephen Parker Date Consultant Report No. 2101264.401 R0 PAGE l 6

Proprietary Information Withhold from Public Disclosure under 10 CFR 2.390 L-2022-035 Enclosure 2 TURKEY POINT UNIT 3 RELIEF REQUEST No. 10 Part II Proprietary Information Related Attachments

1. PMC Engineering Work Scope and Design Input Document for Intake Cooling Water Pipe Spool Restoration, Design Input Document No. 202111-DID-01, 03-03-2022

2. PMC Design Report, ASME B31.1 Calculation for Intake Cooling Water Spool Piece Restoration PMC Restoration by Encapsulation Design Calculation 202111-S-01

3. Restoration Hardware Fabrication Drawings: PMC Dwgs. 202111-M-0001 R2, Sheets 1 thru 5.

4. Restoration Hardware Installation Drawings: PMC Dwgs: 20111-M-002 R0 , Sheets 1 thru13

L-2022-035 Enclosure 3 TURKEY POINT UNIT 3 RELIEF REQUEST No. 10 Part II Proprietary Information Affidavit Supporting Request for Withholding

U3 AFFIDAVIT, Rev. 3 I, Paul S. Manzon, state as follows:

1. I am the owner of PMC Engineering Solutions, Inc., Pottstown, PA, 19465. I am the inventor and owner of United States Patent 6,860,297, "Local degraded area repair and restoration component for pressure retaining items and am addressing the proprietary documents listed in (2) below, containing information which is sought to be withheld, and am applying for its withholding.

2. The information sought to be withheld is contained in the following PMC Engineering Solutions, Inc. documents:

a. PMC Engineering Drawing - Restoration Hardware Assembly Fabrication Details, Drawing No. 202111-M-0001, R2, Sheets 1 through 5.

b. Presentation Slides from the PMC Engineering Design Calculation 202111-S-01, R1, Figures B-1, B-2, B-3, and B-5.

c. PMC Engineering Design Report, ANSI B31.1 Calculation for Intake Cooling Water (ICW)

Discharge Piping Spool Piece Restoration, PMC Restoration By Encapsulation, Calculation No. 202111-S-01, R0

d. PMC Engineering Drawing - Restoration Hardware Assembly Installation Details, Drawing No. 202111-M-0002, R0, Sheets 1 through 13

e. PMC Engineering Work Scope and Design Input Document for Intake Cooling Water Discharge Pipe Spool Restoration, Design Input Document No. 202111-DID-01, R1

3. In making this application for withholding of proprietary information of which it is the owner, PMC Engineering Solutions, Inc. relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The information for which exemption from disclosure is here sought also qualifies under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission.

975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA. 704F2d1280 (DC Cir.

1983).

U4 Affidavit, R2. Page 1 of 4

4. Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analysis, where prevention of its use by PMC Engineering Solutions, lnc.'s competitors without license from PMC Engineering Solutions, Inc. constitutes an economic advantage over other companies

b. Information which, if used by a competitor, would reduce their expenditure of resources, or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product

c. Information which reveals aspects of past, present, or future PMC Engineering Solutions, Inc. customer funded development plans and programs, resulting in potential products to PMC Engineering Solutions, Inc.

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4) a., (4) b., and (4) d., above.

5. To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by PMC Engineering Solutions, Inc., and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by PMC Engineering Solutions, Inc. No public disclosures to third parties including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions which provide for the maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are set forth in paragraphs (6) and (7) following.

6. Approval of proprietary treatment of a document is made by me, Paul S. Manzon, owner of PMC Engineering Solutions, Inc. I am the person most acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within PMC Engineering Solutions, Inc. is limited on a "need to know" basis.

U4 Affidavit, R2, Page 2 of 4

7. The procedure for approval of external release of such a document requires review by me, Paul S. Manzon, owner, PMC Engineering Solutions, Inc., for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside PMC Engineering Solutions, Inc. are limited to regulatory bodies, customers, potential customers, and their agents, suppliers, and business and licensees, Authorized ASME Code Nuclear Inspectors, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

8. The documents identified in paragraphs 2a, 2c, 2d, and 23 above, are classified as proprietary because they contain "know-how" and "unique information" developed by PMC Engineering Solutions, Inc. within our product development programs. The development of this document, supporting methods, and information constitutes a major PMC Engineering Solutions, Inc. asset in this current market. Supporting aspects for the application to withhold information specific to the document containing proprietary information are as follows:

a. PMC Engineering Drawing - PMCap shop fabrication details drawing, Restoration Clamp Assembly Details, Drawing No. 202111-M-0001, R2, Sheets 1 through 5

b. PMC Engineering Design Report, ANSI B31.1 Calculation for Intake Cooling Water (ICW)

Discharge Piping Spool Piece Restoration, PMC Restoration By Encapsulation, Calculation No. 202111-S-01, R0

c. PMC Engineering Drawing - Restoration Hardware Assembly Installation Details, Drawing No. 202111-M-0002, R0, Sheets 1 through 13

d. PMC Engineering Work Scope and Design Input Document for Intake Cooling Water Discharge Pipe Spool Restoration, Design Input Document No. 202111-DID-01, R1

i. The above documents in paragraph 8a, 8b, 8c, and 8d contain specific design, fabrication, and installation details required to design, fabricate, and install ASME B31.1 Code Safety-Related restoration hardware (PMCaps). The development of these document details applicable to and supporting ASME B31.1 Code Safety-Related material, design, fabrication, examination, testing, and installation requirements are a major PMC Engineering Solutions, Inc. asset in this current market. These details were developed at a very high level of effort and expense over the past several years during which PMC Engineering Solutions, Inc. has been offering the nuclear power industry its comprehensive PMC Restoration Method (U.S. Patent 6,860,297) products and services which include those protected by U.S.

Patent 6,860,297.

9. The entirety of the information contained in the documents listed in paragraphs 2.a., above, is sought to be withheld from Public Disclosure under 10 CFR 2.390:

U4 Affidavit, R2, Page 3 of 4

10. Public disclosure of the information sought to be withheld is likely to cause substantial harm to PMC Engineering Solutions, lnc.'s competitive position and foreclose or reduce availability of profit-making opportunities. The information is part of PMC Engineering Solutions, lnc.'s comprehensive PMC Restoration Method products and services offerings which include those protected by U.S. Patent 6,860,297, and its commercial value extends beyond the original development costs. The value of the technology base goes beyond the information contained in the documents and includes development of the expertise to determine and apply the appropriate data, requirements, criteria, limitations, approaches and methodologies used in the development and preparation of the design, design details, and supporting documentation for the restoration covered by the information sought to be withheld.

The research, development, engineering, and analytical costs comprise substantial investment of time and money by PMC Engineering Solutions, Inc.

The precise value of the expertise to devise a restoration method and apply the appropriate and correct Code and regulatory requirements to the restoration is difficult to quantify, but it clearly is substantial.

PMC Engineering Solutions, lnc.'s competitive advantage will be lost if its competitors are able to use the results of the PMC Engineering Solutions, Inc. experience to develop or modify their own restoration method or if they are able to claim an equivalent understanding by demonstrating that they can develop the same or similar restoration method.

The value of this information to PMC Engineering Solutions, Inc. would be lost if the information were disclosed to the public. Making such information available to competitors without them having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive PMC Engineering Solutions, Inc. of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Sincerely, Paul S. Manzon __03.10.2022__

Owner Date PMC Engineering Solutions, Inc.

U4 Affidavit, R2, Page 4 of 4