ML063420372
| ML063420372 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 12/21/2006 |
| From: | Pickett D NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Stall J Florida Power & Light Co |
| Moroney B, NRR/DORL, 415-3974 | |
| References | |
| TAC MD0205, TAC MD0206 | |
| Download: ML063420372 (21) | |
Text
December 21, 2006 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
TURKEY POINT UNITS 3 AND 4 - SAFETY EVALUATION FOR RELIEF REQUESTS 1A, 14A AND 15A ASSOCIATED WITH VOLUMETRIC COVERAGE OF WELD EXAMINATIONS (TAC NOS. MD0205 AND MD0206)
Dear Mr. Stall:
By letter dated February 20, 2006, as supplemented by letter dated July 14, 2006, Florida Power and Light Company (the licensee), submitted revised Relief Requests 1A, 14A, and 15A, for the third 10-year inservice inspection (ISI) intervals at Turkey Point, Units 3 and 4, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(5)(iii). The requests for relief pertained to the amount of coverage obtained during specific examinations compared to the coverage required by the American Society of Mechanical Engineers (ASME) Code.
Based on review of the submittals, the U.S. Nuclear Regulatory Commission (NRC) staff concluded that compliance with the ASME Code coverage requirements is impractical for the configurations identified in the subject relief requests, and that compliance with the specified requirements would result in a significant burden on the licensee. The NRC staff also concluded that the examination coverages obtained by the licensee provide reasonable assurance of the structural integrity of the affected components. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for the third 10-year ISI interval at Turkey Point Unit 3, which began February 22, 1994, and ended February 21, 2005, and for the third 10-year ISI interval at Turkey Point Unit 4, which began April 15, 1994, and ended April 14, 2005.
Sincerely,
/RA/
Douglas V. Pickett, Acting Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Safety Evaluation cc w/encl: See next page
ML063420372 NRR-028 OFFICE LPL2-2/PM LPL2-2/LA CPNB/BC OGC LPL2-2/BC(A)
NAME BMoroney BClayton TChan by memo dated JMartin NLO w/edits DPickett DATE 12/19/06 12/19/06 11/07/06 12/20/06 12/21/06
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION INSERVICE INSPECTION PROGRAM RELIEF REQUEST NOS. 1A, 14A AND 15A FLORIDA POWER AND LIGHT COMPANY TURKEY POINT NUCLEAR PLANT UNITS 3 AND 4 DOCKET NOS. 50-250 AND 251
1.0 INTRODUCTION
By letter dated February 20, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML060520631), as supplemented by letter dated July 14, 2006 (ADAMS Accession Number ML061990015), Florida Power and Light Company (the licensee),
submitted revised Relief Requests 1A, 14A, and 15A, for the third 10-year inservice inspection (ISI) intervals at Turkey Point, Units 3 and 4, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(5)(iii). The requests for relief pertained to the amount of coverage obtained during specific examinations conducted during the third 10-year ISI intervals compared to the coverage required by the American Society of Mechanical Engineers (ASME) Code.
2.0 REGULATORY EVALUATION
The ISI of the ASME Code Class 1, 2, and 3 components is to be performed in accordance with the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," and applicable edition and addenda as required by the10 CFR 50.55a(g), except when specific relief has been granted by the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(g)(6)(i). As stated in 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the applicant demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI Code of record for Turkey Point Units 3 and 4 for the third 10-year ISI interval is the ASME Code,Section XI, 1989 Edition, No Addenda.
Pursuant to 10 CFR 50.55a(g)(5)(iii), if the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in Section 50.4, information to support the determination.
Pursuant to 10 CFR 50.55a(g)(5)(iv) where an examination requirement by the code or addenda is determined to be impractical by the licensee and is not included in the revised ISI program as permitted by 10 CFR 50.55a(g)(4), the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. The third 10-year ISI interval at Turkey Point Unit 3 began February 22, 1994, and ended February 21, 2005. The third 10-year ISI interval at Turkey Point Unit 4 began April 15, 1994, and ended April 14, 2005. For both units, the third 10-year interval was extended by one year as allowed by Paragraph IWA-2430 of the ASME Code,Section XI, 1989 Edition, No Addenda.
Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations under 10 CFR 50.55a(g)(5) that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
3.0 TECHNICAL EVALUATION
3.1 System/Component(s) for Which Relief is Requested Relief Request 1A: Class 1 pressure retaining welds in the reactor pressure vessel.
Relief Request 14A: Class 1 inner radius in vessels; Class 1 and 2 pressure retaining welds in vessel and piping.
Relief Request 15A: Class 1 inner radius in vessels; Class 1 and 2 pressure retaining welds in vessel and piping.
3.2.
Applicable Code Requirements The ASME Boiler and Pressure Vessel Code, Rules for ISI of Nuclear Power Plant Components,Section XI, 1989 Edition, No Addenda.
3.3 Licensees Request Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee has determined that conformance with certain code requirements is impractical for its facility. Specifically, the licensee has submitted three requests for relief addressing the inability to achieve required code volume coverage during examinations due to the components configuration and/or the presence of permanent attachments.
Relief Request 1A requests relief from the requirements listed below:
Examination Category Item No.
Component Examination Requirement B-A B1.21 3-WR-9; 4-WR-9 Essentially 100% volumetric examination of all circumferential head welds.
B-A B1.30 3-WR-18; 4-WR-18 Essentially 100% volumetric examination of the shell to flange weld.
B-G-1 B6.40 3-Lig-1 thru 58; 4-Lig-1 thru 58 Essentially 100% volumetric examination of the 1 inch annular volume of flange surrounding each stud hole Relief Request 14A requests relief from the requirements listed below:
Examination Category Item No.
Component Examination Requirement B-D B3.120 B3.140 Spray Nozzle-SP-03-1-IR 3-SRGN-01-IR 3-SGA-I-IRS 3-SGA-O-IRS 3-SGB-I-IRS 3-SGB-O-IRS 3-SGC-I-IRS 3-SGC-O-IRS Essentially 100% volumetric examination of the nozzle inner radius section B-F B5.70 29"-RCS-1305-4 29"-RCS-1308-4 31"-RCS-1302-5 31"-RCS-1303-5 Essentially 100% volumetric and surface examination of nozzle to safe end butt welds NPS 4 or larger B-J B9.11 4"-RC-1304-18 4"-RC-1304-20 4"-RC-1305-1 8"RHR-1301-3 8"-RHR-1304-8 8"-RHR-1305-2A 8"-RHR-1305-3 10"-SI-1302-1 10"-SI-1302-4 10"-SI-1303-11 10"-SI-1303-15 12"-RCS-1301-1 14"-RHR-1301-6 27.5"-RCS-1306-11 27.5"-RCS-1309-11 29"-RCS-1305-3 31"-RCS-1302-10 31"-RCS-1303-10 31"-RCS-1303-7 Essentially 100% volumetric and surface examination of circumferential welds NPS 4 or larger B-J B9.31 27.5"-RCS-1306-4 27.5"-
RCS-1307-2 27.5-RCS-1309-3 29"-RCS-1305-BC3 29"-RCS-1308-BC-1 Essentially 100% volumetric and surface examination of branch pipe connection welds NPS 4 or larger Examination Category Item No.
Component Examination Requirement C-A C1.10 C1.20 3-RHE-A2 3-RHE-A1 Essentially 100% volumetric examination of the shell circumferential welds C-F-1 C5.11 8"-SI-2303-1 10"-SI-2304-3 14"-RHR-2301-1 Essentially 100% volumetric and surface examination of circumferential piping welds $3/8" nominal wall thickness for piping > NPS 4 C-F-1 C5.21 3"-SI-2301-1 3"-SI-2301-4 Essentially 100% volumetric and surface examination of circumferential piping welds >1/5" nominal wall thickness for piping $NPS 2 and #
NPS 4 C-F-2 C5.51 6"-BDC-2303-6 6"-BDA-2301-8 Essentially 100% volumetric and surface examination of circumferential piping welds $3/8" nominal wall thickness for piping > NPS 4 Relief Request 15A requests relief from the requirements listed below:
Examination Category Item No.
Component Examination Requirement B-D B3.140 B3.120 4-SGA-I-IRS 4-SGA-O-IRS 4-SGB-I-IRS 4-SGB-O-IRS 4-SGC-I-IRS 4-SGC-O-IRS SP-04-1-IR 4-SRGN-01-1R Essentially 100% volumetric examination of the nozzle inner radius section B-F B5.70 12"-RC-1401-9 29"-RCS-1404-4 29"-RCS-1405-4 31"-RCS-1401-5 31"-RCS-1402-5 Essentially 100% volumetric and surface examination of nozzle to safe end butt welds NPS 4 or larger B-J B9.11 8"-RHR-1401-6 8"-RHR-1402-4 8"-RHR-1402-7 10"-SI-1401-14 10"-SI-1401-18 10"-SI-1402-1 10"-SI-1402-13 10"-SI-1402-17 10"-SI-1402-4 12"-RC-1401-1 14"-RHR-1401-1 14"-RHR-1401-5 14"-RHR-1401-6 14"-RHR-1401-9 27.5"-RCS-1406-11 27.5"-RCS-1407-11 31"-RCS-1401-10 31"-RCS-1401-8 Essentially 100% volumetric and surface examination of circumferential welds NPS 4 or larger Examination Category Item No.
Component Examination Requirement B-J B9.31 27.5"-RCS-1406-18 27.5"-RCS-1407-20 27.5"-RCS-1409-16 27.5"-RCS-1409-17 29"-RCS-1404-18 29"-RCS-1405-21 Essentially 100% volumetric and surface examination of branch pipe connection welds NPS 4 or larger C-A C1.10 C1.20 4-RHE-A2 4-RHE-A1 Essentially 100% volumetric examination of the shell circumferential welds C-B C2.21 4-RHE-A11 Essentially 100% volumetric and surface examination of the nozzle to vessel welds.
C-F-1 C5.11 8"-SI-2403-17 8"-SI-2404-2 8"-SI-2407-8 10"-SI-2407-4 10"-SI-2407-5 12"-RHR-2402-15 14"-RHR-2403-1 14"-RHR-2403-2 14"-RHR-2403-4 Essentially 100% volumetric and surface examination of circumferential piping welds $3/8" nominal wall thickness for piping > NPS 4 C-F-1 C5.21 3"-SI-2401-1 Essentially 100% volumetric and surface examination of circumferential piping welds >1/5" nominal wall thickness for piping $NPS 2 and #
NPS 4 3.4 Code Requirements for Which Relief is Requested 3.4.1 Relief Request 1A The 1989 Edition of ASME Code,Section XI, Code Categories B-A and B-G-1, Figures IWB-2500-3, -4, -12 require a volumetric examination which includes 100 percent of the weld length, once during the 10-year interval. Code Category B-G-1, Figure IWB-2500-12, requires a volumetric examination of the threaded region in the reactor vessel flange, once during the 10-year interval.
3.4.2 Relief Request 14A The 1989 Edition of ASME Code,Section XI, Code Categories B-D, B-F, B-J, C-A, C-F-1, and C-F-2, Figures IWB-2500-7, -8, -10, and Figures IWC-2500-1, -7 require a volumetric examination which includes 100 percent of the weld length, once during the 10-year interval.
3.4.3 Relief Request 15A The 1989 Edition of ASME Code,Section XI, Code Categories B-D, B-F, B-J, C-A, C-B, and C-F-1 Figures IWB-2500-7, -8, -10, and Figures IWC-2500-1, -4, -7 require a volumetric examination which includes 100 percent of the weld length, once during the 10-year interval.
3.5 Licensees Proposed Alternative to Code 3.5.1 Relief Request 1A The licensee proposed the following alternatives:
- 1) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1.
- 2) Conduct ultrasonic examinations to the maximum extent possible 3.5.2 Relief Request 14A The licensee proposed the following alternatives:
- 1) Surface examination per category B-F, B-J, C-F-1, and C-F-2.
- 2) Conduct ultrasonic examinations to the maximum extent possible.
- 3) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1 and Category C-H, Table IWC-2500-1.
3.5.3 Relief Request 15A The licensee proposed the following alternatives:
- 1) Surface examination per category B-F, B-J, C-B, and C-F-1.
- 2) Conduct ultrasonic examinations to the maximum extent possible.
- 3) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1 and Category C-H, Table IWC-2500-1.
3.6 Licensees Basis for Relief 3.6.1 Relief Request 1A The licensee stated that due to the configuration of the reactor vessel, it is impractical to meet the examination coverage requirements. The welds or surfaces did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments. Examination of welds 3-WR-9 and 4-WR-9 were limited due to the close proximity of the instrument tubes. Examination of welds 3-WR-18 and 4-WR-18 were limited due to the keyways and irradiation slots. Examination of the reactor pressure vessel threads in the flange were limited due to the o-ring groove machined into the flange surface, limiting the area for transducer placement for the examination. For the welds and surfaces listed, it was not possible to remove the obstruction/interference without significant work, increased radiation exposure, and/or damage to the plant.
3.6.2 Relief Request 14A The licensee stated that due to the configuration and/or the presence of permanent attachments, essentially 100 percent ultrasonic examination coverage of the required examination volume could not be obtained. Pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii), the licensee seeks relief from performing the 100-percent volumetric examination requirements of the ASME Code. For the welds identified, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications.
For Category B-F, the Class 1 dissimilar metal piping welds have carbon steel nozzles buttered with stainless steel and field welded to forged stainless steel or cast stainless steel components with stainless steel weld material.
Radiography was considered impractical due to the amount of work being performed in the areas on a 24-hour basis. This would result in numerous work-related stoppages and increased exposure due to the shutdown and startup of other work in the areas.
The water must be drained from systems where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined. The licensee listed the approximate coverages that were obtained for the welds. No reportable indications were noted by the licensee.
3.6.3 Relief Request 15A The licensee stated that due to the configuration and/or the presence of permanent attachments, essentially 100 percent ultrasonic examination coverage of the required examination volume could not be obtained. Pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii), the licensee seeks relief from performing the 100-percent volumetric examination requirements of the ASME Code. For the welds identified, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant. Additional weld preparation by welding or metal removal is a modification of the examination area requiring significant engineering and construction personnel support. Increased radiation exposure and cost would be incurred in order to perform these modifications.
For Category B-F, the Class 1 dissimilar metal piping welds have carbon steel nozzles buttered with stainless steel and field welded to forged stainless steel or cast stainless steel components with stainless steel weld material.
Radiography was considered impractical due to the amount of work being performed in the areas on a 24-hour basis. This would result in numerous work-related stoppages and increased exposure due to the shutdown and startup of other work in the areas.
The water must be drained from systems where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined. The licensee listed the approximate coverages that were obtained for the welds. No reportable indications were noted by the licensee.
3.7 Evaluation The ISI Code of record for Turkey Point Units 3 and 4 is the1989 Edition of the ASME Boiler and Pressure Vessel Code,Section XI. Table IWB-2500-1, Code Categories B-A, B-D, B-F, B-J, and Table IWC-2500-1, Code Categories C-A, C-B, C-F-1, and C-F-2 require a volumetric examination which includes 100 percent of the weld length, once during the 10-year interval. The examination volume is defined in Figures IWB-2500-3, 4, 7(d), 8, 10, 12, IWC-2500-1, 4(a), 7(a).
ASME Section XI, Table IWB-2500-1, Code Category B-G-1 requires 100 percent volumetric examination of the 1 inch annular volume of flange surrounding each reactor vessel stud, once during the 10-year interval. The examination volume is defined in Figure IWB-2500-12.
ASME Section XI, Table IWB-2500-1, Code Categories B-F, B-J, and Table IWC-2500-1 Code Categories C-B, C-F-1, and C-F-2 also require surface examination of the welds, in addition to the volumetric examination. The examination surface is defined in Figures IWB-2500-8, and 10, and Figures IWC-2500-4(a), and 7(a). All surface examinations were completed with no limitations. No recordable or reportable flaws were detected.
The staffs review of the data submitted for the subject welds regarding the inspection volumes found that obstructions to limit complete coverages were present by the design of the components. Specifically, either (1) the proximity of another component(s) limited access to the welds requiring examination or (2) the configuration of the component or weld crown limited movement and/or coupling of the ultrasonic transducer to the scanning surface. The coverage limitations and inspection results for each component are listed in the tables below.
Relief Request 1A limitations and results:
Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications (Yes/No) 3-WR-9 B-A/B1.21 IWB-2500-3 83% coverage Limited due to proximity of the instrumentation tubes No 4-WR-9 B-A/B1.21 IWB-2500-3 83% coverage Limited due to proximity of the instrumentation tubes No 3-WR-18 B-A/B1.30 IWB-2500-4 71% coverage Limited due to the key ways and irradiation slots No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications (Yes/No) 4-WR-18 B-A/B1.30 IWB-2500-4 71% coverage Limited due to the key ways and irradiation slots No 3-Lig-1 thru 58 B-G-1/B6.40 IWB-2500-12 84.67% coverage Reactor vessel o-ring sealing surface - Inadequate width for transducer.
No 4-Lig-1 thru 58 B-G-1/B6.40 IWB-2500-12 84.67% coverage Reactor vessel o-ring sealing surface - Inadequate width for transducer.
No Relief Request 14A limitations and results:
Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications (Yes/No)
Spray Nozzle-SP-03-1-IR B-D/B3.120 IWB-2500-7(d) 70% Coverage Configuration and raised letters welded in examination zone No 3-SRGN-01-IR B-D/B3.120 IWB-2500-7(d) 55% Coverage Pressurizer heaters penetrations No 3-SGA-I-IRS B-D/B3.140 IWB-2500-7(d) 70% Coverage Welded pads, supports, insulation pins, and Inner Radius configuration No 3-SGA-O-IRS B-D/B3.140 IWB-2500-7(d) 70% Coverage Welded pads, supports, insulation pins, and Inner Radius configuration No 3-SGB-I-IRS B-D/B3.140 IWB-2500-7(d) 70% Coverage Welded pads, supports, insulation pins, and Inner Radius configuration No 3-SGB-O-IRS B-D/B3.140 IWB-2500-7(d) 70% Coverage Welded pads, supports, insulation pins, and Inner Radius configuration No 3-SGC-I-IRS B-D/B3.140 IWB-2500-7(d) 70% Coverage Welded pads, supports, insulation pins, and Inner Radius configuration No 3-SGC-O-IRS B-D/B3.140 IWB-2500-7(d) 70% Coverage Welded pads, supports, insulation pins, and Inner Radius configuration No 29"-RCS-1305-4 B-F/B5.70 IWB-2500-8 43% from elbow side 2% from nozzle side Limited from elbow side due to weld crown. Limited from nozzle side due to taper on nozzle No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications (Yes/No) 29"-RCS-1308-4 B-F/B5.70 IWB-2500-8 47% from elbow side 0% from nozzle side Limited from elbow side due to weld crown. Limited from nozzle side due to taper on nozzle No 31"-RCS-1302-5 B-F/B5.70 IWB-2500-8 75% from elbow side 0% from nozzle side Limited from elbow side due to weld crown. Limited from nozzle side due to taper on nozzle No 31"-RCS-1303-5 B-F/B5.70 IWB-2500-8 62% from elbow side 0% from nozzle side Limited from elbow side due to weld crown. Limited from nozzle side due to taper on nozzle No 4"-RC-1304-18 B-J/B9.11 IWB-2500-8 82% coverage Limited due to radius on elbow and tee.
No 4"-RC-1304-20 B-J/B9.11 IWB-2500-8 82% coverage Limited on both sides due to tee radius.
No 4"-RC-1305-1 B-J/B9.11 IWB-2500-8 87% from Branch 81% from Elbow Limited due to branch connection and weld crown.
No 8"RHR-1301-3 B-J/B9.11 IWB-2500-8 100% from Elbow 39% from valve Limited on valve side due to taper.
No 8"-RHR-1304-8 B-J/B9.11 IWB-2500-8 67% from pipe 55% from Tee Limited from pipe side due to weld crown and tee side due to radius.
No 8"-RHR-1305-2A B-J/B9.11 IWB-2500-8 70% each side Limited due to weld crown.
No 8"-RHR-1305-3 B-J/B9.11 IWB-2500-8 67% from Pipe 99% from Tee Limited from pipe side due to weld crown and tee side due to radius.
No 10"-SI-1302-1 B-J/B9.11 IWB-2500-8 100% from Elbow 85% from Branch Limited from branch side due to taper.
No 10"-SI-1302-4 B-J/B9.11 IWB-2500-8 85% from Elbow 25% from Valve Limited from elbow side due to weld crown and valve side due to taper.
No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications (Yes/No) 10"-SI-1303-11 B-J/B9.11 IWB-2500-8 100% from Elbow 4% from Valve Limited from valve side due to taper.
No 10"-SI-1303-15 B-J/B9.11 IWB-2500-8 100% from Pipe 66% from Branch Limited from branch connection side due to taper.
No 12"-RCS-1301-1 B-J/B9.11 IWB-2500-8 100% from Pipe 67% from Branch Limited from branch connection side due to taper.
No 14"-RHR-1301-6 B-J/B9.11 IWB-2500-8 86% from Pipe 8% from Valve Limited from pipe side due to weld crown and valve side due to taper.
No 27.5"-RCS-1306-11 B-J/B9.11 IWB-2500-8 0% from Pump 100% from Pipe Limited on pump side due to taper.
No 27.5"-RCS-1309-11 B-J/B9.11 IWB-2500-8 0% from Pump 87% from Pipe Limited on pump side due to taper and pipe side due to weld crown.
No 29"-RCS-1305-3 B-J/B9.11 IWB-2500-8 93% from Pipe 69% from Elbow Limited from elbow side due to taper. Limited on pipe side due to 18" branch connection.
No 31"-RCS-1302-10 B-J/B9.11 IWB-2500-8 75% from Elbow 0% from Pump Limited from elbow due to weld crown and pump side due to taper.
No 31"-RCS-1303-10 B-J/B9.11 IWB-2500-8 56% from Elbow 0% from Pump Limited from elbow due to weld crown and pump side due to taper.
No 31"-RCS-1303-7 B-J/B9.11 IWB-2500-8 79% from Pipe 52% from Elbow Limited from pipe and elbow side due to weld crown.
No 27.5"-RCS-1306-4 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Piping Limited from main loop piping side due to taper.
No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications (Yes/No) 27,5"-RCS-1307-2 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Piping Limited from main loop piping side due to taper.
No 27.5-RCS-1309-3 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Piping Limited from main loop piping side due to taper.
No 29"-RCS-1305-BC3 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Piping Limited from main loop piping side due to taper.
No 29"-RCS-1308-BC-1 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Piping Limited from main loop piping side due to taper.
No 3-RHE-A2 C-A/C1.10 IWC-2500-1 71% from Shell 100% from Flange Limited from the shell and flange side due to support integral attachment, welded attachments and nozzle reinforcement plate.
No 3-RHE-A1 C-A/C1.20 IWC-2500-1 95% from Head 57% from Shell Limited from the head and shell side due to support integral attachment, welded attachments and nozzle reinforcement plate.
No 8"-SI-2303-1 C-F-1/C5.11 IWC-2500-7(a) 62% from Pipe 50% from Reducer Limited from pipe side due to weld crown and reducer side due to taper No 10"-SI-2304-3 C-F-1/C5.11 IWC-2500-7(a) 91% from Pipe 8% from Valve Limited from pipe side due to weld crown and valve side due to taper No 14"-RHR-2301-1 C-F-1/C5.11 IWC-2500-7(a) 84% from Valve 94% from Elbow Limited from valve side due to taper and elbow side due to weld crown.
No 3"-SI-2301-1 C-F-1/C5.21 IWC-2500-7(a) 100% from Elbow 0% from Flange Limited from flange side due to taper.
No 3"-SI-2301-4 C-F-1/C5.21 IWC-2500-7(a) 100% from Pipe 0% from Valve Limited from valve side due to taper.
No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications (Yes/No) 6"-BDC-2303-6 C-F-2/C5.51 IWC-2500-7(a) 0% from Valve 100% from Pipe Limited from valve side due to taper.
No 6"-BDA-2301-8 C-F-2/C5.51 IWC-2500-7(a) 100% from Pipe 50% from Wye Limited from wye side due to taper.
No Relief Request 15A limitations and results:
Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications 4-SGA-I-IRS B-D/B3.140 IWB-2500-7(d) 75% overage Limited by welded pads, supports, insulation pins, and inner radius configuration No 4-SGA-O-IRS B-D/B3.140 IWB-2500-7(d) 75% coverage Limited by welded pads, supports, insulation pins, and inner radius configuration No 4-SGB-I-IRS B-D/B3.140 IWB-2500-7(d) 75% coverage Limited by welded pads, supports, insulation pins, and inner radius configuration No 4-SGB-O-IRS B-D/B3.140 IWB-2500-7(d) 75% coverage Limited by welded pads, supports, insulation pins, and inner radius configuration No 4-SGC-I-IRS B-D/B3.140 IWB-2500-7(d) 75% coverage Limited by welded pads, supports, insulation pins, and inner radius configuration No 4-SGC-O-IRS B-D/B3.140 IWB-2500-7(d) 75% coverage Limited by welded pads, supports, insulation pins, and inner radius configuration No SP-04-1-IR B-D/B3.120 IWB-2500-7(d) 70% coverage Limited by configuration and raised letters welded in the examination zone.
No 4-SRGN-01-1R B-D/B3.120 IWB-2500-7(d) 55% coverage Limited by pressurizer heater penetrations No 12"-RC-1401-9 B-F/B5.70 IWB-2500-8 100% from Safe End 74% from Nozzle Limited from nozzle side due to taper.
No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications 29"-RCS-1404-4 B-F/B5.70 IWB-2500-8 74% from Elbow 0% from Nozzle Limited from elbow side due to weld crown and nozzle side due to taper.
No 29"-RCS-1405-4 B-F/B5.70 IWB-2500-8 53% from Elbow 10% from Nozzle Limited from elbow side due to weld crown and nozzle side due to taper.
No 31"-RCS-1401-5 B-F/B5.70 IWB-2500-8 0% from Nozzle 62% from Elbow Limited from elbow side due to weld crown and nozzle side due to taper.
No 31"-RCS-1402-5 B-F/B5.70 IWB-2500-8 8% from Nozzle 42% from Elbow Limited from elbow side due to weld crown and nozzle side due to taper.
No 8"-RHR-1401-6 B-J/B9.11 IWB-2500-8 20% from Valve 100% from Elbow Limited from valve side due to taper.
No 8"-RHR-1402-4 B-J/B9.11 IWB-2500-8 100% from Pipe 30% from Tee Limited from tee side due to taper.
No 8"-RHR-1402-7 B-J/B9.11 IWB-2500-8 60% from upstream Tee 20% from downstream Tee Limited from both sides of tee due to radius.
No 10"-SI-1401-14 B-J/B9.11 IWB-2500-8 26% from Valve 100% from Pipe Limited from valve side due to taper.
No 10"-SI-1401-18 B-J/B9.11 IWB-2500-8 100% from Elbow 18% from Branch Limited from branch connection side due to taper.
No 10"-SI-1402-1 B-J/B9.11 IWB-2500-8 100% from Elbow 26% from Valve Limited from valve side due to taper.
No 10"-SI-1402-13 B-J/B9.11 IWB-2500-8 100% from Pipe 23% from Valve Limited from valve side due to taper.
No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications 10"-SI-1402-17 B-J/B9.11 IWB-2500-8 100% from Elbow 23% from Branch Limited from branch connection side due to taper.
No 10"-SI-1402-4 B-J/B9.11 IWB-2500-8 100% from Elbow 11% from Tee Limited from tee side due to radius.
No 12"-RC-1401-1 B-J/B9.11 IWB-2500-8 36% from Branch 86% from Pipe Limited from branch connection and [Pipe] side due to taper.
No 14"-RHR-1401-1 B-J/B9.11 IWB-2500-8 70% from Branch 35% from Elbow Limited from branch connection and elbow side due to taper.
No 14"-RHR-1401-5 B-J/B9.11 IWB-2500-8 100% from Pipe 0% from Valve Limited from valve side due to taper.
No 14"-RHR-1401-6 B-J/B9.11 IWB-2500-8 0% from Valve 100% from Pipe Limited from valve side due to taper.
No 14"-RHR-1401-9 B-J/B9.11 IWB-2500-8 54% from Elbow 53% from Pipe Limited from pipe side and elbow side due to weld crown.
No 27.5"-RCS-1406-11 B-J/B9.11 IWB-2500-8 0% from Pump 100% from Pipe Limited from pump side due to taper.
No 27.5"-RCS-1407-11 B-J/B9.11 IWB-2500-8 18% from Pump 41% from Pipe Limited from pump side due to taper and pipe side due to instrumentation line.
No 31"-RCS-1401-10 B-J/B9.11 IWB-2500-8 57% from Elbow 0% from Pump Limited from elbow side due to weld crown and taper and pump side due to taper.
No 31"-RCS-1401-8 B-J/B9.11 IWB-2500-8 64% from Elbow 88% from Pipe Limited from elbow side due to taper and pipe side due to weld crown.
No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications 27.5"-RCS-1406-18 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Pipe Limited from main loop piping side due to taper.
No 27.5"-RCS-1407-20 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Pipe Limited from main loop piping side due to taper.
No 27.5"-RCS-1409-16 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Pipe Limited from main loop piping side due to taper.
No 27.5"-RCS-1409-17 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Pipe Limited from main loop piping side due to taper.
No 29"-RCS-1404-18 B-J/B9.31 IWB-2500-10 100% from Branch 0% from Pipe Limited from main loop piping side due to taper.
No 29"-RCS-1405-21 B-J/B9.31 IWB-2500-10 75% from Branch 0% from Piping Limited from branch and main loop piping due to taper.
No 4-RHE-A2 C-A/C1.10 IWC-2500-1 57% from Shell 0% from Flange Limited from shell and flange side due to support integral attachment, welded attachments and nozzle reinforcement plate.
No 4-RHE-A1 C-A/C1.20 IWC-2500-1 79% from Head 52% from Shell Limited from head and shell side due to support integral attachment, welded attachments and nozzle reinforcement plate.
No 4-RHE-A11
[C-B]/C2.21 IWC-2500-4(a) 99% from Nozzle 41% from Shell Limited form nozzle side due to taper and shell side due to weld crown.
No 8"-SI-2403-17 C-F-1/C5.11 IWC-2500-7(a) 100% from Pipe 0% from Valve Limited from valve side due to taper.
No 8"-SI-2404-2 C-F-1/C5.11 IWC-2500-7(a) 100% from Pipe 45% from Valve Limited from valve side due to taper.
No Component ID Exam Category/Item No.
Figure No.
Coverage Obtained Coverage Limitation Recordable Indications 8"-SI-2407-8 C-F-1/C5.11 IWC-2500-7(a) 75% from Tee 100% from Pipe Limited from tee side due to radius.
No 10"-SI-2407-4 C-F-1/C5.11 IWC-2500-7(a) 100% from Pipe 15% from Valve Limited from valve side due to taper.
No 10"-SI-2407-5 C-F-1/C5.11 IWC-2500-7(a) 35% from Valve 100% from Elbow Limited from valve side due to taper No 12"-RHR-2402-15 C-F-1/C5.11 IWC-2500-7(a) 27% from Pipe 70% from Flange Limited from pipe side due to weld crown and flange side due to taper.
No 14"-RHR-2403-1 C-F-1/C5.11 IWC-2500-7(a) 78% from upstream Tee 56% from downstream Tee Limited from both sides of the tee due to the radius.
No 14"-RHR-2403-2 C-F-1/C5.11 IWC-2500-7(a) 78% from Tee 100% from Pipe Limited from tee side due to the radius.
No 14"-RHR-2403-4 C-F-1/C5.11 IWC-2500-7(a) 36% from Elbow 73% from Valve Limited from elbow side due to weld crown and valve side due to taper.
No 3"-SI-2401-1 C-F-1/C5.21 IWC-2500-7(a) 0% Flange side 100% Elbow Side Limited from flange due to taper.
No The staff has determined that the information provided by the licensee supports the licensees conclusions that access to obtain Code required coverages would only be gained through modification of the components.
The dissimilar metal welds of Category B-F were not fabricated with the use of nickel alloys and are therefore not subject to the active degradation mechanism of primary water stress corrosion cracking.
As stated by the licensee in its supplemental letter dated July 14, 2006, there were no flaws or relevant indications adjacent to the areas that could not be examined. The staff concludes, from the information provided by the licensee, that the examination coverages obtained would have identified any pattern of degradation should one have developed, and that a change of component design would be necessary to obtain the increased coverages. Requiring the licensee to redesign the subject components in order to obtain the Code-required volumetric coverages is impractical and would result in a significant burden. Furthermore, significant degradation in the uninspected areas is not expected because there is no active degradation mechanism being identified in those components. Thus, examination coverages obtained by the licensee will provide reasonable assurance of the structural integrity of the affected components.
4.0 CONCLUSION
Based on the above discussion, the NRC staff concludes that compliance with the ASME Code coverage requirements is impractical for the configurations identified in the subject relief requests, and that compliance with the specified requirements would result in a significant burden on the licensee. The staff also concludes that the examination coverages obtained by the licensee will provide reasonable assurance of the structural integrity of the affected components. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for the third 10-year ISI interval at Turkey Point Unit 3, which began February 22, 1994, and ended February 21, 2005, and for the third 10-year ISI interval at Turkey Point Unit 4, which began April 15, 1994, and ended April 14, 2005.
This grant of relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Timothy Lupold Date:
Mr. J. A. Stall TURKEY POINT PLANT Florida Power and Light Company cc:
Mr. William E. Webster Vice President, Nuclear Operations Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW.
Suite 220 Washington, DC 20004 T. O. Jones, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 County Manager Miami-Dade County 111 Northwest 1 Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission 9762 SW. 344th Street Florida City, Florida 33035 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Michael O. Pearce Plant General Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 James Connolly, Licensing Manager Florida Power and Light Company Turkey Point Nuclear Plant 9760 SW 344th Street Florida City, FL 33035 Becky Ferrare Licensing Department Administrator Turkey Point Nuclear Plant 9760 SW 344th Street Florida City, FL 33035 Mark Warner, Vice President Nuclear Operations Support Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420