L-2015-100, Fifth Ten-Year Inservice Inspection (ISI) Interval Relief Request No. 2
| ML15177A085 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/08/2015 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2015-100 | |
| Download: ML15177A085 (9) | |
Text
0 JUN 0 8 2015 F:L.
L-2015-100 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 Fifth Ten-Year Inservice Inspection (ISI) Interval Relief Request No. 2 Pursuant to 10 CFR 50.55a(z)(1), Florida Power & Light Company (FPL) requests approval of the attached Relief Request 2 for the Fifth Ten-Year Inservice Inspection (ISI) Interval Program for Turkey Points 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, 2007 Edition with Addenda through 2008 as amended by 10CFR50.55a, is the code of record for the Turkey Point units 3 and 4, 5th 10-year interval.
Relief is requested from the Code required examinations on the Regenerative Heat Exchanger shell welds, support welds, and component supports.
Regenerative Heat Exchangers are located in locked high radiation areas with limited accessibility to examination areas due to close proximity of the adjacent wall and floor, and limited work area due to cubicle walls built to shield personnel in adjacent areas, as well as interference from other lines and supports in the immediate area. FPL proposes to perform a VT-2 visual examination at the beginning of the outage for leakage and boric acid accumulation and a VT-2 visual examination at startup during the system leakage test.
FPL concluded that the use of the proposed alternative visual examinations provides an acceptable level of quality and safety.
If you have any questions or require additional information, please contact Mr. Mitch Guth, Licensing Manager, at (305) 246-6698.
Sincerely, Michael Kiley Site Vice President Turkey Point Nuclear Plant Attachment cc:
Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant A&f-7 Florida Power, Light Company 9760 S.W. 344"' Street Homestead, FL 33035
L-2015-100 ATTACHMENT TURKEY POINT UNITS 3 AND 4 FIFTH TEN-YEAR ISI INTERVAL RELIEF REQUEST No. 2
L-2015-100, Attachment TURKEY POINT UNITS 3 & 4 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. 2 ALTERNATIVE EXAMINATION FOR THE REGENERATIVE HEAT EXCHANGER Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected Class 1 Regenerative Heat Exchangers at Florida Power & Light (FPL) Turkey Point Nuclear Plants, Units 3 & 4.
Weld Description Weld Numbers (Same for Both Units)
RGX I-1 Head to Shell RGX II - 1 RGX III - 1 RGX I - 2 Shell to Tube Sheet - Primary RGX II - 2 RGX III - 2 Tube Sheet to Shell -
RGX I - 3 Secondary RGX III - 3 RGX II -43 Channel Head Weld RGX I - 4 Secondary RGX III - 4 RGX I - 9 RGXI - 19 Shell I Nozzle Welds RGX I - 10 RGX I-11 RGX I - 12 RGX II - 9 RGX II -10 Shell II Nozzle Welds RGX 11 - 10 RGX 11 - 11 RGX II - 12 RGX III - 9 RGX III1-10 Shell III Nozzle Welds RGX Ill - 10 RGX III - 11 RGX III - 12 RGX I - LUG Integrally Welded Supports RGX II - LUG RGX III - LUG RGX I - CR Clamp Restraint RGX II - CR RGX III - CR 1 of 7
L-2015-100, Attachment TURKEY POINT UNITS 3 & 4 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. 2
2. Applicable Code Edition and Addenda
Inservice inspections (ISI) are performed per the requirements of the ASME Boiler and Pressure Vessel Code Section XI, 2007 Edition with the 2008 Addenda as required by 10CFR50.55a.
3. Applicable Code Requirement
Exam Cat Item Number Examination Requirements Category Volumetric examination, to include 100% of the length B-B of circumferential tube sheet to shell welds and head to B2.80 shell welds B3.150 Volumetric examination, to include 100% of each B3.160 nozzle to vessel weld and nozzle inside radius area Volumetric or surface examination to include 100% of each integrally welded attachments of one exchanger.
Examine welds, mechanical connections, clearances, F-A F1.40 alignment, sliding surfaces, and assembly of the supports.
4. Reason for Request
Pursuant to 10CFR 50.55a (z)(1), FPL requests relief from the Code required examinations on the Regenerative Heat Exchanger shell welds, support welds, and component supports.
Refer to Figure 1 and 2 for Regenerative Heat Exchanger components and examination limitations.
Turkey Point Turkey Point Item Number Examination Areas Unit 3 Unit 4 B2.51 Head to Shell circumferential Welds 6 Welds 6 Welds B2.80 Shell to Tubesheet Welds 6 Welds 6 Welds B3.150 Nozzle to Shell Welds 12 Welds 12 Welds B3.160 Nozzle Inside Radius Section 12 Areas 12 Areas B10.10 Welded Attachments 3 Welds 3 Welds F1.40 Supports 3 Supports 3 Supports Regenerative Heat Exchangers are located in locked high radiation areas. These areas typically have a general radiation field of 2 Rem/hr and are highly contaminated. Other conditions include limited accessibility to examination areas due to close proximity of the adjacent wall and floor, limited work area due to cubicle walls built to shield personnel in adjacent areas, and interference from other lines and supports in the immediate area.
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L-2015-100, Attachment TURKEY POINT UNITS 3 & 4 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. 2 During construction of Turkey Point Units 3 and 4, asbestos insulation was used extensively.
Asbestos insulation is present in the area of the Regenerative Heat Exchangers. Additional protection is required for personnel entering these areas to avoid possible spreading and ingestion of this hazardous material (i.e., an extra layer of protective clothing, tenting, HEPA filters.)
Performing Code required examinations would require large expenditures of man-hours and accumulated Man-Rem dose. These welds must be uninsulated for examination and also require installation of temporary shielding and scaffold.
Effective shielding reduces accessibility to the examination areas.
Proper surface conditioning required to perform surface and volumetric examinations adds additional time and exposure. These areas must be tented to avoid spreading of asbestos fibers found in the insulation.
Estimated Time and Man-Rem for Regenerative Heat Exchanger Weld Examinations Dose Man Estimated Job Description Rate Hours Man-Rem Rem/Hr.
Tenting and HEPA Filter Installation 0.7 8.0 5.600 Insulation Removal (Asbestos) 2.0 8.0 16.000 Scaffold Installation 0.7 3.0 2.100 Lead Installation 2.0 5.0 10.000 Surface Preparation for Examination 2.5 16.0 40.000 ISI Examination 2.5 5.5 13.750 Install Insulation 2.0 12.5 25.000 Remove Scaffold 0.7 1.5 1.050 Remove Tent and HEPA Filter 0.7 2.5 1.750 Temporary Services 0.7 0.5 0.350 Lead Removal 2.0 2.0 4.000 Clean Up 1.0 2.0 2.000 Note: These estimates are valid for both units.
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L-2015-100, Attachment TURKEY POINT UNITS 3 & 4 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. 2
5. Proposed Alternative and Basis for Use
Proposed Alternative FPL will perform a VT-2 visual examination at the beginning of the outage for leakage and boric acid accumulation and a VT-2 visual examination at startup during the system leakage test.
Basis for Use FPL has performed examinations on the Regenerative Heat Exchangers for both Turkey Point Units 3 and 4 during the first inspection interval (approximately early 1972 through late 1983) before the original relief request was approved.
This experience showed that the design arrangement and accessibility are not conducive to meaningful examinations. The configuration, limited accessibility, high radiation levels, and interference from supports, walls, and the floor do not support Code required examination coverage for volumetric and/or surface examinations.
Since 1985, FPL has performed VT-2 examinations on the items listed in this relief request.
These examinations were performed in accordance with the previous approved relief request, which required FPL to look for evidence of leakage around the Regenerative Heat Exchanger just after shutdown for a refueling outage and a second time during the system pressure test at plant startup. No evidence of leakage from the Regenerative Heat Exchanger or its attached piping has been noted in either unit during any of the previous examinations.
FPL concluded that the proposed alternative visual examinations at the stated frequency provides an acceptable level of quality and safety to the Code required examinations conducted once per interval.
- 6. Duration for the Proposed Alternative This relief is requested for the duration of the Fifth Inservice Inspection Interval, which begun on February 22, 2014 for Turkey Point Unit 3, and on April 15, 2014 for Turkey Point Unit 4.
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L-201 5-100, Attachment TURKEY POINT UNITS 3 & 4 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. 2
7. Precedents
USNRC letter to Mr. J. W. Williams, Jr., Vice president, Florida Power & Light, dated February 4, 1985 granting relief from ASME Section Xl Requirements, TAC Nos. 49133, 49936, 54677, 54678, 54973, and 54974.
USNRC letter to Mr. J. H. Goldberg, President Nuclear Division, Florida Power & Light, dated March 31, 1995 granting relief from ASME Section Xl Requirements, TAC Nos. M87725 and M87726).
USNRC letter to Mr. J. A. Stall, President, Nuclear and Chief Nuclear Officer, Florida Power &
Light, dated March 3, 2005 granting relief from ASME Section Xl Requirements, TAC Nos.
MC2420 and MC2421, ADAMS Accession No. ML050350363.
- 8. Figures Figure 1:
Examination Area Limitations Figure 2:
Drawing of Unit 3 & 4 Regenerative Heat Exchanger 5 of 7
L-2015-100, Attachment Turkey Point Units 3 & 4 Fifth Inservice Inspection Interval Relief Request No. 2 Figure 1 Examination Area Limitations Tubesheet ClamD Limited examination from Shell side due to Nozzle.
Limited examination on Cap side due to configuration. Weld examination is limited on cap side due to lug (Typical three welds)
Limited exam in Shell side due to Clamp (Typical 4 areas)
No examination on weld or Nozzle side due to configuration (Typical 12 areas). Limited examination on Shell side due to clamp (Typical 4 areas)
CA CAP SHELL No examination of lug due to angle iron bracket covering.
Limited examination from Shell side due to Nozzle configuration.
No examination on tubesheet side due to clamp.
Limited examination from shell side due to (Typical 3 welds).
No examination from tubesheet side due to clamp.
Limited examination on Cap side due to configuration (Typical 3 welds).
Limited examination from Shell side due to nozzle (Typical 3 welds).
Limited exam in Shell side due to Clamp.
(Typical 4 areas) 6 of 7
L-2015-100, Attachment Turkey Point Units 3 & 4 Fifth Inservice Inspection Interval Relief Request No. 2 Figure 2 Turkey Point Units 3 and 4 2"-CH-1402 3-CH-1403 2"-CH-1 302 3"-CH-1 303 RG RX19RGX-1-1 0
RGX-1-4 RX1LGRGX-1-1 1
RGX-i-2---,mLRGX-1-1 2
Lug Resting on RGX-I-CR Angle iron bracket RGX-CAP SHELL II SHELL CAP RGX-11-LUG RGX-I-1 I RGX-11-2 I-*RGX-11-12 RGX-II-CR I
i 4RGX-I1-3 RGX-III-1 RGX-111-9
/
RGX-III-10 RGX-111-4 2"-CH-1301 3"-CH-1301 2"-CH-1401 3"-CH-1401 7 of 7