ML063420372

SE for Relief Requests 1A, 14A and 15A Associated with Volumetric Coverage of Weld Examinations

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 JMartin DPickett by memo dated NLO w/edits 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 Item No. Component Examination Requirement Category B-A B1.21 3-WR-9; Essentially 100% volumetric examination of all 4-WR-9 circumferential head welds.

B-A B1.30 3-WR-18; Essentially 100% volumetric examination of the shell to 4-WR-18 flange weld.

B-G-1 B6.40 3-Lig-1 thru 58; 4- Essentially 100% volumetric examination of the 1 inch Lig-1 thru 58 annular volume of flange surrounding each stud hole Relief Request 14A requests relief from the requirements listed below:

Examination Item No. Component Examination Requirement Category B-D B3.120 Spray Nozzle-SP-03-1-IR Essentially 100% volumetric examination of the 3-SRGN-01-IR nozzle inner radius section 3-SGA-I-IRS B3.140 3-SGA-O-IRS 3-SGB-I-IRS 3-SGB-O-IRS 3-SGC-I-IRS 3-SGC-O-IRS B-F B5.70 29"-RCS-1305-4 Essentially 100% volumetric and surface 29"-RCS-1308-4 examination of nozzle to safe end butt welds NPS 31"-RCS-1302-5 4 or larger 31"-RCS-1303-5 B-J B9.11 4"-RC-1304-18 Essentially 100% volumetric and surface 4"-RC-1304-20 examination of circumferential welds NPS 4 or 4"-RC-1305-1 larger 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 B-J B9.31 27.5"-RCS-1306-4 27.5"- Essentially 100% volumetric and surface RCS-1307-2 examination of branch pipe connection welds 27.5-RCS-1309-3 NPS 4 or larger 29"-RCS-1305-BC3 29"-RCS-1308-BC-1

Examination Item No. Component Examination Requirement Category C-A C1.10 3-RHE-A2 Essentially 100% volumetric examination of the C1.20 3-RHE-A1 shell circumferential welds C-F-1 C5.11 8"-SI-2303-1 Essentially 100% volumetric and surface 10"-SI-2304-3 examination of circumferential piping welds $3/8" 14"-RHR-2301-1 nominal wall thickness for piping > NPS 4 C-F-1 C5.21 3"-SI-2301-1 Essentially 100% volumetric and surface 3"-SI-2301-4 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 Essentially 100% volumetric and surface 6"-BDA-2301-8 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 Item No. Component Examination Requirement Category B-D B3.140 4-SGA-I-IRS Essentially 100% volumetric examination of the 4-SGA-O-IRS nozzle inner radius section 4-SGB-I-IRS 4-SGB-O-IRS 4-SGC-I-IRS 4-SGC-O-IRS B3.120 SP-04-1-IR 4-SRGN-01-1R B-F B5.70 12"-RC-1401-9 Essentially 100% volumetric and surface 29"-RCS-1404-4 examination of nozzle to safe end butt welds NPS 29"-RCS-1405-4 4 or larger 31"-RCS-1401-5 31"-RCS-1402-5 B-J B9.11 8"-RHR-1401-6 Essentially 100% volumetric and surface 8"-RHR-1402-4 examination of circumferential welds NPS 4 or 8"-RHR-1402-7 larger 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

Examination Item No. Component Examination Requirement Category B-J B9.31 27.5"-RCS-1406-18 Essentially 100% volumetric and surface 27.5"-RCS-1407-20 examination of branch pipe connection welds NPS 27.5"-RCS-1409-16 4 or larger 27.5"-RCS-1409-17 29"-RCS-1404-18 29"-RCS-1405-21 C-A C1.10 4-RHE-A2 Essentially 100% volumetric examination of the C1.20 4-RHE-A1 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 Essentially 100% volumetric and surface 8"-SI-2404-2 examination of circumferential piping welds $3/8" 8"-SI-2407-8 nominal wall thickness for piping > NPS 4 10"-SI-2407-4 10"-SI-2407-5 12"-RHR-2402-15 14"-RHR-2403-1 14"-RHR-2403-2 14"-RHR-2403-4 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. Coverage Limitation Recordable Figure No. Indications Coverage Obtained (Yes/No) 3-WR-9 B-A/B1.21 Limited due to proximity of the No IWB-2500-3 instrumentation tubes 83% coverage 4-WR-9 B-A/B1.21 Limited due to proximity of the No IWB-2500-3 instrumentation tubes 83% coverage 3-WR-18 B-A/B1.30 Limited due to the key ways and No IWB-2500-4 irradiation slots 71% coverage

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained (Yes/No) 4-WR-18 B-A/B1.30 Limited due to the key ways and No IWB-2500-4 irradiation slots 71% coverage 3-Lig-1 thru 58 B-G-1/B6.40 Reactor vessel o-ring sealing No IWB-2500-12 surface - Inadequate width for 84.67% coverage transducer.

4-Lig-1 thru 58 B-G-1/B6.40 Reactor vessel o-ring sealing No IWB-2500-12 surface - Inadequate width for 84.67% coverage transducer.

Relief Request 14A limitations and results:

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained (Yes/No)

Spray Nozzle- B-D/B3.120 Configuration and raised letters No SP-03-1-IR IWB-2500-7(d) welded in examination zone 70% Coverage 3-SRGN-01-IR B-D/B3.120 Pressurizer heaters penetrations No IWB-2500-7(d) 55% Coverage 3-SGA-I-IRS B-D/B3.140 Welded pads, supports, No IWB-2500-7(d) insulation pins, and Inner Radius 70% Coverage configuration 3-SGA-O-IRS B-D/B3.140 Welded pads, supports, No IWB-2500-7(d) insulation pins, and Inner Radius 70% Coverage configuration 3-SGB-I-IRS B-D/B3.140 Welded pads, supports, No IWB-2500-7(d) insulation pins, and Inner Radius 70% Coverage configuration 3-SGB-O-IRS B-D/B3.140 Welded pads, supports, No IWB-2500-7(d) insulation pins, and Inner Radius 70% Coverage configuration 3-SGC-I-IRS B-D/B3.140 Welded pads, supports, No IWB-2500-7(d) insulation pins, and Inner Radius 70% Coverage configuration 3-SGC-O-IRS B-D/B3.140 Welded pads, supports, No IWB-2500-7(d) insulation pins, and Inner Radius 70% Coverage configuration 29"-RCS-1305-4 B-F/B5.70 Limited from elbow side due to No IWB-2500-8 weld crown. Limited from nozzle 43% from elbow side side due to taper on nozzle 2% from nozzle side

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained (Yes/No) 29"-RCS-1308-4 B-F/B5.70 Limited from elbow side due to No IWB-2500-8 weld crown. Limited from nozzle 47% from elbow side side due to taper on nozzle 0% from nozzle side 31"-RCS-1302-5 B-F/B5.70 Limited from elbow side due to No IWB-2500-8 weld crown. Limited from nozzle 75% from elbow side side due to taper on nozzle 0% from nozzle side 31"-RCS-1303-5 B-F/B5.70 Limited from elbow side due to No IWB-2500-8 weld crown. Limited from nozzle 62% from elbow side side due to taper on nozzle 0% from nozzle side 4"-RC-1304-18 B-J/B9.11 Limited due to radius on elbow No IWB-2500-8 and tee.

82% coverage 4"-RC-1304-20 B-J/B9.11 Limited on both sides due to tee No IWB-2500-8 radius.

82% coverage 4"-RC-1305-1 B-J/B9.11 Limited due to branch connection No IWB-2500-8 and weld crown.

87% from Branch 81% from Elbow 8"RHR-1301-3 B-J/B9.11 Limited on valve side due to No IWB-2500-8 taper.

100% from Elbow 39% from valve 8"-RHR-1304-8 B-J/B9.11 Limited from pipe side due to No IWB-2500-8 weld crown and tee side due to 67% from pipe radius.

55% from Tee 8"-RHR-1305-2A B-J/B9.11 Limited due to weld crown. No IWB-2500-8 70% each side 8"-RHR-1305-3 B-J/B9.11 Limited from pipe side due to No IWB-2500-8 weld crown and tee side due to 67% from Pipe radius.

99% from Tee 10"-SI-1302-1 B-J/B9.11 Limited from branch side due to No IWB-2500-8 taper.

100% from Elbow 85% from Branch 10"-SI-1302-4 B-J/B9.11 Limited from elbow side due to No IWB-2500-8 weld crown and valve side due to 85% from Elbow taper.

25% from Valve

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained (Yes/No) 10"-SI-1303-11 B-J/B9.11 Limited from valve side due to No IWB-2500-8 taper.

100% from Elbow 4% from Valve 10"-SI-1303-15 B-J/B9.11 Limited from branch connection No IWB-2500-8 side due to taper.

100% from Pipe 66% from Branch 12"-RCS-1301-1 B-J/B9.11 Limited from branch connection No IWB-2500-8 side due to taper.

100% from Pipe 67% from Branch 14"-RHR-1301-6 B-J/B9.11 Limited from pipe side due to No IWB-2500-8 weld crown and valve side due to 86% from Pipe taper.

8% from Valve 27.5"-RCS-1306-11 B-J/B9.11 Limited on pump side due to No IWB-2500-8 taper.

0% from Pump 100% from Pipe 27.5"-RCS-1309-11 B-J/B9.11 Limited on pump side due to No IWB-2500-8 taper and pipe side due to weld 0% from Pump crown.

87% from Pipe 29"-RCS-1305-3 B-J/B9.11 Limited from elbow side due to No IWB-2500-8 taper. Limited on pipe side due 93% from Pipe to 18" branch connection.

69% from Elbow 31"-RCS-1302-10 B-J/B9.11 Limited from elbow due to weld No IWB-2500-8 crown and pump side due to 75% from Elbow taper.

0% from Pump 31"-RCS-1303-10 B-J/B9.11 Limited from elbow due to weld No IWB-2500-8 crown and pump side due to 56% from Elbow taper.

0% from Pump 31"-RCS-1303-7 B-J/B9.11 Limited from pipe and elbow side No IWB-2500-8 due to weld crown.

79% from Pipe 52% from Elbow 27.5"-RCS-1306-4 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Piping

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained (Yes/No) 27,5"-RCS-1307-2 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Piping 27.5-RCS-1309-3 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Piping 29"-RCS-1305-BC3 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Piping 29"-RCS-1308-BC-1 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Piping 3-RHE-A2 C-A/C1.10 Limited from the shell and flange No IWC-2500-1 side due to support integral 71% from Shell attachment, welded attachments 100% from Flange and nozzle reinforcement plate.

3-RHE-A1 C-A/C1.20 Limited from the head and shell No IWC-2500-1 side due to support integral 95% from Head attachment, welded attachments 57% from Shell and nozzle reinforcement plate.

8"-SI-2303-1 C-F-1/C5.11 Limited from pipe side due to No IWC-2500-7(a) weld crown and reducer side due 62% from Pipe to taper 50% from Reducer 10"-SI-2304-3 C-F-1/C5.11 Limited from pipe side due to No IWC-2500-7(a) weld crown and valve side due to 91% from Pipe taper 8% from Valve 14"-RHR-2301-1 C-F-1/C5.11 Limited from valve side due to No IWC-2500-7(a) taper and elbow side due to weld 84% from Valve crown.

94% from Elbow 3"-SI-2301-1 C-F-1/C5.21 Limited from flange side due to No IWC-2500-7(a) taper.

100% from Elbow 0% from Flange 3"-SI-2301-4 C-F-1/C5.21 Limited from valve side due to No IWC-2500-7(a) taper.

100% from Pipe 0% from Valve

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained (Yes/No) 6"-BDC-2303-6 C-F-2/C5.51 Limited from valve side due to No IWC-2500-7(a) taper.

0% from Valve 100% from Pipe 6"-BDA-2301-8 C-F-2/C5.51 Limited from wye side due to No IWC-2500-7(a) taper.

100% from Pipe 50% from Wye Relief Request 15A limitations and results:

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained 4-SGA-I-IRS B-D/B3.140 Limited by welded pads, No IWB-2500-7(d) supports, insulation pins, and 75% overage inner radius configuration 4-SGA-O-IRS B-D/B3.140 Limited by welded pads, No IWB-2500-7(d) supports, insulation pins, and 75% coverage inner radius configuration 4-SGB-I-IRS B-D/B3.140 Limited by welded pads, No IWB-2500-7(d) supports, insulation pins, and 75% coverage inner radius configuration 4-SGB-O-IRS B-D/B3.140 Limited by welded pads, No IWB-2500-7(d) supports, insulation pins, and 75% coverage inner radius configuration 4-SGC-I-IRS B-D/B3.140 Limited by welded pads, No IWB-2500-7(d) supports, insulation pins, and 75% coverage inner radius configuration 4-SGC-O-IRS B-D/B3.140 Limited by welded pads, No IWB-2500-7(d) supports, insulation pins, and 75% coverage inner radius configuration SP-04-1-IR B-D/B3.120 Limited by configuration and No IWB-2500-7(d) raised letters welded in the 70% coverage examination zone.

4-SRGN-01-1R B-D/B3.120 Limited by pressurizer heater No IWB-2500-7(d) penetrations 55% coverage 12"-RC-1401-9 B-F/B5.70 Limited from nozzle side due to No IWB-2500-8 taper.

100% from Safe End 74% from Nozzle

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained 29"-RCS-1404-4 B-F/B5.70 Limited from elbow side due to No IWB-2500-8 weld crown and nozzle side due 74% from Elbow to taper.

0% from Nozzle 29"-RCS-1405-4 B-F/B5.70 Limited from elbow side No IWB-2500-8 due to weld crown and nozzle 53% from Elbow side due to taper.

10% from Nozzle 31"-RCS-1401-5 B-F/B5.70 Limited from elbow side due to No IWB-2500-8 weld crown and nozzle side due 0% from Nozzle to taper.

62% from Elbow 31"-RCS-1402-5 B-F/B5.70 Limited from elbow side due to No IWB-2500-8 weld crown and nozzle side due 8% from Nozzle to taper.

42% from Elbow 8"-RHR-1401-6 B-J/B9.11 Limited from valve side due to No IWB-2500-8 taper.

20% from Valve 100% from Elbow 8"-RHR-1402-4 B-J/B9.11 Limited from tee side due to No IWB-2500-8 taper.

100% from Pipe 30% from Tee 8"-RHR-1402-7 B-J/B9.11 Limited from both sides of tee No IWB-2500-8 due to radius.

60% from upstream Tee 20% from downstream Tee 10"-SI-1401-14 B-J/B9.11 Limited from valve side due to No IWB-2500-8 taper.

26% from Valve 100% from Pipe 10"-SI-1401-18 B-J/B9.11 Limited from branch connection No IWB-2500-8 side due to taper.

100% from Elbow 18% from Branch 10"-SI-1402-1 B-J/B9.11 Limited from valve side due to No IWB-2500-8 taper.

100% from Elbow 26% from Valve 10"-SI-1402-13 B-J/B9.11 Limited from valve side due to No IWB-2500-8 taper.

100% from Pipe 23% from Valve

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained 10"-SI-1402-17 B-J/B9.11 Limited from branch connection No IWB-2500-8 side due to taper.

100% from Elbow 23% from Branch 10"-SI-1402-4 B-J/B9.11 Limited from tee side due to No IWB-2500-8 radius.

100% from Elbow 11% from Tee 12"-RC-1401-1 B-J/B9.11 Limited from branch connection No IWB-2500-8 and [Pipe] side due to taper.

36% from Branch 86% from Pipe 14"-RHR-1401-1 B-J/B9.11 Limited from branch connection No IWB-2500-8 and elbow side due to taper.

70% from Branch 35% from Elbow 14"-RHR-1401-5 B-J/B9.11 Limited from valve side due to No IWB-2500-8 taper.

100% from Pipe 0% from Valve 14"-RHR-1401-6 B-J/B9.11 Limited from valve side due to No IWB-2500-8 taper.

0% from Valve 100% from Pipe 14"-RHR-1401-9 B-J/B9.11 Limited from pipe side and elbow No IWB-2500-8 side due to weld crown.

54% from Elbow 53% from Pipe 27.5"-RCS-1406-11 B-J/B9.11 Limited from pump side due to No IWB-2500-8 taper.

0% from Pump 100% from Pipe 27.5"-RCS-1407-11 B-J/B9.11 Limited from pump side due to No IWB-2500-8 taper and pipe side due to 18% from Pump instrumentation line.

41% from Pipe 31"-RCS-1401-10 B-J/B9.11 Limited from elbow side due to No IWB-2500-8 weld crown and taper and pump 57% from Elbow side due to taper.

0% from Pump 31"-RCS-1401-8 B-J/B9.11 Limited from elbow side due to No IWB-2500-8 taper and pipe side due to weld 64% from Elbow crown.

88% from Pipe

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained 27.5"-RCS-1406-18 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Pipe 27.5"-RCS-1407-20 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Pipe 27.5"-RCS-1409-16 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Pipe 27.5"-RCS-1409-17 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Pipe 29"-RCS-1404-18 B-J/B9.31 Limited from main loop piping No IWB-2500-10 side due to taper.

100% from Branch 0% from Pipe 29"-RCS-1405-21 B-J/B9.31 Limited from branch and main No IWB-2500-10 loop piping due to taper.

75% from Branch 0% from Piping 4-RHE-A2 C-A/C1.10 Limited from shell and flange side No IWC-2500-1 due to support integral 57% from Shell attachment, welded attachments 0% from Flange and nozzle reinforcement plate.

4-RHE-A1 C-A/C1.20 Limited from head and shell side No IWC-2500-1 due to support integral 79% from Head attachment, welded attachments 52% from Shell and nozzle reinforcement plate.

4-RHE-A11 [C-B]/C2.21 Limited form nozzle side due to No IWC-2500-4(a) taper and shell side due to weld 99% from Nozzle crown.

41% from Shell 8"-SI-2403-17 C-F-1/C5.11 Limited from valve side due to No IWC-2500-7(a) taper.

100% from Pipe 0% from Valve 8"-SI-2404-2 C-F-1/C5.11 Limited from valve side due to No IWC-2500-7(a) taper.

100% from Pipe 45% from Valve

Component ID Exam Category/Item No. Coverage Limitation Recordable Figure No. Indications Coverage Obtained 8"-SI-2407-8 C-F-1/C5.11 Limited from tee side due to No IWC-2500-7(a) radius.

75% from Tee 100% from Pipe 10"-SI-2407-4 C-F-1/C5.11 Limited from valve side due to No IWC-2500-7(a) taper.

100% from Pipe 15% from Valve 10"-SI-2407-5 C-F-1/C5.11 Limited from valve side due to No IWC-2500-7(a) taper 35% from Valve 100% from Elbow 12"-RHR-2402-15 C-F-1/C5.11 Limited from pipe side due to No IWC-2500-7(a) weld crown and flange side due 27% from Pipe to taper.

70% from Flange 14"-RHR-2403-1 C-F-1/C5.11 Limited from both sides of the tee No IWC-2500-7(a) due to the radius.

78% from upstream Tee 56% from downstream Tee 14"-RHR-2403-2 C-F-1/C5.11 Limited from tee side due to the No IWC-2500-7(a) radius.

78% from Tee 100% from Pipe 14"-RHR-2403-4 C-F-1/C5.11 Limited from elbow side due to No IWC-2500-7(a) weld crown and valve side due to 36% from Elbow taper.

73% from Valve C-F-1/C5.21 Limited from flange due to taper. No 3"-SI-2401-1 IWC-2500-7(a) 0% Flange side 100% Elbow Side 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 Attorney General Vice President, Nuclear Operations Department of Legal Affairs Florida Power & Light Company The Capitol P.O. Box 14000 Tallahassee, Florida 32304 Juno Beach, FL 33408-0420 Michael O. Pearce M. S. Ross, Managing Attorney Plant General Manager Florida Power & Light Company Turkey Point Nuclear Plant P.O. Box 14000 Florida Power and Light Company Juno Beach, FL 33408-0420 9760 SW. 344th Street Florida City, FL 33035 Marjan Mashhadi, Senior Attorney Florida Power & Light Company James Connolly, Licensing Manager 801 Pennsylvania Avenue, NW. Florida Power and Light Company Suite 220 Turkey Point Nuclear Plant Washington, DC 20004 9760 SW 344th Street Florida City, FL 33035 T. O. Jones, Site Vice President Turkey Point Nuclear Plant Becky Ferrare Florida Power and Light Company Licensing Department Administrator 9760 SW. 344th Street Turkey Point Nuclear Plant Florida City, FL 33035 9760 SW 344th Street Florida City, FL 33035 County Manager Miami-Dade County Mark Warner, Vice President 111 Northwest 1 Street, 29th Floor Nuclear Operations Support Miami, Florida 33128 Florida Power and Light Company P.O. Box 14000 Senior Resident Inspector Juno Beach, FL 33408-0420 Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission Mr. Rajiv S. Kundalkar 9762 SW. 344th Street Vice President - Nuclear Engineering Florida City, Florida 33035 Florida Power & Light Company P.O. Box 14000 Mr. William A. Passetti, Chief Juno Beach, FL 33408-0420 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