L-2015-172, Response to Request for Additional Information for Relief Request No. 15 for the Fourth 10-Year Inservice Inspection Interval -

Response to Request for Additional Information for Relief Request No. 15 for the Fourth 10-Year Inservice Inspection Interval -

ML15205A317
Person / Time
Site:	Turkey Point
Issue date:	07/08/2015
From:	Summers T Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2015-172
Download: ML15205A317 (26)

Text

0 JUL 08 2015 FPL. L-2015-172 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 RE: Turkey Point Unit 3 and Unit 4 Docket Nos. 50-250 and 50-251 Fourth 10-Year Inservice Inspection Interval Response to Request for Additional Information for Relief Request No. 15 By letter L-2015-020, dated February 13, 2013 (Agency-wide Documents Access and Management System (ADAMS), Accession No. ML15062A279), Florida Power & Light Company (FPL) submitted Relief Request (RR) No. 15, for the Fourth Inservice Inspection (ISI) Interval for Turkey Point Units 3 and 4, requesting relief from the volumetric examination coverage requirements of Section Xl of the American Society of Mechanical Engineers Code (ASME Code,Section XI).

The Nuclear Regulatory Commission (NRC) Staff reviewed RR 15 and identified areas where they need additional information and clarification in order to complete their review.

On June 4, 2015, Ms. Audrey Klett, NRC Project Manager for Turkey Point Units 3 and 4 provided the request for additional information (RAI) via electronic mail and requested the response to these RAI questions by July 10, 2015.

The enclosure to this letter contains the NRC's Request for Additional Information (RAI) questions for RR No. 15, and the corresponding FPL responses.

If there are any questions regarding this request, please contact Mr. Mitch Guth, Turkey Point Licensing Manager, at (305) 246-6698.

Sincerely, 6homas Summers Site Vice-President Turkey Point Nuclear Plant Enclosure cc: Regional Administrator, Region II, USNRC Project Manager, NRR, USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant 4ccnc-7 I

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

FPL Letter L-2015-172 ENCLOSURE Florida Power & Light Company Turkey Point Units 3 and 4 Relief Request No. 15 Responses to NRC Request for Additional Information (RAI)

Questions

L-2015-172, Enclosure Page 2 of 25 NRC RAI-la:

On page 2 of Relief Request No. 15 (Attachment 1), the description for Examination Category B-A, Item B1 .11 for the Reactor Pressure Vessel (RPV) Lower Shell to Lower Head Ring Weld (i.e., Weld 3-WR-31 for Unit 3 and Weld 4-WR-31 for Unit 4) states, "Figure 2 and 3 provides an illustration of the weld volume limitation due to the instrumentation tubes." It is further stated that, "The examination of the Figure IWB-2500-1 A-B-C-D volume is limited due to the proximity of the instrumentation tubes." However, Figures 2 and 3 of Relief Request No. 15 show limitations caused by the Core Support Lugs (or Core Guide Lugs). Clarify the limitations associated with the examinations for Welds 3-WR-31 and 4-WR-31 for Turkey Point 3 and 4. Also, clarify whether the Core Support Lugs are the same as the Core Guide Lugs.

FPL Response to RAI-la:

The limitation referenced for 3-WR-31 and 4-WR-31 welds is a typo. The text should reference the limitation as Core Support Guide Lugs not instrumentation tubes. Figures 2

& 3 reference the correct limitation.

For clarification, Core Support Lugs are the same as the Core Guide Lugs.

NRC RAI-1 b:

With respect to Figure 2 for Category B-A, Item 81.11, Lower Shell to Lower Head Ring Welds (Weld 3-WR-31 for Unit 3 and 4-WR-31 for Unit 4), provide the following information in a diagram showing: (1) the ASME Code, Section Xl required examination volume, (2) the scan angles and axial distances of the search units from the welds used for the examination, and (3) the actual scanned volumes for both the axial and circumferential scan directions. Please refer to the industry/NRC information exchange public meeting held on January 13 -15, 2015 (ADAMS Accession Number ML15013A266),

for a discussion of the NRC staff's expectations for the content of an inspection diagram (see Slide 12 for an example).

FPL Response to RAI-1 b:

The following information is provided for the Category B-A, Item B1.11, Lower Shell to Lower Head Ring Welds (Weld 3-WR-31 for Unit 3 and 4-WR-31 for Unit 4):

(1) The ASME Code, Section Xl required examination volume is illustrated on pages 4 through 9 of this enclosure. The examination volume includes the weld and 1/2 "T" of the base material on each side of the weld for the complete through wall thickness.

(2) The scan angles and axial distances of the search units from the welds used for the examination are provided on pages 4 through 9 of this enclosure. The search unit shown in the illustrations does not reflect the actual size of the UT head configuration. Refer to Figure 1 of the original relief request.

(3) The actual scanned volumes for both axial and circumferential scan directions are located on page 3 of this enclosure.

L-2015-172, Enclosure Page 3 of 25 Turkey Point 31 ESTIMATED EXAMINATION COVERAGE FOR WELD: W04 LOWER SHELL TO LOWER HEAD RING WELD Summary Number: 000400, Component ID: 3-WR-31 Scan Plan Drawing Number: 8068905D Sheets 10 & 13, WELD VOLUME COVERAGE OBTAINED: 85%

Zone Coverage Obtained Inner 15%T: 76.7% Outer 85%T: 86.8% Aggregate: 85.2%

Examination Volume Definition Weld Length: 497.942 in.

Area Measurement (axial plane) Volume Calculation Inner 15%T 6.38 sq. in. Inner 15%T 3176.87 cu. in.

Outer 85%T 32.80 sq. in. Outer 85%T 16332.51 cu. in.

Limitations I Limits scan by: Compensation(s)

Core Support Lugs Restricts UT head movement Single Sided scans Examination Coverage Calculations INNER 15%T Axial Beam Direction Coverages Exam. Area Length Volume Volume Angle Beam Examined Examined Examined Required Percent Entry # (deg.) Direction (sq. in.) (in.) (cu. in.) (cu. in.) Examined Limited Comment 1 70L/45L Up/Dn 6.38 353.40 2254.69 2254.69 100.0% No Coverage between lugs 2 70LU45L Up/Dn 1.80 161.80 291.24 1032.28 28.2% Yes Coverage below lugs Total Axial Coverage 515.20 2545.93 3286.98 77.5%

CircumferentialBeam Direction Coverages Exam. Area Circ Extent Axial Extent Angle Beam Examined Examined Examined Percent Entry # (deg.) Direction (sq. in.) (%) (%) Examined Limited Comment 3 70LU45L CW/CCW 6.38 76.0% 100.0% 76.0% No Coverage between lugs 4 70U45L CW/CCW 0.00 0.0% 0.0% 0.0% Yes No coverage below lugs Total Circ. Beam Direction Coverage: 76.0%

Inner 15% coverage: 76.7%

OUTER 85%T Axial Beam Direction Coverages Exam. Area Length Volume Volume Angle Beam Examined Examined Examined Required Percent Entry # (deg.) Direction (sq. in.) (in.) (cu. in.) (cu. in.) Examined Limited Comment 1 45LJ45S Up/Dn 32.80 353.40 11591.52 11591.52 100.0% No Coverage between lugs 2 451145S Up/Dn 21.84 161.80 3533.71 5307.04 66.6% Yes Coverage below lugs Total Axial Coverage 515.20 15125.23 16898.56 89.5%

CircumferentialBeam DirectionCoverages Exam. Area Circ Extent Axial Extent Angle Beam Examined Examined Examined Percent Entry # (deg.) Direction (sq. in.) (%) (%) Examined Limited Comment 3 45U45S CW/CCW 32.80 80.0% 100.0% 80.0% No Coverage between lugs 4 45U45S CW/CCW 6.56 20.0% 20.0% 4.0% Yes Coverage below lugs Total Circ. Beam Direction Coverage: 84.0%

Outer 85% coverage: 86.8%

Footnote: This is representative for Turkey Point Unit 4: Weld 4-WR-31

L-2015-172, Enclosure Page 4 of 25 3-WR-31 and 4-WR-31 7.88 BMT1 Lii C-)

1.18(15%T1) 6.69(85%T1)

S(Z = 331.56,) -MT1/94 101.01. 102.7T

,'* BMT1i/2 WELD W04 t*_ (Z = 335.50)

(100.50')

(102.13") BMT2/2=2.38 0.71(15%T2) 4.04(85%T2)

Drawlin Positions (deg) Adjuasted Distance from Y*1d (in) 4.75 BMT2 WeldCL IZ, Z, WeldCL IZ, 1 4o 100.52 1 102.75 1 101.01 1 0.00 1 -3.08 1 -0.68 1 45L I 70L Z, is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z2 is the highest vertical elevetion of the two Z positions (excluding the weld center line (CL))

I ACTUAL COVERAGE All measurements from Weld CL are surface distance, Motion on surface is ANGULAR (Alpha Motion on IWS). --1 MISSED VOLUME 15% - "UP" BELOW CORE LUGS

L-2015-172, Enclosure Page 5 of 25 3-WR-31 and 4-WR-31 7.88 BMT1 1.18(15%T1) 6.69(85%T1) z 98.9B"

,o (Z = 331.56) 102.01' VBMT1/2 (Z = 335.50) =3.94 WELD W04 -_ 35 (100.50-)

(102.13") BMT2/2=2.38 0.71(15%T2) 4.04(85%T2)

\ 4.75 BMT2 Drawving Positions (deg) Adjusted Distance from V*Id (in)I WeldCL I Z, Z, Mid CL I Zt Anigles 100.52 I 102.01 I 98.96 I 0.00 I -2.06 I 2.15 I 45L I 70L- I Z, is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z 2 is the highest vrtical elevation of the two Z positions (excluding the weld center line (CL))

E ACTUAL COVERAGE AJl measurements from Weld CL are surface distance.

Motion on surface is ANGULAR (Alpha Motion on TINS). F-- MISSED VOLUME 15% "DOWN" BELOW CORE LUGS

L-2015-172, Enclosure Page 6 of 25 3-WR-31 and 4-WR-31 7.88 BMT1

(-)

C-1.18(15%T1) zI 6.69(85%T1) 101.37"

- (Z = 331.56) T BMT1/2 105.80'

=3.94 WELD W04 _ (Z : 335.50) __

(1.00.5Tr)

(102. 1,T) BMT2/2=2.38 0.71(15%T2) 4.04(85%T2)

$s 4.75 BMT2 Drawing Positions (dleg) Adjuzsted Distance from Mid (n Mid CL I Z, Z, WeldC L Z, I zle 100.52 1105.80 1 101.37 0.00 1 -7.29 1 -1.17 1 45L 5 Z, is the lower vertical elevetion of the two Z positions (excluding the weld center line (CL))

Z2 is the highest m"tical elexetion of the two Z positions (excluding the weld center line (CL)) I ACTUAL COVERAGE Allmeasurements from Weld CL are surface distance.

Motion on surface is ANGULAR (Alpha Motion on "WS).

F-] MISSED VOLUME Lower Head radius 79.09" Ccersion incheSr/=2n(79.09")/360' or 138 in/deg.

85% "UP" BELOW CORE LUGS

L-2015-172, Enclosure Page 7 of 25 3-WR-31 and 4-WR-31 7.88 BMT1 1.18(15%T1) 6.69(85%T1) to (z = 331.56)

,'* BMT1 T /2 A3 98.98*

101.49"

_ (Z = 335.50) _-3"94 WELD W04 (1000.50)

(102.13') BMT2/2=2.38 0.71(15%T2) 4.04(85%T2) 4.75 BMT2 Drawing Poslitons (deg) Adjusted Distance from Mid (in)

WeldCL z, Z, IWed CL Zý Z, Angles 100.52 101.49 98.98 0.00 -1.34 2.13 45L 45S E ACTUAL COVERAGE zl is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z, is the hiohest wrtical elevetion of the two Z Dositions (excludino the weld center line (CL~i

[Z MISSED VOLUME Allmeasurements from Weld CL are surface distance.

Motion on surface is ANGULAR (Alpha Motion on 7WS).

Lower Head radius 79.09" Conversion inches/*=2n(79.09")/360 or 1.38 in/deg.

85% - "DOWN" BELOW CORE LUGS

L-2015-172, Enclosure Page 8 of 25 3-WR-31 and 4-WR-31 7.88 BMT1 C/) 1.18(15%T1)

M, 6.69(85%TI) 99.95.

102.13' S(z = 331.56)

BMT1/2 (z = 335.50) -3.94 WELD W04 ý (100.50)

(102.1')-L BMT2/2=2.38 0.71(15%T2) 4.04(85%T2) 4.75 BMT2 Drawing Positions (deg) Adjusted Distance from Mid (in)..

kId CLI Z, Z, WeldCL I 1 I Z 1 hile 100.52 102.13 99.95 0.00 -2.22 0.79 45, 1 70L N ACTUAL COVERAGE 7- is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Zz is the hiohest vertical elevation of the two Z oositions (excludino the weld center line (CLI) D MISSED VOLUME Allmeasurements from Weld CL are surface distance.

Motion on surface is ANGULAR (Alpha Motion on 1WS).

Lower Head radius 79.09" Convrsion inchesO--2Tr(79.09")y360° or 1.38 Inideg.

15% "cw/ccw"' BELOW CORE LUGS

L-2015-172, Enclosure Page 9 of 25 3-WR-31 and 4-WR-31 7.88 BMT1 1.18(15%T1)

CD 6.69(85%TI) 0 99.95.

102.137

.,* (Z = 331.56)

BMT1/2 WELD W(4 Z.

(Z = 335.50) -3"94 (100.50.)

(102.1 Y) BMT2/2=2.38 0.71(15%T2) 4.04(85%T2) 4.75 BMT2 Z4 is the lower vertical elevtion of the two Z positions (excluding the weld center line (CL)) I ACTUAL COVERAGE Z7 is the highest vertical eleation of the two Z positions (excluding the weld center line (CL))

L] MISSED VOLUME 8507o - 85-"CW/CCW/c" BELOW CORE LUGS

L-2015-172, Enclosure Page 10 of 25 NRC RAI-Ic:

With respect to Figure 5 for Category B-A, Item B13.30, Upper Shell to Flange Welds (Weld 3-WR-18 for Unit 3 and 4-WR-18 for Unit 4), provide the following information in a diagram showing: (1) the ASME Code,Section XI required examination volume, (2) the scan angles and axial distances of the search units from the welds used for the examination, and (3) the actual scanned volumes for both the axial and circumferential scan directions. Please refer to the industry/NRC information exchange public meeting held on January 13 -15, 2015 (ADAMS Accession Number ML15013A266), for a discussion of the NRC staff's expectations for the content of an inspection diagram (see Slide 12 for an example).

FPL Response to RAI-tc:

The following information is provided with respect to Figure 5 for Category B-A, Item B13.30, Upper Shell to Flange Welds (Weld 3-WR-18 for Unit 3 and 4-WR-18 for Unit 4):

(1) The ASME Code,Section XI required examination volume is illustrated on pages 12 through 23 of this enclosure. The examination volume includes the weld and 1/2 "T" of the base material on each side of the weld for the complete through wall thickness.

(2) The scan angles and axial distances of the search units from the welds used for the examination are located on the inspection diagrams on pages 12 through 23 of this enclosure. The search unit shown in the illustrations does not reflect the actual size of the UT head configuration. Refer to Figure 1 of the original relief request.

(3) The actual scanned volumes for both axial and circumferential scan directions are located on page 11 of this enclosure.

L-2015-172, Enclosure Page 11 of 25 Turkey Point 32 ESTIMATED EXAMINATION COVERAGE FOR WELD: W01 FLANGE TO UPPER SHELL WELD Summary Number: 000100 Component ID: 3-WR-18 Scan Plan Drawing Number: 8068905D Sheets 6 & 9 WELD VOLUME COVERAGE OBTAINED: 75%

Zone Coverage Obtained Inner 15%T: 81.5% Outer 85%T: 74.4% Aggregate: 75.5%

Examination Volume Definition Weld Length: 489.49 in.

Area Measurement (axial plane) Volume Calculation Inner 15%T 29.21 sq. in. Inner 15%T 14298.05 cu. in.

Outer 85%T 157.90 sq. in. Outer 85%T 77290.72 cu. in.

Limitations Limits scan by: Cornpensation(s)

Keyways and Slight reduction in axial and circ scan directions above weld due to interference with Irradiation slots. Flange keyways and slots at 150,1050, 1950, 2850, 700, 800, 900, 1300,1900, 3100, 3200, Used single sided scans Radius @ID above 3300 and flange radius 3600 weld.

Examination Coverage Calculations INNER 15%T Axial Beam Direction Coverages Exam. Area Length Volume Volume Angle Beam Examined Examined Examined Required Percent Entry # (deg.) Direction (sq. in.) (in.) (cu. in.) (cu. in.) Examined Limited Limitations 1 70L/45L Up/Down 10.38 489.49 5080.92 14298.05 35.5% Yes Scan from below flange radius 2 70LU45L Up/Down 13.80 384.62 5307.80 11234.84 47.2% Yes Scan from above flange radius Total Axial Coverage 12697.26 14614.89 86.9%

Circumferential Beam Direction Coverages Exam. Area Length Volume Volume Angle Beam Examined Examined Examined Required Percent Entry # (def.) Direction (sq. in.) (in.) (cu. in.) (cu. in.) Examined Limited Comment 3 70LU45L CW/CCW 9.17 489.49 4488.64 14298.05 31.4% Yes Scan from below flange radius 4 70LU45L CW/CCW 12.86 391.79 5038.39 11234.84 44.8% Yes Scan from above flange radius Total Circ. Beam Direction Coverage 76.2%

Inner 15% coverage: 81.5%

OUTER 85%T Axial Beam Direction Coverages Exam. Area Length Volume Volume Angle Beam Examined Examined Examined Required Percent Entry # (deg.) Direction (sq. in.) (in.) (cu. in.) (cu. in.) Examined Limited Limitations 1 45L/45S Up 87.64 489.49 42899.04 77290.72 55.5% Yes Scan from below flange radius 2 45LJ45S Down 51.98 384.62 19992.71 60731.99 32.9% Yes Scan from above flange radius 3 45L145S Down 43.51 49.61 2158.53 60731.99 3.6% Yes Scan from above flange radius Total Axial Coverage 65050.28 198754.69 92.0%

Circumferential Beam Direction Coverages Exam. Area Length Volume Volume Angle Beam Examined Examined Examined Required Percent Entry # (deg.) Direction (sq. in.) (in.) (cu. in.) (cu. in.) Examined Limited Comment 4 45L/45S CW/CCW 53.41 489.49 26143.74 77290.72 33.8% Yes Scan from below flange radius 5 45L/45S CW/CCW 45.33 391.79 17759.75 77290.72 23.0% Yes Scan from above flange radius Total Circ. Beam Direction Coverage 56.8%

Outer 85% coverage: 74.4%

2 This is representative for Turkey Point Unit 4: Weld 4-WR-18

L-2015-172, Enclosure Page 12 of 25 3-WR-18 and 4-WR-18 MATING SURFACE

= 0.00 LOCATIONS AT 105". 195', AND 285" (15%71)

-Z = -24.63

-Z = -28.77

-Z - -34.50 1.37

-(1AT2)

Drawing Positions Adjusted Distance from WlLd WeldCIL Z, Z2 Weid CL Z, Zn2e

-34.50 -28.77 1-24.63 0.00 5.73 9.87 145 70 Z, is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z 2 is the highest vertical elevetion of the two Z positions (excluding the weld center line (CL))

ACTUAL COVERAGE E MISSED VOLUME 15% - "UP" UPPER FLANGE COVERAGE AT SLOTS (8) - NOT SHOWN COVERAGE AT KEYWAYS (4)

L-2015-172, Enclosure Page 13 of 25 3-WR-18 and 4-WR-18

= 0.00 LOCATIONS AT 105', 195', AND 285'

-- Z - -21.92

- Z - -25.90 WELDWO1 I z - -34.50 Z = -40.40 I D)rawing Positions IMdusted Distance from Weld ZI~ I Z, WeldCLI. Z, I Z2e I -34.50 I -25.90 1 -21.92 1 0.00 1 8.60 I 12.58 1 45L 1 70L Z, is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

I Z2 is the highest vertical elevation of the two Z positions (excluding the weld center line (CL))

ACTUAL COVERAGE

[1 MISSED VOLUME

.12 (BMT2).

15r - "DOWN" UPPER FLANGE COVERAGE AT SLOTS (8) NOT SHOWN COVERAGE AT KEYWAYS (4)

L-2015-172, Enclosure Page 14 of 25 3-WR-18 and 4-WR-18

= 0.00

-KEY LOCATIONS AT 15% 105, 195", AND 285" Z - -19.40 6 (15%=I)

I Z - -28.77 Z = -33.17 WELD WOI (I Z - -34.50 D~rawing Positions IMAjusted Distance from Weld ld CE 2 1 Z, IW.Id CL 1 Z7 1 Anlges I -34.50 ' -28.77 I -19.40 I 0.00 I 5.73 I 15.10 I 45L I 45S Z, is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z2 is the highest vertical elevation of the two Z positions (excluding the weld center line (CL))

F1 ACTSAL COLRUME F1 MISSED VOLUME 85% - "UP" UPPER FLANGE COVERAGE AT SLOTS (8) - NOT SHOWN COVERAGE AT KEYWAYS (4)

L-2015-172, Enclosure Page 15 of 25 3-WR-18 and 4-WR-18

= 0.00 LYLOCATIONS AT r, 105", 195., AND285T

- Z - -16.53 (15%T1)

-Z - -25.90

- -34.50 rawing Position Adjustd Distance from Wed II WeldCL Zý 1 Z2 Weld CL 1Zt A1ZlesA I -34.50 1-25.90 1 -16.53 1 0.00 1 8.60 1 17.97 45L I 45S Z1 is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

I Z2 is the highest vertical elevation of the two Z positions (excluding the weld center line (CL))

S COVERAGE ECTUAL D MISSED VOLUME 12 (BMT2) -

85% - "SDOWT UPPER FLANGE COVERAGE AT SLOTS (8) - NOT SHOWN COVERAGE AT KEYWAYS (4)

L-2015-172, Enclosure Page 16 of 25 3-WR-18 and 4-WR-18

= 0.00 LOCATIONS AT 105', 195', AND 285" Z -

-Z - -34.50

- -36.31

- -44.59 l ACTUALCOVERAGE

[] MISSED VOLUME Drýawting Positions I Adjusted Distance from We ld WeIldCL Z I - Z, W0IdCL 1 AnTg8L 0

-34.50 I-44.59 1-36.31 10.00 1-10.09 1 -1.81 1 45L 0 Z4 is the lower vertical elevetion of the two Z positions (excluding the weld center line (CL))

Zz is the highest vertical elevation of the two Z positions (excluding the weld center line (CL))

15% - "UP" LOWER FLANGE

L-2015-172, Enclosure Page 17 of 25 3-WR-18 and 4-WR-18

= 0.00 LOCATIONS AT 10T5. 195'. AND 285 2.56 (15MT1)

BMT1/2 = 853

( Z - -33.44

- -34.50

-Z -40.40 1.37 15%1T2)

Dang Positions Adjusted Distance from Weld WeIdL Z, Z2 Weld CL IZ, I Z Anles I -34.50 40.40 1 -33.44 1 0.00 I -5.90 I 1.06 I 45L I 70L I Z, is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z2 is the highest vertical elevation of the two Z positions (excluding the weld center line (CL))

ACMSAL COVERAGE

] MISSED VOLUME 15% - "DOWN" LOWER FLANGE

L-2015-172, Enclosure Page 18 of 25 3-WR-18 and 4-WR-18

- 0.00 LOCATIONS AT 105". 195, AND285 Z - -24.63 BMT1/2 = 8.53 Z - -33.17-2.67 -Z - -34.50 Z = -35.83

- -36.31 BMT2/2 = 4.56 Z = -40.40 -

1.37

19%T2)

= -49.68 SACTUAL COVSERAGE

[] MISSED VOLUME Drawing Positions Adjusted Distance from Mid Weld-CL Z, 3Z I M i0 1 - 4L / 4

-34.50 I-49.68 1 -36.31 0.00 -15.18 1 -1.81 45L 5 Z, is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z.2 is the highest vertical elevation of the two Z positions (excluding the weld center line (CL))

8 5,y. - " UP" LOWER FLANGE

L-2015-172, Enclosure Page 19 of 25 3-WR-18 and 4-WR-18

- 0.00 11', 105', 195'. AND 2W5 2.56 (15ST":

-Z - -33.44

- -34.50 WELD W01 Q,.

-Z = -40.40 Z, is the lower vertical eleetion of the two Z positions (excluding the weld center line (CL))

Z2 is the highest vertical elevetion of the two Z positions (excluding the weld center line (CL))

ACTUAL COVERACE l MISSED VOLUME 85% - "DOWN" LOWER FLANGE

L-2015-172, Enclosure Page 20 of 25 3-WR-18 and 4-WR-18 z- 0.00 KEYLOCATIONS AT

15. 105', 19,T AND285'

~Z -, -24.63 Z- -29.02 WELD W01 it Z - -34.50 Drawing Positions Adusted Distance from VvId Weld CL Z1 Z2 Weld L 1 Z2 1lZ2

-34.50 I -29.02 I -24.63 I 0.00 I 5.48 I 9.87 I 45L I 70L Z4 is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z2 is the highest wertical eleetion of the two Z positions (excluding the weld center line (CL))

ACTUAL COVERAGE

[- MISSED VOLUME

'.12 (BMT2).

15% - "CW/CCW" UPPER FLANGE COVERAGE AT SLOTS (8) - NOT SHOWN COVERAGE AT KEYWAYS (4)

L-2015-172, Enclosure Page 21 of 25 3-WR-18 and 4-WR-18

- 0.00 LOCATIONS AT 105", 195', AND2W55 2.56 Z - -24.63 -- -Z - -24.63 BMT1/2 = 8.53 -Z = -29.02

= -34.50 Drawing Positions Adjusted Distance from Weld Weld CL Zý Z, Weld CL 1  ! 1 Z Angles I *-34.50 f -29.02 I -24.r3 I 0.00 1 5.48 I 9.87 I 45L I 45S I Z, is the tower vertical elevation of the two Z positions (excluding the weld center fine (CL))

72 is the highest \rtical elevation of the two Z positions (excluding the weld center line (CL))

] CTUALCOVERAGE rIMISSED VOLUME 85% - "CW/CCW' UPPER FLANGE

L-2015-172, Enclosure Page 22 of 25 3-WR-18 and 4-WR-18

= 0.00

-KEYLOCATIONS AT 1T, 105." 195', AND 285 2.56 (15%*I)-

Z = -33.17 -= -33.44

- -34.50 Z = -35.83

= -40.40 Drawilng Positions Adjusted Distance from WeldI Weld CL I Z, Z, Weld CL I Z, Z Angles I -3450 1 -40.40 1 -33.441 0.00 1 -5.90 I 106 I 45L I 70L I Z, is the lower ýertical eleyetion of the two Z positions (excluding the weld center line (CL))

Z2 is the highest '.ertical elevation of the two Z positions (excluding the weld center line (CL))

ACTUAL COVERAGE MISSED VOLUME 15% - "CW/CCW' LOWER FLANGE

L-2015-172, Enclosure Page 23 of 25

- KEY LOCATIONS AT 3-WR-18 and 4-WR-18

= 0.00 15'. 105'. 195'. AND 28S' BMT1/2 = 8.53

-z Z= -33.44 2.67 - -34.50 Z = -35.83 8MT2/2 = 4.58 Z = -40.40 = -40.40 Drawin Positions Adjusted Distance from Mid MidCL I Zý Z, WIMd CIL I Z, 1 1 Angles_

I-334.50 I -4040 1 -33.4 I 000 1 -590 1.06 I 45L I45S Z1 is the lower vertical elevation of the two Z positions (excluding the weld center line (CL))

Z2 is the highest wertical elevation of the two Z positions (excluding the weld center line (CL))

I ACTUAL COVERAGE F] MISSED VOLUME 85% - "CW/CCW" LOWER FLANGE

L-2015-172, Enclosure Page 24 of 25 NRC RAI-2a For the four subsurface fabrication flaws found in Examination Category B-A, Item B 1.11, RPV Lower Shell to Lower Head Ring Weld No. 4-WR-31 for Unit 4, indicate whether the acceptance criteria in ASME Code, Section Xl, Table IWB-3510-1, "Allowable Planar Flaws," were met.

FPL Response to RAI-2a The acceptance criteria in ASME Code, Section Xl, Table IWB-351 0-1, "Allowable Planar Flaws," were met.

NRC RAI-2b For the three subsurface fabrication flaws found in Examination Category B-A, Item B1.30, RPV Upper Shell-to-Flange Weld No. 3-WR-18 for Unit 3, and the twelve subsurface fabrication flaws found in Examination Category B-A, Item B1.30, RPV Upper Shell-to-Flange Weld No. 4-WR-18 for Unit 4, indicate whether the acceptance criteria in ASME Code,Section XI, Table IWB-351 0-1, "Allowable Planar Flaws," were met.

FPL Response to RAI2b:

The acceptance criteria in ASME Code, Section Xl, Table IWB-3510-1, "Allowable Planar Flaws," were met.

NRC RAI-3 Confirm whether the licensee requested relief for the third ISI intervals for Turkey Point 3 and 4 from essentially 100 percent inspection coverage for Examination Category B-A, Item B1.11, RPV Lower Shell to Lower Head Ring Welds for either Units 3 or 4, given that the design configurations for these welds have not changed since the third ISI interval. If relief requests were not previously submitted, explain why.

FPL Response to RAI-3 A relief request for welds 3-WR-31 (Unit 3) and 4-WR-4 (Unit 4) was not submitted in the third Interval. The process previously used to calculate the code volume coverage achieved during the 3rd interval examinations for welds with both single-side and dual-side access has been refined over the past 10-years to a more conservative approach resulting in the Reactor Pressure Vessel (RPV) Lower Shell to Lower Head Ring Welds examination coverage being reduced. The same examination tool and volume examined did not change. Previously, the 3rd interval examination calculation of coverage results identified that the RPV Lower Shell to Lower Head Ring Weld examination achieved essentially 100% (greater than 90%) coverage and as such, there was no need to request relief. Based on lessons learned and the interpretation of the basis of regulations regarding this examination, a more conservative approach was implemented for the coverage calculations in the fourth interval. The fourth interval relief request reflects the expectations of 10 CFR 50.55a(b)(2)(xv)(G), as listed below, for the examination coverage requirements, which resulted in a reduction in the examination volume coverage claimed from that of the previous third interval.

L-2015-172, Enclosure Page 25 of 25 50.55a(b)(2)(xv)(G) (G) Specimen set and qualification:Seventh provision. When applying Supplement 4 to Appendix VIII, Supplement 6 to Appendix VIII, or combined Supplement 4 and Supplement 6 qualification, the following additional conditions must be used, and examination coverage must include:

50.55a(b)(2)(xv)(G)(1) (1) The clad-to-base-metal-interface, including a minimum of 15 percent T (measured from the clad-to-base-metal-interface), must be examined from four orthogonal directions using procedures and personnel qualified in accordance with Supplement 4 to Appendix VIII.

50.55a(b)(2)(xv)(G)(2) (2) If the clad-to-base-metal-interface procedure demonstrates detectability of flaws with a tilt angle relative to the weld centerline of at least 45 degrees, the remainder of the examination volume is considered fully examined if coverage is obtained in one parallel and one perpendicular direction. This must be accomplished using a procedure and personnel qualified for single-side examination in accordance with Supplement 6. Subsequent examinations of this volume may be performed using examination techniques qualified for a tilt angle of at least 10 degrees.

NRC RAI-4 With respect to the subsurface indications detected in Welds 3-WR-1 8 and 4-WR-1 8 that were identified as fabrication-related defects during the fourth ISI interval examinations, explain why similar indications were not recorded during the previous (third) ISI interval.

FPL Response to RAI-4 The subsurface flaw indications identified during the fourth interval examination of welds 3-WR-18 and 4-WR-18 were compared directly to the third interval examination data using the analysis software and all flaws were found essentially unchanged from the previous examination. Although in some instances more flaw indications have been recorded during the fourth interval examination, it does not signify that the vessel flaw population is increasing. The qualified examination procedures allow some latitude on the conditions that must be met to record an indication such as detection with multiple beam angles or directions and amplitude response. Indications that don't meet these criteria do not have to be recorded. There are also instances where flaws very near the recording threshold were slightly below the threshold during the third interval examination. During the fourth interval examination, these flaws are at or slightly over the recording threshold due to slight variances between the examinations. In recent years, the approach taken in recording these flaws has become more conservative, and as such the flaw indications that meet only one of the criteria are documented for evaluation even though they may not be required to be recorded by the examination procedure. Although some of the indications do not necessarily meet all of the criteria for recording they meet at least one and have been recorded to more thoroughly document the condition of the vessel. This conservative approach results in the false appearance of a change in the vessel flaw population, when no changes have occurred.