Text

Response to Request for Additional Information for ISI Relief Request No. 10
	ML21288A544
Person / Time
Site:	Turkey Point
Issue date:	10/15/2021
From:	Hess R; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2021-197
	Download: ML21288A544 (41)
	v • d • e

{{#Wiki_filter:* October 15, 2021 L-2021-197 l=PL. 10 CFR 50.55a U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Turkey Point Unit 3 Docket Nos. 50-250 Response to Request for Additional Information for ISI Relief Request No. 10

1. Florida Power & Light Company letter L-2021-183, Fifth Ten-year Inservice Inspection Interval Relief Request Number 10, September 30, 2021 (ADAMS Accession Nos.

ML21273A240, ML21273A241)

2. NRC Email from Ms. Eva Brown, Senior Project Manager Turkey Point to Ms. Stavroula Mihalakea, Turkey Point Licensing Engineer, Request for Additional Inf01mation Fifth Ten-Year Inspection Interval Relief Request No.IO - Extension EPID: L-2021-LLR-0077, dated October 14, 2021.

In Reference 1, Florida Power & Light Company (FPL) submitted Relief Request (RR) No. 10 from the American Society of Mechanical Engineers Section XI Code (ASME Section XI Code) for the Turkey Point Unit 3 Fifth IO-Year Inservice Inspection (ISI) Interval. RR 10 requested in part, an extension to the time to repair a through-wall leak in the intake cooling water spool piece under the provisions of Section 50.55a(z)(2) to Title 10 to the Code of Federal Regulations. In Reference 2, NRC Staff requested additional information determined necessary for completing their review. Enclosure 1 contains the NRC's request for additional information, and Enclosure 2 provides FPL' s response. If you have any questions or require additional info1mation, please contact Robert J. Hess, Licensing Manager, at (305) 246-4112. Licensing Manager Turkey Point Nuclear Plant Enclosures cc: USNRC Regional Administrator, Region II, USNRC USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant USNRC Project Manager, Turkey Point Nuclear Plant Florida Power & Light Company 9760 SW 344th Street Homestead FL 33035

L-2021-197, Enclosure 1 Page 1 of 1 REQUEST FOR ADDITIONAL INFORMATION ALTERNATIVE RELATED TO INTAKE COOLING WATER SPOOL PIECE REPAIR TURKEY POINT UNIT 3 Paragraph 50.55a(z)(2) to Title 10 to the Code of Federal Regulations (10 CFR) authorizes the Director, Office of Nuclear Reactor Regulation, to approve alternatives to the requirements of paragraphs (b) through (h) of 10 CFR 50.55a. The licensee has requested an alternative based on hardship without a compensating increase in quality and safety. It is the NRC staffs understanding that in part the licensee is requesting to obtain authorization of the continued use of Code Case N-513-4 due to hardship or unusual difficulty without a compensating increase in the level of quality and safety and the NRC approval of the non-Code alternative repair (i.e., the restoration clamp assembly) will be addressed in a separate ASME Code alternative request. In order to complete the review of the proposed alternative related to continued use of Code Case N-513-4 past the current RFO, the NRC staff needs the following information.:

1. Code Case N-513-4 requires a repair/replacement be performed at the next scheduled refueling outage (RFO). The licensee is requesting the repair/replacement to be extended until approximately 6 months following the RFO.

Please provide the licensees analysis which demonstrates that structural integrity will be maintained for this extended time period. This should include the information regarding the degraded location, which has been gathered based on ultrasonic examination and leakage monitoring since the leak was discovered in March 2020.

2. Section 4.0 of the submittal discusses some other considered repair options. Discuss the specific hardship for not performing each of the repair methods evaluated by FPL to repair the through wall leak and provide supporting detail, which addresses the identified adverse risk to the plant.

3. Code Case N-513-4 provides certain compensatory measures to support continued operation until the next RFO. Given the request goes beyond the scope of the NRC approval, describe those measures intended to monitor the structural integrity of the ICW system during the six-month extension past the end of the RFO. For each action, justify any additional assurance that would be provided regarding the integrity of the component.

4. In section 4.0 of the submittal it states the, likely cause of the defect is [inside diameter] ID corrosion due to localized degradation of the concrete liner. Describe the operating experience with ID corrosion of the ICW System.

L-2021-197, Enclosure2 Page 1 of 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR RR NO. 10 RESPONSE TO RAI-1 The detailed flaw growth assessment is provided herein in Attachment 1. The flaw evaluation is based on the flaw analysis provided in Attachment 2 and it incorporates the results of the volumetric examinations obtained since the leak was discovered on March 2020 on the periodicity defined by Code Case N-513-3, except for the period for which the piping classification was changed (April 2020-April 2021). The volumetric examinations are provided in Attachment 3 of this enclosure. The results of the flaw growth assessment demonstrate that structural integrity will be maintained through January of 2023. Turkey Point will continue to update the flaw growth assessment with the results of volumetric examinations and will continue to verify and monitor the structural integrity of the through-wall leak throughout the extended period of six months (Reference 1). Regarding code compliance to ASME Section XI Code Case N-513, it should be noted that the procedure followed for the initial flaw evaluation and the system operability justification was in accordance with Code Case N-513-3 and not Code Case N-513-4 as previously stated in Reference 1. There are no changes to the conclusions stated in Reference 1, since both revisions include the same implementing procedure for flaw evaluation and subsequent actions as it applies to this application, and as such they have been used interchangeably in our flaw evaluations. RESPONSE TO RAI-2

1. Turkey Point evaluated the code repair option to remove the flaw by drilling, tapping the hole, and installing a solid plug. This repair option has been discounted due to the following hazards:

With the Intake Cooling Water (ICW) system in operation, the system would need to be temporarily aligned with throttled flow to minimize leakage out of the system to avoid interference with the work conditions. However, the location of the flaw is at the bottom of the piping, presenting difficulty in accomplishing predictable drilling operation. Further, as drilling is performed to remove the defect, station personnel have identified a high likelihood that system conditions could change, presenting a hazard to personnel working in the area.
Drilling through the pipe and the concrete liner would likely result in further degradation of the concrete liner causing additional pipe interior exposure expanding the area of potential pipe wall loss.
The size of the currently affected area will necessitate use of a plug size, which will limit the number of threads that can be cut into the pipe wall. Depending on the diameter of the plug, the required code thread engagement might not be possible, and

L-2021-197, Enclosure2 Page 2 of 4 as such, leak tightness at the plug may not be obtained. Unable to ensure that the pipe inner diameter is protected from the salt water reduces the long-term effectiveness/success of this option.

This section of piping has been in operation for the life of the plant and drilling/tapping into cast iron pipe could initiate a crack, resulting in the need for expanded area of repairs, which may not be possible using this method.

2. Turkey Point also evaluated the code repair option to replace the pipe spool section. This option also has been discounted due to the following difficulties:

This repair option would require removal of the entire ICW system from service.

Removing the entire Unit 3 ICW system from service, also removes the component cooling water (CCW) system from service, which can only occur during the reactor defueled window. However, during that time all spent fuel is stored in the Spent Fuel Pool (SFP) and without the CCW system in service, SFP would heat up and reach time to boil in a short time.

The time available to complete this repair is not judged to be sufficient, given the decay heat load in the Spent Fuel Pool. A temporary system would need to be evaluated, designed and installed to continue to provide the SFP heat exchanger cooling function, while CCW is out of service.
While in the defueled window, and with the spent fuel pool being cooled by a temporary system, any difficulties in disassembling and reassembling this section of original construction piping would result in extended reliance on the temporary heat removal system. There is high likelihood that removing the spool piece from the system will result in shifting the pipe sections on either or both sides. Realigning or maintaining alignment of the piping system would impart loads on the concrete lined cast iron pipe, which carries a high likelihood of additional degradation to the concrete lining and/or damage to the adjacent cast iron piping. Those additional unplanned repairs would prolong the reliance on the temporary plant configuration for cooling to the SFP.

3. Turkey Point also evaluated other temporary non-code repair options, which would not address flaw degradation and would prevent the performance of ultrasonic examinations. As such these options were not considered further.

4. Repair options involving use of a freeze seal were not considered because of the low probability of success on this size pipe and the potential to cause damage to the cast iron pipe.

5. Options involving welding were also not considered as the cast iron base material is not suitable for welding.

L-2021-197, Enclosure2 Page 3 of 4 FPL has considered the various options for repair, as discussed above, and concluded that each presents a complication or burden, and several are judged to have low likelihood of success. It is essential to maintain ICW system in operation and minimize probability of exacerbating the current leak. As discussed in the response RAI-1 above and attached, the current leak is stable and will remain so for the period of extension requested. As outlined here, these repair options present a hardship or unusual difficulty with no compensating increase in quality or safety. Consequently, FPL requests NRC authorize extending the use of Code Case N-513 beyond start-up from the current refuel outage until the necessary materials can be installed and Relief granted for the non-Code repair. RESPONSE TO RAI-3 Additional measures intended to monitor the structural integrity of the ICW system during the six-month extension past the end of the RFO include:

Leakage Monitoring:

The Code Case N-513-3 procedure requires a daily check of the leak. This check is currently performed by Operations. The leak rate is quantified during the check. Step changes are reported to Operations supervision and communicated to System Engineering for investigation. For the requested extension period of six months beyond the current refueling outage, the frequency of the leak rate check will be increased to twice per day. The increased leak rate checks will ensure the timely identification of leak rate changes and communicate the results for prompt action and system operability determination.

Flaw Growth Monitoring:

NDE UT examination is currently performed at a 90-day frequency in the flaw area to identify and update any flaw growth changes since discovery of flaw. The volumetric examination frequency will be increased to every 30 days. Thickness data will be reported and trended against past inspections. This increase in frequency of the examination will provide additional data to be used in the evaluation of the flaws structural integrity. It will ensure changes in degradation rate and will be identified promptly and evaluated for further action. RESPONSE TO RAI-4 The internal surfaces and cement lining of the ICW piping are periodically inspected during outages on both Turkey Point Units 3 and 4. The scope of these inspections includes the piping between the ICW Pump Discharge Valves to the ICW/CCW and ICW/TPCW basket strainers. These inspections were programmatically instituted in response to Generic Letter 89-13 and continued in accordance with the Intake Cooling Water License Renewal Inspection Aging Management Program (AMP) in the renewed license period of extended operation. The AMP enhanced the scope and frequency of the intake cooling water piping crawl-through inspections and component cooling water heat exchanger tube integrity inspections. To date, only minor liner degradation with little to no associated metal loss have been identified during all inspections. A condition report search was performed for the entire ICW system dating back to 2004 and found no other examples of ICW concrete lined piping leakage due to internal corrosion

L-2021-197, Enclosure2 Page 4 of 4 as the result of internal liner degradation. Additionally, the augmented exams performed in accordance with code case N-513-3 included ultrasonic examinations at 5 separate cement lined cast iron spool piece locations. No wall loss was identified.

L-2021-197 Enclosure 2, Attachment 1 Response to RAI-1

Background

A through-wall non-planar flaw was identified under the coatings downstream of valve 3-50-406 on the 24 inch diameter ICW pipe spool, which is the isolation valve downstream of the Unit 3 ICW flow path from the CCW heat exchangers, during the preparation of the pipe for metalizing/coatings application. The ICW through-wall leak on a safety related cast iron/cement lined pipe has resulted in a leakage rate fluctuating between 5 GPH and 10 GPH depending on system cleanliness and lineup. The flaw is shaped like a crater with two small, through-wall weep holes inside. The size of the outer diameter of the flaw is 9/16in. longitudinal and 13/16in. circumferential. The cast iron spool piece is located downstream of valve 3-50-406 within a piping segment classified as Safety Related Class C. The latest Prompt Operability Determination (POD) Revision 3, (Condition Report AR 234734348-13) which was performed on April 16, 2021 has concluded that the 24-inch diameter ICW spool piece which contains the leak is operable but degraded. Upon discovery, the through-wall leak was evaluated by Structural Integrity Associates (SIA) and documented in the Turkey Point CC N-513 Evaluation of Leaking ICW Cast Iron Pipe SIA report, provided in Attachment 2. The Allowable through-wall flaw diameters were calculated as a function of the surrounding wall thickness in accordance with ASME Code Case N-513-3. The branch reinforcement rules of Paragraph 3.2(c) were utilized in the analysis. The allowable flaw sizes are presented in Table 1 of Attachment 2. The SIA report concludes that after flaw characterization is performed by FPL in accordance with Code Case N-513-3, Paragraph 2(a), the characterized flaw may be compared to the acceptance criteria listed in Table 1. Paragraph 2(a) states that: The flaw geometry shall be characterized by volumetric inspection methods or by physical measurements. The full pipe circumference at that flaw location shall be inspected to characterize the length and depth of all flaws in the pipe section. For the characterized wall thickness value (tadj), if the observed length of the flaw is less than allowable (dadj), the structural evaluation criteria of Code Case N-513-3 will be shown to be met. Turkey Point performed the initial flaw growth assessment on 5/12/2021. This growth assessment provides an update which includes two additional volumetric examination results performed since the issuance of the initial flaw growth assessment. All volumetric examination reports are provided in as references. Table 1.1 below summarizes the wall thickness from all volumetric examinations. This flaw growth assessment re-evaluates the flaw growth by comparing the two most recent UT examination results relative to the two previous UT examination results. Note that the last flaw growth assessment issued on 5/12/2021 evaluated the average of octants at 180 degrees and used the minimum wall thickness value of 0.430 inches. The method used in this assessment offers a greater conservatism in the results as this bounding flaw approach addresses the most conservative wall loss revealed among all the octants within the latest 90-day period with the utilization of two respective UT examination results. By identifying the worst case of wall loss rate, and with the use of the SIA flaw analysis results and acceptance criteria provided in Table 1 of Attachment 2, this flaw growth assessment determines the expected remaining life of the degraded pipe spool at this time.

L-2021-197 Enclosure 2, Attachment 1 Response to RAI-1 Evaluation To evaluate the remaining life of the flawed ICW component with the through-wall leak downstream of valve 3-50-406, the following approach is taken:

Characterize the flaw size based on the measurements taken from the periodic UT examinations performed on the thinned region of piping. Use the results of Table 1 Attachment 2 to determine the appropriate through-wall flaw diameter based on the measured thicknesses surrounding the thinned area.
Calculate the remaining life of the component by subtracting the maximum measured wear rate from the average measured wall thickness circumferentially around the piping cross-section.

Thicknesses less than the average wall thickness can be used for additional conservatism.

The remaining life is equal to the amount of time required to wear the average wall thickness to the point when it exceeds the adjusted evaluated wall thickness, tadj, for the applicable characterized hole diameter from Table 1 of Attachment 2.

Accordingly, to demonstrate the structural stability of the as-found flaw using Code Case N-513-3, the thinned region is conservatively characterized as a through-wall circular hole with a diameter of 3.75 inches, as depicted in Figure 1. Confirmed via the UT examination readings, it encompasses wall values throughout its periphery. This diameter is evident in the information provided in the October 11, 2021 Supplemental Compiled Volumetric Examination Report, provided in Attachment 3. For an allowable adjusted flaw diameter, dadj of 3.77 inches, the surrounding wall thickness, tadj, required to maintain the structural stability of the pipe is 0.650 inch (See Table 1, Attachment 2). The average thickness surrounding the characterized flaw is equal to 0.95-inch. This can be seen in Table 1.2. For the purposes of the flaw growth assessment, it is conservatively assumed that the pipe has a uniform thickness equal to the nominal thickness of 0.73 inch. The values are based on the NDE Report 21-056, summarized in Table 1.3 below (See Attachment 3 for detailed report). The flaw growth assessment is performed by subtracting the maximum measured wear rate on the thinned region of piping from the nominal wall thickness. The maximum wear rate was determined based on the periodic volumetric examinations performed on the region of thinning since the through-wall flaw was identified. Based on the results of the volumetric examinations, listed in Table 1.1 below, the maximum wear rate is 0.013 inch/90 days (1.44E-4 inch/day). Starting with July 15 2021 data, this wear rate is then subtracted from the confirmed nominal wall thickness of 0.73 inches (circled pattern of 3.75 inches), i.e., and every 90 days after that to determine the predicted date which corresponds to the tadj value of 0.650 inches. Based on this method used, it is calculated that the time to reach tadj is approximately 16 months (554 days) from the volumetric results of July 15, 2021. As such, it is estimated that the time at which wall loss would reach tadj of 0.650 inches would be January 20, 2023. This flaw assessment method will be used to determine the remaining life of the component in comparison to the Code Case N-513-4 acceptance criteria during every subsequent volumetric examination. Conclusion The estimated time at which wall loss would reach tadj of 0.650 inches would be January 20, 2023. Page 2 of 5

L-2021-197 Enclosure 2, Attachment 1 Response to RAI-1 Table 1.1 Wall Thickness Data from All UT Reports to Date Table 1.2 - Pipe Wall Thickness Around Flaw With Average Thickness of 0.95 inches Page 3 of 5

L-2021-197 Enclosure 2, Attachment 1 Response to RAI-1 Table 1.3 - Pipe Wall Thickness at Allowable Adjusted Flaw Diameter of 3.75 in. Page 4 of 5

L-2021-197 Enclosure 2, Attachment 1 Response to RAI-1 Figure 1 Supplemental Compiled Report All Roman Numerals are the equivalent of a 3.75 inch diameter circle) Page 5 of 5

L-2021-197 Enclosure 2 Attachment 2 SIA Report Turkey Point CC N-513 Evaluation of Leaking ICW Cast Iron Pipe

File No.: 2000344.301 Project No.: 2000344 Quality Program Type: Nuclear Commercial CALCULATION PACKAGE PROJECT NAME: Turkey Point CC N-513 Evaluation of Leaking ICW Cast Iron Pipe CONTRACT NO.: 2409430 CLIENT: PLANT: FPL Group - NextEra Energy Turkey Point, Unit 3 CALCULATION TITLE: Code Case N-513-3 Evaluation of Leaking ICW Piping Project Manager Preparer(s) & Document Affected Revision Description Approval Checker(s) Revision Pages Signature & Date Signatures & Date 0 1-7 Initial Issue Preparer: Eric Houston EJH 3/17/20 Eric Houston EJH 3/17/20 Checker: Stephen Parker SMP 3/17/20

Table of Contents 1.0 OBJECTIVE .............................................................................................................. 3 2.0 METHODOLOGY ...................................................................................................... 3 3.0 DESIGN INPUTS....................................................................................................... 3 4.0 ASSUMPTIONS ........................................................................................................ 4 5.0 CALCULATIONS ....................................................................................................... 4 5.1 Applied Loads ................................................................................................ 4 5.2 Determination of tmin ....................................................................................... 5 5.3 Branch Reinforcement Rules ......................................................................... 5 6.0 RESULTS OF ANALYSIS .......................................................................................... 6

7.0 CONCLUSION

S AND DISCUSSION ......................................................................... 7

8.0 REFERENCES

.......................................................................................................... 7 List of Tables Table 1: Allowable Flaw Diameter as a Function of Surrounding Wall Thickness ................. 6 Page 2 of 7 F0306-01R3

1.0 OBJECTIVE A through-wall leak was discovered in a flanged spool piece downstream of Valve 3-50-406 in the Intake Cooling Water (ICW) system at Turkey Point, Unit 3. The ICW system is classified as Quality Group C, which is treated as Class 3 safety related piping under ASME Section XI. The objective of this calculation is to demonstrate suitability for continued operation in accordance with ASME Code Case N-513-3 [1]. 2.0 METHODOLOGY The flaw evaluation herein is based on the criteria prescribed in ASME Code Case N-513-3, which allows for the temporary acceptance of part-wall and through-wall flaws in moderate energy Class 2 or Class 3 piping. The NRC has conditionally approved the use of Code Case N-513-3 in Regulatory Guide 1.147, Revision 18 [2] with the requirement that the repair / replacement activity deferred be performed during the next scheduled refueling outage. Code Case N-513-3, Paragraph 2(a) requires the flaw to be characterized by volumetric inspection or physical measurement. Inspection of the full pipe circumference is required for flaw characterization. FPL will need to perform such characterization in order to meet the acceptance criteria developed herein. The through-wall, non-planar flaw is to be evaluated as a branch penetration using the branch reinforcement rules specified in Code Case N-513-3, Paragraph 3.2(c). Allowable through-wall flaw diameters are calculated parametrically as a function of the surrounding wall thickness, tadj. Flaw characterization performed by FPL can be compared to the allowable flaw sizes to determine if the piping is acceptable for continued operation. 3.0 DESIGN INPUTS The following design inputs are used in the evaluation:

1. Nominal pipe size = 24-inch class 23 [3, Sheet 4; 4, Page 39]

2. Outside diameter = 25.8 inches [3, Sheet 4]

3. Nominal wall thickness = 0.730-inch [3, Sheet 4]

4. Maximum operating temperature = 120°F [5]

5. Design pressure = 55 psig [3, Sheet 5]

6. Maximum operating pressure = 25 psig [5]

7. Code of Construction: ANSI B31.1 Power Piping - 1973 Edition with Addenda through Summer 1973 [3, Sheet 3 and Sheet 15, 6]

8. Material allowable stress, Sh = 6,000 psi [3, Sheet 4]

9. Material yield strength, Sy = 10,200 psi [3, Sheet 4]

10. Code Equation allowable stresses [3, Sheet 10]

a. Equation 11 = Sh

b. Equation 12 (OBE) = 1.2 Sh

c. Equation 12 (SSE) = Sy The stress report does not provide moment loading or stress results for each nodal location. Instead, a summary of the maximum calculated stress for each Code Equation is provided [3, Sheet 10]:

File No.: 2000344.301 Page 3 of 7 Revision: 0 F0306-01R3

Equation 11 = 2,692 psi
Equation 12 (OBE) = 3,591 psi
Equation 12 (SSE) = 5,317 psi These stresses are utilized to obtain bounding loads in the analysis (see Section 5.1).

4.0 ASSUMPTIONS

1. As specified in [3, Sheet 4], thermal stresses are assumed to be negligible and are not evaluated herein.

2. The allowable stress is assumed to include the casting quality factor, F. This assumption is supported by 6, Table A.5 which does not specify a casting quality factor for any gray cast iron.

5.0 CALCULATIONS The bounding axial stresses and design pressure are used to determine bounding moment loads. The bounding moment loads are then used with the maximum operating pressure to calculate the minimum required wall thickness, tmin. This tmin value is used in the branch reinforcement calculations in N-513-3 to determine the allowable through-wall flaw sizes. 5.1 Applied Loads The bounding stresses and design pressure are utilized to obtain bounding moment loads in the analysis. The Equation 11 stress due to sustained loading is calculated using the formula [6, 104.8.2]: 0.75

                                                         +              1.0 4

where: P = Design pressure, psig DO = Outside diameter, in tnom = Nominal wall thickness, in i = Stress Intensification Factor MA = Resultant moment due to sustained loads, in-lbs Z = Section modulus, in3 Based on the nominal pipe section properties and the bounding Equation 11 stress, MA is calculated as 773,094 in-lbs. The Equation 12 stress due to sustained plus occasional loading that includes seismic OBE is calculated using the formula [6, 104.8.1]: 0.75 0.75

                                                 +               +

4 where: File No.: 2000344.301 Page 4 of 7 Revision: 0 F0306-01R3

MB = Resultant moment due to occasional loads, in-lbs k = Factor on allowable stress The term k is taken as 1.2 as specified in Section 3.0 for occasional loading that includes OBE. MB is calculated based on the nominal pipe section properties, the bounding Equation 12 (OBE) stress, and the previously calculated MA. The bounding MB is 315,050 in-lbs. The Equation 12 stress due to sustained plus occasional loading that includes seismic SSE is calculated using the formula as Equation 12 OBE, except the allowable stress term on the right side of the equation is replaced with the yield strength: 0.75 0.75

                                                      +             +

4 As with the calculation of MB for OBE, MB loading that includes SSE is calculated based on the nominal pipe section properties, the bounding Equation 12 (SSE) stress, and the previously calculated MA. The bounding MB that includes SSE is 919,918 in-lbs. 5.2 Determination of tmin The minimum required wall thickness due to internal pressure is calculated in Equation 3 as [6, 104.1.2.A]:

                                                      =                +

2( + ) where: S = Allowable stress, psi F = Casting quality factor

             = 1.0 (see Assumption 2) y     = Pressure coefficient
             = 0.4 for cast iron [6, Table 104.1.2,A]

A = Additional thickness, in As allowed by Code Case N-513-3, the maximum normal operating pressure is used instead of the design pressure. Since the analysis is performed for the as-found condition and not design, the additional thickness value is taken as zero. The minimum required wall thickness due to pressure is tm = 0.054 inch. The minimum required wall thickness due to axial loading is determined iteratively. Equation 12 (SSE) is the bounding condition, resulting in a required wall thickness of 0.346 inch. Therefore, the minimum required wall thickness due to all loading is tmin = 0.346 inch. 5.3 Branch Reinforcement Rules The branch reinforcement rules of Code Case N-513-3, Paragraph 3.2(c) are utilized to determine the allowable through-wall flaw size. The analysis is performed iteratively for the adjusted surrounding wall thickness, tadj, to provide flexibility in implementation during the flaw characterization performed by FPL. For each value of tadj, the allowable diameter, dadj, of a through-wall hole is calculated using [1, Equation 8]: File No.: 2000344.301 Page 5 of 7 Revision: 0 F0306-01R3

1.5 where

R = Mean pipe radius, in The Code Case specifies that the tmin value used in Equation 8 be calculated based on Equation 4 of the Code Case, which is equivalent to Equation 3 of the Code of Construction given above (i.e., tm). Use of tm in Equation 8 only accounts for pressure loading. There are no additional requirements for evaluation of axial loads in Code Case N-513-3. Because axial loads are the bounding loads at this location, strict application of the Code Case N-513-3 rules are potentially non-conservative. Therefore, the tmin value of 0.346 inch determined in Section 5.2 is conservatively used in the branch reinforcement rules. 6.0 RESULTS OF ANALYSIS From the inputs in Section 3.0 and using the bounding moments from Section 5.1, the allowable through-wall flaw diameter (dadj) is calculated for a range of tadj values based on Equation 8 reproduced in Section 5.3. The results are shown in Table 1. Code Case N-513-3, Paragraph 3.2(c) requires that the remaining ligament average thickness over the degraded area be sufficient to resist pressure blowout [1, Equation 9]. The morphology of the observed degradation is such that this requirement is not valid. Therefore, the requirements of [1, Equation 9] are not evaluated herein. Table 1: Allowable Flaw Diameter as a Function of Surrounding Wall Thickness tadj [in] Allowable dadj [in] tadj [in] Allowable dadj [in] 0.730 5.04 0.570 2.60 0.720 4.87 0.560 2.47 0.710 4.71 0.550 2.33 0.700 4.55 0.540 2.20 0.690 4.39 0.530 2.06 0.680 4.23 0.520 1.93 0.670 4.08 0.510 1.81 0.660 3.92 0.500 1.68 0.650 3.77 0.490 1.55 0.640 3.62 0.480 1.43 0.630 3.47 0.470 1.31 0.620 3.32 0.460 1.19 0.610 3.17 0.450 1.08 0.600 3.03 0.440 0.96 0.590 2.88 0.430 0.85 0.580 2.74 0.420 0.74 File No.: 2000344.301 Page 6 of 7 Revision: 0 F0306-01R3

7.0 CONCLUSION

S AND DISCUSSION A through-wall leak in the 24-inch ICW system downstream of Valve 3-50-406 has been identified at Turkey Point, Unit 3. Allowable through-wall flaw diameters have been calculated as a function of the surrounding wall thickness in accordance with ASME Code Case N-513-3. The branch reinforcement rules of Paragraph 3.2(c) are utilized in the analysis. The allowable flaw sizes are presented parametrically in Table 1. After flaw characterization performed by FPL in accordance with Code Case N-513-3, Paragraph 2(a), the characterized flaw may be compared to the acceptance criteria in Table 1. For the characterized wall thickness value (tadj), if the observed length of the flaw is less than dadj, the structural evaluation criteria of Code Case N-513-3 will be shown to be met. In addition to flaw characterization, the Code Case also requires other actions by the owner such as:

Volumetric reinspection (30-day interval) in accordance with Paragraph 2(e)
Leaking flaws shall be observed by daily walkdowns in accordance with Paragraph 2(f)
Augmented volumetric examination or physical measurement in accordance with Paragraph 5

8.0 REFERENCES

1. ASME Boiler and Pressure Vessel Code, Code Case N-513-3, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1, January 26, 2009.

2. Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 18, U. S. Nuclear Regulatory Commission, March 2017.

3. Bechtel Calculation No. M12-214-03, Revision 0, Stress Analysis for Intake Cooling Water Discharge Piping from Component Cooling Heat Exchanger Through ICW Piping to Buried Pipe, SI File No. 2000344.201.

4. EDS Nuclear Calculation No. 0040-007-C-036, Revision 3, Circulating Water System CIRC-2 Unit 3, SUPERSEDED, SI File No. 2000344.201.

5. FPL Drawing No. 5613-P-820-S, Turkey Point Nuclear Power Plant Unit 3 Intake Cooling Water System System No. 19 Outside Containment Stress Problem CIRC-2, Sheet 1 of 2, Revision 5, SI File No. 2000344.205.

6. ANSI B31.1, Code for Pressure Piping, 1973 Edition through Summer 1973 Addenda.

File No.: 2000344.301 Page 7 of 7 Revision: 0 F0306-01R3

L-2021-197 Enclosure 2 Attachment 3 Volumetric Examinations

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Flow-Accelerated Corrosion (FAC) Ultrasonic Thickness Report 0 ~ Turkey Point 3 0 Seabrook ULTRASONIC THICKNESS REPORT
@ St. Lucie 1 D St. Lucie2 D Turkey Point 4 Procedure: NDE-5.18 Rev. 9 FPL Component ID Drawing: 5613-P-820-S SH I of2 Component Type: Concrete Lined Cast Building: CCW Pump Room Pioe se1rn1ent between V 3-50-406 & V 3-50-452 Pioe Material: CS Cast Pipe System: !CW Diameter: 24" Elevation: 19'5" INSTRUMENT Manufacturer: GE Range: 3.0" SKETCH Not to Scale Upstream Component v 3-50-406 Serial Number: OIR6B7 Gain: 42DB Downstream Component v 3-50-452 Model: USN60 SW Velocity: 0.1799 Electronic file ID NIA TRANSDUCER Manufacturer: GE Serial No.:153797 Model: MSEB.2 Frequency: 2MHZ Size: t3.5 x IO mm #of Elements 2 Cable Len!J'th: ~, Cable Type: RG-174 TEMPERATURE Manufacturer: PTC Serial Number: 284607 Component: See Remarks !Reference Block: ~ee Remarks REFERENCE BLOCK Serial Number: PTN-ICW-1 Material: Cast Pine COUP LANT Type: Ultra!!el II Batch: 10325F CALIBRATION INFORMATION Calibration Thickness 1 Calibration Times Actual Measured 4f2121 4/13/21 0.498" 0.499" Initial: 1449I1528 0.748" K>.748" Intermediate: 1511I1551 0.998" K>.999" Intermediate: 1549 1.499" 1.498" Intermediate.
Final: 1558 I 1612 DATA2 Nominal <Tnominat) 0.730" View: 0Top D Side Previously examined: 0Yes 0No Screening (Tsucenin*) NIA Grid Size: 01" 02" 04" igj 3" - Scan Exam performed from: igj OD Om Minimum Acceptable (Tminimum 0.120" Alpha grid limit: A through NIA Comments I Remarks I Limitations: Best effort exam due to porous cast material and spots of and raised letterin!! in some !!rids. Raised letterin!! is Listed with an
in data table remarks.
Numeric irrid limit: 1 throue:h l thru 28 Minimum Measured (T min moas) 0.731 "(Q.363" (a) Flaw) Component was examined on April znd and April 131h. Minimum Measured (coordinate) 16 Temnerature: 4/2/21 79.5°F 4/13/21 80°.F Above Screening? IXI Yes I INo
l. To be considered acceptable for use, the instrument shall read +/- 0.005" from loJ)'f~
the actual thickness measured.
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2. Unless otherwise specified, numbers run in the direction of flow. Letters go Exam iner: PrintName: Sie.n ame Level II Date 4/2/2021 clockwise when facing downstream direction of flow (right hand rule). ~ ti ('\ "'c... ~ \1 v4,.)
Reviewer: Print Name Donna Slivon
~~R Sil!llName ,{£ - -- Level UI L//!u/UU Date 4/16/2021 Form: UT-11
ICW Flaw Location Pipe segment between valve 3-50-406 (upstream) and valve 3-50-452 (downstream) Pipe is 24" Diameter Cast Iron (concrete lined) System: 019 Intake Cooling Water P&ID: 5613-M-3019 Sh. 2 ISO: 5613-P-820-S Sheet 1of2 (Nodes 15 to 16) Temperature: 79.5°F (02 .l\pril 2021), & 80.0°F (13 April 2021.) Instrument: USN 60 S/N : 01R6B7 Transducer: MSEB2 2MHz Yi" S/N: 57461-53797 Cal Block: S/N: PTN-ICW-1 4-Step: 0.498", 0.748", 0.998", 1.499" Inspection Date: 02 April 2021 & 13 April 2021 1* 0.862" 18 1.135" 2* 0.912" 19 1.180" 3* 0.932" 20 1.155" 4 0.999" 21 1 .105" 5 1 .081" 22 1.099" 6 1.121" 23 0.947" 7 1 .083" 24* 0.936" 8 1 .020" 25* 0.900" 9 0 .979" 26* 0.793" 10 0.930" 27 0.804" 11 0.887" 28 0.829" 12 0.798" 13 0.819" 14* 0.892" 15* 0.915" 16* (1) 0.731" (See attacl ed sketch for Thick 11ess Measurements at 1/2" from flaw) 17* 0.879"
Denotes Raised (cast) "Lettering" in this inspection segment/block
{1) The Flaw is located in this segment/block. Value is lowest identified outside the Yi" line from the flaw cavity. See readings around flaw location for additional information. Calibration Times: 02 April 2021: 1449, 1511, 1549, & 1558 13 April 2021: 1528, 1551, & 1612 Segments are 3" Circumferential and 3" Longitudinal "blocks" Zero Reference is TDC with 1-28 with direction of flow.
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Flow-Accelerated Corrosion FAC Ultrasonic Thickness Re ort NDE Re ort # 21-040 D St. Lucie 1 [gj Turkey Point 3 D Seabrook ULTRASONIC THICKNESS REPORT D St. Lucie 2 D Turkey Point 4 Procedure: NDE-5 .18 Rev. 9 Component ID: Drawing: 5613-M-3019 SH 2 I Component Type: Concrete Lined Cast Building: CCW Pump Room Pi e se men! between V 3-50-406 & V 3-50-452 5613-P-820-S SH I Iron Pi e Material: System: 019 Intake Cooling Water Diameter: 24" Elevation: 21' 11 - l l /16" CS I Cast Iron Pipe INSTRUMENT Manufacturer: GE Ran e: 3.0" SKETCH Notto Scale Upstream Component v 3-50-406 Serial Number: 01 YKT6 Gain: 51 DB Downstream Component v 3-50-452 Model: USN 58 L Velocity: 0.1799 Electronic file ID NIA TRANSDUCER Manufacturer: GE Serial No.: 53797 Model: MSEB 2 Size:3.5 x 10 mm Cable Len th:6' TEMPERATURE N.._ Serial Number: 284607 FLOW Component:85°F Reference Block: 85 °F REFERENCE BLOCK Serial Number: PTN-ICW-1 Material: Cast Pi e COUPLANT 10325F CALIBRATION INFORMATION Calibration Thickness 1 Calibration Times Actual Measured 0.498" 0.499" Initial: 1305 0.748" 0.748" Intermediate: 1330 0.998" 0.999" 1.499" 1.498" Final: 1351 DATA2 0.730" View: D Top D Side Previously examined: [gl Yes 0 No NIA Grid Size: D 1" 0 2" 04" D 3" - Scan Exam performed from: [gj OD Orn 0.120" N/A Comments I Remarks I Limitations: Bullse e: 1 thru 8 0.346" Minimum Measured coordinate 4 [gj Yes D No
1. To be considered acceptable for use, the instrument shall read +/- 0.005" from the actual thickness measured.

2. Unless otherwise specified, numbers run in the direction of flow. Letters go Examiner: Print Name: Josh Block Level II Date 7/ 1/2021 clockwise when facing downstream direction of flow (right hand rule). -Yo \'"\ rlt SI 1 ~~ µ I Reviewer: Print Name V19-- Level.II!. Date Form: UT-11 R2
AR 02347348 90 Day Re-inspection of U3 ICW Through-Wall Flaw Page 2 of 3 01July2021 Location Thickness Reading Previous Readings 1 0.738" 0.748" and 0.745" 2 0.607" 0.652" and 0.652" 3 0.383" 0.416" and 0.415" 4 0.346" 0.369" and 0.363" 5 0.368" 0.387" and 0.370" 6 0.500" I 0.558" 0.506" /0.619" and 0.500" /0.583" 7 0.766" 0.767" and 0.767" 8 0.720" 0.721" and 0.729"
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Flow-Accelerated Corrosion FAC Ultrasonic Thickness Re ort NDE Re ort # 21-053 D St. Lucie 1 0 Turkey Point 3 D Seabrook ULTRASONIC THICKNESS REPORT D St. Lucie 2 D Turkey Point 4 Procedure: NDE-5.18 Rev. 9 Component ID: Drawing: 5613-M-3019 SH 2 I Component Type: Concrete Lined Cast Building: CCW Pump Room Pi e se ment between V 3-50-406 & V 3-50-452 5613-P-820-S SH I Iron Pi e Material: System: 019 Intake Cooling Water Diameter: 24" Elevation: 21 ' 11-1 1/ 16" CS I Cast Iron Pipe INSTRUMENT Manufacturer: GE Rane: 3.0" SKETCH Notto Scale Upstream Component v 3-50-406 Serial Number: 01 YKT6 Gain: 51 DB Downstream Component v 3-50-452 Model: USN 58 L Velocity: 0.1799 Electronic file ID NIA TRANSDUCER Manufacturer: GE Serial No.:57461-54306 TEMPERATURE N_. Manufacturer: Omega Serial Number: 19376 I 110591 FLOW Component:84.4°F Reference Block: 85.2°F REFERENCE BLOCK Serial Number: PTN-ICW-1 Material: Cast Pi e COUP LANT 10325F CALIBRATION INFORMATION Calibration Thickness' Calibration Times Actual Measured 0.498" 0.498" Initial: 1442 0.748" 0.750" Intermediate: 1530 0.998" 0.997" 1.499" 1.499" Final: 1603 DATA2 0.730" View: D Top D Side Previously examined: 0 Yes 0 No NIA Grid Size: D 1" 0 2" 04" D 3" - Scan Exam performed from: 0 0D Orn 0.120" NIA Comments I Remarks I Limitations: Bullse e: 1 thru 8 90 da re ins ection of leak area. Reference AR 02347348 0.333" See Pa e 2 for table of readin s. See Pa e 3 for Sketch Minimum Measured coordinate 4 0 Yes 0No
1. To be considered acceptable for use, the instrument shall read +/- 0.005" from the actual thickness measured.

2. Unless otherwise specified, numbers run in the direction of flow. Letters go Examiner: Print Name: Keith Arsenault Level: II Date: 27 Se tember 2021 clockwise when facing downstream direction of flow (right hand rule). °"DO'l""'l¥1'l_
Reviewer: Print Name: SI; VON Level: Date: Form: UT- I I R2
AR 02347348 90 Day Re-inspection of U3 ICW Through-Wall Flaw Page 2 of 3 27 September 2021 Location Thickness Reading Previous Readings 1 0.733" 0.738 0.748" and 0.745 11 11 2 0.596" 0.607", 0.652 and 0.652 11 11 3 0.378" 0.383 11 1 0.416 and 0.415" 11 4 0.333" 0.346", 0.369 and 0.363" 11 s 0.368" 0.368 0.387" and 0.370" 11 1 6 0.498" I 0.556" 0.500" I 0.558", 0.506"/0.619" and 0.500"/0.583 11 7 0.759" 0.766", 0.767" and 0.767" 8 0.718" 0.720", 0.721" and 0.729"
PAGc 3 oF 3 (]). ~33 ({). ?SCf (/). 596 " (f).SS6 (/) .,378 (j) . 333 (/). 368 **
Flow-Accelerated Corrosion (F AC) Ultrasonic Thickness Report NDE Report# 21-05 6 D St. Lucie 1 D Seabrook
@ D St. Lucie 2 ~ Turkey Point 3 D Turkey Point 4 ULTRASONIC THICKNESS REPORT Procedure: NDE-5.18 Rev. 9 F=PL Component ID: Drawing: 5613-M-3019 SH 2 I Component Type: Concrete Lined Cast Building: CCW Pump Room Pipe segment between V 3-50-406 & V 3-50-452 5613-P-820-S SH 1 Iron Pioe Material: System: 019 Intake Cooling Water Diameter: 24" Elevation: 21 ' 11-11/16" CS I Cast Iron Pipe INSTRUMENT Manufacturer: GE Range: 3.0" SKETCH Notto Scale Upstream Component v 3-50-406 Serial Number: 01YKT6 Gain: 51 DB Downstream Component v 3-50-452 Model: USN 58 L Velocity: 0. 1799 Electronic file ID NIA TRANSDUCER Manufacturer: GE Serial No.: 53797 Model: MSEB2 Frequency: 2MHZ See attached Sketch on Page 3 of this report.
Size: 3.5x10mm # of Elements: 2 Cable Length: 6' Cable Type:RG-174 Sketch includes/references previous report data/information/locations. TEMPERATURE Manufacturer:~TC Serial Number: 284607 Component: 87oF Reference Block: 85 °F REFERENCE BLOCK Serial Number: PTN-ICW-1 Material: Cast Pipe COUPLANT Type: Ultragel II Batch: 10325F CALIBRATION INFORMATION Calibration Thickness 1 Calibration Times Actual Measured 0.498" 0.497" Initial: 1346 0.748" 0.746" Intermediate: 1415 0.998" 0.999" Intermediate: 1504 1.499" 1.500" Intermediate: 1543 Final: 1610 DATA2 Nominal (TnominaI) 0.730" View: D Top D Side Previously examined: ~ Yes 0 No Screening (Tscreening) NIA Grid Size: 0 1" 0 2" 0 4" D 3" - Scan Exam performed from: ~OD O rn Minimum Acceptable (Tminimum 0.120" Alpha grid limit: A through NIA Comments I Remarks I L imitations: Reference AR 02347348 Numeric grid limit: 1 through 9 + Roman Numerals Sunnlemental Readings taken around flaw location. Minimum Measured (T min meas) 0.336" Readings at Locations 1 through 9 and I, II, IV, VI, VII, & VIII taken on 7/15/2021. Minimum Measured (coordinate) 5 Readin2s at Locations III and V taken on 7/1/2021. Above Screening? ~Yes 0No This Report compiled on 10/11/2021.
1. To be considered acceptable for use, the instrument shall read+/- 0.005" from the actual thickness measured.
Examiner: Print Name: Josh Block Sign ht~ - Level II Date 10/11/2021
r. """""

2. Unless otherwise specified, numbers run in the direction of flow. Letters go
~e.te-/tlt"f_ -r-. . '][!:""
Sign Name ~~~ clockwise when facing downstream direction of flow (right hand rule). 1\/1'-/Z.~I Reviewer: Print Name Level Date Form: UT-1 1
AR 02347348 Supplemental Readings Page 2 of S NOE Report# 21-056 ~ The Flaw Hole is encompassed by a 7/8" diameter circle. ~ Location #5 is axially centered on the Flaw location . Each Location is Yi" apart circumferentially, and 1" downstream from the upstream flange of the spool piece. Location Number Thickness Reading 1 0.82411 2 0.715 11 3 0.591 11 4 o.50711 5 0.336 11 6 0.401 11 7 0.39411 8 0.60911 9 0.68011 ~ *points identify where readings 6f 0.730" were located. Thickness Reading Location I 0.73011 II 0.73011 Ill 0.766 11 IV 0.73011 v 0.738 11 VI 0.73011 VII 0.73011 VIII 0.730 11 ~ The Re-Inspection Points are represented by the 1-3/8" diameter circle with points labeled A(l), B(2), C(3), D(4), E(5), F(6), G(7), and H(8). Note two readings/points in zone F(6). (Reference NDE Report# 21-053) (See Page 4) ~ Roman Numerals XV (15), XVI (16), and XVII (17) indicate the 3" bands that were 100% scanned during the extent of condition inspection(s). (Reference NDE Report# 21-028 performed on 02 and 13 April 2021) (See Page 5)
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AR 02347348 90 Day Re-inspection of U3 ICW Through-Wall Flaw Page'{ of S NDE Report# 21-053: 27 September 2021 0.596" 0.607", 0.652" and 0.652" 0.378" 0.383", 0.416" and 0.415" 0.333" 0.346", 0.369" and 0.363" 0.368" 0.368", 0.387" and 0.370" 0.498" I 0.556" .0.500" / 0.558", 0.506"/0.619" and 0.500"/0.583" 0.759" 0.766", 0.767" and 0.767" 0.718" 0.720", 0.721" and 0.729"
J><TENT 0 ~ CoA101nc"1 NDE' Rci>oRT Zt ;<I - (l)::? 8
!CW Flaw Location Pipe segment between valve 3-50-406 (upstream} and valve 3-50-452 {downstream)
Pipe is 24" Diameter Cast Iron {concrete lined) System: 019 fntake Cooling Water P&lD: 5613-M-3019 Sh. 2 ISO: 5613-P-820-S Sheet 1of2 (Nodes 15 to 16} Temperature: 79.S"F {02 1\pri l 202li, & 80.0"l (13 April 202:1.) lhstrument: USN 60 S/N: 01R6B7 Transducer: MSEB2 2.MHz % S/N: 57461-53797 Cal Block: S/N: ?TN-lCW~1 4-St~p: 0.49811, 0,748", 0.99811, 1.4;J9" Inspection Date: 02 April 2021 & 13 April 2021 1* 01o862" 'd/8 -a,,"iJJ~~? 2* 0.912" 119 ')) ..130'9 3* 0.932" ' 20 1.1551' 4 o,.999n 21 1 ..105" 5 1 ..081" 22 1.099" 6 1.121" 23 I o..947" 7 1 ..083 24* o. 93&" 8 I 1.020" 25* 0~900 9 0.979'1 * .. 26"' 0.79~" 10 o.930,, 27 0 .804" 11 0.887 28 0 $829" 12 0.798" 13 Om 819" 14* 0.892" xv 115* @~~15'~ XVI 116"' (~a) @. 731P~ (See attac ed sketch for Thick h.ess Measurements at 1/2" from t1aw) XVII "di'!*** @.sr1~,
*Denotes Raised (cast) "Lettering" in this inspection segment/block (1) The Flaw is located in this segment/block. Value is lowest identified outside the W' line from the flaw cavity. See readings around ffo\iv location for additional information.
Calibration Times~ 02 April 2021: 1449, 1511, 1549, & 1558 1$ April 2021: 1528, 15511 & 1612 Segments are 3" Circumferential and 3" Longitudinal plocks" Zero Reference is TDC with 1-28 with direction of flow.
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v t e Letter Sequence Response to RAI
EPID:L-2022-LLR-0032, Fifth Ten-Year Inservice Inspection Interval Relief Request No. 10 (Approved, Closed)
Initiation Request, Request Acceptance... Supplement, Supplement Administration Questions 21 March 2022 Answers 15 October 2021 25 October 2021 Results Approval, Approval Other:
MONTHYEAR2022-03-10 [Table View]

L-2021-197, Response to Request for Additional Information for ISI Relief Request No. 10

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L-2021-197, Response to Request for Additional Information for ISI Relief Request No. 10

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