L-95-237, Forwards Inservice Insp Program Relief Requests 6,14,15,16 & 17
| ML17353A490 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/14/1995 |
| From: | Hovey R FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-95-237, NUDOCS 9512190288 | |
| Download: ML17353A490 (88) | |
Text
P RIDRI'YY 1
(ACCELERATED RIDS PROCESSli REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)
ACCESSION NBR:9512190288 DOC.DATE: 95/12/14 NOTARIZED: NO
'FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION HOVEY,R.J.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000250 05000251
SUBJECT:
Forwards inservice insp program relief requests 6,14,15,16 17.
DISTRIBUTION CODE:
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TITLE: OR Submittal: Inservice/Testing/Relief from ASM Code GL-89-04 NOTES:
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DEC 14 1995 L-95-237 10 CFR 550.55a U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D AC. 20555 Gentlemen:
Re:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 Inservice Inspection Program Relief Re uests Nos.
6 14 15 16 and 17 By letters L-93-220, dated September 9,
(FPL) submitted a
summary of the Inservice Inspection (ISI) Program and relief requests for the third ten year interval at Turkey Point Units 3
and 4.
NRC letter dated March 31,
- 1995, documented the Staff's review and evaluation of Turkey Point Units 3 and 4 ISI Program and associated relief requests.
Per NRC letter dated March 31, 1995, Relief Request No.
6, Paragraph IWA-6620, Preparation of Owner's Reports, Forms NIS-1 and NIS-2, and Submittal of 90-Day Summary Reports, was denied.
Code Case N-532, "Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,Section XI, Division 1," was approved by ASME on December 12, 1994.
Attached please find revised Relief Request No.
6 for your consideration.
NRC review and approval of revised Relief Request No.
6 is requested by February 22, 1997.
On May 18,
- 1994, Turkey Point Unit 3 finished its first refueling outage for the third ten year interval.
Pursuant to 10 CFR 50.55a(g)
(5) (iii), FPL has determined that conformance with certain code requirements was impractical for Turkey Point Unit 3.
Attached please find Relief Request No.
14, Impractical ISI Requirements, for the Turkey Point Unit 3, Class 1 and 2 pressure retaining, similar and dissimilar metal welds in vessels and piping.
NRC review and approval of Relief Request No.
14 is requested by February 22, 1997.
On November 14,
- 1994, Turkey Point Unit 4 finished its first refueling outage for the third ten year interval.
Pursuant to 10 CFR 50.55a (g) (5) (iii)I FPL has determined that conformance with certain code requirements was impractical for Turkey Point Unit 4.
Attached please find Relief Request No.
15, Impractical ISI Requirements, for the Turkey Point Unit 4, Class 1 pressure retaining, similar and dissimilar metal welds in vessels and piping.
NRC review and approval of Relief Request No.
15 is requested by February 22, 1997.
9512190288 951214 PDR ADOCK 05000250 Q.,
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L-95-237 Page 2
Additionally, Relief Request No.
16, Pressure Tests for Repairs/Replacements, documents FPL's request to use ASME Code Case N-416-1 for Turkey Point Units 3 and 4.
Please note that relief is requested from performing the system hydrostatic tests on the Turkey Point Units 3 and 4 steam generator nozzle to reducer weld joints previously committed to in FPL letter L-93-139, dated May 17, 1993.
NRC review and approval of Relief Request No
~
16 is requested by February 22, 1997.
Relief Request No.
17, Turkey Point Unit 4 Class 2 Steam Generator Nozzle to Shell Weld and Inner Radius Section, documents FPL's request of relief from reexamining the initially selected components over the service lifetime of the component for the nozzle to shell weld and inside radius section on the steam generator main steam nozzle, for Turkey Point Unit 4.
NRC review and approval of Relief Request No.
17 is requested by February 22, 1997.
Should there be any questions concerning this submittal, please contact us.
L Very truly yours, Robert J.
Hove Vice President Turkey Point Plant OIH Attachment cc:
S.
D. Ebneter, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector, USNRC
Attachment to L-95-237 Page 1
TURKEY POINT UNITS 3 AND 4 REVISED RELIEF REQUEST NO.
6 PARAGRAPH IRK 6620@
PREPARATION OF OWNER 'S REPORTS f FORMS NIS-1 AND NIS-2, AND SUBMITTAL OF 90-DAY'UMMARYREPORTS
.9512190288
Ik 0
Attachment to L-95-237 Page 2
RELIEF REQUEST NUMBER 6 A.
Article Identification:
Turkey Point Units 3 and 4
Article IWA-4000 Repair Procedures Article IWA-6000 Records and Reports Article IWA-7000 Replacement Procedures B.
Article Requirements:
Paragraph ZWA-4800 The records required by IWA-6000 shall be completed for all repairs.
Paragraph IWA-6210(c)
The owner. shall prepare inservice inspection summary reports for Class 1 and 2 pressure retaining components and their supports.
Paragraph IWA-6220(c)
Inservice Inspection summary reports shall be required at the completion of each inspection conducted during a refueling outage.
Examinations,
- tests, replacements and repairs conducted since the preceding summary report shall be concluded.
Paragraph IWA-6220(d)
Each summary report shall contain the following:
(2) Owner's Report for Inservice Inspections, Form NIS-1.
(3) Owner's Report for Repair or Replacement, Form NIS-2.
Paragraph IWA-6230 and within 90 days of the completion of the inservice inspection conducted during each refueli'ng outage, the owner shall file inservice inspection summary reports with the enforcement and regulatory authoriti'es having jurisdiction at the plant site.
Paragraph IWA-7520(a)
(8)Completed Owner's Report for Repairs or Replacements, Form NIS-2.
il
Attachment to L-95-237 Page 3
C. Relief Requested:
Relief is requested from the following:
Preparation of the Owner's Report for Inservice Inspection, Form NIS-1.
2.
3.
Preparation of the Owner's Report for Repair or Replacement, Form NIS-2.
Submittal of the summary report following completion of the inspections conducted during each refueling outage.
D.
Basis for Relief:
Code Case N-532, "Alternative Requirements to Repair and Replacement Documentation Requirements
-and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,Section XI, Division 1," was approved for use by ASME on December 12, 1994.
This code case addresses alternative methods of documenting repairs, replacements, and inservice inspections.
The alternative methods proposed by the, code case include a
revised version of the current NIS-1 and NIS-2 form.
The new single page form serves as a certification record which documents conformance to Section XI requirements.
The revised Form NIS-2A eliminates the need to list each individual item used in a replacement.
- Instead, this information is to be documented within a separate Repair/Replacement Plan.
Upon completion of all required replacement activities, the Repair/Replacement Certification
- Record, Form NIS-2A, is presented to the Authorized Nuclear Inservice Inspector for acceptance.
Both the Plan and Form NIS-2A are maintained on file by the Owner.
An index or abstract used to track completed repair or replacement activities is later submitted as an attachment to the Owner's Activity Report, Form OAR-1.
In addition to the revised NIS-2 Form, Code Case N-532 provides alternatives to the preparation and submittal of the inservice inspection summary report and Form NIS-1, currently prepared in accordance with the requirements of IWA-6220 and IWA-6310.
Attachment to L-95-237 Page 4
These changes eliminate the need to document information on more than one record and the submittal of numerous NIS-2 reports.
E. Alternative Examinations or Tests:
As an alternative to the present requirements of IWA-6220 and IWA-6230, FPL proposes to follow the guidelines of Code Case N-532 as follows:
A Repair/Replacement Plan will be prepared prior to the start of repair or replacement activities.
Each Plan will describe the conditions and elements required by IWA-4130 and IWA-7130.
Each Plan shall be identified and tracked by a unique identification number, which could be a Plant Work Order (PWO)
- number, Construction Work Order (CWO) number, or other unique tracking number designated by the plant.
2.
Upon completion of the repair or replacement activity, FPL will prepare a Repair/Replacement Certification
- Record, Form NIS-2A.
The form will be presented to the inspector for acceptance and be maintained on file.
4.
After each refueling outage, FPL shall prepare an Owner's Activity Report Form, OAR-1, which lists applicable tests and examinations.
Test and Exam information will be maintained in an abstract (or index) similar to Table 1.
5.
The OAR-1 will identify items with flaws or relevant conditions and a summary of the applicable evaluation.
This information shall be maintained in an abstract (or index) similar to Table 2.
6.
An abstract (or index) similar to Table 3, which lists each Repair and Replacement Plan by its identification
- number, shall be maintained..
The index shall also indicate the inspection interval and period when the repair or replacement was completed.
7.
At the end of each inspection period, a copy of the OAR-1 and applicable attachments will be filed with the enforcement and regulatory authorities.
who have jurisdiction at the plant site, following the end of the inspection period.
8.
References to the 1992 Edition of Section XI will.be replaced by the appropriate portion of the 1989 Edition.
IO 0
ik
Attachment to L-95-237 Page 5
9.
Repair/Replacement Plans describing the repair or replacement activity and.containing the essential information as described by IWA-4000 and IWA-7000, will be available for inspection at any time.
F. Implementation Schedule:
This request for relief will be utilized during the second and third inspection periods of the thi;rd inservice inspection interval.
G. Attachments to the Relief:
Copy of Code Case N-532
Attachment to L-95-237 Page 6
CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date:
December 12, 1994 See Numeric Index for expiration and any reaffirmation dates.
Code Case N-532 Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000.
Section XI, Division 1
Inquiry: What alternatives may be used to the IWA-4910(d) and IWA-6210(e) for completion of following repair or replacement, and IWA-6210
- 6220, IWA-6230(b)., (c),
and (d),
and IWA-6240 and submittal of the inservice summary report requirements of Form NIS-2 (c) and (d),
IWA-(b) for preparation and Form NIS-1?
Reply: It is the opinion of the Committee that as an alternative to the requirements of IWA-4910 (d),
IWA-6210'(c),
(d),
and (e),
(c),
and (d),
and IWA-6240)b), the following provisions may be used.
This Case shall.be utilized at least until the end of the inspection period in which it was invoked.
1.0 CERTIFICATION OF THE REPAIR OR REPLACEMENT (a)
(b)
(c)
(d)
(e)
The Owner's Repair/Replacement Program shall identify use of this Case.
A Repair/Replacement Plan shall be prepared in accordance with IWA-4140, and shall be given a unique identification number.
Upon completion of all required activities as associated with the Repair/Replacement
- Plan, the Owner shall prepare a Repair/Replacement Certification
- Record, Form NIS-'2A.
Form NIS-2A shall be presented to the Inspector for certification.
The completed Form NIS-2A shall be maintained by the Owner.
The Owner shall maintain an index of Repair/Replacement Plans in accordance with IWA-6340.
The index shall identify the identification number required by (b) above and the inspection interval and period during which each repair or replacement was completed.
Attachment to L-95-237 Page 7
- 2. 0 OWNER~ S ACTIVITY REPORT PREPARATION AND SUBMITTAL An Owner's Activity Report Form OAR-1 shall be prepared and certified upon completion of each refueling outage.
Each Form OAR-1 prepared during an inspection period.shall be submitted following the end of the inspection period.
Each Form OAR-1 shall contain the following:
(a)
(b)
(c)
Abstract of applicable examinations and tests with the information and format of Table 1.
A listing of item(s) with flaws or relevant conditions that required evaluation to determine acceptability for continued service, whether or not the flaw or relevant condition was discovered during a scheduled examination or test.
The listing shall provide the information in the format of Table 2.
Abstract for repairs, replacements and corrective measures performed, which were required due to an item containing a flaw or relevant condition that exceeded IWB 3000'WC 3000 IWD 3000 IWE 3000 IWF 3000'r IWL-3000 acceptance criteria; even though the discovery of the flaw or relevant condition that necessitated the
- repair, replacement or corrective measure, may not have resulted from an examination or test required by this Division. If acceptance criteria for a particular item is not specified.in this Division, the provisions of IWA-3100(b) shall be used to determine which repairs, replacements, and corrective measures are required to be included in the abstract.
The abstract shall provide the information in the format of Table 3.
t Attachment to L-95-237 Page 8
FORM NIS 2A REPAIR/REPLACEMENT CERTIFICATION RECORD OWNER'S CERTIFICATE 'OF CONFORMANCE I ceztify the Number zepresent by Repair/Roplacoment Plan ropa z or zop acement conforms to the zequircmonts of Section XI.
Typo Code Symbol Stamp t
Ceztificato of Authorization No.
Expiration Dato Owner o Owner s Dosignoo, Title CERTIFICATE OF INSERVICE INSPECTION Ig the undersigned, holding a valid commission issued by the National Board oi Bailor and Pressure Vessel Inspectors and the State or Pzovlnco of and employed by of have inspocte t o toms escribod in Repair/Rep acement an n r
ur ng t e por o to
, and stato that to tho best o
my now e go and belief, tho Owner as per orme a
t e act v es oscz in tho Repair/Replacement Plan ln accordance with the zoquiremonts of Section XI'y signing.this coztificate neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the activities described ln tho Repair/Roplacement Plan.
Furthermore, noithor tho lnspoctor nor his employer shall be liable ln any manner for any personal injury.or property damage oz loss of any kind azlsing from or connectod with this inspection.
nspector s
gnaturo Commissions at ona ar,
- tate, rov nce, an n orsemen s
Dato
Attachment to L-95-237 Page 9
FOHN OAR-1 OWNER',S ACTIVITY REPORT Report Number Owner Plant arne an ress o
nor amo an A
ress o
P ant Unit No.
Commercial Service Data app ca e
curront Inspection Intorval st, n,
r,
t, ot or Current Inspection Porlod st, n,
r Edition and Addonda of Section XI applicablo to tho inspection plan Dato and Revision of lnspoction plan Rofuoling Outage No.
Edition and Addenda of Soctlon XI appllcablo to repairs and replacements, if different than tho inspection plan CERTIFICATE OF CONFOEQCANCE I cortlfy that the statements made in the Owner's Activity Report are correct, and that tho examinations,
- tests, repairs, replacements, evaluations, and corrective measures represented by this report conform to tho requirements of Section XI.
Certificate of Authorization No.
Signed nor or nor s as gnco, app ca e)
Expiration Date Date CERTIFICATE OF INSERVICE INSPECTION I,,tho undersigned, holding a valid ccmaission issued by the National Board of Boiler and Prcssure Vessel Inspectors and tho Stato or Province of and employed:by of have inspccte the tcms ascribed in this Owner s Act v ty Report, ur ng t e por o
'to and state that to the bast of my knowlodgo and of Section XI.
By signing this certificate neither the Inspector nor his employer makes any warranty, expressed or implied, concorning tha examinations,
- tests, repairs, roplacemonts, ovaluations, and corractivo measures described in this report.
Furthermore, neither tha inspector nor his employer shall bo liable ln any mannor for any personal ln)ury or property damage or,loss of any kind arising from or connected with this inspection.
nspoctor s
gnature Commissions at ona ar
- tato, rov nco, an n orscmonts Date
Attachment to L-95-237 Page 10 TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Examination Category Total Examinations Requirod for tho Interval Total Examinations Credited for this Period Total Examinations Creditod (\\)
for tho Poriod Total Examinations Credited (0) to Dato for tho Interval Remarks TABLE 2 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT REQUIRED EVALUATION FOR CONTINUED SERVICE Examination Category Flaw Flaw or Rolovant Condition Found Item Charactorisation During Scheduled Soction XI Item Number Description (IWA-3300)
Examination or Test (Yos or No)
TABLE 3 ABSTRACT OF REPAIRS F REPLACEMENTS F OR CORRECTIVE MEASURES REQUIRED FOR CONTINUED SERVICE Code Class
- Repair, Replacement, or Corroctive Measure Itom Description Description of Work Flaw or Relevant Condition Found During Scheduled Soction XI Examination or Tost (Yos or No)
Date Comploto Repair/
Replacement Plan Number
0
Attachment to Z,-95-.237 Page 11 TURKEY POINT UNIT 3 RELIEF REQUEST'O.
14 IMPRACTICAL INSERVZCE INSPECTION REQUIREMENTS
Attachment to L-95-237 Page 12 RELIEF REQUEST NO.
14 A.
Component Identification:
Class 1 and Class 2 pressure retaining similar and dissimilar metal welds in vessels and piping found during the 1994 outage at Turkey Point Unit 3.
B.
Examination Requirements:
Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1989 Edition with no Addenda Category B-D B-F B-J C-F-1 C-F-2 Item No.
B3.140 B5. 70 B9.11 C5. 11 C5.51 Examination Requirements Fig. IWB-2500-7 (a through d),
area defined by M-N-0-P Fig. IWB-2500-8(b), weld and 1/2" to each side of the weld, 1/3t from the inside surface out to 1/4" from a line drawn from the toe of the outside surface weld crown (area C-D-E-F)
, Fig,.
IWB-2500-8 (b), weld and 1/2" to each s'ide of the weld, 1/3t from the inside surface out to 1'/4" from.a line drawn from the toe of the outside surface weld crown (area C-D-E-F)
Fig.
IWC-2500-7 (a), surface of weld and 1/2" of surface base metal (area A-B), 1/3t from the inside surface out to 1/4" from a line drawn from the toe of the outside surface weld crown (area C-D-E-F)
Fig.
IWC-2500-7 (b), surface of weld and 1/2" of surface base metal (area A-.B), 1/3t from the inside surface out to 1/4" from a line drawn from the toe of the outside surface weld crown (area C-D-E-F)
Attachment to L-95-237 Page 13 ASME Code Case N-460 Alternative Examination Coverage for Class 1 and Class 2 Welds C.
Relief Requested:
Relief is requested from the required code examination area during volumetric and surface examinations.
D.
Basis for Relief:
Several welds examined during the 1994 outage did not receive the required volumetric examinations due to one or more factors:
1.
Portions of the required volumetric area are inaccessible due to permanent physical obstructions.
2.
Some welds could be examined from only one side due to the configuration of the component, high attenuation of the ultrasonic
- sound, or other technical reason.
FPL performed the examinations to the extent possible.
The surface and volumetric examinations performed along with the required system pressure tests provide assurance of an acceptable level of quality and safety.
The attached table summarizes the percent of coverage achieved and references specific figures that show the extent of the limitations.
E.
Alternative Examinations or Tests:
Volumetric and surface examinations were performed to the extent possible.
2.
System pressure tests as. required by ASME Section XI.
3.
Monthly walkdowns by system engineers:are performed on Class 2 systems outside containment to check for
- leakage, piping configuration, and/or damage.
During'utages, system engineers walkdown Class 1 and Class 2
systems inside containment.
This walkdown is performed to look for system anomalies which could affect plant performance.
The examination volume achieved by surface and/or ultrasonic examination, combined with the system pressure tests and system engineer walkdowns, provide an acceptable level of quality and safety.
If permanent obstructions are removed for other reasons, FPL will examine those areas that become accessible to the extent practical'
Attachment to L-.95-237 Page 14 F.
Implementation Schedule:
These examinations were performed during the first outage of the first period of the third inservice inspection interval, from April 4, 1994 through. May 4g 1994.
G.
Attachments Table showing areas where limited examinations were
,performed and the extent of coverage.
Sketches of areas with limited examinations (sketches are for il'lustrative. purposes and" are not to scale.)
Attachment to L-95-237 Page 15 Catgy/
Item No.
B-D B3.140 B-D B3.120 B-F B5.70 B
B9. 11 B-J 89.11 B-F BS F 70 B-J B9.11 B-J B9.11 B-J B9.11 Zone 3-004 3-006 3-010 3-010 3-011 3-011 3-012 3-016 3-038 3-SGB-I-IRS 3-SGB-0-IRS 3-SRGN-01-IR 31"-RCS-1302-5 31"-RCS-1302-10 29"-RCS>>1305-3 29"-RCS-1305-4 27 5"-RCS-1306-11 120-RC-1301-1 10"-SI-1302-1 NDE Technique 1/2 V
Full V
11/2 V
30 60 45 45 45 60 60 Angle and Technique Configuzation or Limitations Weldeci on pads,
- support, and IRS configuration Heater penetrations limited the exam area Steam generator nozzle to elbow Elbow to pump casing Branch connection limits 18", elbow configuration limits cram Nozzle to elbow Pump casing to pipe Branch connection to pipe Elbow to valve 3-8758 Fig.
No.
94-3-1 94-3-2 94-3-3 94-3-4 94-3-5 94-3-6 94-3-7 94-3-8 94-3-9 Comments /
4 Coverage 70% coverage achieved in two directions 55% coverage from 2 directions 75% from the elbow side, 0%
from the nozzle side 75% from the elbow side, 0%
from the pump side 93% from pipe side, 69'rom elbow side 43% from elbow
- side, 2% frau nozzle side 0% from the pump side, 100'rom pipe side 100% fran the pipe side, 67%
from the branch connection side 100% from the elbow side, 85%
from the valve side B-J B9 ~ 11 C-F-1 C5.11 3-038 3-089 10"-SI-1302-4 8"-SI-2309-22 45 45 60 60 Elbow to valve 3-8758 Pipe to tee 94-3-10 94-3-11 85% from the elbow side, 25%
from the valve side 100% frca the pipe side, 47%
from the tee side
Attachment to L-95-237 Page 16 Catgy/
Item No.
C-F-1 CS ~ 11 C-F-2 c5.51 Zone Item 3-089 8"-SI-2309-24 3-103 6"-BDA-2301-8 NDE Technique 1/2 V
Full V
11/s V
60 60 Angle and Technique Configuration or Limitations Pipe to valve 3-876E Tee to pipe Fig.
No 94-3-12 94-3-13 Coements /
8 Coverage 100% from the pipe side, 0%
from the valve side 100% from Pipe
- Side, 50% from Tee Side
Attachment to L-95-237 Page 17 LUG LUG oO 3'ADS TYPICAL 3'ADS TYPICAL 3-SG3-I IRS INLET NOZZLE INNER RADIUS 3-SGB-0-IRS OUTLET NOZZLE INNER RADIUS FIGURE 94 3-1
0 Attachment to L-95-237 Page 18 oo ooo 000 0 ooo o
ooo 0 0 0 00 oo o 000 ooo PRESSURIZER SURGE NOZZLE 3-SR GN-01-IR FIGURE 94-3-2 0
5 0
00 0 TYp 00 o
o o
o 0 o ooo o o o ooooo o
o000o
ll
Attachment to L-95-237 Page 19 STEAM GENERATCIR NgZZLE 31' RCS 1302 5 FIGURE 94 33
Attachment to L-95-237 Page 20 PUMP CASING ELBOV 31"RCS =1302 10 FIGURE 94 3 4
Attachment to L-95-237.
Page 21 PIPE
/
ELBGV SAFETY INJECTION LINE
~VELD 2,125'9'-RCS-1305-3 FIGURE 94-3-5
Attachment to L-95-237 Page 22 PIPE ELBOV 29' RCS-1305 4 FIGURE 94 3 6
Attachment to L-95-237 Page 23 PUMP CASING PIPE 27,5" RCS 1306 11 FIGURE 94 3 7
Attachment to L-95-237 Page 24 REDUCER PIPE 12"RC 1301 1
Attachment to z,-95-237 Page 25 ELBQV BRANCH CCINNECTICIN 10' SI1302 1 FIGURE 94 3 9
if'g>
Attachment to L-95-237 Page 26 ELBOW VALVE 10"SI 1302 4 FIGURE 94 3 10
Attachment to L-95-237 Page 27
Attachment to L-95-237 Page 28 VALVE SURFACE IS IN THE ASCAST CONDITION, NOT CONDUCIVE TO PROPER EXAMINATION.
VALVE PIPE O'-SI-2309-24 FIGURE 94-3-12
I'g)
~
i
Attachment to L-95-237 Page 29 TEE PIPE 6"BDA2301 8 FIGURE 94 3 13
t'ai
Attachment to L-95-237 Page 30 TURKEY POINT UNZT 4 RELIEF REQUEST NO.
15 IMPRACTICAL ZNSERVZCE INSPECTION REQUIREMENTS
i
~gi i
Attachment to L-95-237 Page 31 RELIEF REQUEST NO.
15 A.
Component Identification:
Class 1 pressure retaining similar and dissimilar metal welds in vessels and piping found during the 1994 outage at Turkey Point Unit 4.
B.
Examination Requirements:
Rules for Inservice Inspection of Nuclear Power Plant Components, Section XIg 1989 Edition with no Addenda Category B-D B-F B-J Item No.
B3.140 B5. 70 B9. 11 B9.31 Examination Requirements Fig. IWB-2500-7(a through d)g area defined by M-N-0-P Fig. IWB-2500-8(b), weld and 1/2" to each side of the weld Fig. IWB-2500-8(b), weld and 1/2" to each side.of the weld, 1/3t from the inside surface out to 1/4" from a line drawn from the toe of the outside surface weld crown (area C-.D-E-F)
Fig. IWB-2500-10, weld and 1/2t or 1" (whi.'chever is less) to. each side of the weld, 1/3t from the inside surface out to 1/4" from a line drawn from the toe of the outside surface weld crown,(area C-D-E-F)
ASME Code Case N-460 Alternative Examination Coverage for Class 1 and Class 2 Welds C.
Relief Requested:
Relief is requested from the required code examination area during volumetric and surface examinations.
Attachment to L-95-237 Page 32 D.
Basis for Relief:
Several welds examined during the first outage of the first period of the third ISI inspection interval did not receive the required volumetric and/or surface examinations due to one or more factors:
1.
Portions of the required volumetric and surface area are inaccessible due to permanent physical obstructions.
2
~
Some welds could be examined from only one side due to the configuration of the component, h'igh attenuation of the ultrasonic
- sound, or other technical reason.
FPL performed the examinations to the extent possible.
The surface and volumetric examinations performed along with the required system pressure tests provide assurance of an acceptable level of quality and safety.
The attached table summarizes the percent of coverage achieved and references specific figures that show the extent of the limitations.
E.
Alternative Examinations or Tests:
1.
Volumetric and surface examinations were performed to the extent possible.
2.
System pressure tests as required by ASME Section XI.
3.
Monthly walkdowns by system engineers are performed on Class 2 systems outside containment to check for leaks, piping configuration, and/or damage.
During outages, system engineers walkdown Class 1 and Class 2 systems inside containment.
This walkdown is performed to look for system anomalies which could affect plant performance.
The examination volume achieved by surface and/or ultrasonic examination, combined with the system pressure tests and system engineer walkdowns, provide an acceptable level of quality and safety.
If permanent obstructions are removed for other reasons, FPL will examine those areas that become accessible to the extent practical.
F.
Implementation Schedule:
These examinations were performed during the first outage of the first period of the, third inservice inspection interval, from October 3,
1994 through November 14, 1994.
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Attachment to L-95-237 Page 33 G.
Attachments Table showing areas where limited exami.'nations were performed and the extent of coverage.
Sketches of areas with limited examinations (sketches are for illustrative purposes and are not to scale.)
Attachment to L-95-237 Page 34 Catgy/
Itera No.
Zone Itera NDE Technique 1/2 V
Full V
11/2 V
Angle and Technique Configuration or Liaaitations Fig.
No Ccmaents /
\\ Coverage 8-D 83 '40 8-F 85.70 4-003 4-007 4-SGA-I-IRS 4-SGA-0-IRS 31"-RCS-1401-5 Inner radius section, insulation
- brackets, support,'nd nozzle transition area 1&it exaus Stean generator nozzle to elbow 94-4-1 94-4-2 70% coverage achieved in two directions Oi frma the nozzle
- side, 75% frma the elbow side 8-J 89.11 4-007 31"-RCS-1401-8 UT 45 Elbow to pipe, elbow and weld gemaetry 94-4-3 64% frma the pipe
- side, 88% frma the elbow side 8-J 89 ~ 11 8-F 85.70 4-007 4-008 31"-RCS-1401-10 29"-RCS-1404-4 45 Elbow to reactor coolant punp casing, elbow geo=etry and pu=p configuration Elbow to steau generator nozzle 94-4-4 94-4-5 57% frma the elbow
- side, 0% frma the pump side 74% from the elbow
- side, 0% frma the nozzle side 8-J 89.31 8-J 89.11 8-J 89'1 8-J 89.31 8-J 89.31 4-008 4-009 4-009 4-011 4-012 29"-RCS-1404-18 27.S"-RCS-1407-11 27.5"-RCS-1407-20 29"-RCS-1405-21 27 '"-RCS-1406-18 UT 45 70 45 45 70 45 70 45 70 14" branch connection, weld configuration lhaits coverage Reactor coolant punp case to pipe, instrunent nozzle near weld and pu p and weld configuration 10" branch connection, weld configuration linits coverage 12" branch connection, weld configuration limits coverage 10" branch connection, weld configuration linits coverage 94-4-6 94-4-7 94-4-8 94-4-9 94-4-10 0% frma the pipe
- side, 100% from the branch connection side 18% frma the punp
- side, 41% frma the pipe side 92%
Erma the nozzle
- side, 0% frma the stain loop pipe side 75% branch connection
- side, 0% frma the pipe side 100% frma the nozzle
- side, 0% frma the cain loop pipe side
Attachment to L-95-237 Page 35 Catgy/
Item No.
Zone Item NDE Technictue 1/2 V
Pull V
11/2 V
Angle and Technique Configuration or Limitations pig.
No.
Comments /
% Coverage 8-J 89'1 8-J 89.31 8-J 89.11 8-J 89.11 4-015 4-015 4-036 4-036 27.5"-RCS-1409-16
- 27. 5"-RCS-.1409-17 14" RHR-1401-1 14"-RHR-1401-5 UT 45 60 45 70 45 60 45 60 4" bzanch connection, weld configuration limits coverage 10" branch connection, weld configuration limits coverage Branch connection to elbov Pipe to valve, weld configuration 94-4-11 94-4-12 94-4-13 94-4-14 100% fraa the nozzle
- side, 0%'rom the main loop pipe side 100% from the nozzle
- side, 0% from the main loop pipe side 70% from the elbow
- side, 35% from the branch connection side 100% from the pipe
- side, 0% from the valve side 8-J 89 F 11 8-J 89.11 8 J 89 ~ 11 8-J 89.11 4-036 4-036 4-037 4-037 14"-RHR-1401-6 14"-RHR-1401-9 low-SI-1401-14 10"-SI-1401-18 45 60 45 60 45 60 45 60 Valve to pipe, weld configuration Elbow to pipe, veld configuration Valve to pipe Pipe to branch connection 94-4-15 94-4-16 94-4-17 94-4-18 100% frca the pipe
- side, 0% from the valve side 53% from the pipe
- side, 54% from the elbow side 100% from the pipe
- side, 26% from the valve side 100% from the pipe
- side, 18% from the branch connection side
Attachment to L-95-237 Page 36 LUG LUG oO 3'ADS TYPICAL 3'ADS TYPICAL 4SGA=I-IRS INLET NOZZLE INNER RADIUS 4-SGA-0-IRS OUTLET NOZZLE INNER RADIUS FIGURE 94-4-1
Attachment to L-95-237 Page 37 STEAM GENERATOR NOZZLE ELBOV 31' Rt S 1401 5 F IGURE 94 4 2
1 4s if'gi
Attachment to L-95-237 Page 38 ELBOV 31'-RCS 1401-8 F IGURE 94-4-3
Attachment to L-95-'237 Page 39 PUMP t ASING ELBOV 31"Rt S=1401 10 FIGURE 94 4 4
Attachment to L-95-237 Page 40 STEAM GENERATOR NOZZLE ELBOV 29 RCS 1404 4
Attachment to L-95-237 Page 41 45'0'5'0'LCIT AT O'ND 180'LOT AT 90'ND 270'9'-RCS 1404 18 FIGURE 94-4-6
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Attachment to L-95-237 Page 42 P UMP CASING PIPE 27,5' RCS 1407-11 FIGURE 94 47
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Attachment to L-95-237 Page 43 70'5 70'5'LOT AT 90'N13 270'LOT AT O'ND 180'7,5'-RCS-1407-20 FIGURE 94-4 8
Attachment to L-95-237 Page 44 45 70 PLOT AT 90 AND 270 70 PLOT AT 0
AND 180 29 RCS 1405 21 FIGURE 94 4 9
Attachment to L-95-237 Page 45 70'5'0'5'LOT AT 90'ND 270'LOT AT O'ND 180'7,5' RCS 1406 18 FIGURE 94-4 10
Attachment to L-95-237 Page 46 60'0'S'O COVERAGE PLOT AT O'ND 180'LOT AT 90'ND 270'7,5
=RCS-1409-16 FIGURE 94-4-11
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Attachment to L-95-237 Page 47 70'5 70'5'LOT AT 90 AND 270'LOT AT O'ND 180 27,5'-RCS 1409 17 FIGURE 94-4-12
Attachment to L-95-237 Page 48 BRANCH CGNNECTION 60 ELBCIV BRANCH CONNECTICIN 45 ELBCIV 14 RHR1401 1 FIGURE 94 4 13
Attachment to L-95-237 Page 49 PIPE VALVE 14 RHR 1401 5 FIGURE 94 4 14
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Attachment to L-95-237 Page 50 PIPE VALVE 14"RHR 1401 6 FIGURE 94 4 15
Attachment to L-95-237 Page 51 45'LBOW PIPE 14"RHR 1401 9 FIGURE 94 4 16
Attachment to L-95-237 Page 52 VALVE PIPE 10"SI 1401 14 FIGURE 94 4 17
Attachment to L-95-237 Page 53 PIPE BRANCH CONNECTION 10' SI1401 18 FIGURE 94 4-18
Attachment to L-95-237 Page 54 TURKEY POINT UNITS 3 AND 4 RELIEF RE{}VEST NO.
16 PRESSURE TESTS FOR REPAIRS/REPLACEMENTS
Attachment to L-95-237 Page 55 RELIEF REQUEST NO.
16 A.
Component Identification:
Class 1,
2, and 3 Systems B.
Examination Requirements:
ASME Section XI, 1989 Edition IWA-4700 PRESSURE TEST (a)
After repairs by welding on the pressure retaining
- boundary, a system hydrostatic test shall be performed in accordance with IWA-5000.
C.
Relief Requested:
Relief is requested from performing system hydrostatic tests following welded repairs or replacements..
Relief is requested from performing the system hydrostatic tests on the Turkey Point Unit 4 steam generator nozzle to reducer weld joints as committed to in FPL letter L-93-139, dated May 17, 1993.
D.
Basis for Relief:
Hydrostatic tests result in hardships without a compensating increase in the level of safety and quality.
Their purpose is to enhance leak detection.
Industry experience has demonstrated that leaks are not being discovered as a result of hydrostatic test pressures propagating a pre-existing flaw through wall.
Most leaks are being found when the system is at normal operating pressure.
Hydrostatic tests are time consuming, require extensive operator support,,and usually mean radiation exposure to personnel.
Often additional equipment must be brought in to test a localized repair/replacement, which may involve additional exposure and expense.
In many cases, a system hydrostatic test must be conducted over large parts of the system.
Code hydrostatic tests subject the piping system to a small increase in pressure over the nominal operating pressure and is not intended to present a significant challenge to pressure boundary integrity. It is used primarily as a
means to enhance leak detection during the examination of
Attachment to L-95-237 Page 56 components under pressure, rather than as a measure to determine the structural integrity of components.
Monthly walkdowns by system engineers are performed on Class 2 systems outside containment to check.for leakage, piping configuration, and/or damage.
During outages, system engineers walk down Class 1, Class 2,
and Class 3 systems inside containment.
This walkdown is performed to look for system anomalies which could effect plant performance.
Hydrostatic tests place a burden on the systems, increase radiation exposure and costs, require significant setup
- time, and add marginal value (if any) to the repair or replacement quality.
These tests result in hardships without a compensating increase in the level of quality and safety.
Performing the tests in accordance with the proposed alternative will provide reasonable assurance that flaws wi;ll be discovered.
E.
Alternative Examinations:
In lieu of the Code required hydrostatic testing for repairs and replacements and the steam generator reducer welds, FPL will use the alternative rules of ASME Code Case N-416-1.-.
The following examination requirements will be used:
a.
NDE be performed in accordance with the methods and acceptance criteria of the 1992 Edition of Section III; b.
Visual examinations (VT-2) will be performed in conjunction with a system leakage test using the 1989 Edition of Section XI, in accordance with IWA-5000, at nominal operating pressure; C.
The use of the Code Case will be documented on the NIS-2 or equivalent, except for the steam generator reducer welds, which was submitted to the NRC (FPL letter L-93-139, dated May 17, 1993)
FPL will comply with the requirements of the Code Case with the following exception:
FPL will perform VT-2 examinations using the requirements of the 1989 Edition of Section XI instead of the 1'992 Edition as specified in Code Case N-416-1.
FPL's current ISI Program meets the 1989 Edition of Section XI and has proven effective at finding leaks.
The 1992 Edition of Section XI would require the creation and maintenance of a separate VT-2 program, and would not be cost effective.
Attachment to L-95-237 Page 57 F.
Implementation Schedule:
Third Inspection Interval for Turkey Point Units 3 and 4.
G.
Attachments:
None
Attachment to L-95-237 Page
'-58 TURKEY'OINT UNITS 3 AND 4 RELIEF REQUEST NO.
17 CLASS 2'CHEDULE
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Attachment to L-95-237 Page 59 RELIEF REQUEST NO.
17 A.
Component Identification:
Turkey Point Unit 4 Class 2 Steam Generator Nozzle to Shell Weld and Inner Radius Section, Nozzle to Shell Weld 4-SGA-ST Inner Radius Section 4-SGA-ST-IRS B.
Examination Requirements:
ASME Section XI, 1989 Edition Category C-B, Pressure Retaining Nozzle Welds in Vessels Item No. C2.21, Nozzles Without Reinforcing Plate in Vessels
>1/2 in. Nominal Thickness, Nozzle to Shell (Head)
Weld Item No. C2.22, Nozzles Without Reinforcing Plate in Vessels
>1/2 in. Nominal Thickness, Nozzle Inside Radius Section Note (3)
The nozzles selected initially for examination shall be reexamined over the service lifetime of the component.
C.
Relief Requested:
Relief is requested from reexamining the initially selected components over the service lifetime of the component (nozzle to shell weld and inside radius section on the Steam Generator Main Steam nozzle)
D.
Basis for Relief:
On Steam Generator "C", the Upper Shell to Head weld is scheduled for examination during the third period.
Steam Generator "A" Main Steam Nozzle is scheduled for examination during the first period.
These welds and inner radius sections are required to be volumetrically examined once each interval,.
This schedule-is consistent with the previous interval and Note (4) of Category C-A and Note (3) of Category C-B.,
By scheduling the welds and inner radius section on the same steam generator, FPL will reduce radiation exposure and costs.
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Attachment to L-95-237 Page 60 In order to examine the head to shell weld, scaffold must be built around the steam generator and insulation removed.
This process is repeated for the steam nozzle examinations.
Holding to the same schedule as previous intervals would require this work to be performed 2 times.,
Scheduling the examinations together on the same steam generator would save the radiation exposure and costs required for the majority of one of these examinations.
A review of 1995 Edition of Section XI shows that the Code Committee has recognized that Owners may not always be able to adhere to the strict scheduling requirements of the earlier Codes.
The words "to the extent practical" were added to each Note.
This would enable Owners to change to different Steam Generators if unanticipated problems were to occur or if significant reduction in costs; and radiation exposure could be realized.
The proposed schedule for the examination of substitute nozzle to shell weld and the associated inside radius section compl'ies with FPL's Turkey Point Relief Request No.
9, "Alternative Scheduling of Examinations."
E.
Alternative Examinations:
FPL will substitute the same Main Steam nozzle to shell weld and inner radius section on a different Steam Generator.
The proposed schedule will be to examine the Nozzle to Shell weld and its Inside Radius Section on Steam Generator "C".
The examinations will be scheduled in accordance with the attached tables.
F.
Implementation Schedule:
Third Inspection Interval.
G.
Attachments:
Drawing showing current schedule and proposed schedule.
Attachment to L-95-237 Page 61 4SGA ST 4SGASTIRS 4SGC ST 4SGC STIRS 4-SGC P
~4 SGC P C
Gen A
Gen C
Gen Currently Scheduled fields Proposed Schedule
Attachment to L-.95-237 Page 62 Unit 4, Category C-A Zone Number 4-060 4-060 4-061 4-061 4-062 4-117 4-117 Weld Identification 4-SGA-Y 4-SGA-.N 4-SGB-CL 4-SGB-G 4-SGC-P 4-RHE-A1 4-RHE-A2 Code Item Number C1.30 C1.10 C1.10 C1.10 C1.20 C1.20 C1.10 2nd Interval Examination 3rd Interval Schedule Note:
2 welds will be examined during an earlier period.
No welds will be examined during a later period.
5 welds will be examined during the same period as the second interval.
This proposed schedule moves examinations to earlier dates than was previously requested in FPL Turkey Point Relief Request No; 9.
Examination schedule:
SG Welds RHE Welds Total 1st Per 2nd Per 4 = 57%
+2 =
85%
3rd Per
+1 = 100%
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Attachment to L-95-237 Page 63 Unit 4, Category C-B Zone Number 4-061 4=061 4-062 4-062 4-117 4-117 4-117 4-117 Weld Identification 4-SGB-FW 4-SGB-FW-IRS 4-SGC-ST 4-SGC-ST-IRS 4-RHE-A7 4-RHE-AS 4-RHE-A9 4-RHE-A10 Code Item Number C2.21 C2.22 C2.21 C2.22 C2.31 C2.31 C2.31 C2.31 2nd Interval Examination Not Examined Not Examined 3rd Interval Schedule Note:
4 welds will be examined during an earlier period.
No welds will be examined during a later period.
1 weld and IRS will be examined during the same period as the second interval.
1 new weld and IRS will be examined.
This proposed schedule is closer to Code requirements than was previously requested in FPL Turkey Point Relief Request No.
9.
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Attachment to L-95-237 Page 64 Examination schedule:
3rd Per SG IRS RHE Welds RHE IRS Total 0
0 0
Will be examined if access to the inside surface becomes available.
4 = 50%
+2 = 75%
+2 = 100o
'T
.,ill 0
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