ML040860099
| ML040860099 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/22/2004 |
| From: | Jones T Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2004-046 | |
| Download: ML040860099 (82) | |
Text
Enclosure 1 L-2004-046
Florida Power and Light Company Nuclear Engineering Department Component, Support & Inspections Group Code & Inspections Section 700 Universe Blvd.
Juno Beach, Florida 33408 Fourth Interval Inservice Inspection Program for Turkey Point Nuclear Power Plants Units 3 and 4 P.O. Box 4332 Florida City, Florida 33032 Commercial Service Dates:
Unit 3 - December 14,1972 Unit 4 - September 7, 1973 USNRC Docket Numbers:
50-250 Unit 3 50-251 Unit 4 Document Number: 4th Interval-ISI-PTN-314-Program Rev. 0 Date: February 22, 2004 Hi~ R /
Pk&LJ /
Prepared by:
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Reviewed b_
2 Reviewed by:
Approved by:
Reviewed by:
Wpervisor Codes & lnspE tions Section Manager-Component, Support & Inspections Authorized Nucti r Inservice Inspector
Turkey Point Units 3 and 4 ISI Program Document No. ISI-PTN 3/4-Program Revision 0 February 22, 2004 Record of Revision Entire Original Issue of fourth 10-Year 0
February 22, 2004 Docuent Inspection Interval Program as required Document by 10 CFR 50.55a(g)(4) 2
Turkey Point Units 3 and 4 ISI Program Document No. ISI-PTN 3/4-Program Revision 0 February 22, 2004 List of Effective Pages Program Text 54 February 22, 2004 Date to be added after Appendix A 1 Page NRC approval Appendix B 2 Page Relief Request 1 7 pages February 22, 2004 Relief Request 2 17 pages 3
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 Table of Contents Cover Page.............................................................................
1 Record of Revision............................................................................
2 List of Effective Pages............................................................................
3 Table of Contents.............................................................................
4 List of Tables.............................................................................
7 Abbreviations............................................................................................................................................8 Abstract.............................................................................
12 1.0 Introduction.............................................................................
13 1.1 ISI Program Development 13 1.2 Other ISI Programs 13 1.2.1 Inspection Testing Program (ST).13 1.2.2 Steam Generator (SG) Eddy Current (ET) Program.13 1.2.3 Snubber Program.13 1.2.4 Pressure Test Program.14 1.2.5 Repair and Replacement Program.14 1.2.6 Metal Containment Inservice Inspection Program (IWE).14 1.2.7 Concrete Containment Inservice Inspection Program (IWL).14 1.2.8 Licensing Renewal Commitment Documents.14 1.3 Construction Permit 14 1.4 Commercial Service Date 14
1.5 Background
14 1.5.1 Preservice Inspection.15 1.5.2 First Inspection Interval.15 1.5.3 Second Inspection Interval.15 1.5.4 Third Inservice Inspection Interval.15 1.5.5 Fourth Inspection Interval.15 1.6 Applicable Editions and Addenda to Section Xl 16 1.7 System Classification.16 1.7.1 System Classifications.17 1.7.2 Optional Construction.17 1.7.3 Containment Penetrations.17 1.7.4 Class MC Components.17 1.7.5 Class CC Components.17 1.8 Inspection Program 17 1.9 Regulatory Guides 18 1.10 ASME Section Xl Code Cases........................................................................
18 1.11 Branch Technical Position MEB 3-1........................................................................
20 1.12 Plant Life Extension........................................................................
20 1.12.1 Licensing Renewal Commitment Documents.20 4
Turkey Point Units 3 and 4 1SI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 1.13 Successive Examinations.................................................
21 1.14 NDE Examinations and Personnel Qualification/Certification.
21 1.14.1 Alternative Examinations (IWA-2240).22 1.14.2 Certification and Recertification ([WA-2314).22 1.14.3 Alternative Qualifications of VT-2 Visual Examination Personnel (IWA-2316). 22 1.14.4 Alternative Qualifications of VT-3 Visual Examination Personnel (IWA-2317). 22 1.14.5 Appendix VIII Requirements.22 2.0 Risk Informed (RI) Requirements..................................
23 3.0 Development of Class 1 Examination Plan
................................ 23 3.1 Class 1 Code Exemptions.23 3.2 Component Examination Basis 24 3.2.1 Category B-A......................................................................................................24 3.2.2 Category B-B.25 3.2.3 Category B-D.26 3.2.4 Category B-F.27 3.2.5 Category B-G-1.28 3.2.6 Category B-G-2.29 3.2.7 Category B-J.30 3.2.8 Category B-K.30 3.2.9 Category B-L-1.31 3.2.10 Category B-L-2.31 3.2.11 Category B-M-1.31 3.2.12 Category B-M-2.31 3.2.13 Category B-N-1.32 3.2.14 Category B-N-2.33 3.2.15 Category B-N-3.33 3.2.16 Category B-O.33 3.2.17 Category B-P.33 3.2.18 Category B-Q.34 4.0 Development of Class 2 Examination Plan
................................ 34 4.1 Class 2 Code Exemptions.34 4.1.1 IWC-1221.34 4.1.2 IWC-1222.35 4.1.3 IWC-1223.35 4.2 Component Examination Basis 37 4.2.1 Category C-A.37 4.2.2 Category C-B.37 4.2.3 Category C-C.38 4.2.4 Category C-D.39 4.2.5 Category C-F-1.39 4.2.6 Category C-F-2.40 4.2.7 Category C-F-3.40 4.2.8 Category C-F-4.41 4.2.9 Category C-G.41 4.2.10 Category C-H.41 5.0 Development of Class 3 Examination Plan..................................
41 5
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-ISI-PTN 3/4-Program February 22, 2004 5.1 Class 3 Code Exemptions.........................
42 5.1.1 IWD-1220.........................
42 5.1.2 IWD-5222.........................
42 5.2 Component Examination Basis 43 5.2.1 Category D-A.........................
43 5.2.2 Category D-B.........................
44 6.0 IWE Metal Containment Requirements.44 7.0 Development of Component Supports Examination Plan 44 7.1 Code Exemptions for Supports 45 7.2 Support Examination Basis........................
45 7.2.1 Category F-A........................
45 7.2.2 Item Numbers........................
46 7.3 Snubbers.........................
46 8.0 IWL Concrete Containment Requirements 46 9.0 Augmented and Other Programs 46 9.1 Class..........................
47 9.1.1 Reactor Coolant Pump........................
47 9.1.2 Reactor Pressure Vessel........................
47 9.2 Class 2..........................
47 9.2.1 NRC Bulletin 79-13........................
47 10.0 Evaluation/Acceptance Criteria.47 10.1 Supplemental Examinations 48 10.2 Additional Examinations 48 10.3 Successive Inspections for Components 48 10.3.1 Class 1 Components.48 10.3.2 Class 2 Components.48 10.3.3 Class 3 Components.48 10.3.4 Component Supports.49 11.0 Repair/Replacement Activities.49 12.ORelief Requests.49 13.0 Boundary Classifications.49 14.OAddition of Welds, Components, and Component Supports
.51 15.0 Records 51 15.1 General 51 15.2 Nondestructive Examinations.51 15.3 Final Reports.51 15.4 Inservice Inspection Summary Report.51 15.5 NIS-2 or NIS-2A Reports.51 15.6 NIS-BB Form.51 16.0 References.52 6
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4m Interval-ISI-PTN 3/4-Program February 22, 2004 List of Tables Table 1 Fourth Inservice Interval Dates...............................
16 Table 2 USNRC Regulatory Guides...............................
18 Table 3 Applicable Code Cases...............................
19 Table 4 Listing of Class 1 Valves by Group - Unit 3...............................
32 Table 5 Listing of Class 1 Valves by Group - Unit 4...............................
32 Table 6 Listing of Class 2 Exempt Components...............................
36 Table 7 Listing of Class 3 Exempt Components...............................
43 Table 8 Program Boundary Drawings...............................
50 Table 9 Relief Requests...............................
B2 Appendix A-Fourth Inservice Inspection Interval SER..
Al Appendix B-Relief Requests.....
BI Relief Request No. 1, Alternative examinations for the Regenerative Heat Exchanger.............................................................................. 7 page Relief Request No. 2, Alternative Requirements for Implementation of Appendix VIII, Supplement 10.....
17 pages 7
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4h Interval-ISI-PTN 3/4-Program February 22, 2004 Abbreviations ANII Authorized Nuclear Inservice Inspector ANSI American Nuclear Standard Institute ASME American Society of Mechanical Engineers BC Branch Connection B & PV Boiler & Pressure Vessel CCW Component Cooling Water CRDM Control Rod Drive Mechanism CFR Code of Federal Regulations CH Charging System CPS Code Programs Section CRS Code Required Surface CSI Component Support and Inspections CTMT Containment CS Containment Spray Control valve CV CVCS Chemical and Volume Control System CW Clockwise ECCS Emergency Core Cooling System ECT Eddy Current Testing ENG Nuclear Engineering FPL Florida Power & Light Company 8
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 Abbreviations FPS Fuel Pool System FSAR Final Safety Analysis Report FW Feedwater System HPSI High Pressure Safety Injection HS High Stress HX Heat Exchanger ID Identification IE Inspection and Enforcement ISI Inservice Inspection IST Inservice Testing JPN Juno Nuclear Engineering LER License Event Report LS Long Seam MOV Motor Operated Valve MSIV Main Steam Isolation Valve MS Main Steam System MT Magnetic Particle Testing N/A Not Applicable NDE Nondestructive Examination NPS Nominal Pipe Size PDS Program Boundary Drawings 9
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4 Ih nterval-lSI-PTN 3/4-Program February 22, 2004 Abbreviations P&ID Piping and Instrumentation Diagram POV Pneumatic Operated Valve PSI Preservice Inspection PT Liquid Penetrant Testing PTN Plant Turkey Nuclear PWR Pressure Water PZR Pressurizer QA Quality Assurance QC Quality Control Qp Quality Procedure RCS Reactor Coolant System RCP Reactor Coolant Pump RGX Regenerative Heat Exchanger RHR Residual Heat Removal RI-ISI Risk Informed Inservice inspection RPV Reactor Pressure Vessel SD Structural Discontinuity SG Steam Generator SGBD Steam Generator Blowdown SRP Standard Review Plan Si Safety Injection 10
Turkey Point Units 3 and 4 ISI Program Document No. 4 th Interval-ISI-PTN 3/4-Program Abbreviations Revision 0 February 22, 2004 T
TE USNRC UT VT Thickness of Component, Pipe, etc.
Terminal End United States Nuclear Regulatory Commission Ultrasonic Testing Visual Testing 11
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 Abstract This document describes the Class 1, 2, and 3 Inservice Inspection (ISI) Program Fourth 10-Year Inservice Inspection Interval for Turkey Point Nuclear Power Plant Units 3 and 4.
This program was developed and prepared to meet the requirements of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section Xl, 1998 Edition with Addenda through 2000, and 10CFR50.55a for Class 1, 2, and 3 systems. This program is subject to the limitations and modifications of 1 OCFR50.55a(b)(2), except design and access provisions and preservice examination requirements. This program identifies those components and/or systems and their supports that are subject to examination and testing.
Where applicable, ASME Code Cases are incorporated. The code cases used are either approved through publication in 10CFR50.55a, NRC Regulatory Guide 1.147, or are included in a Relief Request.
Other alternatives to the Code requirements have been included as relief requests, or they reference specific NRC regulations. Areas where Code compliance is not possible are also included as relief requests, along with proposed alternatives.
This document implements a Risk Informed selection criterion for Examination Category B-F and B-J piping welds. This alternative to the requirements of Section Xl was submitted to the NRC during the third 10-year interval as Relief Request #27 for Unit 3 (SE dated November 30, 2000 TAC No.
MA81 11) and Relief Request #32 for Unit 4 (SE dated August 1, 2003 TAC No. MB5551). These relief requests will be submitted as Relief Request #3 and #4 in the fourth 10-year interval.
The ISI Programs for Containment, Inservice Pressure Tests, and Snubber Examinations are covered under separate plant documents. General requirements for these programs are included for completeness.
Additional requirements for augmented examinations are addressed. The ISI Program does not require these examinations, but rather are included and administered at the request of the plant.
12
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 1.0 Introduction Turkey Point Units 3 and 4 are three-loop Westinghouse Pressurized Water Nuclear Power Plant, Florida Power and Light Company (FPL) is the Owner of Record.
1.1 ISI Program Development This document details the Inservice Inspection Program of Class 1, 2, and 3 components for the fourth 10-Year Inservice Inspection Interval for Turkey Point Nuclear Power Plant, Units No. 3 and 4.
The plan and schedule of examinations is located in documents 4th Interval-ISI-PTN Plan and 4t Interval-ISI-PTN-4-Plan. The isometrics used for locations of welds during examinations are located at the Turkey Point Nuclear site. The schedule and isometrics are separate controlled documents.
Inservice examination of component and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in 1 0CFR50.55a 12 months prior to the start of the 120-month inspection interval. These requirements are subject to the limitations and modifications listed within the 10CFR50.55a.
This program reflects the Inservice Inspection requirements of ASME Section Xl, 1998 Edition with Addenda through 2000 as modified by IOCFR50.55a, effective date October 28, 2002.
1.2 Other ISI Programs This document does not address every aspect of Inservice Inspection. The following details the examination and testing requirements of those parts covered by other documents.
1.2.1 Inservice Testing Program (IST)
The program for Inservice Testing of Class 1, Class 2, and Class 3 Pumps and Valves is covered by the Turkey Point Inservice Testing (IST) Program, which is submitted and approved separately.
1.2.2 Steam Generator (SG) Eddy Current (ET) Program The Steam Generator (SG) Eddy Current Testing (ET) Program is governed by the requirements of Turkey Point Technical Specifications, Section 3/4.4.5 and NEI 97-06. This program is administered separately.
1.2.3 Snubber Program The program for the examination and testing of safety-related snubbers is addressed by Turkey Point Plant procedures.
13
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-lSI-PTN 3/4-Program February 22, 2004 1.2.4 Pressure Test Program The program for Inservice System Pressure Testing of ASME Code Class 1, Class 2, and Class 3 components and systems is addressed in a separate document.
1.2.5 Repair and Replacement Program The Repair and Replacement Program for ASME Code Class 1, 2, and 3 component and systems is addressed by Turkey Point Plant procedures.
1.2.6 Metal Containment Inservice Inspection Program (IWE)
The Metal Containment Inservice Inspection Program, ISI/IWE-PTN-3/4-Program, controls the examination of Containment Building under Subsection IWE and is administered separately. On September 9, 1996, 10CFR50.55a was amended to include Section IWE of the 1992 Edition with Addenda through 1992 of Section Xl. This amendment required FPL to implement and complete the initial period examination requirements by September 9, 2001.
1.2.7 Concrete Containment Inservice Inspection Program (IWL)
The Concrete Containment Inservice Inspection Program, ASME Section XI, Subsection IWL, Concrete Containment Inservice Inspection Program for Turkey Point Units 3 and 4, controls the examination of Containment Building under Subsection IWL and is administered separately. On September 9, 1996, 1 OCFR50.55a was amended to include Section IWE of the 1992 Edition with Addenda through 1992 of Section XI. This amendment required FPL to implement and complete the initial period examination requirements by September 9, 2001.
1.3 Construction Permit The Construction permit for Turkey Point Nuclear Power Plant Units 3 & 4 was issued on April 27,1967.
1.4 Commercial Service Date The Operating Licenses for Turkey Point Nuclear Power Plants were issued on July 19, 1972 for Unit 3 and April 10, 1973 for Unit 4.
The Commercial Service Dates for Turkey Point Nuclear Power Plants are December 14, 1972 for Unit 3 and September 7,1973 for Unit 4.
1.5 Background
Vessels, piping, pumps and valves were built and installed in accordance to the rules of ASME Section III and VIII, and USA Standard B31.1 for those systems classified as Class 1, 2, and 3.
14
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 40 Interval-ISI-PTN 3/4-Program February 22, 2004 Turkey Point Units 3 and 4 have been examined to the requirements of different Editions and Addenda of Section Xl.
The applicable Edition of Section Xl was mandated by changes to 10 CFR 50.55a at 10-year intervals or earlier.
1.5.1 Preservice Examinations The Preservice Inspection was conducted in accordance with the 1970 Edition with Addenda through Winter 1970 Addenda of the ASME Boiler and Pressure Vessel (B&PV) Code, Section Xl.
1.5.2 First Inservice Inspection Interval During the first 10-year Inservice Inspection Interval, the first two periods were conducted in accordance with the 1970 Edition with Addenda through Winter 1970 Addenda of the ASME Boiler and Pressure Vessel (B&PV)
Code, Section Xl. The last period was conducted in accordance with the 1974 Edition with Addenda through Summer 1975 of ASME B&PV Code,Section XI.
The first 10-year interval for Turkey Point Unit 3 began on December 13, 1972 and ended on February 21, 1984. The first interval for Turkey Point Unit 4 began on September 7,1973 and ended on April 14, 1984. An extension of the first interval was granted by the USNRC on March 1, 1984.
1.5.3 Second Inservice Inspection Interval The second 10-Year Inservice Inspection Interval for both units was conducted in accordance with the 1980 Edition through Winter 1981 Addenda of Section XI. Turkey Point Unit 3 second interval ran from February 22,1984 to February 21, 1994. Turkey Point Unit 4 second interval ran from April 15, 1984 to April 14, 1994.
1.5.4 Third Inservice inspection Interval The third 10-year Inservice Inspection Interval for both units was conducted in accordance with the 1989 Edition of Section Xl. Turkey Point Unit 3 third interval ran from February 22, 1994 to February 21, 2004. Turkey Point Unit 4 third interval ran from April 15, 1994 to April 14, 2004.
1.5.5 Fourth Inservice Inspection Interval The fourth 10-year Inservice Inspection Interval will be conducted in accordance with ASME Section XI, 1998 Edition with Addenda through 2000 as modified by 1 OCFR50.55a.
The fourth 10-Year Inservice Inspection Interval is divided into three successive Inspection periods as determined by calendar years of plant service within the interval. The dates of the fourth 10-year Inservice Inspection Interval and Periods are as follows:
15
Turkey Point Units 3 and 4 ISI Program Document No. 40 Interval-lSI-PTN 3/4-Program Revision 0 February 22, 2004 4th Interval February 22, 2004 February 21, 2014 1 st Period February 22, 2004 February 21, 2007 2nd Period February 22, 2007 February 21, 2011 3rd Period February 22, 2011 February 21, 2014
.. 3 Fouth ln eryg Insecion.I,.nt -bee.,,.>:U.ervAHA..*8z:J.gSal
_. fs ::3.::.H2o 4th Interval April 15, 2004 April 14, 2014 1 st Period April 15, 2004 April 14, 2007 2nd Period April 15, 2007 April 14, 2011 3rd Period April 15, 2011 April 14, 2014 Table 1 1.6 Applicable Editions and Addenda to Section Xi In accordance with 10 CFR 50.55a(b)(2), effective date 10-28-2002, the Inservice Inspection Requirements for the fourth Inservice Inspection interval applicable to Class 1, 2, and 3 components at Turkey Point Units 3 and 4 are based on ASME Section Xl, 1998 Edition with Addenda through 2000.
Portions of the ISI Program are based on other Editions and Addenda of Section Xl, Relief Requests, the Code of Federal Regulations, Regulatory Guides, and Plant Technical Specifications and commitments. Where this has occurred, it is documented within this Program.
1.7 System Classification System safety classifications, design and fabrication requirements meet the intent of 10 CFR 50.2(v) and Regulatory Guide 1.26, as identified within the Turkey Point Units 3 and 4 FSAR.
Water, steam and radioactive containing components (other than turbines and condensers) are designated Quality Group A, B, C, or D in accordance with their importance to safety.
16
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-ISI-PTN 3/4-Program February 22, 2004 1.7.1 System Classifications Class 1 system boundaries are developed based on 10 CFR 50.2(v), and the Turkey Point Units 3 and 4 FSAR. Class 2 and 3 system boundaries are developed based on Regulatory Guide 1.26 and the Turkey Point Units 3 and 4 FSAR.
System Quality Group classification interfaces between components of different quality groups are designated on various system piping and instrument diagrams (PID's) (see Section 13).
1.7.2 Optional Construction Optional construction of a component within a system boundary to a classification higher than the minimum class established in the component design specification does not affect the overall system classification by which the applicable rules of Section Xl are determined.
1.7.3 Containment Penetrations Portions of piping penetrating the containment vessel which are required to be constructed to Class 1 or 2 rules for piping and which may differ from the classification of the balance of the piping system, may not affect the overall system classification that determines the applicable rules of Section Xl.
1.7.4 Class MC Components 10 CFR 50.55a was amended, effective November 22, 1999, to address the requirements of ISI of metal containment buildings. Subsection IWE of the 1992 Edition with Addenda through 1992 was implemented on an expedited basis. The program for IWE examinations specifically defines the classification of those areas examined.
1.7.5 Class CC Components 10 CFR 50.55a was amended, effective November 22, 1999, to address the requirements of [SI of concrete containment buildings. Subsection IWL of the 1992 Edition with Addenda through 1992 was implemented on an expedited basis. The program for IWL examinations specifically defines the classification of those areas examined.
1.8 Inspection Program Examinations for Class 1, 2, and 3 components are scheduled in accordance with Inservice Inspection Program B (IWB-2412 and Table IWB-2412-1). Examinations are scheduled based upon previous 10-Year intervals, to the extent practical and within the limits of Code Case N-624. Class 1 piping weld examinations are based on the Risk Informed selection criteria (Reference Relief Request #3 for Unit 3 and Relief Request
- 4 for Unit 4).
17
Turkey Point Units 3 and 4 ISI Program Document No. 4h Interval-ISI-PTN 3/4-Program Revision 0 February 22, 2004 In order to be consistent in determining percentages, FPL chose to multiply the number of examination areas by the minimum or maximum percentages of Program B and rounding to the nearest whole number.
This will be the number FPL uses for determining how many welds/components will be examined each period.
The Inservice Inspection Schedule Tables for inservice examinations of the major components of PTN-3 and PTN-4 are located in 4th Interval-ISI-PTN-3-Plan and 4th Interval-ISI-PTN-4-Plan. The 4t Interval-lSI-PTN-3-Plan and 4th Interval-ISI-PTN-4-Plan include tables that have brief descriptions of each component subject to examination, the required Code references, and any other pertinent information that is useful for determining examination requirements. The information and summary tables located in the 4 th Interval-ISI-PTN-3-Plan and 4th Interval-ISI-PTN-4-Plan satisfy the requirements of IWA-2420(b)(1) through (6) respectively.
1.9 Regulatory Guides The Regulatory Guides determined to be applicable to PTN 3 and 4 for purposes of this ISI Program are listed below:
R
-eut ory G
-uie 1.26 Quality Group Classifications 1.65 Materials and Inspections for Reactor Vessel Closure Studs 1.83 Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes, Revision 1, July 1985 1.147 Section Xl Code Case Acceptability 1.150 Rev. 1 UT of RPV Welds During PSI and ISI Table 2 1.10 ASME Section XI Code Cases Section Xl Code Cases applicable to the ISI Program are shown below. Each of the Code Cases has been approved and listed in USNRC Regulatory Guide 1.147, or are the subject of a relief request. When Code Cases are approved for use through a relief request, and are later added to Regulatory Guide 1.147, FPL may continue to use them in accordance with the Regulatory Guide.
18
Turkey Point Units 3 and 4 ISI Program Document No. 4 th Interval-lSI-PTN 3/4-Program Revision 0 February 22, 2004 Numb e Decptn Alternative Pressure Test Requirement for Welded Repairs or Installation N-416-2 of Replacement Items by Welding, Class 1, 2, and 3, Section Xi, Division 1 (with conditions Reg. Guide 1.147, Rev. 13)
N-460 Alternate Examination Coverage for Class 1 and Class 2 Welds, Section Xl, Division 1 (without conditions Reg. Guide 1.147, Rev. 13)
Evaluation Procedures and Acceptance Criteria for Flaws in Class 1 Ferritic N-463-1 Piping that Exceed the Acceptance Standards of IWB-3514.2, Section Xl, Division 1 (without conditions Reg. Guide 1.147, Rev. 13)
Alternative Rules for 10-Year Hydrostatic Testing for Class 1, 2, and 3 N-498-4 Systems, Section Xl, Division 1 (with conditions Reg. Guide 1.147, Rev.
13)
Evaluation Criteria For Temporary Acceptance of Flaws in Class 3 Piping, N-513 Section Xl Division 1, as referenced in 10CFR 50.55a paragraph 50.55a(b)(2)(xiii) (see note below)
N-522 Pressure Testing of Containment Penetration Piping, Section Xl, Division 1 (without conditions Reg. Guide 1.147, Rev. 13)
N-52-2 Mechanical Clamping Devices for Class 2 and 3 Piping, Section Xl,
-5232 Division 1 (without conditions Reg. Guide 1.147, Rev. 13)
Alternative Requirements to Repair and Replacement Documentation N-532-1 Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000, Section Xl, Division 1 (with conditions Reg. Guide 1.147, Rev. 13)
Alternative Requirements for VT-2 Visual Examination of Class 1, 2, and 3 N-533-1 Insulated Pressure-Retaining Bolted Connections, Section Xl, Division 1 (with conditions Reg. Guide 1.147, Rev. 13)
N-566-1 Corrective Action for Leakage Identified at Bolted Connections, Section Xl, Division 1 (without conditions Reg. Guide 1.147, Rev. 13)
Alternative Requirements for VT-2 Visual Examination of Classes 1, 2, 3 N-616 Insulated Pressure Retaining Bolted Connections, Section Xl, Division 1 (with conditions Reg. Guide 1.147, Rev. 13)
Deferral of Inspections of Shell-to-Flange and Head-to-Flange Welds of a N-623 Reactor Vessel, Section Xl, Division 1 (without conditions Reg. Guide 1.147, Rev. 13)
N-624 Successive Inspections, Section Xl, Division 1 (without conditions Reg.
Guide 1.147, Rev. 13)
Alternative Requirements for Inner Radius Examination of Class 1 Reactor N-648-1 Vessel Nozzles, Section Xl, Division 1 (with condition Reg. Guide 1.147.
Rev. 13)
Table 3 19
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 Note: When implementing Code Case N-513, the specific safety factors in paragraph 4.0 must be satisfied. Code Case N-513 may not be applied to:
(a) Components other than pipe and tube, such as pumps, valves, expansion joints, and heat exchangers; (b) leakage through a flange gasket; (c) threaded connections employing nonstructural seal welds for leakage prevention (through seal weld leakage is not a structural flaw, thread integrity must be maintained); and (d) degraded socket welds.
1.11 Branch Technical Position MEB 3-1 Branch Technical Position MEB 3-1 required FPL to determine where piping failure in fluid systems outside of the containment would have an adverse effect on other components and equipment. FPL completed a detailed engineering analysis of the Residual Heat Removal, Chemical Volume Control, Main Steam, Main Feedwater, Auxiliary Feedwater, and Steam Generator Blowdown systems in 1973. At that time, modifications to the plant were made to eliminate areas of concern. Based on this analysis, augmented ISI examinations on these systems are not required. (Ref.
16.38) 1.12 Plant Life Extension The ISI Program will implement the FPL commitment to manage the effects of aging for systems/structures/components within the scope of license renewal. The Section Xl Program is credited as an aging management program for license renewal. As such, changes to the Section Xl Program shall consider License Renewal requirements described in the Turkey Point Units 3 & 4 Design Basis Document, 561 0-000-DBD-001, "Selected Licensing and Issues (SLI)",Section XVIII.
1.12.1 Licensing Renewal Commitment Documents PTN-ENG-LRAM-00-0027, Revision 1, ASME Section Xl, Subsection IWF Inservice Inspection Program - License Renewal Basis Document, has been credited as a License Renewal commitment for performing the inspections as required by this document.
PTN-ENG-LRAM-00-0044, Revision 2, ASME Section Xl, Subsection IWB, IWC and IWD Inservice Inspection Program -
License Renewal Basis Document, has been credited as a License Renewal commitment for performing the inspections as required by this document.
PTN-ENG-LRNS-01 -0019, Revision 0, RAI 3.2.4 A VT-1 20
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 0h Interval-ISI-PTN 3/4-Program February 22, 2004 visual examination will be implemented in addition to the Code required VT-3 visual examination for the reactor vessel core support lugs. This commitment is to be implemented in the fifth ISI interval during the period of extended operation.
PTN-ENG-LRAM-00-0055, Revision 1 - Incorporate in the fourth interval of the Inservice Inspection Program to report to Site Engineering any new flaws identified in the pressurizer surge line.
PTN-ENG-LRAM-00-0041, Revision 3 - Reactor Vessels internals Inspection Program - License Renewal Basis Document, has been credited as a License Renewal commitment for performing the inspections as required by this document. This is a fifth and sixth interval commitment. This inspection will correspond with ASME Section Xl reactor vessel inspections.
PTN-ENG-LRAM-00-039 - License Renewal Basis Document, has been credited as a License Renewal commitment for performing the inspections as required by this document. These activities are to be completed by 7119/12 for Unit 3 & Common and 4/10/13 for Unit 4.
PTN-ENG-LR-00-0030 - Develop volumetric examination procedure for small bore piping in order to accomplish volumetric inspection of a sample of <4" NPS piping to address NRC concerns.
1.13 Successive Examinations The sequence of component examinations will be modified in accordance with the requirements of ASME Code Case N-624. This allows FPL to alter the sequence of examinations to allow the examination of several components in an area during one outage instead of over several outages. This will reduce costs and radiation exposure.
The percentage requirements of IWB-2412, IWC-2412, IWD-2412, and IWF-2410 (Program B) will be satisfied. Due to the implementation of the Risk Informed ISI Program (Relief Request #3 for Unit 3 and Relief Request #4 for Unit 4), the scheduling of piping weld examinations will not follow Code requirements, as the selection criteria are different. However, the percentage requirements of IWB-2412 for those components selected will be maintained.
The modified examination schedule is designed to optimize the performance of work within the plant to reduce radiation dose, eliminate interference with other work, and reduce costs.
1.14 NDE Examinations and Personnel Qualification/Certification All NDE will be performed in accordance with the requirements of ASME Section Xl, 1998 Edition to 2000 Addenda with the following modifications as required by 1 OCFR50.55a.
21
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-lSI-PTN 3/4-Program February 22, 2004 1.14.1 Alternative Examinations (IWA-2240)
The provisions for the substitution of alternative examination methods, a combination of methods, or newly developed techniques in the 1997 Addenda of IWA-2240 must be applied. The provisions in IWA-2240 and IWA-4520(c),
ASME Section Xl, 1998 Edition with Addenda through 2000 are not approved for use (Reference 10CFR50.55a(b)(2)(xix)).
1.14.2 Certification and Recertification (IWA-2314)
Level I and 11 nondestructive examination personnel, and personnel qualified under the American Society for Nondestructive Testing Central Certification Program and ANSVASNT CP-1 89 shall be recertified on a 3-year interval in lieu of the 5-year interval specified in IWA-2314(a) and IWA-2314(b) (Reference 10 CFR 50.55a(b)(2)(xviii)(A)).
1.14.3 Alternative Qualifications of VT-2 Visual Examination Personnel (IWA-2316)
Paragraph IWA-2316 may only be used to qualify personnel that observe for leakage during system leakage and hydrostatic tests conducted in accordance with IWA-521 1(a) and (b) of ASME Section Xl, 1998 Edition with Addenda through 2000 (Reference 10 CFR 50.55a(b)(2)(xviii)(B)).
1.14.4 Alternative Qualifications of VT-3 Visual Examination Personnel (IWA-2317)
In addition to the requirements of Paragraph IWA-2317, the proficiency of the training required under IWA-2317 must be demonstrated by administering an initial qualification examination and administering re-certification examinations on a 3-year interval (Reference 10 CFR 50.55a(b)(2)(xviii)(C)).
1.14.5 Appendix Vil Requirements 1.14.5.1 1 OCFR50.55a(b)(2)(xiv) requires that all personnel qualified for performing ultrasonic (UT) examinations in accordance with Appendix Vill shall receive additional annual hands-on training. This requirement consists of at least eight hours of hands on training on samples containing cracks no earlier than six months prior to performing examinations at a licensee's facility. Turkey Point will comply with these additional training requirements for personnel performing Section Xl Appendix VilI, UT examinations.
1.14.5.2 In September 1999, 10CFR50.55a incorporated an expedited implementation schedule for ASME Section Xl, Appendix Vil.
FPL implemented the requirements in accordance with the expedited schedule within the third 10-year interval Turkey Point Units 3 and 4. FPL will implement the requirements of ASME Section Xl, 1998 Edition with Addenda through 2000 with modifications as stated in Paragraph 10CFR50.55a(b)(2)(xv) and applicable relief requests.
22
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-ISI-PTN 3/4-Program February 22, 2004 2.0 Risk Informed (RI) ISI Requirements PTN-3 and PTN-4 are implementing Risk Informed Inservice Inspection (RI-ISI) Programs for Class 1 piping welds. This alternative to the requirements of Section Xl was submitted to the NRC during the third 1 0-year interval as Relief Request #27 (approved by SE dated November 30, 2000 - TAC No. MA81 11) for Unit 3 and Relief Request #32 (approved by SE dated August 1, 2003 - TAC No. MB5551) for Unit 4, and will be submitted as Relief Request #3 for Unit 3 and Relief Request #4 for Unit 4 for the fourth 10-year interval. The RI-ISI program is a living program requiring feedback of new relevant information to ensure the appropriate identification of high safety significance piping locations. More frequent adjustments may be required as directed by NRC Bulletin or Generic Letter requirements, or by industry and plant specific feedback.
3.0 Development of the Class 1 Examination Plan Plant controlled isometric, P&ID's, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.
Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.
3.1 Class 1 Code Exemptions The October 28, 2002 revision of 10CFR50.55a(b)(2)(xi) requires the exemption criteria found in IWB-1220 of the 1989 Edition of Section Xl in lieu of ASME Section Xl, 1998 Edition with Addenda through 2000.
IWB-1220 -Components Exempt from Examination (1989 Edition of Section Xl)
The following components (or parts of components) are exempted from the volumetric and surface examination requirements of IWB-2500:
(a)
Components (notes 1 and 2) that are connected to the reactor coolant system and part of the reactor coolant pressure boundary (note 3), and that are of such a size and shape so that upon postulated rupture the resulting flow of coolant from the reactor coolant system under normal plant operating conditions is within the capacity of makeup systems which are operable from on-site emergency power; (b) (1) Piping of 1 " nominal pipe size and smaller, except steam generator tubing; (2) Components and their connections in piping (note 4) of 1" nominal pipe size and smaller; (c)
Reactor Vessel Head connections and associated piping, 2" nominal pipe size and smaller, made inaccessible by control rod drive penetrations.
23
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4' Interval-lSI-PTN 3/4-Program February 22, 2004 Note 1: Refer to 10 CFR 50, Section 50.55a(e)(2), revised March 15, 1984.
Note 2:The exemptions from examination in IWC-1 220 may be applied to those components permitted to be Class 2 in lieu of Class 1 by the regulatory authority having jurisdiction at the plant site.
Note 3:Reactor Coolant pressure boundary is defined in 10 CFR 50, Section 50.2(v), revised January 1, 1975.
Note 4:In piping is defined as having one inlet and one outlet pipe, each of which shall be NPS 1 or smaller.
There are no Class 1 systems exempt from surface or volumetric examinations in Turkey Point Units 3 and 4 for reasons other than size.
3.2 Component Examination Basis This section describes each Examination Category.
The required percentage of examinations and any limitations for each Examination Category is described. All other requirements are found in ASME Section Xl, 1998 Edition with Addenda through 2000.
The Summary Tables located in 4t Interval-ISI-PTN-3-Plan and 4t Interval-lSI-PTN Plan satisfy the requirements of IWA-2420(b)(1) through (6) respectively.
A narrative discussion of Class 1 components subject to examination and testing are described in detail below:
3.2.1 Category B-A, Pressure Retaining Welds in Reactor Vessel ASME Section Xl, Appendix VIII requirements are implemented as required.
The requirements of Regulatory Guide 1.150 are utilized, when applicable.
Items B13.10-Shell Welds B1.1 1-Circumferential B1.12-Longitudinal Examine essentially 100% of all longitudinal and circumferential shell welds (does not include shell to flange weld). Deferral is permissible.
There are no longitudinal shell welds on the reactor vessel at Turkey Point Units 3&4.
Item B1.20-Top Head Welds B1.21 -Circumferential B1.22-Meridional Examine essentially 100% of accessible length of circumferential and meridional head welds.
24
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4I nterval-ISI-PTN 3/4-Program February 22, 2004 There are no meridional head welds in the reactor vessel at Turkey Point Units 3&4.
Item 81.30 - Shell-to-Flange Weld Examine essentially 100% of the shell to flange weld.
Code Table Note 3-The examination may be performed during the first and third inspection periods, in which case 50% of the shell-to-flange weld shall be examined by the end of the first period, and the remainder by the end of the third period. During the first period, the examination need only be performed from the flange face, provided this same portion is examined from the shell during the third period. Alternatively, FPL may implement Code Case N-623.
The use of this code case allows FPL to defer the examination to the end of the interval provided the conditions identified in note 5 are met.
Item 81.40 - Head to Flange Weld Examine essentially 100% of the head to flange weld.
Code Table Note 4-Deferral is not permissible for the head-to-flange weld.
Altematively, FPL may implement Code Case N-623. The use of this code case allows FPL to defer the examination to the end of the interval provided the conditions identified in note 5 are met.
Items B1.50-Repair Welds 813.51-Beltline Region There are no repair welds in the beltline region of Turkey Point Units 3 & 4 Reactor Pressure Vessels.
3.2.2 Category B-B, Pressure Retaining welds in vessels other than Reactor Vessels.
All examinations are performed from the outside surface of the components.
Pressurizer:
Item B2.10-Shell-to-Head B2.1 1-Circumferential B2.12-Longitudinal Examine 100% of both shell to head welds and 1 ft. on one intersecting longitudinal weld at each circumferential weld.
Pressurizer Items B2.20-Head Welds B2.21 -Circumferential B2.22-Meridional There are no circumferential or meridional head welds in the pressurizer at Turkey Point Units 3 and 4.
25
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 Steam Generators (Primary Side)
Items B2.30-Head Welds B2.31 -Circumferential B2.32-Meridional There are no circumferential or meridional head welds in the Turkey Point Units 3 and 4 steam generators.
Steam Generators (Primary Side)
Item B2.40-Tubesheet to Head Welds Examine 100% of one weld on one vessel. The examinations are limited to one vessel among the group of vessels performing a similar function (Reference note 1 Table IWB-2500-1 and Figure IWB-2500-20(d)).
Heat Exchangers (Primary Side)- Head Item B2.50-Head Welds B2.51 -Circumferential B2.52-Meridional An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger was submitted to the NRC during the third 10-year interval as Relief Request #3 for Units 3 & 4 (SE dated March 31, 1995 TAC No. MA87725 and M87726). This Relief Request has been submitted as Relief Request #1 in the fourth 10-year interval.
Heat Exchangers (Primary Side)-Shell Item B2.60-Tubesheet-to-Head Welds B2.70-Longitudinal Welds B2.80-Tubesheet-to-Shell Welds An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger was submitted to the NRC during the third 10-year interval as Relief Request #3 for Units 3 & 4 (SE dated March 31, 1995 TAC No. MA87725 and M87726). This Relief Request has been submitted as Relief Request #1 in the fourth 10-year interval.
There are no longitudinal welds in the Turkey Point Units 3 & 4 Regenerative Heat Exchanger.
3.2.3 Category B-D, Full Penetration Welds of Nozzle in Vessels (Program B)
Examination category B-D, Item Numbers B3.120 and B3.140, will be examined in accordance with the requirements of ASME Section Xl, 1998 Edition (Reference 10 CFR 50.55a(b)(2)(xxi)(A)).
Reactor Vessel Item B3.90-Nozzle-to-Vessel Welds B3.100-Nozzle Inside Radius Section 26
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. th Interval-lSI-PTN 3/4-Program February 22, 2004 Examine all nozzles during the interval. In place of the UT examination required by Table IWB-2500-1, FPL may implement the alternative requirements of code case N-648-1 as modified by NRC Reg. Guide 1.147, Rev. 13. A visual examination with enhanced magnification that has a resolution sensitivity to detect a 1 -mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1 with limiting assumptions on the flaw aspect ratio. The provisions of Table IWB-2500-1 for this examination category continue to apply except that, in place of the examination volumes, the surfaces to be examined are the external surfaces shown in the figures applicable to this table.
Pressurizer Item B3.110-Nozzle-to-Vessel Welds B3.120-Nozzle Inside Radius Sections Examine all nozzles during the interval. The inside radius sections are required to be examined by 10 CFR 50.55a(b)(2)(xxi)(A). A visual examination with enhanced magnification that has a resolution sensitivity to detect a 1 -mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1 may be performed in place of an ultrasonic examination (Reference 1 OCFR50.55a(b)(2)(xxi)(A)).
Steam Generators Item B3.130-Nozzle-to-Vessel Welds B3.140-Nozzle Inside Radius Sections Examine all nozzles during the interval. The inside radius sections are required to be examined by 10 CFR 50.55a(b)(2)(xxi)(A). A visual examination with enhanced magnification that has a resolution sensitivity to detect a 1 -mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1 may be performed in place of an ultrasonic examination (Reference 1 OCFR50.55a(b)(2)(xxi)(A)).
Heat Exchangers (*Primary Side)
Item B3.150-Nozzle-to-Vessel Welds B3.160-Nozzle Inside Radius Sections An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger was submitted to the NRC during the third 10-year interval as Relief Request #3 for Units 3 & 4 (SE dated March 31, 1995 TAC No. MA87725 and M87726). This Relief Request has been submitted as Relief Request #1 in the fourth 10-year interval.
3.2.4 Category B-F, Pressure Retaining Dissimilar Metal Welds These components will be examined under the RI ISI Program (Reference Section 2.0) and Relief Request #3 for Unit 3 and Relief Request #4 for Unit 4.
27
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-lSI-PTN 3/4-Program February 22, 2004 3.2.5 Category B-G Pressure Retaining Bolting, Greater Than 2 in. in Diameter For heat exchangers, piping, pumps, and valves, examinations are limited to components selected for examination under B-B (vessels other than RPV), B-J (piping), B-L-2 (pump casings), and B-M-2 (valve bodies exceeding NPS 4).
Reactor Vessel Item B6.10-Closure Head Nuts B6.20-Closure Studs, in place B6.30-Closure Studs, when removed B6.40-Threads in Flange B6.50-Closure Washers, Bushings Examine 100% of the bolting each interval.
Pressurizer Item B6.60-Bolts and Studs B6.70-Flange Surface, when connection disassembled B6.80-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 & 4 Steam Generators Item B6.90-Bolts and Studs B6.1 00-Flange Surface, when connection disassembled B6.1 10-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 & 4 Heat Exchangers Item B6.120-Bolts and Studs B6.130-Flange Surface, when connection disassembled B6.140-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 & 4 Piping Item B6.150-Bolts and Studs B6.160-Flange Surface, when connection disassembled B6.170-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 & 4 Pumps Item B6.180-Bolts and Studs B6.190-Flange Surface, when connection disassembled B6.200-Nuts, Bushings, Washers Examine 100% of the above items of one Reactor Coolant Pump during the interval.
28
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-lSI-PTN 3/4-Program February 22, 2004 Valves Item B6.21 0-Bolts and Studs B6.220-Flange Surface, when connection disassembled B6.230-Nuts, Bushings, Washers Not applicable to Turkey Point Units 3 & 4 3.2.6 Category B-G-2, Pressure Retaining Bolting, 2 in. and Less in Diameter For heat exchangers, piping, pumps, and valves, examinations are limited to components selected for examination under B-B (vessels other than RPV), B-J (piping), B-L-2 (pump casings), and B-M-2 (valve bodies exceeding NPS 4).
Reactor Vessel Item B7.10-Bolts, Studs, and Nuts Not applicable to Turkey Point Units 3 & 4 Pressurizer Item B7.20-Bolts, Studs, and Nuts Examine 100% of the bolting each interval.
Steam Generators Item B7.30-Bolts, Studs, and Nuts Examine 100% of the bolting each interval on the steam generator selected for examination under Examination Category B-B.
Heat Exchangers Item B7.40-Bolts, Studs, and Nuts Not applicable to Turkey Point Units 3 & 4 Piping Item B7.50-Bolts, Studs, and Nuts Examine 100% of the bolting each interval.
Pumps Item B7.60-Bolts, Studs, and Nuts Not applicable to Turkey Point Units 3 & 4 Valves Item B7.70-Bolts, Studs, and Nuts Examine 100% of the bolting on one of each group of valves each interval.
29
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 CRD Housings Item B7.80-Bolts, Studs, and Nuts Not applicable to Turkey Point Units 3 & 4. Examinations would be required under 10 CFR 50.55a(b)(2)(xxi)(B).
3.2.7 Category B-J, Pressure Retaining Welds in Piping These components will be examined under the RI ISI Program (Reference Section 2.0) and Relief Request #3 for Unit 3 and Relief Request #4 for Unit 4.
3.2.8 Category B-K, Welded Attachments for Vessels, Piping, Pumps, and Valves For piping, pumps, and valves, a sample of 10% of the welded attachments will be examined. Each welded attachment will receive a surface examination of 100% of required areas of each welded attachment. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, Inservice Inspection, or testing. Examinations performed as a result of support deformation cannot be credited under the requirements of Inspection Program B.
Pressure Vessels Item B10.10-Welded Attachments For multiple vessels of similar design, function and service, only one of the welded attachments of only one of the multiple components requires examination. Under 10 CFR 50.55a(b)(xxi)(C), Turkey Point Units 3 and 4 must utilize the 95A95 Section Xl for the examination of Item No. B10.10 components. The difference is found in Note 7 of Examination Category B-K, which stipulates a different examination area.
An alternative to the requirements of ASME Section Xl for the Regenerative Heat Exchanger was submitted to the NRC during the third 10-year interval as Relief Request #3 for Units 3 & 4 (SE dated March 31, 1995 TAC No. MA87725 and M87726). This Relief Request has been submitted as Relief Request #1 in the fourth 10-year interval.
Piping Item B10.20-Welded Attachments Examine 10% of the welded attachments associated with the component supports selected for examination under IWF-251 0.
Pumps Item 610.30-Welded Attachments Examine 10% of the welded attachments associated with the component supports selected for examination under IWF-2510.
30
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-lSI-PTN 3/4-Program February 22, 2004 Valves Item B10.40-Welded Attachments Not applicable to Turkey Point Units 3 & 4 3.2.9 Category B-L-1, Pump Casing Welds Pumps Item B12.10-Pump Casing Welds The outside surface of the welds of one reactor coolant pump will be examined by the VT-1 visual method during the inspection interval. The pump selected shall be based on pump disassembly for maintenance under B-L-2 or end of inspection interval, whichever comes first.
3.2.10 Category B-L-2, Pump Casing Pumps Item B12.20-Pump Casing Examination of the internal surfaces of one of the three reactor coolant pumps when disassembled for maintenance. Pump to be identified when pump is disassembled.
3.2.11 Category B-M-1, Pressure Retaining Welds in Valve Bodies Valves Item 81 2.30-Less than NPS 4 B12.40-NPS 4 or Larger Not applicable to Turkey Point Units 3 & 4 3.2.12 Category B-M-2, Valve Bodies Valves that are of the same size, constructional design, and manufacturing method, and that perform similar functions in the system are grouped together.
Valves Item B12.50-Valve Body, Exceeding NPS 4 Examination of at least one valve of each group of valves once per interval when disassembled for maintenance, repair, or volumetric examination.
31
Turkey Point Units 3 and 4 ISI Program Document No. 4 Interval-ISI-PTN 3/4-Program Revision 0 February 22, 2004 Unit 3 Class 1 Valve Grouping Group Number Valve Number Type Size 3-036 MOV-3-750 Gate Isol 14" 3-036 MOV-3-751 Gate Isol 14" 3-037 3-875A Check 10" 3-038 3-875B Check 10" 3-039 3-875C Check 10" 2
3-037 3-875D Check 10" 3-038 3-875E Check 10" 3-039 3-875F Check 10" 3-037 3-876A Check 8"
3-038 3-876B Check 8"
3 3-039 3-876C Check 8"
3-038 3-876D Check 8"
3-039 3-876E Check 8"
Table 4 Unit 4 Class 1 Valve Grouping Group Zone Valve Number Type Size Number Number 4-036 MOV-4-750 Gate Isol 14" 4-036 MOV-4-751 Gate isol 14" 4-037 4-875A Check 10" 4-038 4-875B Check 10" 4-039 4-875C Check 10" 2
4-037 4-875D Check 10" 4-038 4-875E Check 10" 4-039 4-875F Check 10" 4-037 4-876A Check 8"
4-038 4-876B Check 8"
3 4-039 4-876C Check 8"
4-038 4-876D Check 8"
4-039 4-876E Check 8"
Table 5 3.2.13 Category B-N-1, Interior of Reactor Vessel Reactor Vessel Item B13.10-Vessel Interior Examine accessible areas once each inspection period above and below the reactor core made accessible for examination by removal of components during 32
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 normal refueling.
3.2.14 Category B-N-2, Welded Core Support Structures and Interior Attachments to Reactor Vessels Reactor Vessel (PWR)
Item B1 3.50-Interior Attachments within Beltline Region Examine interior attachments within the beltline region once per interval.
These examinations may be deferred until the end of the interval.
Item B1 3.60-Interior Attachments Beyond Beltline Region Examine interior attachments beyond the beltline region once per interval.
These examinations may be deferred until the end of the interval.
3.2.15 Category B-N-3, Removable Core Support Structures Item B133.70-Core Support Structure Examine accessible surfaces of core support structures once per interval.
The structure shall be removed from the vessel. These examinations may be deferred until the end of the interval.
3.2.16 Category B-O, Pressure Retaining Welds in Control Rod Housings Reactor Vessel Item B14.10-Welds in CRD Housing Examine 10% of the peripheral housing welds. These examinations may be deferred until the end of the interval.
3.2.17 Category B-P, All Pressure Retaining Components The system leakage test shall be conducted prior to plant startup following each refueling outage.
On systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connections for visual examination VT-2 (IWA-5242). The examinations may be performed in accordance with the alternative requirements of Code Case N-533-1 and/or N-616 (Reference USNRC Reg. Guide 1.147 Rev. 13 for conditions).
Reactor Vessel Item B15.10-Pressure Retaining Boundary Pressurizer Item B15.20-Pressure Retaining Boundary 33
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-ISI-PTN 3/4-Program February 22, 2004 Steam Generators Item B15.30-Pressure Retaining Boundary Heat Exchangers Item B15.40-Pressure Retaining Boundary Piping Item B1 5.50-Pressure Retaining Boundary Pumps Item B135.60-Pressure Retaining Boundary Valves Item 815.70-Pressure Retaining Boundary 3.2.18 Category B-Q, Steam Generator Tubing Item: B1 6.20-Steam Generator Tubing in U-Tube Design The extent and frequency of examination is governed in accordance with the Turkey point Units 3 & 4 Plant Technical Specifications 3/4.4.5 (Reference 10 CFR 50.55a[b][2][iii]).
4.0 Development of the Class 2 Examination Plan Plant controlled isometric, P&ID's, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.
Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.
4.1 Class 2 Code Exemptions The following Class 2 exemption criteria are applicable. Article IWC-1220 of ASME Section Xl, 1998 Edition with Addenda through 2000 lists those piping and components exempt from examination.
IWC-1 220 - Components Exempt from Examination The following components (or parts of components) are exempted from the volumetric and surface examination requirements of IWC-2500; 4.1.1 IWC-1221, Components within RHR, ECC, and CHR Systems or Portions of Systems (Note 1).
(a)
For systems, except high pressure safety injection systems in pressurized water reactor plants:
34
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-ISI-PTN 3/4-Program February 22, 2004 (1)
Piping NPS 4 (DN100) and smaller.
(2)
Vessels, pumps, and valves and their connections in piping (Note 2) NPS 4 (DN1 00) and smaller.
(b)
For high pressure safety injection systems in pressurized water reactor plants:
(1)
Piping NPS 1-1/2 (DN40) and smaller.
(2)
Vessels, pumps, and valves and their connections in piping (Note 2) NPS 1-1/2 (DN40) and smaller.
(c)
Vessels, piping, pumps, valves, other components, and component connections of any size in statically pressurized, passive (i.e., no pumps) safety injection systems (Note 3) of pressurized water reactor plants.
(d)
Piping and other components of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions.
4.1.2 IWC-1222, Components within Systems or Portions of Systems Other Than RHR, ECC, and CHR Systems (Note 1).
(a)
For systems, except auxiliary feedwater systems in pressurized water reactor plants:
(1)
Piping NPS 4 (DN100) and smaller.
(2)
Vessels, pumps, and valves and their connections in piping (Note 2) NPS 4 and smaller.
(b)
For auxiliary feedwater systems in pressurized water reactor plants:
(1)
Piping NPS 1-1/2 (DN40) and smaller.
(2)
Vessels, pumps, and valves and their connections in piping (Note 2) NPS 1-1/2 and smaller.
(c)
Vessels, piping, pumps, valves, other components, and component connections of any size in systems or portions of systems that operate (when the system function is required) at a pressure equal to or less than 275 psig (1900 kPa) and at a temperature equal to or less than 2000 F (930 C).
(d)
Piping and other components of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions.
4.1.3 IWC-1223, Inaccessible Welds Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.
35
Turkey Point Units 3 and 4 IS Program Document No. 4th Interval-ISI-PTN 3/4-Program Revision 0 February 22, 2004 Note 1:RHR, ECC, and CHR systems are the Residual Heat Removal, Emergency Core Cooling, and Containment Heat Removal Systems, respectively.
Note 2: In piping is defined as having a cumulative inlet and a cumulative outlet pipe cross-sectional area neither of which exceeds the nominal OD cross-sectional area of the designated size.
Note 3:Statically pressurized, passive safety injection systems of pressurized water reactor plants are typically called:
(a)
Accumulator tank and associated system.
(b)
Safety injection tank and associated system.
(c)
Core flooding tank and associated system.
The following Class 2 systems are exempt from surface and volumetric requirements for reasons other than size:
Unit 3 Class 2 Exempt Components Component/Piping System Exemption Criteria Accumulator Tank 3T299A to Valve 3-875D IWC-1221(c)
Accumulator Tank 3T299B to Valve 3-875E IWC-1221(c)
Accumulator Tank 3T299C to Valve 3-875F IWC-1221(c)
Containment Spray from Valve 3-891 A to IWC-1 221(d) spray headers inside containment
_________(d)
Containment Spray from Valve 3-891 B to IWC-1 221 (d) spray headers inside containment Unit 4 Class 2 Exempt Components Component/Piping System Exemption Criteria Accumulator Tank 4T299A to Valve 3-875D IWC-1 221 (c)
Accumulator Tank 4T299B to Valve 3-875E IWC-1 221 (c)
Accumulator Tank 4T299C to Valve 3-875F IWC-1221(c)
Containment Spray from Valve 4-891 A to IWC-1 221 (d) spray headers inside containment Containment Spray from Valve 4-891 B to IWC-1 221(d) spray headers inside containment
-_(d)
Table 6 36
Turkey Point Units 3 and 4 [SI Program Revision 0 Document No. 40 Interval-lSI-PTN 3/4-Program February 22, 2004 4.2 Component Examination Basis This section describes each Examination Category. The required percentage of examinations and any limitations for each Examination Category is described. All other requirements are found in ASME Section Xl, 1998 Edition with Addenda through 2000.
The Summary Tables located in 40 Interval-lSI-PTN-3-Plan and 4th Interval-lSI-PTN Plan satisfy the requirements of IWA-2420(b)(1) through (6) respectively.
A narrative discussion of Class 2 components subject to examination and testing are described in detail below:
4.2.1 Category C-A, Pressure Retaining Welds in Pressure Vessels Item C1.10-Shell Circumferential Welds Examine 100% of welds at gross structural discontinuities. The examinations may be limited to one vessel or distributed among a group of vessels.
Item C1.20-Head Circumferential Welds Examine 100% of head-to-shell welds. The examinations may be limited to one vessel or distributed among a group of vessels.
Item Cl.30-Tubesheet-to-Shell Welds Examine 100% of tubesheet-to-shell welds. The examinations may be limited to one vessel or distributed among a group of vessels.
4.2.2 Category C-B, Pressure Retaining Nozzle Welds in Vessels Items C2.10-Nozzles in Vessels < Y/2 inch Nominal Thickness C2.11 -Nozzle-to-Shell (Nozzle to Head) Weld Not applicable to Turkey Point Units 3 and 4 Items C2.20-Nozzles Without Reinforcing Plate in Vessels > Y/2 Inch Nominal Thickness C2.21-Nozzle-to-Shell (Head) Weld C2.22-Nozzle Inside Radius Section Applicable to Nozzle-to-Shell (Head) weld for nozzles greater than 4 NPS (Reference General Note-Figures IWC-2500-4).
Nozzle Inner Radius requirement applies to nozzles greater than 12 NPS (Reference Figures IWC-2500-4(a), (b), and (c)). Examine nozzles at terminal ends of piping runs. The examination may be limited to one vessel or distributed among the vessels.
Items C2.30-Nozzles With Reinforcing Plate in Vessels > Y/2 Inches Nominal Thickness.
C2.31-Reinforcing Plate Welds to Nozzle and Vessel 37
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-lSI-PTN 314-Program February 22, 2004 Examine nozzles at terminal ends of piping runs. The examination may be limited to one vessel or distributed among the vessels.
C2.32-Nozzle-to-Shell (or Head) Welds When Inside of Vessel is Accessible Not applicable to Turkey Point Units 3 & 4 C2.33-Nozzle to Shell (or Head) Welds When Inside of Vessel is Inaccessible Applicable to Nozzle-to-Shell (Head) weld for nozzles greater than 4 NPS (Reference General Note-Figures IWC-2500-4).
Examine telltale hole in reinforcing plates once each period. The examination may be limited to one vessel or distributed among the vessels. This examination will be performed during the pressure test of the system.
4.2.3 Category C-C, Welded Attachments for Vessels, Piping, Pumps, and Valves For piping, pumps, and valves, a sample of 10% of the welded attachments will be examined. Each welded attachment will receive a surface examination of 100% of required areas of each welded attachment.
Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, Inservice Inspection, or testing. Examinations performed as a result of support deformation cannot be credited under the requirements of Inspection Program B.
Pressure Vessels Item C3.1 0-Welded Attachments For multiple vessels of similar design, function and service, only one of the welded attachments of only one of the multiple components requires examination.
Examine one integrally welded attachment on one Residual Heat Removal Heat Exchanger.
There are no integrally welded attachments on the Turkey Point Units 3 and 4 Steam Generators.
Piping Item C3.20-Welded Attachments Examine 10% of the welded attachments associated with the component supports selected for examination under IWF-2510.
Pumps Item C3.30-Welded Attachments 38
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 Not applicable to Turkey Point Units 3 & 4 Valves Item C3.40-Welded Attachments Not applicable to Turkey Point Units 3 & 4 4.2.4 Category C-D, Pressure Retaining Bolting > 2" in Diameter Pressure Vessels Item C4.10-Bolts and Studs Not applicable to Turkey Point Units 3 & 4 Piping Item C4.20-Bolts and Studs Not applicable to Turkey Point Units 3 & 4 Pumps Item C4.30-Bolts and Studs Not applicable to Turkey Point Units 3 & 4 Valves Item C4.40-Bolts and Studs Not applicable to Turkey Point Units 3 & 4 4.2.5 Category C-F-1, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping.
Item C5.10-Piping welds greater than or equal to 3/8" nominal wall thickness for piping greater NPS 4.
C5.1 1-Circumferential Weld Item C5.20-Piping welds greater than 1/5" nominal wall thickness for piping greater than or equal to NPS 2 and less than or equal to NPS 4 C5.21-Circumferential Weld Item C5.30-Socket Welds Item C5.40-Pipe branch connections of branch piping greater than or equal to NPS 2 C5.41-Circumferential Welds Examine 7.5%, but not less than 28 welds, of all dissimilar metal, austenitic stainless steel or high alloy welds not exempted by IWC-1 220. The welds to be examined shall be distributed among the systems in a manner such that a 39
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 0h Interval-ISI-PTN 3/4-Program February 22, 2004 representative sample of each system and size is selected. Welds that are not exempted by IWC-1220 and not addressed by the requirements to be nondestructively examined per Category C-F-1 are listed as C-F-3 within the 4 Interval-lSI-PTN-3-Plan and 4th Interval-ISI-PTN-4-Plan. The weld population of C-F-1 and C-F-3 are added together and multiplied by 7.5% to determine the number of required examinations.
Longitudinal welds are examined in accordance with note 6 in Table IWC-2500-1 for this examination category.
4.2.6 Category C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping Item C5.50-Piping welds greater than or equal to 3.8" nominal wall thickness for piping greater than NPS 4 C5.51-Circumferential Weld Item C5.60-Piping welds greater than or equal to 1/5" nominal wall thickness for piping greater than or equal to NPS 2 and less than or equal to NPS 4 C5.61-Circumferential Weld Item C5.70-Socket Welds Item C5.80-Pipe branch connections of branch piping greater than or equal to NPS2 C5.81-Circumferential Welds Examine 7.5%, but not less than 28 welds, of all dissimilar metal, austenitic stainless steel or high alloy welds not exempted by IWC-1 220. The welds to be examined shall be distributed among the systems in a manner such that a representative sample of each system and size is selected. Welds that are not exempted by IWC-1220 and not addressed by the requirements to be nondestructively examined per Category C-F-2 are listed as C-F-4 within the 40 Interval-ISI-PTN-3-Plan and 4' Interval-ISI-PTN-4-Plan. The weld population of C-F-2 and C-F-4 are added together and multiplied by 7.5% to determine the number of required examinations.
Longitudinal welds are examined in accordance with note 7 in Table IWC-2500-1 for this examination category.
4.2.7 Category C-F-3 Those welds that are not exempt and not addressed by the requirements of category C-F-1 are counted as part of the selection criteria. These welds have been given the category of C-F-3 and are for counting purposes only. No examinations are required.
40
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 4.2.8 Category C-F-4 Those welds that are not exempt and not addressed by the requirements of category C-F-2 are counted as part of the selection criteria. These welds have been given the category of C-F-4 and are for counting purposes only. No examinations are required.
4.2.9 Category C-G, Pressure Retaining Welds in Pumps and Valves Pumps Item C6.10-Pump Casing Welds Not applicable to Turkey Point Units 3 & 4 Valves Item C6.20-Valve Body Welds Not applicable to Turkey Point Units 3 & 4 4.2.10 Category C-H, All Pressure Retaining Components Item C7.10-Pressure Retaining Components The pressure retaining components within the Class 2 system boundaries are subjected to system leakage tests in accordance with IWC-5220 and visually examined per IWA-5240.
System leakage tests will be performed in accordance with the rules of Section Xl as modified by the following.
Code Case N-522, "Pressure Testing of Containment Penetration Piping".
Code Case N-533-1, "Alternative requirements for VT-2 visual examination of Class 1 Insulated Pressure-Retaining Bolted Connection, Section Xl, Division 1" as modified by NRC Reg. Guide 1.147.
5.0 Development of the Class 3 Examination Plan Plant controlled isometric, P&ID's, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.
Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.
The Class 3 system boundaries subject to examination and testing were developed based upon the requirements of Regulatory Guide 1.26, and ASME Section Xl, Table IWD-2500-1.
41
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-lSl-PTN 3/4-Program February 22, 2004 5.1 Class 3 Code Exemptions The following Class 3 exemption criteria are applicable. Article IWD-1220 of ASME Section Xl, 1998 Edition with Addenda through 2000 lists those piping and components exempt from examination.
5.1.1 IWD-1 220 - Components Exempt from Examination The following components or parts of components are exempted from the VT-1 visual examination requirements of IWD-2500:
(a)
Piping NPS 4 (DN100) and smaller (b)
Vessels, pumps, and valves and their connections in piping (Note 1)
NPS 4 (DN100) and smaller.
(c)
Components that operate at a pressure of 275 psig (1 900kPa) or less and at a temperature of 200 F (932 C) or less in systems (or portions of systems) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling.
(d)
Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.
Note 1: In piping is defined as having a cumulative inlet and cumulative outlet pipe cross-sectional area neither of which exceeds the nominal OD cross-sectional area of the designated size.
5.1.2 IWD-5222(g) System Hydrostatic Test Exemption Open ended vent and drain lines from components extending beyond the last shutoff valve and open ended safety or relief valve discharge lines, including safety or relief valve piping which discharges into the containment pressure suppression pool, shall be exempt from hydrostatic test.
The following Class 3 systems are exempt from the surface and volumetric requirements other than size:
42
Turkey Point Units 3 and 4 ISI Program Document No. 4th Interval-lSI-PTN 3/4-Program Revision 0 February 22, 2004 Unit3 Class 3 Exempt Components Component/Piping System Exemption Criteria From Spent Fuel Pool through Pump 3P21 2A and 3P212B through Spent Fuel Pool Heat IWD-1220.c Exchanger 4E208 back to spent fuel Pool Note: Unit 3 Emergency diesel lines are exempt due to size Unit 4 Class 3 Exempt Components Component/Piping System Exemption Criteria From Spent Fuel Pool through Pump 3P212A and 3P212B through Spent Fuel Pool Heat IWD-1220.c Exchanger 4E208 back to spent fuel Pool Radiator lines from the Unit 4 Emergency IWD-1220.c Diesels to the radiators Table 7 5.2 Component Examination Basis This section describes each Examination Category.
The required percentage of examinations and any limitations for each Examination Category is described. All other requirements are found in ASME Section Xl, 1998 Edition with Addenda through 2000.
The Summary Tables located in 4 t Interval-lSI-PTN-3-Plan and 4th Interval-lSI-PTN Plan satisfy the requirements of IWA-2420(b)(1) through (6) respectively.
A narrative discussion of Class 3 components subject to examination and testing are described in detail below:
5.2.1 Category D-A, Welded Attachments for Vessels, Piping, Pumps, and Valves Each welded attachment will receive a visual (VT-1) examination of 100% of required areas of each welded attachment. Examination is also required whenever component support member deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, Inservice Inspection, or testing. Examinations performed as a result of support deformation cannot be credited under the requirements of Inspection Program B.
Pressure Vessels Item D1.10-Welded Attachments For multiple vessels of similar design, function and service, the welded attachments of only one of the multiple vessels requires examination.
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Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4I nterval-ISI-PTN 3/4-Program February 22, 2004 Piping Item D13.20-Welded Attachments The percentage sample shall be proportional to the total number of nonexempt welded attachments connected to the piping in each system subject to examination. Examine 10% of the welded attachments.
Pumps Item D1l.30-Welded Attachments Not applicable to Turkey Point Units 3 & 4 Valves Item D1.40-Welded Attachments Not applicable to Turkey Point Units 3 & 4 5.2.2 Category D-B, All Pressure Retaining Components Item D2.10-Pressure Retaining Components A system leakage test (IWD-5221) shall be performed during each inspection period.
Item D2.20-Pressure Retaining Components System Functional Test shall be performed in accordance with alternate examination techniques of Code Case N-498-4, Alternative Rules for 10 Year Hydrostatic Pressure Testing for Class 1 and 2 Systems Section Xl, Division 1 as modified by NRC Reg. Guide 1.147.
6.0 IWE Metal Containment Requirements The requirements for Code Class MC (Metal Containment) are found in the Turkey Point Containment Building Metal Containment Inservice Inspection Program, which is administered separately (Reference paragraph 1.2.6).
This document establishes the administrative, managerial, and implementation control for the IWE Containment Inspection Program Plan for the first 1 0-year Inservice Inspection interval.
7.0 Development of Component Supports Examination Plan Plant controlled isometric, P&lD's, component drawings, and plant walkdowns were used to develop the ISI drawings and the scope of examinations. During examinations, drawings will be used to locate and identify each component. Other plant controlled drawings or documents will be used when additional information is required.
Refer to the Class 1, 2, and 3 ISI Schedule for a complete listing of components subject to examination and the proposed examination schedule.
44
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4h Interval-lSI-PTN 3/4-Program February 22, 2004 The Class 1, 2, and 3 system boundaries subject to examination and testing were developed based upon the requirements of Regulatory Guide 1.26, and ASME Section Xi, Table IWD-2500-1.
7.1 Code Exemptions for Supports Under IWF-1230, component supports exempt from the examination requirements of IWF-2000 are those connected to piping and other items exempted from volumetric, surface, or VT-1 or VT-3 visual examination by IWB-1 220, IWC-1 220, IWD-1 220, and IWE-1 220. In addition, portions of supports that are inaccessible by being encased in concrete, buried underground, or encapsulated by guard pipe are also exempt from the examination requirements of IWF-2000.
7.2 Support Examination Basis This section describes Examination Category F-A.
The required percentage of examinations and any limitations is described. All other requirements are found in ASME Section Xl, 1998 Edition with Addenda through 2000. The Summary Tables located in 4 th Interval-ISI-PTN-3-Plan and 4 th Interval-ISI-PTN-4-Plan satisfy the requirements of IWA-2420(b)(1) through (6) respectively.
A narrative discussion of F-A supports subject to examination and testing is described in detail below:
7.2.1 Category F-A, Supports Item F1.10-Class 1 Piping Supports Examine 25% of Class 1 piping supports. The total percentage sample shall be comprised of supports from each system (e.g., Main Steam, Feedwater, or RHR), where the individual sample sizes are proportional to the total number of nonexempt supports of each type and function within each system.
Item F1.20-Class 2 Piping Supports Examine 15% of Class 2 piping supports. The total percentage sample shall be comprised of supports from each system (e.g., Main Steam, Feedwater, or RHR), where the individual sample sizes are proportional to the total number of nonexempt supports of each type and function within each system.
Item F1.30-Class 3 Piping Supports Examine 10% of Class 3 piping supports. The total percentage sample shall be comprised of supports from each system (e.g., Main Steam, Feedwater, or RHR), where the individual sample sizes are proportional to the total number of nonexempt supports of each type and function within each system.
Item F1l.40-Supports Other Than Piping Supports (Class 1, 2, 3, and MC)
Examine the supports of only one of the multiple components within a system 45
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4' Interval-lSI-PTN 3/4-Program February 22, 2004 of similar design, function, and service.
7.2.2 Item Numbers Item numbers will be categorized to identify support types by component support function.
A - Single Acting Restraints B - Double Acting Restraints C - Spring Hangers and Supports D - Anchors P - Pumps S - Snubbers T - Tanks V - Vessels (includes Heat Exchangers)
W - Welded Stanchions Other codes may be used as necessary.
Several supports hold more than one classified line. These supports are counted only once and if scheduled for examination, will cover all of the applicable lines. The support will be counted once for credit.
7.3 Snubbers Snubbers are functionally tested under the Snubber Program, which is administered separately. The requirements for the snubber program are included in 0-OSP-1 05.1.
Visual, VT-3, examinations are performed on snubbers as required by Examination Category F-A. If welded attachments are present, then these will be examined under the Class 1, 2, or 3, F-A Examination Category, as appropriate.
The welded attachments are tracked within the ISI Program database.
8.0 IWL Concrete Containment Requirements The requirements for Code Class CC (Concrete Containment) are found in the Turkey Point Containment Building Concrete Containment Inservice Inspection Program, which is administered separately (Reference paragraph 1.2.7).
This document establishes the administrative, managerial, and implementation control for the IWL Containment Inspection Program Plan for the first 1 0-year Inservice Inspection interval.
9.0 Augmented and Other Programs This section identifies augmented inspection programs maintained within the ISI Program that are not required by ASME Section Xl.
However, due to the nature of the augmented requirements, these programs have been included within the ISI Program. These augmented programs satisfy NRC requirements, operating experience, engineering judgment, etc.
Augmented program revisions or deviations shall be governed by the referenced documents.
The following is the detailed description of the Turkey Point's Inservice Inspection Program Plan Basis for Augmented Examination of additional components/systems.
46
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 9.1 Class 1 9.1.1 Reactor Coolant Pump As required by Plant Technical Specification 4.4.110, each Reactor Coolant Pump Flywheel shall be inspected at an interval not to exceed 20 years per the requirements of TSTF-421 and WCAP-1 5666. This examination shall be conducted by an in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle of one-half the outer radius, or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the disassembled flywheel. All RCP flywheels will be tracked for location and examination cycle in both Units 3 & 4 Inservice Inspection database by the RCP motor designation. (Ref. 16.6, 16.7, and 16.8) 9.1.2 Reactor Pressure Vessel Reactor Pressure Vessel Examinations will be performed during the 2004 outage for Units 3 and the 2005 outage for Unit 4. These examinations will meet the requirements stated in 10 CFR 50.55a(g)(6)(ii)(A), Augmented Examination of Reactor Vessel. Relief requests were submitted to the USNRC to cover those areas where examination requirements were not satisfied.
The examinations covered the reactor vessel shell welds specified in Item No.
B1.10 of Examination Category B-A, Pressure Retaining Welds in Reactor Vessels, as defined in the 1989 Edition of Section Xl, Division 1, of the ASME Boiler and Pressure Vessel Code, subject to the conditions specified in 10 CFR 50.55a(g)(6)(ii)(A)(3) and (4).
9.2 Class 2 9.2.1 NRC Bulletin 79-13 Augmented Feedwater Examinations, as a result of a continuation of NRC Bulletin 79-13, and NRC Informational Notice 93-20, Thermal Fatigue Cracking of Feedwater Piping to Steam Generators.
FPL will perform a continuous enhanced ultrasonic examination starting at the Feedwater Nozzle ramp and extending out to a point of 1 diameter on the elbow. Examinations will be performed in conjunction with the Code examination schedule as identified within the Examination Tables.
10.0 Evaluation/Acceptance Criteria Florida Power and Light will perform non-destructive examinations using visual, surface (Penetrant and Magnetic Particle), and volumetric (Ultrasonic, Radiography, and Eddy Current) techniques. Other NDE techniques may be utilized when required.
During inservice inspections, NDE indications are evaluated against the acceptance standards of ASME Section Xl. Components with indications that do not exceed the acceptance criteria will be considered acceptable for continued service. Additional examinations are not required.
47
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4t Interval-ISI-PTN 3/4-Program February 22, 2004 Examinations that reveal indications shall be evaluated in accordance with article IWA-3000, IWB-3000, IWC-3000, IWD-3000, and IWF-3000, as applicable. Additional guidance for conditions identified during component support examinations, including minimum thread engagement acceptability, is located in engineering discipline standard STD-C-01 1.
10.1 Supplemental Examinations Examinations that detect flaws/conditions that require evaluation in accordance with the requirements of IWB-3100, IWC-31 00, or IWF-31 00, may be supplemented by other examination methods and techniques within the limits specified by IWB-3200, IWC-3200, or IWF-3200.
10.2 Additional Examinations Examinations that reveal flaws or relevant conditions that exceed the referenced acceptance standard, shall be extended to include additional examinations during the current outage. The additional examination requirements of IWB-2430, IWC-2430, IWD-2430, or IWF-2430, (as applicable) shall be performed as determined by Nuclear Engineering.
10.3 Successive Inspections for Components Where components are accepted for continued service by analytical evaluation, IWB-2420(b), IWC-2420(b), IWD-2420(b) or IWF-2420(b), the area containing the flaws or component support shall be subsequently reexamined in accordance with the following; 10.3.1 Class 1 Components (IWB-2420)
If a component is accepted for continued service by analytical evaluation, the areas containing flaws or relevant conditions shall be reexamined during the next three inspection periods of Inspection Plan B (IWB-2412-1). Provided the flaws or relevant conditions remain essentially unchanged for three successive inspection periods, the component examination schedule will revert to the original schedule of successive inspections.
10.3.2 Class 2 Components (IWC-2420)
If a component is accepted for continued service by analytical evaluation, the areas containing flaws or relevant conditions shall be reexamined during the next inspection period of Inspection Plan B (IWC-2412-1). Provided the flaws or relevant conditions remain essentially unchanged for the next inspection period, the inspection schedule will revert to the original schedule of successive inspections.
10.3.3 Class 3 Components (IWD-2420)
If a component is accepted for continued service by analytical evaluation, the areas containing flaws or relevant conditions shall be reexamined during the 48
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 4 Interval-ISI-PTN 3/4-Program February 22, 2004 next inspection period of Inspection Plan B (IWD-2412-1). Provided the flaws or relevant conditions remain essentially unchanged for the next inspection period, the inspection schedule will revert to the original schedule of successive inspections.
10.3.4 Component Supports (IWF-2420)
If a component support is accepted for continued service by analytical evaluation, the component support shall be reexamined during the next inspection period of Inspection Plan B (IWF-2410-2).
Provided the examinations do not require additional corrective measures during the next inspection period, the inspection schedule will revert to the original schedule of successive inspections.
11.0 Repair/Replacement Activities The requirements of ASME Section Xl, 1998 Edition with Addenda through 2000 and the Repair and Replacement Program for Turkey Point Nuclear Plant shall be met for Class 1, 2, and 3 piping and components and their supports.
Specific requirements for the repair, replacement, or modification of ISI components are detailed in 0-ADM-532, ASME Section XI Repair/Replacement Program.
12.0 Relief Requests A relief request is required when there are situations where Code requirements cannot be met or where an alternative is desired. Relief Requests shall be prepared using the NEI guidance for the standard format for requests from commercial reactor licenses pursuant to 10CFR50.55a. Relief requests will be reviewed for completeness, technical adequacy, and implementation.
Reviewers may be the site ISI Coordinators, the ISI Specialist, NDE personnel, and any other group the relief request may affect. Typical examples where relief requests are submitted are as follows:
12.1 For Class 1 and 2 weld examinations, relief is required if 90% or less of the Code required coverage were achieved (unable to meet Code examination requirements).
12.2 The request for use of an alternative to a requirement listed within ASME Section Xl.
An example is the use of a Code Case that has not been approved for use by the latest revision of NRC Reg. Guide 1.147.
13.0 Boundary Classifications The code required boundaries for all Class 1, 2, and 3 systems are denoted by a boxed-in letter (A, B, and C respectively) on Piping and Instrument Diagrams (P&lDs). The following list shows those P&lDs applicable to the Turkey Point ISI Program. As a general rule, 5610 series drawings are common between units, 5613 series are for Unit 3 and 5614 series are for Unit 4. The latest revision will be used.
49
Turkey Point Units 3 and 4 ISI Program Document No. 4th Interval-ISI-PTN 3/4-Program Revision 0 February 22, 2004
,,n Its 14 '
- 6 a Cassifications 561 3-M-301 8 1
Condensate Storage System 5614-M-3018 1
Condensate Storage System 5613-M-3019 1 thru 2 Intake Cooling Water System 5614-M-3019 1 thru 2 Intake Cooling Water System 5614-M-3022 1 thru 6 Emergency Diesel and Oil System 561 3-M-3030 1 thru 5 Component Cooling Water System 561 4-M-3030 1 thru 4 Component Cooling Water System 561 3-M-3033 1
Spent Fuel Pool Cooling System 561 4-M-3033 1
Spent Fuel Pool Cooling System 5613-M-3036 1
Reactor Coolant System 5614-M-3036 1
Reactor Coolant System 5613-M-3041 1 thru 4 Reactor Coolant System 5614-M-3041 1 thru 4 Reactor Coolant System 5610-M-3046 1
Chemical and Volume Control System 561 3-M-3047 1 thru 3 CVCS - Charging, Letdown & RCP seal 561 4-M-3047 1 thru 3 CVCS - Charging, Letdown & RCP Seal 561 3-M-3050 1
Residual Heat Removal System 561 4-M-3050 1
Residual Heat Removal System 561 3-M-3056 1
Containment Emergency Filter System 5614-M-3056 1
Containment Emergency Filter System 5613-M-3062 1, 2 Safety Injection System 5614-M-3062 1, 2 Safety Injection System 5613-M-3064 1
Safety Injection Accumulator System (CTMT) 5614-M-3064 1
Safety Injection Accumulator System (CTMT) 5613-M-3068 1
Containment Spray System 5614-M-3068 1
Containment Spray System 5613-M-3072 1, 3 Main Steam System 5614-M-3072 1, 3 Main Steam System 561 3-M-3074 3, 4 Feedwater System 561 4-M-3074 3, 4 Feedwater System 561 3-M-3075 1,2 Auxiliary Feedwater System 561 4-M-3075 1, 2 Auxiliary Feedwater System 0-M-3075 1
Auxiliary Feedwater System - Turbine Drive for 5610 Auxiliary Feedwater Pumps 5610-M-3075 2
Auxiliary Feedwater System - Auxiliary Feedwater P um ps Table 8 50
Turkey Point Units 3 and 4 1SI Program Revision 0 Document No. 4' Interval-ISI-PTN 3/4-Program February 22, 2004 14.0 Addition of Welds, Components, and Components Supports The rules for selection and scheduling of examinations for new welds shall be in accordance with paragraphs IWB-2412(b), IWC-2412(b), IWID-24112(b), 1WF-2410(c)).
15.0 Records 15.1 General Records of Inservice Inspection Program, Plans, outage schedules, calibration standards, examination and test procedures, results of activities, final reports, certifications, and corrective actions will be developed and maintained in accordance with IWA-6000.
15.2 Nondestructive Examinations Completed NDE examination data packages shall be submitted to the ISI Specialist following completion of the inservice examination activity.
15.3 Final Reports 15.3.1 Final reports will be generated for the following activities:
(a)
Nondestructive examination activities performed on Class 1, 2, and 3 systems, components and their supports (b)
Nondestructive examination activities performed on Class MC systems (c)
Snubber examinations and tests (d)
System pressure tests (e)
Eddy current examinations (f)
Repairs and replacements 15.3.2 The final reports shall contain, as a minimum, the information required in the NIS-1 or OAR-1 (Code Case N-532-1 as modified by NRC Reg. Guide 1.147).
15.4 Inservice Inspection Summary Report FPL shall forward a summary report, NIS-1 or OAR-1, of the ISI activity to the Nuclear Regulatory Commission in accordance with IWA-6230 or Code Case N-532-1 (as modified by NRC Reg. Guide 1.147), as applicable.
15.5 NIS-2 or NIS-2A Reports NIS-2 forms, or if Code Case N-532-1 is followed, a NIS-2A form, will be completed for each repair or replacement.
15.6 NIS-BB Form A NIS-BB form will be completed after each Steam Generator tube examination.
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Turkey Point Units 3 and 4 IS Program Revision 0 Document No. 4th Interval-ISI-PTN 3/4-Program February 22, 2004 16.0 References The Inservice Inspection Program for Class 1, 2, and 3 (or Quality Groups A, B, and C respectively) systems and components and supports, was developed after reviewing the following documents and procedures.
Limitations of design, geometry, and materials of construction may have an impact on the implementation of some of these documents.
16.1 10 CFR 50.55(a) Code of Federal Regulations.
16.2 American Society of Mechanical Engineers (ASME) Section Xl Code, 1989 Edition.
16.3 American Society of Mechanical Engineers (ASME) Section Xl Code, 1992 Edition with Addenda through 1992.
16.4 American Society of Mechanical Engineers (ASME) Section Xl Code, 1995 Edition with Addenda through 1996.
16.5 American Society of Mechanical Engineers (ASME) Section Xi Code, 1998 Edition with Addenda through 2000.
16.6 WCAP 15666 - "Extension of Reactor Coolant Pump Motor Flywheel", dated July, 2001.
16.7 Federal Register Notice: Notice of Opportunity of Comment on Model Safety Evaluation on Technical Specification Improvement Regarding Extension of Reactor Coolant Pump Motor Flywheel Examination for Westinghouse Plants Using the Consolidated Line Item Improvement Process, published June 24, 2003 (68 FR 37590).
16.8 Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-421, "Revision to RCP Flywheel Inspection Program (WCAP-15666), " Revision 0, November 2001.
16.9 USNRC Regulatory Guide 1.26 - Quality Group Classifications and standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants, Revision 3, dated February 1976.
16.10 USNRC Regulatory Guide 1.65 - Materials and Inspections for Reactor Vessel Closure Studs, October 1973.
16.11 USNRC Regulatory Guide 1.83 - Inservice Examination of Pressurized Water Reactor Steam Generator Tubes, Revision 1, dated July 1975.
16.12 USNRC Regulatory Guide 1.85 - Materials Code Case Acceptability, ASME Section III, Division 1.
16.13 USNRC Regulatory Guide 1.147 - Inservice Inspection Code Case Acceptability ASME Section Xl.
16.14 USNRC Regulatory Guide 1.150 - Ultrasonic Testing of Reactor Vessel Welds during Preservice and Inservice Examinations, Revision 1, dated February 1983 52
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. th Interval-ISI-PTN 3/4-Program February 22, 2004 16.15 USNRC Regulatory Guide 1.178 - An Approach for Plant-Specific Risk Informed Decision Making Inservice Inspection of Piping.
16.16 USNRC Information Notice 93-20, Thermal Fatigue Cracking of Feedwater Piping to Steam Generators, dated March 24,1993.
16.17 USNRC Bulletin 88-11, Pressurizer Surge Line Thermal Stratification.
16.18 USNRC Bulletin 79-13, Cracking in Feedwater System Piping.
16.19 EPRI Document, Guideline for the Implementation of Appendix VIII and 10 CFR 50.55a, Volume One Programmatic Implementation, dated 10/14/2000.
16.20 The Performance Demonstration Initiative (PDI), a utility developed guideline for the qualification of ultrasonic examination personnel.
16.21 USNRC Standard Review Plan 6.6, paragraph 1.8, (for Class 2 Augmented Inspections).
16.22 Branch Technical Position MEB 3-1, High Energy Fluid Systems, Protection Against Postulated Piping Failures in Fluid Systems Outside Containment.
16.23 Branch Technical Position APCSB 3.1. Paragraph B.2.c(4).
16.24 First, Second and Third Interval Inservice Inspection Long Term Programs, Plans, and Schedules for Turkey Point Units 3 & 4.
16.25 Turkey Point's Units 3 & 4 Final Safety Analysis Report 16.26 Turkey Point Technical Specifications, Docket number 50-250 for Unit 3 and 50-251 for Unit 4, Sections 4.0.5, 3/4.4.5, 3/4.7.6, 3/4.4.10, 4.4.10.
16.27 STD-C-01 1, "Acceptance Criteria for As-Built Safety Related Piping and Pipe Supports,"
and Specification SPEC-M-004, "Maintenance Bolting Specification for St. Lucie Units 1 and 2 and Turkey Point Units 3 and 4."
16.28 Generic Aging Lessons Learned (GALL) Report.
16.29 Turkey Point Document - QI-1 1 -PTN-4, "ASME Section Xl Tests."
16.30 Turkey Point Document - O-OSP-105.1, 'Visual Inspection, Removal and Reinstallation of Mechanical Shock Arrestors."
16.31 Turkey Point Document -
0-ADM-532, "ASME Section XI Repair/Replacement Program."
16.32 Turkey Point Document ADM-523, "ASME Section Xl Pressure Test for Quality group A, B, C Systems/Components."
53
Turkey Point Units 3 and 4 ISI Program Revision 0 Document No. 0h Interval-lSI-PTN 3/4-Program February 22, 2004 16.33 Engineering QI -
ENG-QI 5.2, "Implementation of ASME Section XI (Inservice Inspection)."
16.34 Turkey Point Units 3 & 4 Design Basis Document, 5610-000-DBD-001, "Selected Licensing and issues (SL1)", Section XVIlI, Revision 11.
16.35 Engineering Evaluation PTN-ENG-LRAM-00-0041, Revision 1, "Reactor Vessel Integrity Program - License Renewal Basis Document."
16.36 Engineering Evaluation PTN-ENG-LRAM-00-0044, Revision 2, "ASME Section Xl, Subsections IWB, IWC and IWD Inservice Inspection Program - License Renewal Program Basis Document."
16.37 Engineering Evaluation PTN-ENG-LRAM-00-0027, Revision 1, "ASME Section XI, Subsection IWF Inservice Inspection Program -License Renewal Program Basis Document."
16.38 Letter to Mr. Angelo Giambusso of the Atomic Energy Commission, February 22, 1973, from Florida Power & Light Letter to Dr. James Coughlin of Florida Power &
Light, April 2,1973, from Mr. Angelo Giambusso of the Atomic Energy Commission 54
Turkey Point Units 3 and 4 ISI Program Document No. 4th Interval-ISI-PTN 3/4-Program Revision 0 February 22, 2004 Appendix A Fourth Inservice Inspection Interval SER (To be added after NRC approval)
Al
Turkey Point Units 3 and 4 ISI Program Document No. 4 h Interval-ISI-PTN 314-Program Revision 0 February 22, 2004 Appendix B Relief Requests B1
Turkey Point Units 3 and 4 ISI Program Document No. 4m Interval-ISI-PTN 3/4-Program Revision 0 February 22, 2004 Table X
0 1
Alternative Examination for the Regenerative Submitted with Heat Exchanger Program 2
Alternative Requirements for Implementation of Submitted with Appendix Vill, Supplement 10 Program B2
Page 1 of 7 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 1 "ALTERNATIVE EXAMINATION FOR THE REGENERATIVE HEAT EXCHANGER" Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected Class 1 Regenerative Heat Exchangers at Turkey Point Nuclear Plants, Units 3 & 4.
Weld Description Weld Numbers * (Same for Both Units)
RGX I - 1 Head to Shell RGX II - 1 RGX Ill - 1 RGX I -2 Shell to Tube Sheet - Primary RGX II - 2 RGX III - 2 Tube Sheet to Shell -
RGX I - 3 Secondary RGX ll - 3 RGX III-43 Channel Head Weld RGX I - 4 Secondary RGX 1I -4 RGX II-4 RGX i-9 Shell I Nozzle Welds RGX I -11 RGX I - 1 2 RGX I-12 RGX II - 9 Shell II Nozzle Welds RGX II - 11 RGX 11 - 1 2 RGX 11-129 RGX IlIl - 9 Shell IlIl Nozzle Welds RGX Ill - 11 RGX III-12 RGX I - LUG Integrally Welded Supports RGX II - LUG RGX Ill - LUG RGX I - CR Clamp Restraint RGX II - CR RGX Ill -
CR
2. Applicable Code Edition and Addenda
The Code of Record for Turkey Point Units 3 & 4 is the 1998 Edition with 2000 Addenda of ASME Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components."
Page 2 of 7 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 1
3. Applicable Code Requirement
Category Item Number Examination Requirements B2.51 Volumetric examination, to include 100% of the length B-B1 2 80 of circumferential tube sheet to shell welds and head B2.80to shell welds BBD 13.150 Volumetric examination, to include 100% of each BB3.160 nozzle to vessel weld and nozzle inside radius area B-K 1310.10 Volumetric or surface examination to include 100% of
.1 each integrally welded attachments of one exchanger.
Examine welds, mechanical connections, clearances, F-A F1.40 alignment, sliding surfaces, and assembly of the supports.
The extremities of piping runs that connect to N/A Terminal Ends structures, components, or pipe anchors, each of which acts as a rigid restraint or provides at least 2 degrees of restraint to piping thermal movement.
- 4. Proposed Alternative Florida Power and Light will perform a VT-2 visual examination at the beginning of the outage for leakage and boric acid accumulation and a VT-2 visual examination at startup during the system leakage test.
- 5. Basis of Alternative for Providing Acceptable Level of Quality and Safety Pursuant to 10CFR 50.55a (a)(3)(i), Florida Power and Light Company (FPL) requests relief from the Code required examinations on the Regenerative Heat Exchanger shell welds, support welds, and component supports.
Item Number Examination Areas Unit 3 Unit 4 B2.51 Head to Shell circumferential Welds 6 Welds 6 Welds B2.80 Shell to Tubesheet Welds 6 Welds 6 Welds B3.150 Nozzle to Shell Welds 12 Welds 12 Welds B3.160 Nozzle Inside Radius Section
!2 Areas 12 Areas B130.10 Welded Attachments 3 Welds 3 Welds I 1.40 Supports 3 Support 3 Support The Regenerative Heat Exchanger is located in a locked high radiation area. This area has a
Page 3 of 7 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 1 general field of 2 Rem/hr and is highly contaminated. Turkey Point Health Physics (HP) rules require the constant presence of a HP technician during entry to this area.
Other conditions include limited accessibility to the examination areas due to the close proximity of the adjacent wall and floor, limited work area due to cubicle walls built to shield personnel in adjacent areas, and interference from other lines and supports in the immediate area.
During construction of Turkey Point Units 3 and 4, asbestos insulation was used extensively.
Asbestos insulation is present in the area of the Regenerative Heat Exchanger.
Additional protection is required for personnel entering this area to avoid possible spreading and ingestion of this hazardous material (i.e., an extra layer of protective clothing, tenting, HEPA filters.)
Performing Code required examinations would require large expenditures of man-hours and accumulated Man-Rem dose. The welds must be de-insulated for examination and temporary shielding and scaffold installed. Effective shielding reduces accessibility to the examination areas.
Proper surface conditioning will add to their time and exposure required to perform valid surface and volumetric examinations. The area must be tented to avoid spreading of asbestos fibers found in the insulation. The design and arrangement of the Regenerative Heat Exchanger are not conducive to meaningful examinations.
FPL has performed examinations on the Regenerative Heat Exchangers for both Turkey Point Units 3 and 4 during the first inspection interval (approximately early 1972 through late 1983) before the original relief request was approved.
This experience showed that the design arrangement and accessibility are not conducive to meaningful examinations. The configuration, limited accessibility, high radiation levels, and interference from supports, walls, and the floor do not allow the Code required volumetric and/or surface examinations.
Since 1985, FPL has performed VT-2 and VT-3 examinations on the items listed in this relief request. These examinations were performed in accordance with the previous approved relief request, which required FPL to look for evidence of leakage around the Regenerative Heat Exchanger just after shutdown for a refueling outage and a second time during the system pressure test at plant startup.
During the 1991 outages of both units, the system hydrostatic tests were performed on the affected systems. No leakage was detected. No evidence of leakage from the Regenerative Heat Exchanger or its attached piping has been noted in either unit during any of the previous examinations.
Performing the alternative examinations will not increase the health and safety risk to the public.
Page 4 of 7 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 1 Estimated Time and Man-Rem for Regenerative Heat Exchanger Weld Examinations Dose Man Estimated Rate Hours Man-Rem Tenting and HEPA Filter Installation 0.7 8.0 5.600 Insulation Removal (Asbestos) 2.0 8.0 16.000 Scaffold Installation 0.7 3.0 2.100 Lead Installation 2.0 5.0 10.000 Surface Preparation for Examination 2.5 16.0 40.000 ISI Examination 2.5 5.5 13.750 Install Insulation 2.0 12.5 25.000 Remove Scaffold 0.7 1.5 1.050 Remove Tent and HEPA Filter 0.7 2.5 1.750 Temporary Services 0.7 0.5
.350 Lead Removal 2.0 2.0 4.000 Clean Up 1.0 2.0 2.000 Note: These estimates are valid for both units.
- 6. Duration for the Proposed Alternative Florida Power & Light will performed the proposed alternative examinations during each refueling outage for both Turkey Point Units 3 & 4 during the fourth 10-year Inservice Inspection Interval.
7. Precedents
USNRC letter to Mr. J. W. Williams, Jr., Vice president, Florida Power & Light, dated February 4, 1985 granting relief from ASME Section Xl requirements (TAC Nos. 49133, 49936, 54677, 54678, 54973, and 54974)
USNRC letter to Mr. J. H. Goldberg, President Nuclear Division, Florida Power & Light, dated March 31, 1995 granting relief from ASME Section Xl requirements (TAC Nos. M87725 and M87726)
Page 5 of 7 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 1
- 8. Attachments Sketch of Coverage Achieved Sketch of Unit 3 & 4 Regenerative Heat Exchanger
Page 6 of 7 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 1 Examination Area Coverage Tubesheet Clamp Limited examination from Shell side due to Nozzle -
76% Coverage achieved. Limited examination on Cap side due to configuration - less than 50%
coverage achieved. Only 76% of weld length examined on cap side due to lug (Typical three welds)
Limited exam in Shell side due to Clamp, 87% coverage achieved (Typical 4 areas)
_XfG-No examination on weld or Nozzle side due to configuration - 0%
coverage achieved. (Typical 12 areas)
Limited examination on Shell side due to clamp -
87%
coverage achieved (Typical 4 areas)
I I CAP No examination of lug due to angle iron bracket covering weld -
50%
coverage achieved.
SHELL SHELL CAP Limited examination fro Shell side due to Nozzle configuration -
76%
Limited examination fron coverage achieved. No shell side due to NozzlE examination on tubesheet 53% coverage achieved side due to clamp -
0%
(Typical 3 welds).
No coverage achieved.
examination from tubeshE side due to clamp -
0%
coverage achieved.
LI es -
Limi eet sidE covE (Tw
.ted exam in Shell
? due to Clamp, 87%
erage achieved ical 4 areas)
Limited examination on Cap side due to configuration -
<50%
coverage achieved (Typical 3 welds).
Limited examination from Shell side due to nozzle -
53% coverage achieved (Typical 3 welds).
.s
Page 7 of 7 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 1 Turkey Point Units 3 and 4 2"-CH-1302 3"-CH-1303 RGX-1-1 RGX-1-9
[
RGX-I-10 RGX-1-4 CAP SHELL I SHELL CAP RGX-I-LUJG RX-1-1 1
RGX-1-2--V_v 61, IG,-RGX-1-12 Lug Resting on R
1 RGX-I-CR
/
Angle iron bracket RGX-1-3/
01 RGX-11-1 RGX-11-9\\^^~
R l,
/GX-11-10 RGX-11-4 CAP SHELL II SHELL CAP RGX-II-LUG RGX-11-1 1 RGX-11-2 RGX-11-12 RGX-11-CR RGX-11-3 RGX-111-1 RGX-111-9 RGX-111-10 RGX-111-4 2"-CH-1 301 3"-CH-1 301
Page 1 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 "ALTERNATIVE REQUIREMENTS FOR IMPLEMENTATION OF APPENDIX VIII, SUPPLEMENT 10" Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected Class 1 and 2, Pressure Retaining Piping Welds subject to Ultrasonic (UT) examination using procedures, personnel, and equipment qualified to ASME Section XI, 1998 Edition with Addenda through 2000, Appendix VilIl, Supplement 10.
2. Applicable Code Edition and Addenda
The Code of record for Turkey Point Units 3 and 4 is the 1998 Edition with Addenda through 2000 of ASME Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components."
(a) Applicable Code Requirement Pursuant to IOCFR 50.55a (a)(3)(1), Florida Power and Light Company (FPL) requests approval to use alternatives to the requirements within ASME Section Xl, 1998 Edition 2000 Addenda, Appendix VIII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds. The following paragraphs referenced and statements identify the specific requirements that are included in this request for relief.
Item 1 - Paragraph 1.1(b) states in part - Pipe diameters within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent.
Item 2 - Paragraph 1.1 (d) states - All flaws in the specimen set shall be cracks.
Item 3 - Paragraph 1.1 (d)(1) states - At least 50% of the cracks shall be in austenitic material. At least 50% of the cracks in austenitic material shall be contained wholly in weld or buttering material.
At least 10% of the cracks shall be in ferritic material. The remainder of the cracks may be in either austenitic or ferritic material.
Item 4 - Paragraph 1.2(b) states in part - The number of unflawed grading units shall be at least twice the number of flawed grading units.
Item 5 - Paragraphs 1.2(c)(1) and 1.3(c) state in part - At least 1/3 of the flaws, rounded to the next higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness.
Paragraph 1.4(b) distribution table requires 20% of the flaws to have depths between 10% and 30%.
Item 6 - Paragraph 2.0 first sentence states - The specimen inside surface and identification shall be concealed from the candidate.
Page 2 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 Item 7 - Paragraph 2.2(b) states in part - The regions containing a flaw to be sized shall be identified to the candidate.
Item 8 - Paragraph 2.2(c) states in part - For a separate length sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.
Item 9 - Paragraph 2.3(a) states - For the depth sizing test, 80% of the flaws shall be sized at a specific location on the surface of the specimen identified to the candidate.
Item 10 - Paragraph 2.3(b) states -
For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
Item 11 - Table VIII-S2-1 provides the false call criteria when the number of unflawed grading units is at least twice the number of flawed grading units.
(a) Reason For Request FPL requests relief to use the following alternative requirements for implementation of Appendix Vil, Supplement 10 requirements.
These alternatives will be implemented through the Performance Demonstration Initiative (PDI) Program.
A copy of the proposed revision to Supplement 10 is attached. The Table identifies the proposed alternatives and allows them to be viewed in context. It also identifies additional clarifications and enhancements for information. The proposed revision has been submitted to the ASME Code for consideration and as of April 2003 had been approved by the Main committee.
(a) Proposed Alternative and Basis for Use Item 1 - The proposed alternative to Paragraph 1.1 (b) states:
"The specimen set shall include the minimum and maximum pipe diameters and thicknesses for which the examination procedure is applicable. Pipe diameters within a range of 1/2 in.
(13 mm) of the nominal diameter shall be considered equivalent. Pipe diameters larger than 24 in. (610 mm) shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of +25% is acceptable."
Technical Basis - The change in the minimum pipe diameter tolerance from 0.9 times the diameter to the nominal diameter minus 0.5 inch provides tolerances more in line with industry practice. The alternative is less stringent for small diameter pipe because they typically have a thinner wall thickness than larger diameter piping. A thinner wall thickness results in shorter sound path distances that reduce the detrimental effects of the curvature.
This change maintains consistency between Supplement 10 and the recent revision to Supplement 2.
Item 2 - The proposed alternative to Paragraph 1.1(d) states:
"At least 60% of the flaws shall be cracks, the remainder shall be alternative flaws.
Page 3 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 Specimens with IGSCC shall be used when available. Alternative flaws, if used, shall provide crack-like reflective characteristics and shall be limited to the case where implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 in. (.05 mm). Note, to avoid confusion the proposed alternative modifies instances of the term "cracks" or "cracking" to the term "flaws" because of the use of alternative flaw mechanisms."
Technical Basis - As illustrated below, implanting a crack requires excavation of the base material on at least one side of the flaw. While this may be satisfactory for ferritic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at least one side, producing an unrealistic flaw response.
In addition, it is important to preserve the dendritic structure present in field welds that would otherwise be destroyed by the implantation process. To resolve these issues, the proposed alternative allows the use of up to 40%-fabricated flaws as an alternative flaw mechanism under controlled conditions.
The fabricated flaws are isostatically compressed which produces ultrasonic reflective characteristics similar to tight cracks.
ExcavtionMechanical fatigue crack lrAl in Base material Item 3 - The proposed alternative to Paragraph 1.1 (d)(1) states:
"At least 80% of the flaws shall be contained wholly in weld or buttering material. At least one and a maximum of 10% of the flaws shall be in ferritic base material. At least one and a maximum of 10% of the flaws shall be in austenitic base material."
Technical Basis - Under the 1998 Edition with 2000 Addenda, as few as 25% of the flaws are contained in austenitic weld or buttering material. Recent experience has indicated that flaws contained within the weld are the likely scenarios.
The metallurgical structure of austenitic weld material is ultrasonically more challenging than either ferritic or austenitic base material.
The proposed alternative is therefore more challenging than the current Code.
Item 4 - The proposed alternative to Paragraph 1.2(b) states:
"Detection sets shall be selected from Table VIIl-S1O-1. The number of unflawed grading units shall be at least one and a half times the number of flawed grading units."
Technical Basis - Table S10-1 provides a statistically based ratio between the number of unflawed grading units and the number of flawed grading units. The proposed alternative reduces the ratio to 1.5 times to reduce the number of test samples to a more reasonable number from the human factor perspective. However, the statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful and less skilled personnel being unsuccessful. The acceptance criteria for the statistical basis are in Table Vill-S10-1.
Page 4 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 Item 5 - The proposed alternative to the flaw distribution requirements of Paragraphs 1.2(c)(1)
(detection) and 1.3(c) (length) is to use the Paragraph 1.4(b) (depth) distribution table (see below) for all qualifications.
Flaw Depth Minimum Number of
(% Wall Thickness)
Flaws 10-30%
20%
31-60%
20%
61-100%
20%
Technical Basis - The proposed alternative uses the depth sizing distribution for both detection and depth sizing because it provides for a better distribution of flaw sizes within the test set. This distribution allows candidates to perform detection, length, and depth sizing demonstrations simultaneously utilizing the same test set. The requirement that at least 75% of the flaws shall be in the range of 10 to 60% of wall thickness provides an overall distribution tolerance yet the distribution uncertainty decreases the possibilities for testmanship that would be inherent to a uniform distribution. It must be noted that it is possible to achieve the same distribution utilizing the present requirements, but it is preferable to make the criteria consistent.
Item 6 - The proposed alternative to Paragraph 2.0 first sentence states:
"For qualifications from the outside surface, the specimen inside surface and identification shall be concealed from the candidate. When qualifications are performed from the inside surface, the flaw location and specimen identification shall be obscured to maintain a "blind test"."
Technical Basis - The 1998 Edition with 2000 Addenda requires that the inside surface be concealed from the candidate. This makes qualifications conducted from the inside of the pipe (e.g., PWR nozzle to safe end welds) impractical.
The proposed alternative differentiates between ID and OD scanning surfaces, requires that they be conducted separately, and requires that flaws be concealed from the candidate. This is consistent with the recent revision to Supplement 2.
Items 7 and 8 - The proposed alternatives to Paragraphs 2.2(b) and 2.2(c) state:
"... containing a flaw to be sized may be identified to the candidate."
Technical Basis - The 1998 Edition with 2000 Addenda requires that the regions of each specimen containing a flaw to be length sized shall be identified to the candidate. The candidate shall determine the length of the flaw in each region (Note, that length and depth sizing use the term "regions" while detection uses the term "grading units" - the two terms define different concepts and are not intended to be equal or interchangeable). To ensure security of the samples, the proposed alternative modifies the first "shall" to a "may" to allow the test administrator the option of not identifying specifically where a flaw is located. This is consistent with the recent revision to Supplement 2.
Page 5 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 Items 9 and 10 - The proposed alternative to Paragraphs 2.3(a) and 2.3(b) state:
"... regions of each specimen containing a flaw to be sized may be identified to the candidate."
Technical Basis - The 1998 Edition with 2000 Addenda requires that a large number of flaws be sized at a specific location. The proposed alternative changes the "shall" to a "may" which modifies this from a specific area to a more generalized region to ensure security of samples. This is consistent with the recent revision to Supplement 2. It also incorporates terminology from length sizing for additional clarity.
Item 11 - The proposed alternative modifies the acceptance criteria of Table VIII-S2-1 as follows:
TABLE VIII-SP-1" PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE CRITERIA Detection Test False Call Test Acceptance Critera Acceptance Criteria No. of No. of Maximum Flawed Minimum Unflawed Number Grading Detection Grading of False Units Criteria Units Calls 5
5 10 0
6 6
12 l
7 6
14 l
8 7
16 2
9 7
1 10 82-15 3-2 11 9
2-17 3
12 9
24-18 3-3 13 10 2t-20 4-3 14 10 28-21 3
15 22 3-23 5-3 16 12 3-24 6-4 17 12 3-26 6-4 18 13 36-27 4
19 13 38 29 7-4 20 14 40- 30 8-5 Technical Basis - The proposed alternative is identified as new Table S10-1 above. It was modified to reflect the reduced number of unflawed grading units and allowable false calls.
As a part of ongoing Code activities, Pacific Northwest National Laboratory (PNNL) has reviewed the statistical significance of these revisions and offered the revised Table S1O-1.
Page 6 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.
(a) Duration for the Proposed Alternative FPL will implement the alternative requirements during the fourth 10-year Inservice Inspection interval at PTN 3 & 4.
(a) Attachments to the Relief Proposed Revision to Supplement 10-Qualification Requirements for Dissimilar Metal Welds
Page 7 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 1.0 SCOPE Supplement 10 is applicable to dissimilar A scope statement provides added clarity metal piping welds examined from either regarding the applicable range of each individual the inside or outside surface. Supplement Supplement. The exclusion of CRC provides 10 is not applicable to piping welds consistency between Supplement 10 and the containing supplemental corrosion recent revision to Supplement 2 (Reference BC resistant clad (CRC) applied to mitigate 00-755). Note, an additional change identifying Intergranular Stress Corrosion Cracking CRC as "in course of preparation" is being (IGSCC).
processed separately.
1.0 SPECIMEN REQUIREMENTS 2.0 SPECIMEN REQUIREMENTS Renumbered Qualification test specimens shall meet the Qualification test specimens shall meet the No Change requirements listed herein, unless a set of requirements listed herein, unless a set of specimens is designed to accommodate specific specimens is designed to accommodate limitations stated in the scope of the examination specific limitations stated in the scope of the procedure (e.g., pipe size, weld joint examination procedure (e.g., pipe size, weld configuration, access limitations). The same joint configuration, access limitations). The specimens may be used to demonstrate both same specimens may be used to demonstrate detection and sizing qualification.
both detection and sizing qualification.
1.1 General. The specimen set shall conform to 2.1 General. The specimen set shall conform Renumbered the following requirements.
to the following requirements.
(a) The minimum number of flaws in a test New, changed minimum number of flaws to 10 so set shall be ten.
sample set size for detection is consistent with length and depth sizing.
(a) Specimens shall have sufficient volume to (b) Specimens shall have sufficient volume to Renumbered minimize spurious reflections that may interfere minimize spurious reflections that may with the interpretation process.
interfere with the interpretation process.
(b) The specimen set shall include the minimum (c) The specimen set shall include the Renumbered, metricated, the change in pipe and maximum pipe diameters and thicknesses minimum and maximum pipe diameters and diameter tolerance provides consistency between for which the examination procedure is thicknesses for which the examination Supplement 10 and the recent revision to applicable. Pipe diameters within a range of 0.9 procedure is applicable. Pipe diameters within Supplement 2 (Reference BC 00-755) to 1.5 times a nominal diameter shall be a range of 1/2/2 in. (13 mm) of the nominal considered equivalent. Pipe diameters larger diameter shall be considered equivalent. Pipe than 24 in. shall be considered to be flat. When diameters larger than 24 in. (610 mm) shall be a range of thicknesses is to be examined, a considered to be flat. When a range of thickness tolerance of +25% is acceptable.
thicknesses is to be examined, a thickness tolerance of +25% is acceptable.
Page 8 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning
© The specimen set shall include examples of (d) The specimen set shall include examples Renumbered, changed "condition" to "conditions" the following fabrication condition:
of the following fabrication conditions:
(1) geometric conditions that normally require (1) geometric and material conditions that Clarification, some of the items listed relate to discrimination from flaws (e.g., counterbore or normally require discrimination from flaws material conditions rather than geometric weld root conditions, cladding, weld buttering, (e.g., counterbore or weld root conditions, conditions. Weld repair areas were added as a remnants of previous welds, adjacent welds in cladding, weld buttering, remnants of previous result of recent field experiences.
close proximity);
welds, adjacent welds in close proximity, and weld repair areas);.
(2) typical limited scanning surface conditions (2) typical limited scanning surface conditions Differentiates between ID and OD scanning (e.g., diametrical shrink, single-side access due (e.g., weld crowns, diametrical shrink, single-surface limitations. Requires that ID and OD to nozzle and safe end external tapers).
side access due to nozzle and safe end qualifications be conducted independently (Note, external tapers for outside surface new paragraph 2.0 (identical to old paragraph examinations; and internal tapers, exposed 1.0) provides for alternatives when "a set of weld roots, and cladding conditions for specimens is designed to accommodate specific inside surface examinations).
limitations stated in the scope of the examination Qualification requirements shall be procedure.").
satisfied separately for outside surface and inside surface examinations.
(d) All flaws in the specimen set shall be cracks.
Deleted this requirement, because new paragraph 2.3 below provides for the use of "alternative flaws" in lieu of cracks.
(1) At least 50% of the cracks shall be in 2.2 Flaw Location. At least 80% of the flaws Renumbered and re-titled. Flaw location austenitic material. At least 50% of the cracks in shall be contained wholly in weld or buttering percentages redistributed because field austenitic material shall be contained wholly in material. At least one and a maximum of experience indicates that flaws contained in weld weld or buttering material. At least 10% of the 1 0% of the flaws shall be in ferritic base or buttering material are probable and represent cracks shall be in ferritic material. The material. At least one and a maximum of the more stringent ultrasonic detection scenario.
remainder of the cracks may be in either 10% of the flaws shall be in austenitic base austenitic or ferritic material.
material.
Page 9 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (2) At least 50% of the cracks in austenitic base 2.3 Flaw Type.
Renumbered and re-titled. Alternative flaws are material shall be either IGSCC or thermal fatigue (a) At least 60% of the flaws shall be required for placing axial flaws in the HAZ of the cracks. At least 50% of the cracks in ferritic cracks, the remainder shall be alternative weld and other areas where implantation of a material shall be mechanically or thermally flaws. Specimens with IGSCC shall be crack produces metallurgical conditions that induced fatigue cracks.
used when available. Alternative flaws, if result in an unrealistic ultrasonic response. This used, shall provide crack-like reflective is consistent with the recent revision to characteristics and shall be limited to the Supplement 2 (Reference BC 00-755).
case where implantation of cracks produces spurious reflectors that are The 40% limit on alternative flaws is needed to uncharacteristic of actual flaws.
support the requirement for up to 70% axial Alternative flaw mechanisms shall have a flaws. Metricated tip width of less than or equal to 0.002 in.
(.05 mm).
(3) At least 50% of the cracks shall be coincident (b) At least 50% of the flaws shall be Renumbered. Due to inclusion of "alternative with areas described in © above.
coincident with areas described in 2.1 (d) flaws", use of "cracks" is no longer appropriate.
above.
2.4 Flaw Depth. All flaw depths shall be Moved from old paragraph 1.3© and 1.4 and re-greater than 10% of the nominal pipe wall titled. Consistency between detection and sizing thickness. Flaw depths shall exceed the specimen set requirements (e.g., 20% vs. 1/3 nominal clad thickness when placed in flaw depth increments, e.g., original paragraph cladding. Flaws in the sample set shall be 1.3©)
distributed as follows:
Flaw Depth Minimum
(% Wall Thickness)
Number of Flaws 10-30%
20%
31-60%
20%
61-100%
20%
At least 75% of the flaws shall be in the range of 10 to 60% of wall thickness.
1.2 Detection Specimens. The specimen set Renumbered and re-titled and moved to shall include detection specimens that meet the paragraph 3.1 (a). No other changes following requirements.
Page 10 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) Specimens shall be divided into grading Renumbered to paragraph 3.1(a)(1). No other units. Each grading unit shall include at least 3 changes.
in. of weld length. If a grading unit is designed to be unflawed, at least 1 in. of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit.
Grading units need not be uniformly spaced around the pipe specimen.
(b) Detection sets shall be selected from Table Moved to new paragraph 3.1 (a)(2).
Vill-S2-1. The number of unflawed grading units shall be at least twice the number of flawed grading units.
© Flawed grading units shall meet the following Flaw depth requirements moved to new criteria for flaw depth, orientation, and type.
paragraph 2.4, flaw orientation requirements moved to new paragraph 2.5, flaw type requirements moved to new paragraph 2.3, "Flaw Type".
(1) All flaw depths shall be greater than 10% of Deleted for consistency in sample sets. The the nominal pipe wall thickness. At least 1/3 of depth distribution is the same for detection and the flaws, rounded to the next higher whole sizing.
number, shall have depths between 10% and 30%
of the nominal pipe wall thickness.
However, flaw depths shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.
(2) At least 30% and no more than 70% of the 2.5 Flaw Orientation.
Note, this distribution is applicable for detection flaws, rounded to the next higher whole number, (a) At least 30% and no more than 70% of the and depth sizing. Paragraph 2.5(b)(1) requires shall be oriented axially. The remainder of the flaws, rounded to the next higher whole that all length-sizing flaws be oriented flaws shall be oriented circumferentially.
number, shall be oriented axially. The circumferentially.
remainder of the flaws shall be oriented circumferentially.
1.3 Length Sizing Specimens. The specimen Renumbered and re-titled and moved to new set shall include length sizing specimens that paragraph 3.2 meet the following requirements.
Page 11 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) All length sizing flaws shall be oriented Moved, included in new paragraph 3.2(a) circumferentially.
(b) The minimum number of flaws shall be ten.
Moved, included in new paragraph 2.1 above
© All flaw depths shall be greater than 10% of the nominal pipe wall thickness. At least 1/3 of the flaws, rounded to the next higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness.
However, flaw depth shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.
Moved, included in new paragraph 2.4 above after revision for consistency with detection distribution 1.4 Depth Sizing Specimens. The specimen Moved, included in new paragraphs 2.1, 2.3, 2.4 set shall include depth sizing specimens that meet the following requirements.
(a) The minimum number of flaws shall be ten.
Moved, included in new paragraph 2.1 (b) Flaws in the sample set shall not be wholly Moved, potential conflict with old paragraph contained within cladding and shall be 1.2©(1); "However, flaw depths shall exceed the distributed as follows:
nominal clad thickness when placed in cladding.".
Revised for clarity and included in new paragraph 2.4
Page 12 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning Moved, included in paragraph 2.4 for consistent Flaw Depth Minimum applicability to detection and sizing samples.
(% Wall Thickness)
Number of Flaws 10-30%
20%
31-60%
20%
61-100%
20%
The remaining flaws shall be in any of the above categories.
(b) Sizing Specimen sets shall meet the Added for clarity following requirements.
(1) All length-sizing flaws shall be oriented Moved from old paragraph 1.3(a) circumferentially.
(2) Depth sizing flaws shall be oriented as Included for clarity. Previously addressed by in 2.5(a).
omission (i.e., length, but not depth had a specific exclusionary statement) 2.0 CONDUCT OF PERFORMANCE 3.0 CONDUCT OF PERFORMANCE Renumbered DEMONSTRATION DEMONSTRATION The specimen inside surface and For qualifications from the outside Differentiate between qualifications identification shall be concealed from the surface, the specimen inside surface conducted from the outside and inside candidate. All examinations shall be and identification shall be concealed surface.
completed prior to grading the results and from the candidate. When presenting the results to the candidate.
qualifications are performed from the Divulgence of particular specimen results or inside surface, the flaw location and candidate viewing of unmasked specimens specimen identification shall be after the performance demonstration is obscured to maintain a "blind test".
prohibited.
All examinations shall be completed prior to grading the results and presenting the results to the candidate. Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.
2.1 Detection Test. Flawed and unflawed 3.1 Detection Qualification.
Renumbered, moved text to paragraph grading units shall be randomly mixed 3.1 (a)(3)
Page 13 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) The specimen set shall include Renumbered, moved from old paragraph detection specimens that meet the 1.2.
following requirements.
(1) Specimens shall be divided into Renumbered, moved from old paragraph grading units. Each grading unit shall 1.2(a). Metricated. No other changes.
include at least 3 in. (76 mm) of weld length. If a grading unit is designed to be unflawed, at least 1 in. (25 mm) of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit.
Grading units need not be uniformly spaced around the pipe specimen.
(2) Detection sets shall be selected from Moved from old paragraph 1.2(b). Table Table VIII-S10-1. The number of revised to reflect a change in the minimum unflawed grading units shall be at least sample set to 10 and the application of one and a half times the number of equivalent statistical false call parameters to flawed grading units.
the reduction in unflawed grading units.
Human factors due to large sample size.
(3) flawed and unflawed grading units Moved from old paragraph 2.1 shall be randomly mixed.
(b) Examination equipment and Moved from old paragraph 3.1. Modified to personnel are qualified for detection when reflect the 100% detection acceptance personnel demonstrations satisfy the criteria of procedures versus personnel and acceptance criteria of Table VIII S10-1 for equipment contained in new paragraph 4.0 both detection and false calls.
and the use of 1.5X rather than 2X unflawed grading units contained in new paragraph 3.1 (a)(2). Note, the modified table maintains the screening criteria of the original Table VIII-S2-1.
2.2 Length Sizing Test 3.2 Length Sizing Test Renumbered
Page 14 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) The length-sizing test may be conducted (a) Each reported circumferential flaw Provides consistency between Supplement separately or in conjunction with the in the detection test shall be length 10 and the recent revision to Supplement 2 detection test.
sized.
(Reference BC 00-755).
(b) When the length sizing test is conducted (b) When the length sizing test is Change made to ensure security of in conjunction with the detection test, and conducted in conjunction with the samples, consistent with the recent revision less than ten circumferential flaws are detection test, and less than ten to Supplement 2 (Reference BC 00-755).
detected, additional specimens shall be circumferential flaws are detected, provided to the candidate such that at least additional specimens shall be provided to Note, length and depth sizing use the term ten flaws are sized. The regions containing the candidate such that at least ten flaws "regions" while detection uses the term a flaw to be sized shall be identified to the are sized. The regions containing a flaw "grading units". The two terms define candidate. The candidate shall determine to be sized may be identified to the different concepts and are not intended to the length of the flaw in each region.
candidate. The candidate shall determine be equal or interchangeable.
the length of the flaw in each region.
(c) For a separate length sizing test, the (c) For a separate length sizing test, the Change made to ensure security of regions of each specimen containing a flaw regions of each specimen containing a samples, consistent with the recent revision to be sized shall be identified to the flaw to be sized may be identified to the to Supplement 2 (Reference BC 00-755).
candidate. The candidate shall determine candidate. The candidate shall determine the length of the flaw in each region.
the length of the flaw in each region.
(d) Examination procedures, equipment, Moved from old paragraph 3.2(a) includes and personnel are qualified for length inclusion of "when" as an editorial change.
sizing when the RMS error of the flaw Metricated.
length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 in. (19 mm).
2.3 Depth Sizing Test 3.3 Depth Sizing Test Renumbered
Page 15 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) For the depth sizing test, 80% of the (a) The depth sizing test may be Change made to ensure security of flaws shall be sized at a specific location on conducted separately or in samples, consistent with the recent revision the surface of the specimen identified to the conjunction with the detection test.
to Supplement 2 (Reference BC 00-755).
candidate.
For a separate depth sizing test, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
(b) For the remaining flaws, the regions of (b) When the depth sizing test is Change made to be consistent with the each specimen containing a flaw to be conducted in conjunction with the recent revision to Supplement 2 (Reference sized shall be identified to the candidate.
detection test, and less than ten flaws BC 00-755).
The candidate shall determine the are detected, additional specimens maximum depth of the flaw in each region.
shall be provided to the candidate Changes made to ensure security of such that at least ten flaws are sized.
samples, consistent with the recent revision The regions of each specimen containing to Supplement 2 (Reference BC 00-755).
a flaw to be sized may be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
(c) Examination procedures, equipment, Moved from old paragraph 3.2(b).
and personnel are qualified for depth Metricated.
sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. (3 mm).
3.0 ACCEPTANCE CRITERIA Delete as a separate category. Moved to new paragraph detection (3.1) and sizing 3.2 and 3.3
Page 16 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 3.1 Detection Acceptance Criteria.
Moved to new paragraph 3.1 (b), reference Examination procedures, equipment, and changed to Table S1 0 from S2 because of personnel are qualified for detection when the change in the minimum number of flaws the results of the performance and the reduction in unflawed grading units demonstration satisfy the acceptance from 2X to 1.5X.
criteria of Table VIII-S2-1 for both detection and false calls.
3.2 Sizing Acceptance Criteria Deleted as a separate category. Moved to new paragraph on length 3.2 and depth 3.3 (a) Examination procedures, equipment, and personnel are qualified for length sizing the RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch.
Moved to new paragraph 3.2(d), included word "when" as an editorial change.
(b) Examination procedures, equipment, Moved to new paragraph 3.3(c) and personnel are qualified for depth sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in.
4.0 PROCEDURE QUALIFICATION New
Page 17 of 17 Turkey Point Units 3 & 4 Fourth Inservice Inspection Interval Relief Request Number 2 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning Procedure qualifications shall include New. Based on experience gained in the following additional requirements.
conducting qualifications, the equivalent of 3 (a) The specimen set shall include the personnel sets (i.e., a minimum of 30 flaws) equivalent of at least three personnel is required to provide enough flaws to sets. Successful personnel adequately test the capabilities of the demonstrations may be combined to procedure. Combining successful satisfy these requirements.
demonstrations allows a variety of (b) Detectability of all flaws within the examiners to be used to qualify the scope of the procedure shall be procedure. Detectability of each flaw within demonstrated. Length and depth the scope of the procedure is required to sizing shall meet the requirements of ensure an acceptable personnel pass rate.
paragraph 3.1, 3.2 and 3.3.
The last sentence is equivalent to the (c) At least one successful personnel previous requirements and is satisfactory for demonstration has been performed.
expanding the essential variables of a (d) To qualify new values of essential previously qualified procedure variables, at least one personnel qualification set is required. The acceptance criteria of 4.0(b) shall be met.