Text

Closeout of the Fourth Ten-Year Inservice Inspection (ISI) Interval Relief Requests Nos. 15, 16, 17
	ML15062A279
Person / Time
Site:	Turkey Point
Issue date:	02/13/2015
From:	Kiley M; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2015-020
	Download: ML15062A279 (85)
	v • d • e

FPL.

February 13, 2015 L-2015-020 10 CFR 50.55a U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 RE: Florida Power and Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Closeout of the Fourth Ten-Year Inservice Inspection (ISI) Interval Relief Requests Nos. 15, 16, 17 In accordance with 10 CFR 50.55a(g)(6), Florida Power & Light Company (FPL) hereby requests approval of the attached Relief Requests 15, 16, and 17 as part of the closeout of the Fourth Ten-year Inservice Inspection (ISI) Interval Program for Turkey Point Units 3 and 4.

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components, Section Xl, 1998 Edition with Addenda through 2000 as amended by 10CFR50.55a, is the code of record for the Turkey Point Units 3 and 4 Fourth Ten-Year Inservice Inspection Interval.

Due to the configuration of the Reactor Vessel, it is impractical to meet the examination coverage requirements of the ASME Code, Section Xl, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460. ASME Code Category B-A weld and B-G-1 flange ligament surface are addressed in Relief Request No. 15. This relief is requested for both Turkey Point Units 3 and 4 and it is provided in Attachment 1.

Additionally, due to the configuration of the ASME Code Category B-A, C-A, C-B, C-F-1 and R-A welds, it is not possible to meet the examination coverage requirements of the ASME Code, Section Xl, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460. As such, Relief Requests No. 16 and No. 17 are requested for Turkey Point Unit 3 and Turkey Point Unit 4, respectively. These reliefs are provided in Attachments 2 and 3, respectively.

The attached reliefs are requested on the basis of Inservice Inspection impracticality. FPL has determined that the examinations addressed in the Relief Requests 15, 16, and 17 were performed to the extent possible. As discussed in the attachments, the use of the proposed alternative examinations for each of these reliefs provides assurance of an acceptable level of quality and safety.

Florida Power & Light Company 9760 S.W. 344 Street Homestead, FL 33035

L-2015-020 Page 2 of 2 If you have any questions or require additional information, please contact Mr. Mitch Guth, Licensing Manager, at (305) 246-6698.

Sincerely, x3. -CTT Michael Kiley - - .

Site Vice President Turkey Point Nuclear Plant Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant

L-2015-020, Attachment 1 L-2015-020 ATTACHMENT 1 TURKEY POINT UNITS 3 AND 4 RELIEF REQUEST No. 15

Page 1 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 Relief Request In Accordance with 10 CFR 50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1. ASME Code Component(s) Affected Class 1 pressure retaining welds in the reactor pressure vessel (RPV).

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 the ASME Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components" as modified by 10CFR50.55a.

The 1998 Edition with Addenda through 2000 was utilized for ASME Section XI, Appendix VIII.

3. Applicable Code Requirement

Exam Item No. Examination Requirements Cat.

B-A B1.11 Essentially 100% volumetric examination of all circumferential shell welds.

B-A B1.30 Essentially flange weld.100% volumetric examination of the shell to B-G-1 B6.40 Essentially 100% volumetric examination of the 1 inch annular surface of flange surrounding each stud hole.

As defined by 10CFR50.55a(g)(6)(ii)(A)(2) and ASME Code Case N-460, essentially 100% means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.

4. Impracticality of Compliance Due to the configuration of the Reactor Vessel, it is impractical to meet the examination coverage requirements of the ASME Code,Section XI, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460. Relief is requested in accordance with 10 CFR 50.55a(g)(5)(iii). These areas were found during the 4 th 10-year inservice inspection interval.

When examined, the welds listed within this request did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments. These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume, but 100% of the accessible welds were covered. The volumetric coverage obtained and angle(s)/mode(s) used for

Page 2 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 the inner 15% T and outer 85% T is provided in Table 1.

Described below, coupled with figures, are details of the examination limitations by weld description. Figure 1 provides an illustration of the contact UT head used for scanning from the vessel shell. Figures 2 through 8 provide the dimensions and locations of obstructions and views of each of the affected welds showing the interference caused by the permanent attachments on the Trans World System (TWS) robot and the effect of the obstructions on scanning. Figure 6 provides the dimensions and locations of obstructions and views for the Flange Ligament examination.

RPV Lower Shell to Lower Head Ring Weld (3-WR-31 and 4-WR-31)

Examination Category B-A, Item B11.11 The mechanized scanning of the lower shell to lower head ring welds 3-WR-31 and 4-WR-31 are limited due to interference from the core support lugs. Figure 2 and 3 provides an illustration of the weld volume limitation due to the instrumentation tubes The examination of the Figure IWB-2500-1 A-B-C-D volume is limited due to the proximity of the instrumentation tubes. Access to approximately 15% of the examination volume is restricted. The remaining 85% of the examination volume was examined with techniques which have been qualified by demonstration in accordance with ASME Section Xl, Appendix VIII, Supplements 4 and 6 of the 1998 Edition with Addenda through Section Xl, using the Performance Demonstration Initiative Protocol. This weld was examined from both sides of the weld, scanning both parallel and perpendicular. For unit 3, ultrasonic examination revealed no indications and for unit 4, ultrasonic examination revealed four acceptable small fabrication flaws in the weld. All recorded indications were characterized as subsurface in accordance with the ASME Code Section Xl, 1998 Edition up to and including the 2000 Addenda.

RPV Upper Shell-to-Flange Weld (3-WR-1 8 and 4-WR-1 8)

Examination Category B-A, Item B13.30 The upper shell-to-flange weld 3-WR-18 and 4-WR-18 is examined from the shell side and from the flange seal surface. The examination performed from the flange seal surface was not limited by configuration. Figure 4, 5 & 6 shows the inside surface scan limitations and the location of the areas of incomplete coverage to the mechanized scanning due to the presence of the keyways and Irradiation slots.

The examination of the Figure IWB-2500-4 A-B-C-D volume is limited due to the Keyways and Irradiation Slots. Access to approximately 25% of the examination volume is restricted. The remaining 75% of the examination volume was examined with ASME Code acceptable techniques. Additionally, the mechanized techniques employed for examination from the RPV inside surface have also been qualified by demonstration in accordance with ASME Section Xl, Appendix

Page 3 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 VIII, Supplements 4 and 6 of the 1998 Edition with Addenda through Section Xl, using the Performance Demonstration Initiative Protocol. This weld was examined from both sides of the weld, scanning both parallel and perpendicular.

For unit 3, ultrasonic examination revealed three acceptable small fabrication flaws and for unit 4, ultrasonic examination revealed twelve acceptable small fabrication flaws in the weld. All recorded indications were characterized as subsurface in accordance with the ASME Code Section Xl, 1998 Edition up to and including the 2000 Addenda.

RPV Threads in Flange (3-Lig-1 thru 58 and 4-Lig-1 thru 58)

Examination Category B-G-1, Item B6.40 The manual scanning of the 1 inch annulus surface around the RPV flange stud hole 3-Lig 1 thru 58 and 4-Lig 1 thru 58 is performed from the RPV flange surface. Figure 8 provides an illustration of the RPV flange surface limitation due to interference from the sealing surface configuration. There is a step-down groove on the flange surface where the 0-ring fits. This causes an unparallel surface to perform the 0-degree examination.

The examination of the Figure IWB-2500-12 A-B-C-D-E-F-G-H volume is limited when scanning the carbon steel base material surrounding the stud holes due to the sealing surfaces configuration. Access to approximately 15.33% of the examination volume is restricted. The remaining 84.67% of the examination volume was examined with ASME Code acceptable techniques. The ultrasonic examination did not reveal any recordable or reportable flaws in accordance with the ASME Code Section Xl, 1998 Edition up to and including the 2000 Addenda.

5. Burden Caused by Compliance It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments. Examinations are performed to the maximum extent possible. The Ultrasonic (UT) techniques for each weld or surface were reviewed to determine if additional coverage could be achieved. For the welds or surfaces listed above, it was not possible to remove the obstruction without significant work, increased radiation exposure, and/or damage to the plant.

6. Proposed Alternative and Basis for Use Proposed Alternative

1) Periodic system pressure tests in accordance with ASME Section Xl Category B-P, Table IWB-2500-1.

2) Conduct ultrasonic examinations to the maximum extent possible.

Page 4 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 Basis FPL performed inservice examinations of selected welds and surfaces in accordance with the requirements of 10CFR50.55a, plant technical specifications, and the 1998 Edition up to and including the 2000 Addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

FPL performed mechanized ultrasonic examinations of the reactor vessel during the Unit 3, March 2014 and Unit 4, September 2014 refueling outage.

10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.

FPL performed the examinations to the extent possible. There is no plant-specific, NextEra fleet or industry operating experience regarding potential degradation specific to the subject welds included in this relief request.

Leakage monitoring inside containment at Turkey Point Unit 4 is provided by the reactor cavity (containment) sump inlet flow monitoring system. This system has high level and alert status alarms in the control room. This system has Tech Spec required monitoring (TS 3/4.4.6.2.1(b)) at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

By letter dated November 13, 2012, FPL submitted relief request #10 to the U.S. Nuclear Regulatory Commission (NRC). The purpose of the relief request was to obtain permission to implement an alternative from certain provisions of the ASME Code,Section XI, 1998 Edition up to and including the 2000 Addenda, contained in the 4 th 10-year interval inservice inspection (ISI) program. FPL proposes to use procedures, personnel, and equipment qualified to the requirements of ASME Section XI, Appendix VIII, Supplements 4 and 6 of the 1998 Edition with Addenda through 2000, as administered by the Electric Power Research Institute's (EPRI) Performance Demonstration Initiatives (PDI) program to conduct the reactor vessel upper shell-to-flange weld examination. The examinations from the inside surface will be implemented to achieve the maximum coverage possible utilizing procedures and personnel qualified by the PDI Program. The proposed alternative represents the best techniques, procedures, and qualifications available to perform UT examinations of RPV welds. The PDI Program addresses qualification requirements for each of the supplements that are defined in ASME Section XI, Appendix VIII. The applicable vendor procedure has been qualified in accordance with PDI's implementation of Supplements 4 and 6 of ASME Section XI, Appendix VIII. The NRC authorized the proposed alternative by letter dated November 29, 2013 (TAC NO. MF0086 and MF0087). The accessible areas of the shell weld were examined with personnel, equipment and procedures that were qualified by demonstration in accordance with Supplements 4 and 6 of the 1998 Edition up to and

Page 5 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 including the 2000 Addenda of the ASME Code, Section Xl, Appendix VIII, using the Performance Demonstration Initiative (PDI) protocol. These examinations were performed from both sides of the welds, scanning both parallel and perpendicular to the weld to the maximum extent possible. The examinations performed utilizing demonstrated and qualified techniques provided an equivalent or better examination than the requirements of ASME Section Xl, 1998 Edition up to and including the 2000 Addenda.

FPL performed ultrasonic examinations of the remaining reactor vessel welds in accordance with the requirements of 10 CFR 50.55a, plant technical specifications, and the 1998 Edition up to and including the 2000, of ASME Section Xl to the maximum extent possible. Additionally, the mechanized techniques employed for examination from the RPV inside surface have been demonstrated in accordance with Supplements 4 & 6 of the 1998 Edition up to and including the 2000 of the ASME Code Section Xl, Appendix VIII, using the Performance Demonstration Initiative Protocol. The Ultrasonic (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved. Access for examination of the affected welds from the outside of the reactor vessel is not possible. Access and permanently installed attachments inside the reactor vessel limit additional scanning of the welds included in this request for relief.

In addition to the required ultrasonic examination, the interior of the reactor vessel, including welded attachments, received a visual examination in accordance with Table IWB-2500-1, Examination Categories B-N-l, B-N-2 and B-N-3. The visual examinations revealed no relevant indications.

The subject welds were examined in the fourth interval during the 10-year reactor vessel examination. All flaws identified in the welds were characterized as subsurface fabrication flaws in the weld.

The extent of examination volume achieved ultrasonically, the alternate scans performed, and the system pressure tests provide assurance of an acceptable level of quality and safety.

7. Duration of Proposed Alternative This relief request is applicable to the Turkey Point unit 3 Fourth Inservice Inspection Interval which began February 22, 2004 and ended February 21, 2014 and the unit 4 Fourth Inservice Inspection Interval which began April 15, 2004 and ended April 14, 2014.

8. References 1 OCFR50.55a ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components,"

1998 Edition with Addenda through 2000 ASME Section Xl, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds, Section Xl, Division 1"

Page 6 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 TABLE I CATEGORY B-A Angle(s)/

ASME Code Component Applicable Code Wave ComponentID Requirement and Mode Impracticality of Component ID Weld Volume Coverage Inner Outer Compliance Obtained 15% T 85% T RPV Lower Shell to 3-WR-31 Exam Category B-A 45L 45L Inservice examination limited due Lower Head Ring 4-WR-31 Item No. B1.11 70L 45S to the core support lugs Weld 85% volume coverage RPV Upper Shell- 3-WR-18 Exam Category B-A 45L 45L Inservice examination limited due to-Flange Weld 4-WR-18 Item No. B1.30 70L 45S to interference with keyways and irradiation slots at 150, 1050, 1950, 2850, 700, 80°, 90°, 1300, 1900, 75% volume coverage 3100, 3200, 3300 and flange radius 3600.

TABLE 1 CATEGORY B-G-1 Applicable Code ASME Code Component ID Requirement and Angle/ Impracticality of Weld Volume WaveCompli Coverage Mode Compliance Obtained Exam Category Inservice examination RPV Threads in 3-Lig-1 thru 58 limited due to seal surface Flange 4-Lig-1 thru 58 B6.40 edge

Page 7 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 CH #2-CONTACT HEAD DIRECTIONAL ARROW CH 2x3 UT HEAD CONFIGURATION #3 FOR SHELL SCANNING (AS VIEWED FROM BACK OF ROBOHAND COUPUNG)

Illustration of the typical UT head configuration used for vessel shell weld scanning. Overall head dimensions are approximately 12" x 8".

Figure 1

Page 8 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 0.16 MIN.CAIAING 1MUG D M7.715)

W F? 5,so(,9n) 93.77 MIP (100.501 R79Dn 0A16MR. CLAMS Total Scan Area of Weld W-31 is Limited Due to Core Support Lugs 4.75 B1T2 Total Coverage Achieved 85%

RPV Lower Shell to Lower Head Ring Weld (3-WR-31 and 4-WR-31)

Figure 2

Page 9 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 View of TWS robot in vessel lower head region showing scan limitations caused by the Core Guide Lugs. The inspection area above the weld is limited by the Core Guide Lugs. The Core Guide Lugs restrict the UT head from scanning the entire weld. This limitation occurs at each lug set. Single sided scan parameters are used near obstructions to improve examination coverage. Coverage obtained on this weld is 85%.

RPV Lower Shell to Lower Head Ring Weld (3-WR-31 and 4-WR-31)

Figure 3

Page 10 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 DIRECTIONS 3 & 4 Parallel Scan Limitation Missed Volume

L DIRECTEINS 1 & 2 Perpendicular Scan Limitation Missed Volume Total Coverage Achieved 75%

Upper Shell to Flange Weld Volume Limitation Illustration (3-WR-18 and 4-WR-18)

Figure 4

Page 11 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15

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Page 12 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 View of TWS robot in vessel upper flange region showing scan limitations caused by the keyways, irradiation slots, and flange inner radius. The keyways and irradiation slots provide a scan limitation above the weld at several locations around the flange. The flange inner radius provides a 360 degree limitation around the vessel. Single sided scan parameters are used near obstructions to improve examination coverage. Coverage obtained on this weld is 75%.

Upper Shell to Flange Weld Volume Limitation Illustration Figure 6

Page 13 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 p Wa's Elm;t3v-Ammmmummm WR-18 2 = -3E.50 Z =-51,44 WR-331 WR-10 WR-31 Z = -33*.35 4-WR-9 2 -361.%

La La L4 6 6 c U i5

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LI.t. I I L c a t C C, U Figure 7 RPV Vessel Rollout

Page 14 of 14 TURKEY POINT UNITS 3 AND 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 15 Ligament Exam Coverage CE EDGE Tota Code Required Ezamdnatlon area:

22.3139 sq. Inches Tot* Area where no

=ogqpo we obtaiened Ar um*ea):

26436 sq. ;

Total Percentau of

.125" mmnon Coedrgeo obtained: 84967%

6.125" ID I

Total Coverage Achieved 84.67%

RPV Flange Ligament Volume Limitation Illustration Figure 8

L-2015-020, Attachment 2 L-2015-020 ATTACHMENT 2 TURKEY POINT UNIT 3 RELIEF REQUEST No. 16

Attachment 2 1 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Relief Request In Accordance with IOCFR 50.55a(g)(5)iii)

--Inservice Inspection Impracticality--

1. ASME Code Component(s) Affected Class 1 inner radius in vessels Class 1 and 2 pressure retaining welds in vessel and piping

2. Applicable Code Edition and Addenda

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 1998 Edition with Addenda through 2000 as amended by 10CFR50.55a, is the code of record for the Turkey Point Unit 3, 4th 10-year interval. ASME Section Xl, 1998 Edition with Addenda through 2000 as amended by 10CFR50.55a, was utilized for Appendix VIII.

3. ADDlicable Code Reauirement Exam Item No. Examination Requirements Cat.

B-D B3.120 Essentially 100% volumetric radius. As mandated examination of the nozzle inner by 10CFR50.55a(b)(2)(xxi)(A).

C1.10 C-A C1.20 Essentially 100% volumetric examination of the weld length.

Essentially 100% volumetric and surface examination of C-F-1 C5.11 circumferential welds >3/8" nominal wall thickness for piping

>4" nominal pipe size.

Essentially 100% volumetric and surface examination of C-F-1 C5.21 circumferential welds >1/5" nominal wall thickness for piping

>2" and <4" nominal pipe size.

R-A RI.11 Essentially 100% volumetric examination of the circumferential welds. Risk Informed Selection.

As defined by ASME Code Case N-460, essentially 100% means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.

Attachment 2 2 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

4. Impracticality of Compliance Due to the configuration, it is not possible to meet the examination coverage requirements of the ASME Code,Section XI, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460. Relief is requested in accordance with 10CFR50.55a(g)(5)(iii). These areas were found during the 4th 10-year inservice inspection interval.

When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

When examined, the welds listed within this request did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments. These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume.

The Table included in this Relief Request summarizes the percent of coverage credited and references specific figures that show the extent of coverage.

Relief is requested from the ASME Boiler and Pressure Vessel Code required volume as identified in Figure IWB-2500-7, IWC-2500-1 and IWC-2500-7. Additionally, for welds categorized as R-A in accordance with the Turkey Point Risk Informed (RI) Program (MD7740), the Figure IWB-2500-8 exam volume is increased, when required, to include internal counterbore areas.

5. Burden Caused by Compliance It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments. Examinations are performed to the maximum extent possible. The Ultrasonic (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved. For the welds listed in the Table, FPL determined that removal of the obstruction was not possible 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.

Radiography is 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 of 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. There would be significant burden associated with the performance of weld or area modifications or radiography in order to increase the examination coverage.

Attachment 2 3 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

6. Proposed Alternative and Basis for Use Proposed Alternative

1) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1 and C-H, Table IWC-2500-1.

2) Conduct ultrasonic examinations to the maximum extent possible.

3) Regular walkdowns by operations personnel and system engineers are performed on systems outside containment to check for leakage, piping configuration, and/or damage. During outages, system engineers walkdown systems inside and outside containment. This walkdown is performed to look for system anomalies that could affect plant performance.

Basis The attached Table provides the percent of coverage credited and references specific figures that illustrate the extent of coverage for each weld. The examination figures of ASME Section Xl, 1998 Edition with Addenda through 2000, define the examination volume required. The system, diameter, pipe schedule and material are identified for each item within the Table. The angles, Ultrasonic wave modes (Shear-S or Longitudinal-L) that were employed for examination and impracticality of compliance are listed for each weld. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.

FPL performed the examinations to the extent possible. There is no plant-specific, NextEra fleet or industry operating experience regarding potential degradation specific to the subject welds included in this relief request. However, isolated occurrences of stress corrosion cracking have occurred in stainless steel materials in the industry. To address the concerns of these isolated cases, periodic walkdowns by plant personnel provide assurance that any isolated degradation would be identified at the onset before a safety concern could develop.

The Class 1 and 2 items identified in the table are located within either the reactor containment building or reactor auxiliary building. Regular walkdowns by operations personnel and system engineers are performed on systems in the reactor auxiliary building to check for leakage, piping configuration, and/or damage. During outages, system engineers perform boric acid walkdowns of all systems inside containment. This walkdown is performed to look for borated system as well as system abnormalities that could affect plant performance. Also, a system pressure test and VT-2 visual examination is performed each refueling outage for Class 1 connections and each period

Attachment 2 4 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 for Class 2 and 3 connections without removal of insulation by examining the accessible and exposed surfaces and joints of the insulation.

Leakage monitoring inside containment at Turkey Point Unit 3 is provided by the reactor cavity (containment) sump inlet flow monitoring system. This system has high level and alert status alarms in the control room. This system has Tech Spec required monitoring (TS 3/4.4.6.2.1 (b)) at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

All preservice and inservice examinations were performed by personnel certified in accordance with IWA-2300 of 1998 Edition with Addenda of the ASME Section XI Code.

UT examinations of the austenitic piping welds utilized equipment, procedures, and personnel qualified in accordance with ASME Section X1, Appendix VIII, Supplement 2, 1998 Edition with Addenda through 2000 and the Performance Demonstration Initiative (PDI) program.

The UT techniques for each weld were reviewed to determine if additional coverage could be achieved. FPL's procedures require the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the qualified procedure. Alternate techniques were investigated at the time of discovery.

For piping welds performed in accordance with Appendix VIII, Supplement 2, the coverage credited is limited when access can only be obtained from one side. No coverage is claimed past the centerline in the coverage credited in the Table since access for scanning was not available from that side of the weld and the Performance Demonstration Qualification Summary (PDQS) for the qualified procedure, PDI-UT-2, states that "the austenitic single side qualification documented on this summary demonstrates application of best available technology, but do not meet the requirements of 10CFR 50.55a(b)(2)(xvi)(B)." It should be noted that UT was performed through the weld to obtain the maximum possible Code examination volume and, as shown in the figures, the theoretical beam path extends into the far side for the examinations performed. While the coverage is not included in the Table, the techniques employed for the single side examination are noted in the figures and provided for a best effort examination. The coverage obtained was the maximum practical. Therefore, the UT examinations conducted using the Appendix VIII, Supplement 2, qualified procedure provide reasonable assurance for the detection of flaws on the far side of welds where the ultrasonic beam has been transmitted even though not presently qualified.

The Risk Informed Inservice Inspection (RI-ISI) Program for Class 1 piping welds was submitted (Relief Request 3) and approved (SE dated December 9, 2008 TAC No.

MD7740) as an alternative to the requirements of Section Xl as for the fourth 10-year interval.

For the Risk Informed (RI) weld 31"-RCS-1301-8, the ASME Section X1 1998 Edition with Addenda through 2000, Figure IWB-2500-8(c) examination volume is %" from toe of the weld on each side for the bottom 1/3t. However, the Risk Informed examination

Attachment 2 5 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 volume is extended to /2" from each toe of the weld and due to the counterbore on the elbow side as shown in Figure 19, the examination volume is extended an additional 1/".

If a dotted line was drawn vertically 1/4" from the elbow weld toe and the ASME Code Section XI 1998 Edition with Addenda through 2000, the examination volume identified in Figure IWB-2500-8 from the elbow side would be essentially 100% coverage achieved. Because of the extended volume past the elbow counterbore, the elbow OD transition and the risk informed extended volume prohibits obtaining essentially 100%

coverage as identified in the ASME Section XI 1998 Edition with Addenda through 2000, Figure IWB-2500-8. There are 6 welds in the reactor coolant system selected with similar configurations in the Risk Informed Program. This is the only weld considered limited.

Weld 3"-SI-2303-2312 was installed in 2011 as part of the extended power uprate project and examined. This weld was replaced as part of a valve replacement and not due to weld or base metal degradation. Preservice examinations performed during the replacement process included in-process and final surface examinations, and final radiography (RT) in accordance with the requirements of ASME Section III. The surface and radiographic examinations were not limited. Final RT and surface examinations performed during the installation of the weld revealed no recordable or reportable flaws in the examination zone or adjacent to any UT limitations. The acceptable surface and RT results were obtained prior to the preservice UT examination being performed.

Subsequently, the weld was examined in 2014 as part of the population selected for examination in accordance with IWC-2500-1, Examination Category C-F-1. The preservice UT/PT and inservice examination UT/PT examinations did not reveal any recordable or reportable flaws in the examination zone..

For all welds except 3"-RC-1301-1, 31"-RCS-1302-8, 3-RHE-Al, 3-RHE-A2, and 3"-SI-2403-36 listed in Table 1, surface examinations were performed and not limited. Welds 3"-RC-1301-1 and 31"-RCS-1302-8 did not require a surface exam per FPL's Risk Informed Program. Welds 3-RHE-Al and 3-RHE-A2 are Class 2 Category C-A welds, which do not require surface examinations by ASME Code Category C-A, Item No.

C1.20. And the surface exam of weld 3"-SI-2403-36 achieved 97.5% of the code required surface as shown in IWC-2500-8 due to a support saddle weld at the toe of weld..

In all cases, 100% of the accessible Code required surface area was examined. All welds had a surface examination (liquid penetrant) and radiographic (RT) performed and were acceptable for service in accordance with the requirements of ASA B31.1, 1955 Edition.

The surface and volumetric examinations of all the items listed did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations.

The extent of examination volumes achieved via surface and/or volumetric examinations, combined with the system pressure tests and system walk downs, provide assurance of an acceptable level of quality and safety.

Attachment 2 6 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

7. Duration of Proposed Alternative This relief request is applicable to the Turkey Point unit 3 Fourth Inservice Inspection Interval which began February 22, 2004 and ended February 21, 2014.

8. References 10CFR50.55a ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components,"

1998 Edition with Addenda through 2000 ASME Section XI, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1"

Attachment 2 7 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 System Year Applicable Code Examination Sstem DComponent ID of Requirement and Angle and Fig. Impracticality of Compliance Results Configuration Diameter-Schedule Exam Coverage Credit Wave Mode Material Pressurizer Pressurizer 2010 Exam Category B-D 60 0S 1 Inservice examination Surface examination is Spray Nozzle Spray Nozzle Item No. B3.120 limited due to Raised not required by Code.

Inner Radius SP-03-1-IR Fig. IWB-2500-7(d) Letters in required scanning Carbon Steel area 82%

No Recordable Indications Residual Heat Residual Heat 2010 Exam Category C-A 45 0S 2 Inservice examination Surface examination is Exchanger Removal Item No. Cl.20 600 L limited due to support not required by Code.

Head to Shell 3-RHE-Al Fig. IWC-2500-1 45 0 L proximity to weld on head Stainless Steel side and reinforcement plates and welded attachments on the shell side.

35% No Recordable Indications Residual Heat Residual Heat 2010 Exam Category C-A 45 0 S 3 Inservice examination Surface examination is Exchanger Removal Item No. C1.10 60 0L limited due to flange not required by Code.

Shell to 3-RHE-A2 Fig. IWC-2500-1 45 0 L configuration. Shell side is Flange Stainless Steel limited due to nozzle reinforcements and welded attachments.

40% No Recordable Indications Flange to Safety Injection 2014 Exam Category C-F-1 45 0 S 4 Inservice examination Liquid Penetrant Elbow 3"-SI-2301-1 Item No. C5.21 60°S limited to single side access examination performed (3"-80) Fig. IWC-2500-7(a) 70°S due to flange configuration. obtaining 100%

Stainless Steel Elbow limited on intrados coverage. No recordable due to curvature which indications detected.

limits contact.

1 45.4% No Recordable Indications

Attachment 2 8 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 System Year Applicable Code Examination System Component ID of Requirement and Angle and Fig. Impracticality of Compliance Surface Examination Configuration Diameter-Schedule Exam Coverage Credit Wave Mode Results Material Pipe to Valve Safety Injection 2014 Exam Category C-F-1 450S 5 Inservice examination Liquid Penetrant 3"-SI-2301-4 Item No. C5.21 60°S limited to single side access examination performed (3"-80) Fig. IWC-2500-7(a) 70°S due to valve configuration. obtaining 100%

Stainless Steel Examination pipe side coverage. No recordable complete. indications detected.

50% No Recordable Indications Valve to Pipe Safety Injection 2011 Exam Category C-F-1 450S 6 Preservice/Inservice Liquid Penetrant 3"-SI-2303-2312 2014 Item No. C5.21 60°S examination limited to single examination performed (3"-80) Fig. IWC-2500-7(a) 70°S side access due to valve obtaining 100%

Stainless Steel configuration. Examination pieside complete, obtag 100%

coverage. No recordable pipe sindications detected.

50% No Recordable Indications Valve to Safety Injection 2014 Exam Category C-F-1 450S 7 Inservice examination Liquid Penetrant Elbow 3"-SI-2303-24 Item No. C5.21 60 0 S limited to single side access examination performed (3-80) Fig. IWC-2500-7(a) 70 0 S due to valve configuration. obtaining 100%

Stainless Steel Wave Elbow limited on intrados coverage. No recordable due to curvature which indications detected.

limits contact.

45.4% No Recordable Indications Pipe to Valve Safety Injection 2014 Exam Category C-F-1 450S 8 Inservice examination Liquid Penetrant 4"-SI-2303-49 Item No. C5.21 60 0 S limited to single side access examination performed (4"-80) Fig. IWC-2500-7(a) 70°S due to valve configuration. obtaining 100%

Stainless Steel Examination on pipe side coverage. No recordable complete. indications detected.

47.3% No Recordable Indications

Attachment 2 9 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 System Year Applicable Code Examination System Component ID of Requirement and Angle and Fig. Impracticality of Compliance Surface Examination Configuration Diameter-Schedule Exam Coverage Credit Wave Mode Results Material Pipe to Valve Safety Injection 2009 Exam Category C-F-1 450S 9 Inservice examination Liquid Penetrant 8"-SI-2302-6 Item No. C5.11 60°S limited to single side access examination performed (8"-120) Fig. IWC-2500-7(a) 70 0 L due to valve configuration, obtaining 100%

Stainless Steel Examination pipe side coverage. No recordable complete. indications detected.

50% No Recordable Indications Pipe to Tee Safety Injection 2006 Exam Category C-F-1 450S 10 Inservice examination Liquid Penetrant 8"-SI-2309-22 Item No. C5.11 600 S limited to due to intrados of examination performed (8"-120) Fig. IWC-2500-7(a) 70 0 S tee. Examination pipe side obtaining 100%

Stainless Steel 70% Achieved 450 L complete. coverage. No recordable 700 L indications detected.

82% No Recordable Indications Tee to Pipe Safety Injection 2006 Exam Category C-F-1 45 0 S 11 Inservice examination Liquid Penetrant 8"-SI-2309-23 Item No. C5.11 60°S limited to due to intrados of examination performed (8"-120) Fig. IWC-2500-7(a) 70 0 S tee. Examination pipe side obtaining 100%

Stainless Steel 70% Achieved 450 L complete. coverage. No recordable 70 0 L indications detected.

82% No Recordable Indications Pipe to Valve Safety Injection 2006 Exam Category C-F-1 45 0 S 12 Inservice examination Liquid Penetrant 8"-SI-2309-24 Item No. C5.11 60 0 S limited to single side access examination performed (8"-120) Fig. IWC-2500-7(a) 70 0 S due to valve configuration. obtaining 100%

Stainless Steel 70% Achieved 450 L Examination pipe side coverage. No recordable 6001 complete. indications detected.

70 0 L 50% No Recordable Indications

Attachment 2 10 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 System Year Applicable Code Examination System Component ID of Requirement and Angle and Fig. Impracticality of Compliance Surface Examination Configuration Diameter-Schedule Exam Coverage Credit Wave Mode Results Material Elbow to Safety Injection 2009 Exam Category C-F-1 450S 13 Inservice examination Liquid Penetrant Valve 10"-SI-2304-2 Item No. C5.11 60 0S limited to single side access examination performed (10"-40) Fig. IWC-2500-7(a) 70°S due to valve configuration. obtaining 100%

Stainless Steel Examination elbow side coverage. No recordable complete. indications detected.

50% No Recordable Indications Valve to Residual Heat 2004 Exam Category C-F-1 45 0S 14 Inservice examination Elbow Removal Item No. C5.11 60°S limited to single side access Liquid Penetrant 14"-RHR-2301-1 Fig. IWC-2500-7(a) 70°S due to valve configuration. examination performed (14"-40) Examination elbow side obtaining 100%

Stainless Steel complete. coverage. No recordable indications detected.

50% No Recordable Indications Valve to Pipe Residual Heat 2007 Exam Category C-F-1 450S 15 Inservice examination Liquid Penetrant Removal Item No. C5.11 600 S limited to single side access examination performed 14"-RHR-2301-18 Fig. IWC-2500-7(a) 70 0 S due to valve configuration. obtaining 100%

(14"-40) Examination pipe side coverage. No recordable Stainless Steel complete. indications detected.

50% No Recordable Indications Pipe to Valve Residual Heat 2007 Exam Category C-F-1 450 S 16 Inservice examination Liquid Penetrant Removal Item No. C5.11 60 0 S limited to single side access examination performed 14"-RHR-2305-3 Fig. IWC-2500-7(a) 70°S due to valve configuration. obtaining 100%

(14"-40) Examination pipe side coverage. No recordable Stainless Steel complete. indications detected.

1 50% No Recordable Indications

Attachment 2 11 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 System Year Applicable Code Examination Configuration Diameter-Schedule of Requirement and Angle and Fig. Impracticality of Compliance Surface Examination Configuration Material Exam Coverage Credit Wave Mode Results Pipe to Valve Residual Heat 2007 Exam Category C-F-1 45 0 S 17 Inservice examination Liquid Penetrant Removal Item No. C5.11 60 0 S limited to single side access examination performed 14"-RHR-2305-11 Fig. IWC-2500-7(a) 70 0 S due to valve configuration. obtaining 100%

(14"-40) Examination pipe side coverage. No recordable Stainless Steel complete. indications detected.

50% No Recordable Indications Reducer to Reactor Coolant 2010 Exam Category R-A 450S 18 Inservice examination Risk-Informed. Surface Valve 3"-RC-1305-1 Item No. R1.11 60 0S limited to single side access examination is not (3"-120) Fig. IWB-2500-8(b) 70°S due to valve configuration. required.

Stainless Steel Examination reducer side complete.

50% No Recordable Indications Elbow to Pipe Reactor Coolant 2004 Exam Category R-A Cast 19 Inservice examination Risk-Informed. Surface 31"-RCS-1302-8 Item No. R1.11 45 0 L limited due to elbow OD examination is not Cast Material Fig. IWB-2500-8(c) geometry. Examination required.

Stainless Steel Stainless pipe side complete.

45S 60S No Recordable Indications 78.75% 45L

Attachment 2 12 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 p &I Total Coverage Achieved 268 Sq. Inches O Total RcPstired Examination Area 326 Sq. Inches Achieved 82% Code Required Coverage SP-03-1-IR Figure 1

Attachment 2 13 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 1.01, .9(Y' 1.1"1 .96.0 .95. .95.

Examinhiaon tlenftd oni Se11 side da&so Nozzles awk Swppoft~ Tooal Lou* 91' Total Wced Lcagtb 132-ReqiirdEianu Volume.- .8ff q.1ndwe AxLB Examininaiim Cowwagc AcdiLcvd 1-44 Sq. luck&~

(29%)

Circ. Exmniabaio Covasp c bie-cd 1-00 3q. TIclacs (42%)

Total Examination Cweragee Achieved 35%

3-RHE-A1 Figure 2

Attachment 2 14 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 1.26" 3.2" 1.15" I" .96 .91r Flange 60ORL 45o Shell Examination limted due to Nozzles and Supports Total Length 29" Total Weld Length 132" Required Exam Volume - 2.13 Sq. Inches Axial Examination Coverage Achieved .87 Sq. Inches (31%)

Circ. Examination Coverage Achieved 1.34 Sq. Inches (501%)

3-RHE-A2 Total Examination Covcragc Achicved 40%

3-RHE-A2 Figure 3

Attachment 2 15 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 LkwDela jr ~Nouh

'Jl//////////////I/////////////I/////*

Head Si& Vuw 4-RHE-A2 & 4-RHE-A1 Figure 2 & 3

Attachment 2 16 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 FLOW NR NR .42r .350' 34" 33" Flange Elbow ReafredEwum Volime-3.2 Sq. Enciws L~dwmni R@quird Ewin Vol.. O54i Sq. Imche Vaiw., OEuammdnhdw tUpsmm ido- .0 S%. h1-- Z (D

iii mý

&mmcu~~~dcn DhTinimI Laillh W x Wdch L2E x H.mIt X VA~d~lidwmi AD- VMW OPInib r dW ddV~h Wr Cmawra Summrwy- V"~I # 3r-SI2301-1 kqiukW Smru- sodh hm aiwdgIi. fmta of EW= for amnlilet.cu Auunemup II - W Dwwmuu heldm~m Mn 4W ~~ (FA 0% 8L8% 21D0%

706% (Imst effort) _ _ _ _ _ _ _

Cod.cawinugae~ol 45A4%

Bat Bfnt Cwamgm (Itx25%) TolmII 17.M5 L. cod Comvw..rfumtthemnidnun pu~ut of thurwiiroiumt*utlonvwimdmtihu efhedieymnrinmdvft0thqumMltdn unolon procedwu

2. Bmtffloxt CmmW iall to the nuqmimd untmutlonvwlwurpae the kmututiehIs

ýn Ined In tht udal hmcinmrs+/-Ian vmidi an Appui~c ViII cluxmzut.1 proceurumfor skabi iddd cowrq 3"-SI-2301 -1 Figure 4

Attachment 2 17 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

.310r .300" .300" .300" .360" Flow-,

Valve Pipe RoqqiTud hum Volvrno - .1415q. lnchaswRRR5 Doiwusbwn Roqurd Eum Volume .061 Sq. Iindcw Volum -n. ilnmedo dmifwo~u Ado- AlS55q. inches (Badt Effixt)

Eeinmnatdoe Volume Oimemsious: Lalgth 11t x Width 1.26" x Height .100 Weld ThiCkaess= .360* Weld Leagth= 11" Weld Width= .70" Coverage Summary- Weld # 3N-S1-2301-4 Reqlied Scans- each has a wehing factor of 100% for complete coverage Amale Upstream-Axid Upstream-Circ. Downstream Axia Downstream Circ.

45/60/70 100% 100% 10% o0%

70 24.51best effort)

Code Coverage Tola I 0o%

Best Effort Coverae (Max 25) Total 0.14%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined In the axial beam diection with an Appendi VIN demonstrated procedure for single sided covesrge 3"-SI-2301-4 Figure 5

Attachment 2 18 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 3 2 I 0 1 2 3 1'

7b Sk%*A IW m duemo po*Aýlve 2.25 MH-z 70w s used uplarm

,oefigurs*m.

lo atk best-eo~ nt mmom for Me* dammarmaids d tho wld.

46IP*I 0nQ=bO0.74Wh~

USAOW 4W6OAXdmI

US tXUl Pme:.091W-0 -7t16W~

45 USvCW GM8006 n'5.7410i 45DSOtc uNOAM 70 06Add t*ftimmivdumd~ievwdiewfqmao.

- TeeAN Volve MOV-3-869 I Exmmnmu V*Valm Dlmstn.m Lumu 11.jj x wdth Lfm x HaOiN 0,131" Weld Tthtsms , %W Weld LeM a" iiW Wed WV -aME Coverage Summary - Weld 0 3"-S1-2303-2312 ftJq~ird cens -Each Im slhi WMO* of 100% for ,pF awag AngleUpmm - AMa I UpWae -CIrc IDownslrsin - Axial Dowuetre.. - Ciro 45 100% 100% 0% 0%

70 N/A WA N/A WA co Coveame TOW 50%

al Bet 2% otl E

1. Code Coverage rfem l the mmdemm pwretg a the requhed xinmtWlon valume OWd Isellivhly muralne w~th lie quMlifd euhminlaon procdmre

2. Bew ~ Coverage der to the recquird mnalmadon valume p the cemndlIme 00 Is eamlned Intio .dal beim direcion wlh a App**Ntx VIII damu Wprocedure for &Ingle sdid caueage 3"-SI-2303-2312 Figure 6

Attachment 2 19 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

.340" .340" .340" .340" .410"

, Flow 45.4 WValve Elbow FZi~Z1 Required Exam Volume -, 14 Sq. Inches UPS=a Requircd Exam Volunc .073 Sq. "nch\s Volume Examined on Upsmam side -. 034 Sq. hics (Best Effort)

Examination Vobme Dinensions: Length I'. x Width 1.20o x Height .11t Weld Thickness- .410 Weld Lengat- 2 Weld Width- .M0 Coverage Sum mary- Weld # 3--SI-2303-24 Required Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream- Cire. Downstream Axial Downstream Circ.

45/60 0% 0% 81.8% 100%

70 38.1(best effort)

Code Coverage Total 45.4%

Best Effort Coverage (Max 25%) Total 9.5%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage 3"-SI-2303-24 Figure 7

Attachment 2 20 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

, Flw

-500" .450" 380" -W 380" ValveTo 45.

7 PIPE Required FExzin Voluro-1.U Sq. Inchm Downstream Required l-am Vol urn .ONS Sq. Inchdi Volumie EXeMliwdon Downsuvun sWd- .035 Sq. Inhee oZ .. 1 (Best Effort) rzhao emu lejs Iaupbh M14. a Widdin LJA a "night .11, WddThwhnein. .450 Weld Lenjt. 111,39 Wahl Width- AP Coverage Summary- Weld # 4"-SI-2303-49 Required Scams- each has a weighing facter of 1001 for mimplate coverals LA,le Upsremn-Auie Up;trim-.ic. Duu-n reDnuAnijl DOwureamu Circ.

45IO0[70 4 9.0 94A a%

70 1 G134besteffb I code Covera Ttal 473%

Best Efbrt Coverae (Max 25%)Total 1 15.3%

Notes:

1. code Coverage efers to the maximum percentageaofthe required examination volume that is effectively examined wth the qualIled examination p rocedura

2. east Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix Vm demonstrated procedure for single sided coverage 4"-SI-2303-49 Figure 8

Attachment 2 21 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Flow \

.71" .73" Pipe Dowdowam RoqwiAks tima WVirn.14 Sq+ kewbs volume Eemhimd an Dowur. SWe- .U Sq hwmt Emmkfdrmaishumedmnilcm IBr 2WAI x Wich UAr x Hedt Ir VJdmNdnm. W Vi~d~e. 25 V~ddWih= M Al wreitmec ayoeftdarlarfo L CaifrCavmWrerusbstenW puuanpWildtereiqkeduin"aini.Uonkinettu eroo~ady mmtIquU ldinnbiecoduprooeurie Z. Deint gktCOMWqerfw~thwemqgikd fin*mIrdvumeIp.atheCtkt.*toi~s urw bIa nihtheashl bmdmdhomgmvthan Appendix Vola dmlale pmeuirefosk&~

8"-SI-2302-6 Figure 9

Attachment 2 22 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Flow -_

." 1.06L

.,8' .7'/

TCC MK Required Exam Volume - 33 Sq. Inches Required Exam Volume - .34 Sq. Inches MDownstrem Required Exam Vohune .16 Sq. Inches Examination Limited to Single side from 11.5" to 16" and 22.5 to 2.0" total 9.00" Volume Examined oniDownsream side - .05 Sq. Inches (BtEffodt)

Siiuulyrv-WM#1ru4W23CIZ2 ftft~cwuhwahibfflt Mladr 7.Ee 1.;ý I M wk DdmA mbm m~Uwstw~p7rm2a Lauhi~~

D&bW(=bfJmwbsw= dtmAe*kW vUua duwxaVe~We 8"-SI-2309-22 Figure 10

Attachment 2 23 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Flow - .93" A' 1.27" QRequired Exna Volume - .43 Sq. Ices f m lRequired Exam Volume -.37 Sq. Inches Upslrewn Requred Exn Volume .20 Sq. Inches Volumne Examined an Upstream side - .20 Sq. Incd (Best Effort)

Examination Limited to Single side from 11.5" to 16" and 22.5 to 2.0" tota 9.00"

- VNWM

- , Iin~, ZF a V~ LW x N~t .2,

~mauvbufamrv-ddinftWHW2W 0

7Il I Wb~ateffoo QabcrfwWM~fd IT s

COO WOSDWaaa gdee" I urea db*Ajs IudvtuwM~sd pmad z &AEAr5 vimwj d monkffiflerddslmfibusbaAwmin% p-u.Im-hfa'dr*

8"-SI-2309-23 Figure 11

Attachment 2 24 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Flow \-

.68" .76" 1.23" Valve Roqifre r~am V~kune - -W0 Sq. Wncha Dmmwmgrm ftcquiak EXAMV06mm .16 Sq. Iwhs VON=~ EIambea"D ouwnuUA&sIe.3Sq.*Incbu Eimidi~mVciui Chnsndar Iargh 2&," xr Wdht U x HOW .12 V"THdnio- & E~ U~th A M ~dVih- M Cmwrmp Simnry- Wld#1r-9-2a09-24 70t 936r P td i _______

t O m~rinpucuqCalwr~kai mn*ponu 1.Ca Cq~d~ aut s sldkiyemuinabmufueqmflmie-;dnilm prouw.kr 2- BM~ SbtCaNIeq. Iekm~ow uuhwi nIUknvkIIw&nps*#wncusIwt n b oll,*wI kmtIn~mu~Ibn&dreiiananAppemdk VE Is~rna lpracaukmf*usk&~

8"-SI-2309-24 Figure 12

Attachment 2 25 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

,- Flow

.43" .38" .38" Elbow ftvufrd ixam, Vdhmm - .1.3 Sq. hnim~s

[OwwasivamI RapabW Iam=

r Vahuw iM Sq. Iuidfms Vabmu. I:iamjnwd un Du~awsiwt suki 53 S&. hIdie iam* MrJt)

Exuida Wm&due~hmerdem Length " x A th LID' x Hd&gt .12 QGiruampwiuiwy-VWbd # 3-Sl-23041-2 newdred~~mwemb av~ffaiinlndrLm,,

45MW Im (19 as 70 5bestdb ______

axiarcmempTaw MG rt BestE~dCWW O 22-%6 L. GmdeCOWWqm efw fAVnuinua ith ~nptqeottheupkuI U Ikri&UIONr~WhEi~b dkdhm* mm theqn~iedamdhaanpac-Uhpd

2. Best skrt: Cosergereh tothereus!emka w*ionvkmise t pat therm~m Inetha b mmi*-intheaddibmnNdIONk anAppmih Al dminmmba~promwikrsfk&,~

10"-SI-2304-2 Figure 13

Attachment 2 26 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Flow

.500" .470" .375" .375" so Valve Pipe Requicad rxa=i Volume - .11 Sq. Inctuo Wwnxkm Required Exaum Volume, A~70 Sq. jchow Vold= IiWzn~ht0ml 3D&wnsMamm slick .0545S.nches E=udrim~Aime Uhnswilc Le~th 43.9 x VWfh 2.27 x HOW .22 Vd1dV~mso= AM Wd Lffgth 4W d~fip= ME WenSnor, Abdd # W4M-IK2301-l 70 6.596(best ___ ___

Bes EfFort Cb WP1599TWMm

1. Odle O~fflrdWrefS1Dthe nudnuan penstapthereqkuId amkdiIon vokfm~#tt Is Z.B ~Iart~w wm~erdm tothevmrediu esrnkiadionvku pad thwterlmuett Is N= 1 kuthem U.bmmdetian uhawuAperuK WI dnummI rpmamnkmfbr skW*

MsuWanae 14"-RHR-2301-1 Figure 14

Attachment 2 27 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

.49I .43" .44" Ruquimad l.m Vigauzu .19 Sq. Inches02u Upwsum Raqukod E'lm Vahw0IAh5 q Im~$iu Volime rumnimdu, thmuouon side -D4 Sq. Irdb (Red EMii) bin~wdaum,'tAawDbn~wdo Lem*~ A x ViftI MW X EWu W"Mldmmin= Ar V"ad I~ WMdW VA" Cawemp Sawiwmy- V"M~ # 1E'-RIUI230-1B I "kinSomu- eini ta w*igfakr3 d 1W~fc' 4xmujte q 4W3 am (3 lam 70 42%(besteffot) ____

Go~d~amp Taw5W Bes EfflitomWt 29 Tul ______

L. God~eouuw~ri~dsbtlhe niiumnwdaIttu reqikedliudnatim wdwuretti dwelemmnedv the qxdffe uuranklo mn *1 P

2. Bes Efftor wW ,dintotl. rekqfedldn~an mdwne pet th callmline is einnnedin the aftl b..n drbwdmuithan Appendix VU dMnormbgdp nwrukeforsinde 14"-RHR-2301-18 Figure 15

Attachment 2 28 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

.37" .37" Valve toqinei Pmem vr~am - I1 -4, below MWrnuaan ftuqufrU ErM~V01M~.0b 5q. hLUMO voraud mmumiheftW~Wmfm ISt-.10 94. momh C(r £fvm F w* -M*h.euunh let* 4W x Vfh LW1 x N*MWt.1 V&Mdbkkmm Jr W~Lo~h- Yr _MVk-A ftq~md~ymwo~lqevAW6_____

PA&to~ndBtlm fbtm mwI_____oL4 n 4%0 xmx ma e~dCadeammy~ae 2.12M6 N*

LGdd~ m rm~mv~vm~ f*mmn &moi 14"-RHR-2305-3 Figure 18

Attachment 2 29 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0

/ Flow 37" .37" Valve 7W.400 as*

Pipe X*Wmia~dEx=mVcdwwi - .14 Sq Taches Douumini Raqudu IFnun VAlM b6 94. hdwm Valin Fxunhncgan Dow~wu si- M!4.qq Incebs

(&MbEtFoat)

ExmirmdanVcilmu Cndouinne Lerigth 4j x Vifh J.=0 x HeWgt ,i V~dThkkdes- .37 vid Lavo). 43.9' vid v'Miii- .ar Coverag Swnmmry- VWld # WV-RHR-2305-11 IRewired Sw..- ewhacm a nWrIii factor of UM0 for conqidteaw An&tjpl .- al Uprm Ckc. DawadeM AM [DOiiiewncic 45/W0I 10 10096% I 0% 0%

70 3396 (best elki _______

Code CowaeTotal M______

Best Effar (bwse (Mm 25%)Total, &.32%

NOUN IL. Code Covmageft~ to the nUmIurn prcentap of the requlmd awunmatonvolunetInt Is edftweI~v umnimmi with Owe qwKAllel an~iaton procekre 2- Bm Effort Coqe rW~ tothe requied emandnitlon whanue pat the amterne that b einmkmod In the aidal bearn lrecton with an Appendbc Vim demotrleI wocedwelfor single skied coveage 14"-RHR-2305-11 Figure 17

Attachment 2 30 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Flow '-.

.63" .62" .57" .75" MoýR pqiwmd 1.-" Vdw .3mft. howlu Dmouwmwt Raquhud rxm auiume.9 Sq I"bAw Vu~u~ Iwuns

-Thu~aw ad.m Sq.hkUca t~l cuft Iawý bdrbns~~,um~bvdm: [mob W x Wuft IM x gMZ CMiWW lmwy- Vdd# 3"IE4r.,L%&

4is#W ma n fmdIN 0a hub IUpiam~

I IlzwdxI ruhd smd

-- OWf Om _____259______0 emdmdlntheaM bndmiwivftaiippm& WlldwiumWacsdmafiadr~ie 3"-RC-1 305-1 Figure 18

Attachment 2 31 of 31 TURKEY POINT UNIT 3 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 16, REVISION 0 Flow 2.620 23r OD Transiom RgqUW. Ewn- VGiUuiw*2.OO q. idmh l@*9Exam Voiwim a 1.4 $q. a ca~

OMME Cire Vdnmg EzW*nd n Maw SW-10 Sq.

84- (3211)

Examination Volume Dimensions: Length 97.3" x Width 3.95" x Height .91" Weld Thickness = 2.62" Weld length = 97.3" Weld Width = 2.37" Coverage Summary - 31 "-RCS-1 402-6 Required Scans - each has a weighing factor of 100% for complete coverage Upstream - Upstream - Downstream - Downstream -

Angle Axial Circ Axial Circ 45S/60S/45RL 0% 0% 100% 100%

45RL 63% 52% 0% 0%

Code Coverage Total 78.75%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

31"-RCS- 1302-8 Figure 19

L-2015-020, Attachment 3 L-2015-020 ATTACHMENT 3 TURKEY POINT UNIT 4 RELIEF REQUEST No. 17

Attachment 3 1 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17, REVISION 0 Relief Request In Accordance with 10CFR 50.55a(g)(5)(iii)

--Inservice Inspection Impracticality--

1. ASME Code Component(s) Affected Class 1 inner radius in vessels Class 1 and 2 pressure retaining welds in vessel and piping

2. Applicable Code Edition and Addenda

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components, Section Xl, 1998 Edition with Addenda through 2000 as amended by 10CFR50.55a, is the code of record for the Turkey Point Unit 4, 4th 10-year interval. ASME Section XI, 1998 Edition with Addenda through 2000 as amended by 10CFR50.55a, was utilized for Appendix VIII.

3. Applicable Code Reauirement Exam Item No. Examination Requirements Cat.

B-D 133.120 Essentially 100% volumetric examination of the nozzle inner radius. As mandated by 10CFR50.55a(b)(2)(xxi)(A).

C-A C1.20 Essentially 100% volumetric examination of the weld length.

C-B C2.21 Essentially 100% volumetric and surface examination of the nozzle to vessel welds.

Essentially 100% volumetric and surface examination of C-F-1 C5.11 circumferential welds >3/8" nominal wall thickness for piping

>4" nominal pipe size.

Essentially 100% volumetric and surface examination of C-F-1 C5.21 circumferential welds >1/5" nominal wall thickness for piping

>2" and <4" nominal pipe size.

R-A R1.11 Essentially 100% volumetric examination of the circumferential welds. Risk Informed Selection.

As defined by ASME Code Case N-460, essentially 100% means more than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.

4. Impracticality of Compliance

Attachment 3 2 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Due to the configuration, it is not possible to meet the examination coverage requirements of the ASME Code, Section Xl, 1998 Edition with Addenda through 2000, as clarified by Code Case N-460. Relief is requested in accordance with 10CFR50.55a(g)(5)(iii). These areas were found during the 4th 10-year inservice inspection interval.

When a component has conditions, which limit the examination volume, Florida Power and Light is required to submit the information to the enforcement and regulatory authorities having jurisdiction at the plant site. This Relief Request has been written to address areas where those types of conditions exist and the required amount of coverage was reduced below the minimum acceptable.

When examined, the welds listed within this request did not receive the required code volume coverage due to their configuration and/or the presence of permanent attachments. These scanning limitations prohibit essentially 100% ultrasonic examination coverage of the required examination volume.

The Table included in this Relief Request summarizes the percent of coverage credited and references specific figures that show the extent of coverage.

Relief is requested from the ASME Boiler and Pressure Vessel Code required volume as identified in Figure IWB-2500-7, IWC-2500-1, IWC-2500-4 and IWC-2500-7.

Additionally, for welds categorized as R-A in accordance with the Turkey Point Risk Informed (RI) Program (MD8875), the Figure IWB-2500-8 exam volume is increased, when required, to include internal counterbore areas.

5. Burden Caused by Compliance It is not possible to obtain ultrasonic interrogation of greater than 90% of the required examination volume due to interference caused by configuration and/or permanent attachments. Examinations are performed to the maximum extent possible. The Ultrasonic (UT) techniques for each weld were reviewed to determine if additional coverage could be achieved. For the welds listed in the Table, FPL determined that removal of the obstruction was not possible 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.

Radiography is 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 of 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. There would be significant burden associated with the performance of weld or area modifications or radiography in order to increase the examination coverage.

6. Proposed Alternative and Basis for Use

Attachment 3 3 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Proposed Alternative

1) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1 and C-H, Table IWC-2500-1.

2) Conduct ultrasonic examinations to the maximum extent possible.

3) Regular walkdowns by operations personnel and system engineers are performed on systems outside containment to check for leakage, piping configuration, and/or damage. During outages, system engineers walkdown systems inside and outside containment. This walkdown is performed to look for system anomalies that could affect plant performance.

Basis The attached Table provides the percent of coverage credited and references specific figures that illustrate the extent of coverage for each weld. The examination figures of ASME Section XI, 1998 Edition with Addenda through 2000, define the examination volume required. The system, diameter, pipe schedule and material are identified for each item within the Table. The angles, Ultrasonic wave modes (Shear-S or Longitudinal-L) that were employed for examination and impracticality of compliance are listed for each weld. Arrows and lines on the figures illustrate the UT transducer beam direction and extent of the area examined.

10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of design, geometry and materials of construction of the components.

FPL performed the examinations to the extent possible. There is no plant-specific, NextEra fleet or industry operating experience regarding potential degradation specific to the subject welds included in this relief request. However, isolated occurrences of stress corrosion cracking have occurred in stainless steel materials in the industry. To address the concerns of these isolated cases, periodic walkdowns by plant personnel provide assurance that any isolated degradation would be identified at the onset before a safety concern could develop.

The Class 1 and 2 welds identified in the table are located within either the reactor containment building or reactor auxiliary building. Regular walkdowns by operations personnel and system engineers are performed on systems in the reactor auxiliary building to check for leakage, piping configuration, and/or damage. During outages, system engineers perform boric acid walkdowns of all systems inside containment. This walkdown is performed to look for borated system as well as system abnormalities that could affect plant performance. Also, a system pressure test and VT-2 visual examination is performed each refueling outage for Class 1 connections and each period for Class 2 and 3 connections without removal of insulation by examining the accessible and exposed surfaces and joints of the insulation.

Attachment 3 4 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Leakage monitoring inside containment at Turkey Point Unit 4 is provided by the reactor cavity (containment) sump inlet flow monitoring system. This system has high level and alert status alarms in the control room. This system has Tech Spec required monitoring (TS 3/4.4.6.2.1 (b)) at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

All preservice and inservice examinations were performed by personnel certified in accordance with IWA-2300 of 1998 Edition with Addenda of the ASME Section Xl Code.

UT examinations of the austenitic piping welds utilized equipment, procedures, and personnel qualified in accordance with ASME Section XI, Appendix VIII, Supplement 2, 1998 Edition with Addenda through 2000 and the Performance Demonstration Initiative (PDI) program.

The UT techniques for each weld were reviewed to determine if additional coverage could be achieved. FPL's procedures require the examiner to make an attempt to achieve complete coverage by using alternative techniques such as using a smaller wedge thus reducing the distance from the exit point to the front of the wedge, changing angles or reducing the search unit element size. Any alternative equipment is required to be in compliance with the limits specified in the qualified procedure. Alternate techniques were investigated at the time of discovery.

For piping welds performed in accordance with Appendix VIII, Supplement 2, the coverage credited is limited when access can only be obtained from one side. No coverage is claimed past the centerline in the coverage credited in the Table since access for scanning was not available from that side of the weld and the Performance Demonstration Qualification Summary (PDQS) for the qualified procedure, PDI-UT-2, states that "the austenitic single side qualification documented on this summary demonstrates application of best available technology, but do not meet the requirements of 10CFR 50.55a(b)(2)(xvi)(B)." It should be noted that UT was performed through the weld to obtain the maximum possible Code examination volume and, as shown in the figures, the theoretical beam path extends into the far side for the examinations performed. While the coverage is not included in the Table, the techniques employed for the single side examination are noted in the figures and provided for a best effort examination. The coverage obtained was the maximum practical. Therefore, the UT examinations conducted using the Appendix VIII, Supplement 2, qualified procedure provide reasonable assurance for the detection of flaws on the far side of welds where the ultrasonic beam has been transmitted even though not presently qualified.

The Risk Informed Inservice Inspection (RI-ISI) Program for Class 1 piping welds was submitted (Relief Request 3) and approved (SE dated December 9, 2008 TAC No.

MD8875) as an alternative to the requirements of Section XI as for the fourth 10-year interval.

For the Risk Informed welds 31"-RCS-1402-6 and 31"-RCS-1403-8, the ASME Section XI 1998 Edition with Addenda through 2000, Figure IWB-2500-8(c examination volume is %"from toe of the weld on each side for the bottom 1/3t. However, the Risk Informed examination volume is extended to '/" from each toe of the weld and due to the

Attachment 3 5 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 counterbore on the elbow side as shown in Figure 19, the examination volume is extended an additional 1/2". If a dotted line was drawn vertically Y/"from the elbow weld toe and the ASME Code Section Xl 1998 Edition with Addenda through 2000, the examination volume identified in Figure IWB-2500-8 from the elbow side would be essentially 100% coverage achieved. Because of the extended volume past the elbow counterbore, the elbow OD transition and the risk informed extended volume prohibits obtaining essentially 100% coverage as identified in the ASME Section Xl 1998 Edition with Addenda through 2000, Figure IWB-2500-8. There are 5 welds in the reactor coolant system selected with similar configurations in the Risk Informed Program.

Welds 31"-RCS-1402-6 and 31"-RCS-1403-8 are the only weld considered limited.

For all welds except 31"-RCS-1402-6, 31"-RCS-1403-8, 4-RHE-Al, and 4-RHE-A2 listed in Table 1, surface examinations were performed and not limited. Welds 31"-RCS-1402-6 and 31"-RCS-1403-8 do not require a surface exam per FPL's Risk Informed Program.

Welds 4-RHE-Al and 4-RHE-A2 are Class 2 Category C-A welds, which do not require surface examinations by Code.

In all cases, 100% of the accessible Code required surface area was examined. All welds had a surface examination (liquid penetrant) and radiographic (RT) performed and were acceptable for service in accordance with the requirements of ASA B31.1, 1955 Edition.

The surface and volumetric examinations of all the items listed did not reveal any recordable or reportable flaws in the examination zone or adjacent to any volumetric limitations.

The extent of examination volumes achieved via surface and/or volumetric examinations, combined with the system pressure tests and system walk downs, provide assurance of an acceptable level of quality and safety.

7. Duration of Proposed Alternative This relief request is applicable to the Turkey Point unit 4 Fourth Inservice Inspection Interval which began April 15, 2004 and ended April 14, 2014.

Attachment 3 6 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0

8. References 10CFR50.55a ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components,"

1998 Edition with Addenda through 2000 ASME Section X1, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1"

Attachment 3 7 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 System A System Component ID Year of Ultrasonic Examination angles(s)i and Wave Fig. Impracticality of ComplianceReut Surface Examination Configuration Diameter-Schedule Exam Coverage (%) Mode Results Material Pressurizer Pressurizer 2011 Exam Category B-D 60°S 1 Examination limited due to Surface examination is Spray Nozzle Spray Nozzle Item No. B3.120 Raised Letters in required not required by Code.

Inner Radius SP-04-1-IR Fig. IWB-2500-7(D) scanning area 82% No Recordable Indications Residual Heat Residual Heat 2005 Exam Category C-A 450 S 2 Inservice examination Surface examination is Exchanger Removal Item No. C1.20 600 S limited due to support not required by Code.

Head to Shell 4-RHE-Al Fig. IWC-2500-1 70°S proximity to weld on head Stainless Steel 60 0 L side and reinforcement plates and welded attachments on the shell side.

51.5% No Recordable Indications Residual Heat Residual Heat 2005 Exam Category C-A 450S 3 Inservice examination Surface examination is Exchanger Removal Item No. C1.10 60 0 S limited due to flange not required by Code.

Shell to Flange 4-RHE-A2 Fig. IWC-2500-1 70°S configuration. Shell side is Stainless Steel 600 L limited due to nozzle reinforcements and welded attachments.

43% No Recordable Indications Outlet Nozzle to Residual Heat 2011 Exam Category C-B 45 0 S 4 Inservice examination Liquid Penetrant Shell Removal Item No. C2.21 60 0 S limited to single side examination 4-RHE-Al 1 Fig. IWC-2500-4(a) 70°S access due to nozzle performed obtaining Stainless Steel 450 L configuration. Shell side is 100% coverage. No 600 L limited due to close recordable indications proximity of flange to detected.

nozzle weld and weld

Attachment 3 8 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 System System Component ID Year of Ultrasonic Examination Angles(s)/ Impracticality of Surface Examination Configuration Diameter-Schedule Exam Coverage (%) and Wave Fig. Compliance Results Material Mode crown configuration.

53.5% No Recordable Indications Flange to Elbow Safety Injection 2014 Exam Category C-F-1 45 0 S 5 Inservice examination iquid Penetrant 3"-SI-2401-1 Item No. C5.21 60°S limited to single side examination (3"-80) Fig. IWC-2500-7(a) 70°S access due to flange performed obtaining Stainless Steel configuration. Elbow side 100% coverage. No is limited on intrados due recordable indications to curvature which limits detected.

contact.

45.4% No Recordable Indications Pipe to Elbow Safety Injection 2011 Exam Category C-F-1 450 S 6 Inservice examination Liquid Penetrant 3"-SI-2403-35 Item No. C5.21 60 0 S 11 limited due to intrados of examination (3-80) Fig. IWC-2500-7(a) 70 0 S elbow. Examination on performed obtaining Stainless Steel pipe side complete. 100% coverage. No recordable indications 86.5% No Recordable Indications detected.

Elbow to Pipe Safety Injection 2011 Exam Category C-F-1 450S 7 Inservice examination Liquid Penetrant 3"-SI-2403-36 Item No. C5.21 600 S limited due to intrados of examination (3"-80) Fig. IWC-2500-7(a) 70°S elbow. Pipe side is performed obtaining Stainless Steel limited due to welded 97.5% coverage.

saddle. Support welds located at toe of weld from 4.5" to 6.76". No recordable indications

Attachment 3 9 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 System A System Component ID Year of Ultrasonic Examination angles(s)i and Wave Fig. Impracticality ComplianceReutof Surface Examination Configuration Diameter-Schedule Exam Coverage (%) Mode Results Material 66% No Recordable Indications detected Pipe to Valve Safety Injection 2009 Exam Category C-F-1 450S 8 Inservice examination Liquid Penetrant 8"-SI-2404-2 Item No. C5.11 70°S limited to single side examination (8"-120) Fig. IWC-2500-7(a) 600 L access due to valve performed obtaining Stainless Steel configuration. 100% coverage. No Examination on pipe side recordable indications complete. detected.

50% No Recordable Indications Tee to Pipe Safety Injection 2011 Exam Category C-F-1 45 0 S 9 Inservice examination Liquid Penetrant 8"-SI-2407-8 Item No. C5.11 60 0 S limited due to intrados of examination (8"-120) Fig. IWC-2500-7(a) 70 0S tee. Examination on pipe performed obtaining Stainless Steel 600L side complete. 100% coverage. No recordable indications 76% No Recordable Indications detected.

Pipe to Valve Safety Injection 2009 Exam Category C-F-1 45 0 S 10 Inservice examination Liquid Penetrant 10"-SI-2407-4 Item No. C5.11 60°S limited is limited to single examination (10"-140) Fig. IWC-2500-7(a) 70 0 S side access due to valve performed obtaining Stainless Steel 600 L configuration. 100% coverage. No Examination on pipe side recordable indications complete. detected.

50% No Recordable Indications

Attachment 3 10 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 System System Component ID Year of Ultrasonic Examination Angles(s)/

and Wave Fg.CmlacReutImpracticality of Surface Examination Configuration Diameter-Schedule Exam Coverage (%) Mode Compliance Results Material Valve to Elbow Safety Injection 2009 Exam Category C-F-1 450 S 11 Inservice examination Liquid Penetrant 10"-SI-2407-5 Item No. C5.11 60 0 S limited is limited to single examination (10"-140) Fig. IWC-2500-7(a) 70 0 S side access due to valve performed obtaining Stainless Steel 60 0 L configuration. 100% coverage. No Examination on pipe side recordable indications complete. detected.

50% No Recordable Indications Pipe to Flange Safety Injection 2005 Exam Category C-F-1 45 0 S 12 Inservice examination Liquid Penetrant 12"-RHR-2402-15 Item No. C5.11 60 0 S limited to single side examination (12"-40) Fig. IWC-2500-7(a) 70°S access due to flange performed obtaining Stainless Steel configuration. Examination 100% coverage. No on pipe side complete. recordable indications detected.

50% No Recordable Indications Tee to Tee Residual Heat 2005 Exam Category C-F-1 45 0S 13 Inservice examination Liquid Penetrant Removal Item No. C5.11 60°S limited on both sides due examination 14"-RHR-2403-1 Fig. IWC-2500-7(a) 70 0 S to intrados of tee to tee performed obtaining (14"-40) configuration. 100% coverage. No Stainless Steel recordable indications 62% No Recordable Indications detected.

Tee to Pipe Residual Heat 2005 Exam Category C-F-1 450S 14 Inservice examination Liquid Penetrant Removal Item No. C5.11 600S limited due to intrados of examination 14"-RHR-2403-2 Fig. IWC-2500-7(a) 70 0S tee. Examination on pipe performed obtaining (14"-40) side complete. 100% coverage. No Stainless Steel recordable indications 81% No Recordable Indications detected.

Attachment 3 11 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 System Configuration System ID Component Diameter-Schedule Material Yearof Exam Ultrasonic Examination Coverage (%)

angles(s)/

A ge~ )

Mode I Impracticality of Surface Examination Results Elbow to Valve Residual Heat 2005 Exam Category C-F-1 450S 15 Inservice examination Liquid Penetrant Removal Item No. C5.11 60°S limited to single side examination 14"-RHR-2403-4 Fig. IWC-2500-7(a) 70 0 S access due to valve performed obtaining (14"-40) configuration. 100% coverage. No Stainless Steel Examination on elbow side recordable indications complete. detected.

50% No Recordable Indications Pipe to Tee Residual Heat 2008 Exam Category C-F-1 450S 16 Inservice examination Liquid Penetrant Removal Item No. C5.11 70 0S limited due to intrados of examination 14"-RHR-2404-17 Fig. IWC-2500-7(a) tee. Examination on pipe performed obtaining (14"-40) side complete. 100% coverage. No Stainless Steel recordable indications 81% No Recordable Indications detected.

Elbow to Pipe Reactor Coolant 2011 Exam Category R-A Cast 17 Inservice examination Risk-Informed.

31"-RCS-1402-6 Item No. R1.11 45 0 L limited due to elbow OD Surface examination is Cast Material - Fig. IWB-2500-8 configuration. not required.

Thickness 2.76" Stainless Examination from pipe Stainless Steel - 45S side complete Thickness 2.33" 60S 45L 78.75% No Recordable Indications

Attachment 3 12 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 System A System Component ID Year of Ultrasonic Examination and Wave angles(s)i Fig. ImrciaiyoSufcEx Impracticality of intn Surface Examination Configuration Diameter-Schedule Exam Coverage (%) Mode Compliance Results Material Elbow to Pipe Reactor Coolant 2014 Exam Category R-A Cast 18 Inservice examination Risk-Informed.

31"-RCS-1403-8 Item No. R1.11 450 L limited due to elbow OD Surface examination is Cast Material - Fig. IWB-2500-8 configuration. not required.

Thickness 2.75" Stainless Examination complete Stainless Steel - 450 S from pipe side.

Thickness 2.40 600 L 85.5% No Recordable Indications

Attachment 3 13 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 p f Total Coverage Achieved 268 Sq. Inches O Total Required Examination Area 326 Sq. Inches Limitation Due to I 2"x7" Achieved 82% Code Required Coverage SP-04-1-IR Figure 1

Attachment 3 14 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 1.0" .90" 1.1" .96" .95" .95" Examination Limtcd on Shell side duc to Nozzles and Supports Total Length 81" Total Weld Length 132" Required Exam Volume - 1.88 Sq. Inches Axial Examination Coverage Achieved 1.44 Sq. Inches (6 1%)

Circ. Examination Coverage Achieved 1.00 Sq. Inches (42%)

4-RHE-Al Total Examination Coverage Achieved 51.5%

4-RHE-Al Figure 2

Attachment 3 15 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Examination himted due to Nozzles and Supports Total Length 29" Total Weld Length 132" ERequired Exam Volume - 2.13 Sq. Inches Axial Examination Coverage Achieved 1.01 Sq. Inches (36%)

Cirv. Examination Coverage Achieved 1.34 Sq. Inches 4-RHE-A2 Total Examination Covcragc Achicvcd 43%

4-RHE-A2 Figure 3

Attachment 3 16 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Lum"ingDow Sd&Vew 4-RHE-A2 & 4-RHE-A1 Figure 2 & 3

Attachment 3 17 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Examlnadon Coverag Sunwnwsy Sedon Am Exam W En perCeM

&D*edon E.amh, d Afm Exmbie Lwt Covwag.

1/1 ( 0.41 I 0.88 )x( 8.0 1 37.0 )x100= 10.1%

11J, ( 0.29 1 0.88 )x( 8.0 1 37.0 )xlOO1 7.1% -= , ,.

1/4- ( 0.42 / 0.88 )x( 8.0 1 37.0 )x100u 10.3%

11-. ( 0.42 1 0.88 )x( 8.0 1 37.0 )x100= 10.3%

21t ( 0.67 I 0.88 )x( 21.0 1 37.0 )x100a 43.2%

21, ( 029 I 0.88 )x( 21.0 / 37.0 )xl00= 18.7%

21- ( 0.51 I 0.88 )x( 21.0 1 37.0 )x100- 32.9%

21-. ( 0.51 1 0.88 )x( 21.0 1 37.0 )xl100 32.9% MICB 2 OAs 31T ( 0.67 I 0.88 )x( 8.0 1 37.0 )x100= 16.5%

3/1 ( 0.29 I 0.88 )x( 8.0 I 37.0 )xl00= 7.1% ' rr 31.- ( 0.51 I 0.88 )x( 8.0 / 37.0 )xl00- 12.5%

31-- ( 0.51 1 0.88 )x( 8.0 1 37.0 )xl00= 12.5%

I - )x( I - )xlO00 -

I - )x( I - )x100= -

( I - )x( - )xx lOO - Co.mge IsdMded kilo 3 8cftion duegdifewin sca lM"", WM I Secdon I - lonW .

( I - )x( )x100= -

Secdon 2 - (10.5 + 10.5) - 21" long.

/ - )x( ; - )xloo= - SeDon 3- W.

or Totai Percnt 2i4.1% Weld WeGM - SriJ YW - r f Exam Ams - (0.3W x2.51 - 0.88 Wi.

Code Ex ion Covere (Total Pemret 14 Sound Bems):

4-RHE-Al 1 Figure 4

Attachment 3 18 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Nozzle E Ccverin. 45- RL / GD-RL E Coverage: 45' RL Examn Area - 0.88 In' Examlmned (0.2 x 0.35) + (0.15 x 0.35) + (0.35(0.85 ÷ 1)/2) m0.41 inW Exam Area , 0.88 InW (0.41 /0.88) x (8" of 37) = 1.

Coverage: 45' Shar 70' Shear Coverage: 45' RL / 60' RL R Coverage: 45 RL Exam Area = 0.88 in?

Examined (0.35(0.8 + 1.4)/2) + (0.35(0.65 + 1)12) - 0.67 ink Exam Area a 0.88 inM (0.6710.88) x (21" of 37) = 43*2 Examnked (1.2 x 0.35) m0.42 In2 (0.42 / 0.88) x (8" of 37) a 10.%

4-RHE-A 11 Figure 4

Attachment 3 19 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Nozzle SCoverage: 45" RL 1M Coverage: 45° Shear U Coverage 45 Shear / 70 Shear Coveravegaee 45* RL10'R Exam Area = 0.88 InW Exam Are - 0.88 Irn Examiine (0.35(0.8 + 1A4)12) + (0.35(0.65 + 1)/2) -0.67 In' Examkned (0.35(0.65 + 1)/2) O.29 inW (0.67 / 0.88) x (8"of 37-) - JIM (0.29 / 0.88) x (8' of 37) a 7.1%

4-RHE-Al 1 Figure 4

Attachment 3 20 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Nozzle I*I Coverage: 45a Shear 111] Coverage: 45° RL Exam Area = 0.88 in0 Examined (0.25 x 0.35) + (1.2 x 0.35) - 0.51 Inr (0.51 / 0.88) x (8" of 37') 1a2.%

4-RHE-Al 1 Figure 4

Attachment 3 21 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 FLOW --I-NR NR .403" .316" .330" Flange 45' Elbow "nWke ExamuVoIauu .12 Sq. tudias Upsulmni L'qut&d Winm¶Aduiw -036 SW. bahw V.1.1,. Examhod on ~parnuem side - AW Sq. tnd t

IBMu Effio binirdmailmtftdmffCimmi Lawh 1139' x 'iAft LIT x F"awt .2W tmmWveSlUnnrv- IA"d 3-SI-m40-1 Ir~mi*WuScm- inh hiav~#Wfadlta' fU%*zruwiIp ..

Augle UgabtmAHW Up~bmtrm 0..ivb hd Dautwmb dm.

70 6%1bot efibrt) _ _ _ __ _ _ _ __ _ _ _

CodeComapeaiI 45^4 Patec L. CbGmmraWqerf.totheuinkwun p.waguWdttme~reqksiUIm'INd wibmmthut e§Bdk*mm* u~hedaWoedemm~tn* -rcdr

2. qeq~f dkpXS ristothereqp~dm fw. en* fin axnuaepmdttiewtbefjjth~t mm s*u hmtheas.Ib..nefruia ManAppendhc II demomiba~i racuemfi skye sidaxvrWq 3"-SI-2401 -1 Figure 5

Attachment 3 22 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 3"-$1-2403,36 Flow .

WCW = 0.6, 8*of I I Coverage = 100%

US Coverane = 100%

3"ofll" Pipe 3"of 11" PIPe Far Side Covensage Far side of weld examined as per single sided access ruln - No coverage credit taken.

Scan Limitation No exams peformed on intrados of elbow for 3n due to poor contact.

Coverae Cac:

9 USAxial:100%(11"of1I"):100%

DSAdaI: 100% (8"of I1") = 73%

0 USCirc: 100%(11'of 11")= 100%

DS Ckc: 100% (8" of 11") = 73%

Code Coverage: (100% + 73% + 100% + 73%)14 - 86,5%

3"-SI-2403-35 Figure 6

Attachment 3 23 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0

-Flow Sketch 2 of 2 wCw = 0.8*

6.5" E Coverage = 100%

1.5" of 11" US Coverage

= 100%

1.5" of 11" Far Side Coverage Far side of weld examined as per single sided access rules - No coverage credit taken.

Comae CmLal :

" US Axial: 100% (8" of I1V) = 73%

" DS Axial: 100% (6.5" of 11") = 59%

" US Circ: 100% (8"of 11") =73%

" DS Circ: 100% (6.5" of 11") = 59%

Code Coverage: (73% + 59% + 73% + 59%)4 A 3"-SI-2403-36 Figure 7

Attachment 3 24 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Scan Umfiatfio

" Upstream: Intrados of Elbow. No exams for 3" of 8" due to poor contact.

" Downstream: Pipe Support 4-SIH-35. Dimension - 2.5", scans obstructed for an additional 1" on each side due to U-bolt contacting back of probe. Obstructed length = 4.5" of 11" Lo Exam Length obtructd Pipe by 4-SIH 4.5" Elbow InV161O6 ExIhados

[HI] Singlv sided socess from elbow side.

,3"-St-2403-38 Flow 3"-SI-2403-36 Figure 7

Attachment 3 25 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Flow

.71" .75" 1.01" 45' 700' C- Valve xx Pipe Required Exam Volume - .40 Sq. Inches Downstream Required Exam Volume. 19 Sq. Inches

~ Volume Examined on Downstream side - .06 Sq. Inches (Best Effort)

Exmiauim Vohume Wu Dimensi: Length 2ar x Width L60" x Hdlht .Sr Weld Thickness- Weld Length- W Vd Midth- L=-

Coverage Summary- Weld N 8"-SI-2404-2 Requred Scans- each has a welgNng factor of 100% for complet coverage Angle Upwemm-iAd Upstrem- irc. DoItenmAxll Downstream Cinc.

4500 10D% 0% 0%

6ORL 31% (best effort)

Code Covrage Total 50%

Best Effort Cover 5%T Mae 25%) Total 7.79%

Notes:

L Code Coverage refers to the maximum percentqe of the required exanmination volume that Is effectively exandned with the qualified exami nation procedure

2. Best Effort Coverage refers to the required examination volume pad the centedine that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage 8"-SI-2404-2 Figure 8

Attachment 3 26 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0

ýv

ýVW*

Far side of weld examined as per single aided access rules -

No coverage crodl taken.

T,se r --------

$an Urn n: Radius of Toe lmitd US scans.

Examined 12" of 270 axial exam. Examined 16" of 27 circ exam.

" US Axial = 100% (12" of 27) = 44%

" DSAxial = 100% (27' of 27') = 100%

US Circ= 100% (16" of 27") = 59%

DS Circ = 100% (27" of 27") - 100%

Code Coverage = (44% + 100% + 59% + 100%)/4 = 76%

8"-SI-2407-8 Figure 9

Attachment 3 27 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 1.11" 1.09' 1.12'"

Valve 450 Required Exam Volume - .64 Sq. Inches EM Downstream Required Exam Volume .31 Sq. Inches Volume Examined on Downstream side -. 10 Sq. Inches (Best Effort)

Emiaazom Voblme CDwmesio.: Leagik X1.0 x Wtih 1jr x Hitit WeM lThides- 1Ar Weli leagi- 31.0 Weli Width- L20' Coverage Summary- Weld # 1C-S1-2407-4 Required Scans- each has a weighing factor of 100% for complete coverage AglU m Upstuuamn- Ckc. Dowastrem Axial Downstram Ckc.

45/60,0 100% 100% 0% 0%

GORL 32% (beg effort)

Code Coverae Tota 50%

Best Effort Coverag NLlax 25%) Total 8%

Notes:

1. Code Coverage refers to the minimum percentage of the required eaminatlon volume that is effectvey eaminll with thequ-alfed iaminakton procedure

2. Best Effort Coverage refers to the requdred evarnimnlon volume post the centerline that is evamined in the xdi bmm drecton with an Append. VIM demonstrated procedure for single sided coverage 1 0"-SI-2407-4 Figure 10

Attachment 3 28 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Flow N.

.93" 1.13" 1.12" Valve OWNq Required Exam Volume - .56 Sq. Inches RM Upstream Required Exam Volume .29 Sq. Inches Volume Examined on Upstream side - .29 Sq. Inches go (Best Effort)

Exammatis on OlmeD'siaas: Lengh 31A x Width LW" x elckgt .57" Weld Thkkiess- M WelN teth- R& Wewl Width- LW Coverage Summary- Weld # 10'-SI-2407-5 Required Scans- each has a wekniJ factor of =0 for competoverae Anl Uostreanbdal stbemn-CIc. twnmsuemn A"ii Downstream Oi.

45/60/70 0% 0% 1009 100%

OAL. 50%(besto code Coverage Total 50%

Best EffortCoverag (Max 25%) Total 25%

Notes:

1 Code Coverae refers to the mniintua n percetlage of the required ermmtinatlon volume that is elfefacti eml ined with the qumlified eulnution procedure

2. Best Effort Covemage refers tI the required ,mlnaton volune past thecenterine that is emaAined in theaxidal beam direction with an Appentix VIM demonstrated procedure for single sided covere 10"-SI-2407-5 Figure 11

Attachment 3 29 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0

_,-Flow

.50" .37,, .37" Flange>

Pipe RRequired Exam Volume -. 16 Sq. Inches Downstream Required Exam Volume .07 Sq. Inches Volume Examined on Downstream side - .04 Sq. Inches (Best Effort)

Examination Volume Dimenstao Leqrth W8 x Width LW" x Heiht .12 Weld Thldmces- .%0" Weld Le"I,. 38" Weld Width- .78' Covera. Summary- Weld # 12'-RHR-2402-15 Required Scans- each has a weighing factor of 100% for complete covera Anle Upstrem-Axial Upstream- Circ. Downstream AMial Downstream Cic 45/60/70 100% 10r0 0% 0%

70 52% (best effort)

Code Coverage Total 50%

Best Effort Coverae Max 25%) Total 14%

Notes:

1. Code Coverage refers to the maxhnum percentage of the required examination volume that is effectively examined with the quaflfled examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerlne that Is examined in theaxial beam direction with an Appendix ViII demonstrated procedure for single sided coverage 12"-RH R-2402-15 Figure 12

Attachment 3 30 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 36 .9 AS' Flow '.. _W .9* .S Tee

'rev ORequired Exam Volume -. 15 Sq. Inches Required Exam Volume - .15 Sq. Inches 9=Upstream Required Exam Volume .07 Sq. Inches Downstrm Required Exam Volume .07 Sq. Inches

_Volume Examined on Upstream side - .04 Sq. Inches Volume Examined on Downstream side - .04 Sq. Inche (Best Effort) (Best Effort)

Examinatiotn Limitedto Single side from rto IS" and 29to 37"total 16"

=1-Ww~bmd ILob ar x WAM IM zHa W Cwuowp-ArV Lalb-Wy 5 V Wdaj r-s m2 1 Cmwq~umw. VAddrC4M24D5 mff 70 2M -kt I I 22%Ibdb't Cffmt M 105

2. ~ uinwi~udujuizmtCut ftkwa.~u upe~a

. C~GA~~v* i ifill 111III , 11, "w~ide

anEnta 1411ed l" 14"-RHR-2403-1 Figure 13

Attachment 3 31 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0

.,0 A. .37" Flow -..

.41 .3r pipe ipec URequired Exam Volume -. 15 Sq. Tuches 0Requred Examn Volume - .40 Sq. Inches n24 Ulstream Required Exam Volume .20 Sq. Indhes

-:24 Volume Examined an Upstreamn side - .04 Sq. Incht (Best Effort)

Examination Limited to Single side from 7" to 15" and 29 to 37" total 16" v9 Vmeswubm Loh 4 x Vdh L.W' s HW*t .I w'

b 4r" dWib- .Wi" cMrAp SunWy AWdd# lr-NH-WZD2 N702kws m-chWavdat- wI I w II

'M zTi &Ed Mtat)

FudCUk1le're 14 x cEffCmwqp*tethftt Anmdormomup h qmpmdt 1 1, iht is 14"-RHR-2403-2 Figure 144

Attachment 3 32 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0

,ZF~ow

.50" .37" .37" Valve -wrww7 r ibow Required Exam Volume -. 15 Sq. Inches Downstream Required Exam Volumc .07 Sq. Inches Volume Examined on Downstream side - .03 Sq. Inches (Best Effort)

Examination Volume Dimensions: Length 44' x Wkdth LjD x Height .12" Weld Thickness- .50- Weld Lefnth Weld Width= .7j" Covera*e Summary- Weld # 14"-RHR-2403-4 Reqired Scans- each has a weighing factor of 100% for complete coverage Angle Upstrea-Ai"d Upstream- Crc. Downsbeam Axial Downstreum Circ.

45/o0/70 100% 100% 0% 0%

70 42% (best effort)

Code Coverage Total 50%

Best Effort Coverage (Max 25%) Total 10.5%

Notes:

1. Code Coverage refers to the maximum percentage of the requlred examination voklue that is effectively examined with the qualifed examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage 14"-RHR-2403-4 Figure 15

Attachment 3 33 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0

.. Flow .41" .3J 39* W3 .37$1 T=* W4?

Tee ý7 Pipe OEM = Required Exam Volume -.40 Sq. Inches 9 0 1quirid Exam Volume- .40 Sq. Inches EDownstream Required Exam Volume .20 Sq. Inches Volume Examined on Downstream si -.04 S4 Inches (Beat Effort)

Examination Limited to Single side from 7" to 15" and 29 to 37" total 16" Fj ~~ ~- - L~s r zaffhW LI xvd x NeW .1?

- Wh*(b ftI-A bwpm XM 1 62 2 D~(bsdut SO w Ojj.hwW Tidv sm bteabmbmm thmw Tol if~

ddkd 14"-RHR-2404-17 Figure 16

Attachment 3 34 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Flow 2.76" 2.620 2.33*

O Transition Require Exam Volume - 1.4 Sq. Inches Require Exam Volume a2.00 Sq. Inches o Axial Volime Exwa ined on EIbow S -125 Sq.

kise (3%)

in M CWc Voxrne E ned on Ebow Side - 1.06 Sq. In(52%)

Examination Volume Dimensions: Length 97.3" x Width 3.95" x Height

.91" Weld Thickness = 2.62" Weld length = 97.3" Weld Width = 2.37" Coverage Summary - 31"-RCS-1402-6 Required Scans - each has a weighing factor of 100% for complete coverage Angle Upstream - Upstream - Downstream - Downstream -

Axial Circ Axial Circ 45S/60SI45RL 0% 0% 100% 100%

45RL 63% 52% 0% 0%

Code Coverage Total 78.75%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

31 "-RCS- 1402-6 Figure 17

Attachment 3 35 of 35 TURKEY POINT UNIT 4 FOURTH INSPECTION INTERVAL RELIEF REQUEST NUMBER 17 REVISION 0 Flow 2.75" 2.25" 2.40" 2.40" O0 Transition Elbow pipe 66VIRL Requie Exam Vokmae - 1.15 Sq. Inch* Requie Exm. Volume - 1.3 Sq. Inche (1.52'.90 - 1.36 Sq. Inches) RE (1.60*M0 a 1.44 Sq. Inches)

EF AxMl Volume Exwiined on Elbow Side - 1.05 Sq. In (90%)

Circ Volume Examined on Elbow Side - .61 Sq. in (52%) 1l Examination Volume Dimensions: Length 97.3" x Width 1.51" x Height .90" Weld Thickness = 2.43" Weld length = 97.3" Weld Width = 2.10" Coverage Summary - 31"-RCS-1403-8 Required Scans - each has a weighing factor of 100% for complete coverage Upstream - Upstream - Downstream - Downstream -

Angle Axial Circ Axial Circ 45S160S/45RL 0% 0% 100% 100%

45RL 90% 52% 0% 0%

Code Coverage Total 85.5%

Notes:

2. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

31 "-RCS- 1403-8 Figure 18

v t e Letter Sequence Request
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Initiation Request Acceptance... Administration Questions Answers 25 September 2015 Results Approval Other:
MONTHYEAR2015-02-13 [Table View]

L-2015-020, Closeout of the Fourth Ten-Year Inservice Inspection (ISI) Interval Relief Requests Nos. 15, 16, 17

Text

2. Applicable Code Edition and Addenda

3. Applicable Code Requirement

2. Applicable Code Edition and Addenda

2. Applicable Code Edition and Addenda

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L-2015-020, Closeout of the Fourth Ten-Year Inservice Inspection (ISI) Interval Relief Requests Nos. 15, 16, 17

Text

2. Applicable Code Edition and Addenda

3. Applicable Code Requirement

2. Applicable Code Edition and Addenda

2. Applicable Code Edition and Addenda

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