ML13303B561

Response to Request for Additional Information and Re-submittal of Relief Request No. 12

ML13303B561
Person / Time
Site:	Turkey Point
Issue date:	10/09/2013
From:	Kiley M W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2013-288
Download: ML13303B561 (35)

Text

1 "10 October 9, 2013PPL. L-2013-288 10 CFR 50.55aU.S. Nuclear Regulatory Commission Attn: Document Control DeskWashington, DC 20555-0001 RE: Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251Relief Request No. 12Response to Request for Additional Information and Re-submittal of Relief RequestNo. 12By letter L-2013-113, dated May 24, 2013, (Agencywide Documents Access andManagement System (ADAMS) Accession No. ML1 3164A1 86), Florida Power & LightCompany (FPL) submitted Relief Request No. 12 to the U.S. Nuclear Regulatory Commission (NRC) for review and authorization.

FPL requested relief from ASME SectionXI, section IWB-5200, subsection IWB-5222, paragraph (b), for the Class 1 pressure testboundaries subject to system pressurization identified in Table 1 and plant drawings ofRelief Request No. 12.On September 9, 2013, via electronic mail, Ms. Farideh E. Saba, NRC Senior ProjectManager for Turkey Point Units 3 and 4, requested additional information regarding ReliefRequest No. 12, by October 11, 2013.Enclosure 1 to this letter contains NRC's Request for Additional Information (RAI) questions for Relief Request No. 12, and the corresponding FPL responses.

Enclosure 2 to this lettercontains the revised Relief Request No. 12, which supersedes in its entirety the previousRelief Request No. 12.Due to the extended refueling outages for the extended power uprate (EPU) Turkey Pointplant modifications, FPL is invoking the provision of ASME Code Section XI, IWA-2430(d)l toextend the Fourth 10-Year ISI interval by 1-year for both Turkey Point Units 3 and 4 tocomplete the required inservice inspections during the refueling outages for Cycle 27 andCycle 28 for Units 3 and Units 4 respectively, and to credit those inspections/examinations tothe Fourth 10-Year ISI Interval.

Accordingly, FPL requests the approval of the attachedrevised Relief Request No. 12 by February 1, 2014 to support the Unit 3 refueling outage forCycle 27 currently scheduled in the Spring of 2014, and the Turkey Point Unit 4 refueling outage activities currently scheduled for Cycle 28 in the Fall of 2014.Florida Power & Light Company9760 S.W. 344" Street Homestead, FL 33035 L-2013-288 Page 2 of 2If you have any questions, please contact Mr. Robert J. Tomonto, Licensing

Manager, at(305) 246-7327.

Very truly yours,Michael KileySite Vice President Turkey Point Nuclear PlantEnclosures SMcc: Regional Administrator, Region II, USNRCSenior Resident Inspector, USNRC, Turkey Point PlantProject Manager, NRR, USNRC FPL Letter L-2013-288 ENCLOSURE 1Florida Power & Light CompanyTurkey Point Nuclear Plant Units 3 and 4Responses to NRCRequest for Additional Information For Relief Request No. 12 L-2013-288 Enclosure 1Page 1 of 4NRC RAI-1Describe any history of degradation, such as fatigue or stress corrosion

cracking, of thesubject lines at Turkey Point Nuclear Generating Unit Nos. 3 and 4.FPL Response to RAI-1A review of the In-service Inspection Reports and Corrective Action Program (CAP) database indicate that there is no history of degradation, such as fatigue or stress corrosion

cracking, of the subject lines at Turkey Point Units 3 and 4.NRC RAI-2Provide an estimate of the radiological dose associated with pressurizing the subjectvent and drain lines to the required pressure.

FPL Response to RAI-2The activity to pressurize the subject vent and drain lines to the required

pressure, wouldinvolve Operations and ISI personnel to operate the valve and to perform these inspections.

This activity would normally be performed during Mode 3. The historical Mode 3 Radiation Protection survey maps were utilized to provide an estimate of the radiological doseassociated with pressurizing the subject vent and drain lines to the required pressure.

Theradiological dose estimates for this activity yielded a value of 280 mrem for Turkey PointUnit 3 and a value of 344 mrem for Turkey Point Unit 4.NRC RAI-3For the 14-inch diameter segment between the residual heat removal (RHR) inletmotor operated valves (MOVs) 750 and 751, a VT-2 visual examination would indicateleakage only if the lines are pressurized or have been pressurized during operation.

a. What is the pressure in this segment during normal operation?

b. Is there a provision to pressurize the subject piping segment between the twoMOVs to the required test pressure (i.e., is there a test connection in thissegment)?

c. Describe the hardship associated with pressurizing this segment to thepressure corresponding to 100 percent rated reactor power and performing theVT-2 visual examination.

d. Provide a technical basis for expectation of leak tightness of the subjectsegment if the line is not pressurized to the required pressure whenperforming the VT-2 visual examination.

L-2013-288 Enclosure 1Page 2 of 4FPL Response to RAI-3a. What is the pressure in this segment during normal operation?

During normal RHR operation, this segment of pipe experiences pressures equivalent to reactor cavity static head and up to 450 psig. During normal plantoperations, this 14-inch diameter segment is isolated from the Reactor CoolantSystem (RCS). However, it is possible that the segment of pipe between MOV-3/4-750 and MOV-3/4-751 becomes pressurized due to minor leak-by past the firstisolation valve. This pressurization could come close to RCS pressure.

b. Is there a provision to pressurize the subject piping segment between the twoMOVs to the required test pressure (i.e., is there a test connection in thissegment)?

Yes, there is a provision to pressurize the subject piping segment between the twoMOVs. Both Turkey Point Units 3 and 4 have a drain connection (valves 3-750D and4-750D respectively) in this segment.

In addition, Turkey Point Unit 4 has a ventvalve, 4-750A, at that pipe segment.c. Describe the hardship associated with pressurizing this segment to thepressure corresponding to 100 percent rated reactor power and performing theVT-2 visual examination.

The RHR system limiting pressure is at 450 psig. The hardship associated withpressurizing this segment to the pressure corresponding to 100 percent rated reactorpower, and performing the VT-2 visual examination, is the fact that MOV-3/4-750 would need to be bypassed by installing a pipe jumper. This pipe jumper willexperience the RCS pressure and temperature conditions.

Risks associated withutilizing a pipe jumper include the possibility of over pressurizing the RHR systemshould the RHR Inlet valves MOV-3-751 or MOV-4-751 fail. Additionally, if a leakdevelops at the pipe jumper; it could result in an un-isolable RCS leak. Testing andsupporting personnel safety would be at risk, due to the leakage being at RCSconditions.

d. Provide a technical basis for expectation of leak tightness of the subjectsegment if the line is not pressurized to the required pressure whenperforming the VT-2 visual examination.

The subject segment is pressurized to RHR system pressure for a significant periodof time during a refueling outage. Therefore, there is reasonable assurance that anyleakage in this subject segment would be identified during the RCS system leakagetesting.Also, a review of the In-service Inspection Reports and CAP data base wasperformed.

Based on this review, no leak tightness issues of the subject segmenthave occurred.

L-2013-288 Enclosure 1Page 3 of 4NRC RAI-4Are the subject low head safety injection check valves and upstream pipingcontinuously pressurized during an operating cycle? Would the provisions of ASMECode Case N-731 apply to these segments?

FPL Response to RAI-4The subject low head safety injection check valves and upstream piping are continuously pressurized during an operating cycle by the Safety Injection Accumulators.

Therefore, theprovisions of ASME Code Case N-731 apply to these segments.

Hence, no relief request isrequired for the subject low head safety injection check valves and upstream piping. ReliefRequest No. 12, previously submitted in L-2013-113, dated May 24, 2013, has been revisedto delete Section 4.0 discussions addressing Safety Injection Loops Low Head CheckValves 3-875A/B/C and 4-875A/B/C, and upstream piping. The associated pressureretaining components have been deleted from Table 1 of the revised relief request.NRC RAI-5For the subject safety injection loop high head check valves and upstream pipinglines, a VT-2 visual examination would indicate leakage only if the lines arepressurized or have been pressurized during operation.

a. What is the maximum pressure in these lines during normal operation?

b. Describe the hardship associated with pressurizing this segment to thepressure corresponding to 100 percent rated reactor power.c. Is there a provision to pressurize the subject piping segment to a pressure thatis at least the pressure of the high head safety injection pump in operation?

Ifa hardship is associated with pressurizing the subject piping segment, pleasedescribe it.d. Provide a technical basis for expectation of leak tightness of the subject linesif they are not pressurized when performing the VT-2 visual examination.

L-2013-288 Enclosure 1Page 4 of 4FPL Response to RAI-5a. What is the maximum pressure in these lines during normal operation?

The subject piping lines are isolated during normal operation.

Therefore, these linesdo not experience pressure.

However, it is possible that the piping becomespressurized due to minor leakage past the first isolation valve.b. Describe the hardship associated with pressurizing this segment to thepressure corresponding to 100 percent rated reactor power.The following evolutions describe the hardship associated with pressurizing thissegment to the pressure corresponding to 100 percent rated reactor power:To pressurize these lines, the high head check valve will need to be temporarily modified by removing its internals.

This modification will create a configuration whereonly one isolation valve will be available to prevent over pressurizing the high headsafety injection system. At the completion of this evolution, the affected pipesegment will need to be de-pressurized in order to restore the affected check valveto its original configuration.

Another option would be to bypass one of the high head check valves by installing apipe jumper. This pipe jumper will experience RCS pressure and temperature conditions.

If a leak develops at the pipe jumper; it could result in a potential un-isolable RCS leak. Testing and supporting personnel safety would be at risk, due tothe leakage being at RCS conditions.

c. Is there a provision to pressurize the subject piping segment to a pressure thatis at least the pressure of the high head safety injection pump in operation?

Ifa hardship is associated with pressurizing the subject piping segment, pleasedescribe it.There is a provision to pressurize the subject piping segment by performing theSafety Injection System Full Flow Test. FPL performs this test during a refueling outage when the reactor head is removed and the reactor cavity is flooded.

A VT-2visual examination of the subject piping is then performed while a Safety Injection Pump is running.d. Provide a technical basis for expectation of leak tightness of the subject linesif they are not pressurized when performing the VT-2 visual examination.

Based on a review of the In-service Inspection Reports and CAP data base, it isconcluded that there are no leak tightness issues identified for the subject lines. Thesubject lines will be pressurized during the Safety Injection System Full Flow Test.During this test, the lines will be VT-2 visually examined.

FPL Letter L-2013-288 ENCLOSURE 2Florida Power & Light CompanyTurkey Point Nuclear Plant Units 3 and 4RevisedRelief Request No. 12 L- 2013-288, Enclosure 2Page 1 of 1110 CFR 50.55a Relief Request Number 12Proposed Alternative in Accordance with 10 CFR 50.55a (a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety1. ASME Code Component(s)

Affected:

The affected components associated with this relief request are the Turkey Point Units 3and 4 Class 1 pressure retaining components within the identified system boundary listed inTable 1 and the attached plant drawings.

2. Applicable Code Edition and Addenda:The code of record for Turkey Point Units 3 and 4 for the Fourth 10-year Inservice Inspection (ISI) interval is the 1998 Edition with Addenda through 2000 of the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV), Section Xl, "Rules forInservice Inspection of Nuclear Power Plant Components."

3. Applicable Code Requirement:

The ASME B&PV Section XI 1998 Edition with Addenda through 2000, Table IWB-2500-1, Section IWB-5200 "System Test Requirements",

subsection IWB-5222 "Boundaries",

paragraph (b), requires that "The pressure retaining boundary during the system leakage testconducted at or near the end of each inspection interval shall extend to all Class 1 pressureretaining components within the system boundary."

4. Basis for Hardship or Unusual Difficulty without Compensating Increase In level ofQuality or Safety:Florida Power & Light Company (FPL) requests relief from IWB-5222(b) in accordance with10 CFR 50.55a(a)(3)(ii) on the basis that hardship or unusual difficulty exists, without acompensating increase in the level of quality and safety. The attached Table 1 and plantdrawings identify the Class 1 pressure retaining components that are associated with therequested relief.The reason for the relief is discussed below.Turkey Point Units 3 and 4 design of Class 1 vents and drains typically consist of a singleisolation valve with a capped/blind flanged end that constitutes the Class 1 system boundary.

Many of these valves are not readily accessible due to their physical locations andradiation/contamination levels in the area. Pressurization of these locations for testing wouldbe performed in Mode 3 and would involve opening these single isolation valves to L- 2013-288, Enclosure 2Page 2 of 11pressurize to the extended Class 1 pressure retaining components within the systemboundary.

After performance of the required VT-2 visual examination, these single isolation valves would be closed, isolating a high temperature, pressurized volume of water betweenthe isolation valve and the capped/blind flanged end. This results in an undesirable plantconfiguration that would be conducive to pressure lock or the initiation of system leakagefrom valve packing or capped/blind flanged ends.In addition, the piping associated with the vents and drains will contain pressurized reactorcoolant fluid between the valve and cap/blind flange. During the subsequent refueling outage, after depressurization of the reactor coolant system, the valve would need to beopened prior to cap/blind flange removal in order to release the pressurized slug of reactorcoolant system fluid contained between the valve and cap/blind flange. This will need to beperformed in order to eliminate a safety hazard.Turkey Point Units No. 3 and 4 design also requires substantial effort to extend the Class 1system boundary where check valves or non-redundant components serve as the firstsystem isolation from the reactor coolant system. Such configurations may require checkvalve disassembly or other temporary configurations to achieve test pressures at upstreampiping and valves. Since the Class 1 system pressure testing is performed in Mode 3, thesetemporary configurations could conflict with Technical Specification requirements and valvealignments.

Establishing and restoring such temporary configurations could also result in anunwarranted increase in worker radiation exposures.

Relief is requested from fully pressurizing piping between the first and second isolation device on small bore size vent, drain, test, and fill lines in the Reactor Coolant System(RCS), which range in size from 0.5 inch to 2 inches. The configurations are either two smallisolation valves in series, a valve and blind flange, or a valve and cap. In certainconfigurations, the piping between the two isolation boundaries will tee to a third valve that isalso the second isolation boundary.

The piping segments provide the design requireddouble isolation barrier for the reactor coolant pressure boundary.

The code requiredleakage test would be performed in Mode 3 at the normal operating temperature andpressure.

Leakage testing of these piping segments at nominal operating pressure in Mode 3 wouldrequire the opening of the inboard isolation valve at the normal operating RCS temperature and pressure conditions.

In doing so, the design requirement for two primary coolantpressure boundary isolation devices would be violated.

Additionally, opening of these valvesintroduces the potential risk for spills and personnel contamination.

For configuration whereblind flanges or caps are installed as the isolation device, opening of the inboard valveintroduces the possibility of a personnel safety hazard if a flange or cap fails in the presenceof inspection personnel.

A VT-2 visual examination is performed on these piping segments through the entire lengthas part of the Class 1 system inspection at the conclusion of each refueling outage. Thisleakage test does not specifically pressurize past the first isolation valve. Also, this leakagetest is considered successful when no external or visible leakage is identified.

Since this type L- 2013-288, Enclosure 2Page 3 of 11of test assures that the combined first and second isolation devices are effective inmaintaining the reactor coolant pressure boundary at normal operating temperature andpressure, the increase in safety achieved from the code required leakage test (IWB-5222(b))

is not commensurate with the hardship of performing such code required leakage testing.14-inch Residual Heat Removal (RHR) Motor Operated Valves (MOV)Turkey Point Unit 3: This piping segment consists of approximately 26 feet of 14-inch pipingbetween RHR inlet valves MOV-3-750 and MOV-3-751.

Within this piping segment there is a3/4 inch pipe branch with a 3/4 inch valve that branches off into a two 1/2 inch valves.Turkey Point Unit 4: This piping segment consists of approximately 44 feet of 14 inch pipingbetween RHR inlet valves MOV-4-750 and MOV-4-751.

Within this piping segment there is a1 inch pipe branch with a 1 inch valve that branches off into a 1 inch valve and a 1/2 inchvalve. Also, within this 14-inch piping segment, there is a 3/4 inch vent valve.MOV-3/4-750 and MOV-3/4-751 are interlocked to avoid over-pressurization of the RHRsystem. The interlock prevents manual opening of the valves with RCS pressure above therequired pressure interlock setpoint.

A VT-2 visual examination is performed on these piping segments through the entire lengthas part of the Class 1 system inspection at the conclusion of each refueling outage. Thisproposed system pressure test does not specifically pressurize past the first isolation valve.It is possible that the piping becomes pressurized due to minor leakage past the firstisolation valve. The leakage test is considered successful when no external or visibleleakage is identified.

This test will provide assurance that the combined first and secondisolation devices are effective in maintaining the reactor coolant pressure boundary atnormal operating temperature and pressure.

Based on the above, extension of the pressure retaining boundary during system leakagetests to Class 1 pressure retaining components within the system boundary represents ahardship and unusual difficulty that does not provide a compensating increase in the level ofquality and safety.Safety Injection Loops High Head Check Valves 3-874A/B, 4-874A/B, and UpstreamPipingThese two piping segments consist of a 2-in. piping span between two check valves orientedtoward the RCS. Pressure testing of these piping segments at nominal operating pressure inMODE 3 would require a modification to allow pressurizing to the normal operating RCStemperature and pressure conditions.

A VT-2 visual examination is performed on these piping segments through the entire lengthas part of the Class 1 system inspection at the conclusion of each refueling outage. Theproposed system pressure test will not specifically pressurize past the first isolation valve for L- 2013-288, Enclosure 2Page 4 of 11this inspection.

It is possible that the piping becomes pressurized due to minor leakage pastthe first isolation valve. The acceptance criteria will be that no external or visible leakage willbe allowed for the test to be successful.

Based on the above, it has been determined that compliance with the ASME Coderequirement to perform the system pressure test on the subject line segments would result ina hardship that would not be compensated by an increase in quality and safety. Theproposed alternative provides reasonable assurance that the subject line segments' leakageintegrity will be maintained.

5. Proposed Alternative and Basis for Use:Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(4),

specifies thatASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except for the design and access provisions and the preservice examination requirements, set forth in the ASME Code, Section Xl to the extent practical within the limitations of designgeometry and materials of construction of the components.

Paragraph 50.55a(a)(3) of 10 CFR Part 50 states, in part, that alternatives to therequirements of 10 CFR 50.55a(g) may be used when authorized by the NRC if the licenseedemonstrates (i) the proposed alternatives would provide an acceptable level of quality andsafety, or if (ii) compliance with the specified requirements would result in hardship orunusual difficulty without a compensating increase in the level of quality and safety. FPL isrequesting authorization of an alternative to the requirements of the ASME Code Section Xl,IWB-5222(b) pursuant to 10 CFR 50.55a(a)(3)(ii).

The proposed alternative for this request relief uses leakage testing.

The Class 1 systemboundary will be maintained in a normal, operational alignment during leakage tests for theitems identified within Table 1 constituting exceptions to the Code-required boundary of IWB-5222(b).

The VT-2 visual examination will extend to the Class 1 pressure retaining components within the system boundary during the performance of each system leakagetest required by Table IWB-2500-1 examination category B-P. Items within Table 1 will bevisually examined for evidence of leakage during system leakage testing without beingpressurized to nominal reactor coolant system operating pressure.

Based on the discussion provided in Section 4, it is concluded that compliance with thespecified requirements would result in hardship or unusual difficulty without compensating increase in the level of quality and safety, while the proposed alternative providesreasonable assurance of structural integrity or leak tightness of the subject components.

6. Duration of Proposed Alternative:

Relief Request No. 12 is requested for Turkey Point Units 3 and 4 for the Fourth 10-Year ISIInterval.

The Unit 3 Fourth 10-Year ISI Interval began February 22, 2004 to February 21,2014 and the Unit 4 Fourth 10-Year Interval began April 15, 2004 to April 14, 2014.

L- 2013-288, Enclosure 2Page 5 of 11Due to the extended refueling outages for the extended power uprate (EPU) Turkey Pointplant modifications, FPL is invoking the provision of ASME Code Section Xl, IWA-2430(d)1 to extend the Fourth 10-Year ISI interval by 1-year for both Turkey Point Units 3 and 4 tocomplete the required inservice inspections during the refueling outages for Cycle 27 andCycle 28 for Units 3 and Units 4 respectively, and to credit those inspections/examinations tothe Fourth 10-Year ISI Interval.

7. Precedent Similar relief has been granted for H.B Robinson Steam Electric Plant Unit No.2, Docket No.50-261, TAC No. ME 8255, ML12181A26.

B. Attachments Plant Drawings referenced in Table 1 L-2013-288, Enclosure 2Page 6 of 11Table IRelief Request No. 12Turkey Point Unit 3 Affected Class I Pressure Retaining Components Code Pipe Pipe Approx ExamAffected Line or Component Class Diameter Schedule Length Category Drawing No. Boundary Exception(s)

Drain line below PZR safety A376 TP316 5613-M-3041 Valve 3-545 remains closed to avoidvalve RV-3-551A (pipe piece 1 3/4 in. SMLS Sch. 160 < 1 ft. B-P Sh. 2 pressurizing downstream Class 1 pipebetween 3-545 and 3-545A) piece and valve 3-545ADrain line below PZR safety Valve 3-546 remains closed to avoidvalve RV-3-551 B (pipe piece 1 3/4 in. A376 TP316 2 ft. B-P 5613-M-3041 pressurizing downstream Class 1 pipebetween 3-546 and 3-546A SMLS Sch. 160 Sh. 2 piece and valves 3-546A and 3-585and 3-585) ____ ______ ____ _____ ______Drain line below PRZ safety A376 TP316 5613-M-3041 Valve 3-547 remains closed to avoidvalve RV-3-551C (pipe piece 1 3/4 in. SMLS Sch. 160 1 ft. B-P Sh. 2 pressurizing downstream Class 1 pipebetween 3-547and 3-547A) piece and valve 3-547AA376 TP316RCS loop intermediate loop 2 in. SMLS Sc.16 1 ft. Valve 3-508A remains closed to avoid"A" drain valve, liquid waste 1SMLS Sch. 160 5613-M-3041 pressurizingemains Clos 1dipoalpiinhndlek-ffpressurizing downstream Class 1disposal piping, and leak-off A376 TP316 Sh. 1 piping and valves 3-508B and 3-542valve. 3/4 in. SL c.10 28 ft.SMLS Sch. 160 28tRCS loop intermediate loop A376 TP316 5613-M-3041 Valve 3-515A remains closed to avoid"B" drain valve and liquid 1 2 in. A376 TP316 1 ft. B-P 51M31 pressurizing downstream Class 1waste disposal piping SMLS Sch. 160 Sh. 1 piping and valve 3-515B.RCS loop intermediate loop A376 TP316 5613-M-3041 Valve 3-505A remains closed to avoid"C" drain valve and liquid 1 2 in. SMLS Sch. 160 ft. B-P Sh.1 pressurizing downstream Class 1waste disposal piping piping and valve 3-505B.RCP "A" seal injection drain A376 TP316 5613-M-3047 Valve 3-300A remains closed to avoidflange SMLS Sch. 160 1 ft. B-P Sh. 3 pressurizing downstream pipe piecevalve and blind andgeSMSflange S.and flangeValve 3-300C remains closed to avoidRCP 'A" seal water bypass 1 / n A376 TP316 51-307pressurizing downstream pipe piecevent valve and blind flange 3/4 in. SMLS Sch. 160 < 1 ft. B-P Sh. 3 and3fiange L-2013-288, Enclosure 2Page 7 of 11Table IRelief Request No. 12Turkey Point Unit 3 Affected Class I Pressure Retaining Components Code Pipe Pipe Approx ExamAffected Line or Component Class Diameter Schedule Length Category Drawing No. Boundary Exception(s)

Valve 3-300D remains closed to avoidRCP "B" seal injection drain A376 TP316 5613-M-3047 pressurizing edowns pipe p ievleadcp13/4 in. _<L 1c. 6 ft. B-P S.3pressurizing downstream pipe piecevalve and cap SMLS Sch. 160 Sh. 3 n aand capValve 3-300F remains closed to avoidRCP "B" seal water bypass A376 TP316 5613-M-3047 pressurizing downstream pipe pieceVent valve and blind flange. 3/4 in. SMLS Sch. 160 1 ft. B-P Sh. 3 and flangeRCP "C" seal injection drain A376 TP316 5613-M-3047 Valve 3-300G remains closed to avoidvalve and cap 1SMLS Sch. 160 ft. B-P Sh. 3 pressurizing downstream pipe pieceand capRCP "C" s t b Valve 3-300J remains closed to avoidRP""seal water bypass 1A376 TP316 5613-M-3047 pressurizing downstream pipe pieceVent valve and blind flange. 3/4 in. SMLS Sch. 160 1 ft. B-P Sh. 3 and flangeS A376eTP316 2 in. A c76 16 139 ft. Valve CV-3-311 remains closed toAuxiliary spray line vent valve B-P 5613-M-3047 avoid pressurizing downstream pipingand upstream piping A376 TP316 Sh. 2 up to check valve 3-313 and vent pipe3/4 in < 1 ft. and vent valve 3-120JSMLS Sch. 160 -14 in. A376TP316 26 ft. Valve MOV-3-750 to remain closed toResidual heat removal motor- SMLS Sch. 140 5613-M-3050 avoid pressuring downstream pipingoperated valve MOV-3-750 B-P Sh. 1 and valves, MOV-3-751, 3-750B, 3-and common suction piping 3/4 in. 1/2 in. A376 TP316 3 ft. 750C and 3-750D.SMLS Sch. 160Valve CV-3-310B to remain closed toDownstream piping of CV A376 TP316 5613-M-3047 VleC--1O ormi lsdt31 p o 1 3 in. A36 TP316 45 ft. B-P 5 M3 avoid pressurizing downstream piping310 SMLS Sch.-160 Sh. 2up to check valve 3-312 B L-2013-288, Enclosure 2Page 8 of 11Table IRelief Request No. 12Turkey Point Unit 3 Affected Class I Pressure Retaining Components Line or Component Code Pipe Pipe Approx ExamAffected LineorComponent Class Diameter Schedule Length Category Drawing No. Boundary Exception(s)

A376 TP316 Check valves 3-874A and 3-874B to2 in. SMLS Sch. 160 222 ft. remain closed to avoid disassembly orSafety Injection check valves 5613-M-3062 other temporary configurations 3-874A, 3-874B and 1 B-P Sh. 1 required to achieve test pressures atupstream piping A376 TP316 upstream piping and valves MOV-3-3/4 in. SMLS Sch. 160 1 ft. 866A and B, 3-941C and D, and 3-957Valve 3-568 remains closed toPressurizer Spray line drain A376 TP316 5613-M-3041 avo presring dostreamvleadcp1 3/4 in. _<1 c. 6 ft. B-P S.2avoid pressurizing downstream valve and cap SMLS Sch. 160 -Sh. 2 pp ic n apipe piece and capValve 3-569 remains closed toPressurizer Spray line drain A376 TP316 5613-M-3041 avo presring dostreamvleadcp1 3/4 in. _<1S ft.16 B-P S.2avoid pressurizing downstream valve and cap SMLS Sch. 160 -Sh. 2 pp ic n apipe piece and capValve 3-201A remains closed toRegenerative Heat Exchanger A376 TP316 5613-M-3047 avo p resr ing dostreamoutlet drain line and cap 3/4 in. SMLS Sch. 160 _ 1 ft. B-P Sh. 1 avoid pressurizing downstream I pipe piece and cap L-2013-288, Enclosure 2Page 9 of 11Table 1Relief Request No.12Turkey Point Unit 4 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Categorý Drawing No. Boundary Exception(s)

Class Diameter Schedule LengthValve 4-545 remains closed tovalve RV-4-551A (pipe piece 1 3/4 in. SMLS TP316 B-P 5614-M-3041 avoid pressurizing downstream between 4-545 and 4-545A) SMLS Sch. 160 Sh. 2 Class 1 pipe piece and valve 4-545ADrain line below PZR safety Valve 4-546 remains closed tovalve RV-4-551B (pipe piece 3/4 in. A376 TP316 < 2 ft. B-P 5614-M-3041 avoid pressurizing downstream between 4-546, 4-546A, and SMLS Sch. 160 Sh. 2 Class 1 pipe piece and valves 4-4-585) 546A and 4-585Valve 4-547 remains closed toDrain line below PRZ safety .A376 TP316 5614-M-3041 avoid pressurizing downstream valve RV-4-551C (pipe piece 3/4 in. SMLS Sch. 160 < 1 ft. B-P Sh. 2 Class 1 pipe piece and valve 4-between 4-547and 4-547A) 547AA376 TP316RCS loop intermediate loop 2 in. SMLS Sch. 160 <1ft. Valve 4-508A remains closed to"A" drain valve, liquid waste ___10B-P 5614-M-3041 avoid pressurizing downstream disposal piping, and leak-off A376 TP316 Sh. 1 Class 1 piping and valves 4-508Bvalve 3/4 in. 28 ft. and 4-542RCS loop intermediate loop A376 TP316 5614-M-3041 Valve 4-515A remains closed to"B" drain valve and liquid 1 2 in. SMLS Sch. 160 1 ft. B-P Sh. 1 avoid pressurizing downstream waste disposal piping Class 1 piping and valve 4-515B.RCS loop intermediate loop A376 TP316 5614-M-3041 Valve 4-505A remains closed to"C" drain valve and liquid 1 2 in. SMLS Sch. 160 1 ft. B-P Sh. avoid pressurizing downstream waste disposal piping Class 1 piping and valve 4-505B.RCP "A" seal injection drain A376 TP316 5614-M-3047 Valve 4-300A remains closed tovalve and blind flange 1 3/4 in. SMLS Sch. 160 B-P Sh. 3 avoid pressurizing downstream pipe piece and flange L-2013-288, Enclosure 2Page 10 of 11Table IRelief Request No.12Turkey Point Unit 4 Affected Class I Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Categorý Drawing No. Boundary Exception(s)

Class Diameter Schedule LengthRCP "A" seal water bypass A376TP316 5614-M-3047 Valve 4-300C remains closed tovent valve and blind flange 1 3/4 in. SMLS Sch. 160 5B-P Sh. 3 avoid pressurizing downstream pipe piece and flangeA376P316Valve 4-300D remains closed toRCP "B" seal injection drain A376 TP316 5614-M-3047 Vle430 ean lsdtjc tn3/4 in. 10 B-P avoid pressurizing downstream RCPa B"veald dria1 34pn SMLS Sch. 160 Sh.f. -514M30pipe piece and capA376P316Valve 4-300F remains closed toRCP "B" seal water bypass A376 TP316 5614-M-3047 avo p resr ing dostreamVent valve and blind flange. h33/4 in. SMLS Sch. 160 < 1 B-P avoid pressurizing downstream pipe piece and flangeValve 4-300G remains closed toRCP "C" seal injection drain A376 TP316 5614-M-3047 Vle43O ean lsdtvalve and cap 3/4 in. A36 1 ft.1B-P 56143 avoid pressurizing downstream RCPaC"veald inetindrip SMLS Sch. 160 1f. BP Sh. 3 iepec n apipe piece and capsA376TP316 Valve 4-300J remains closed toRCPt ""ale wat bypndfasse 1 3/4 in. SMLS Sch. 160 5614-M-3047 avoid pressurizing downstream Vent valve and blind flange. SSh. 3 pipe piece and flangeValve CV-4-31 1 remains closed toPiping downstream of CV 1 2i. A376 TP316 564h. 34 2av V43 ean lsdt311 1 2 in. SMLS Sch. 160 142 ft. B-P Sh.5614-M-30472 avoid pressurizing downstream piping up to check valve 4-313.14 in. 44 ft. Valve MOV-4-750 to remain closedResiual eat emovl moor-SMLS Sch. 140Residual heat removal motor- 5614-M-3050 to avoid pressuring downstream operated valve MOV-4-750 B-P Sh. 1 piping and valves, MOV-4-751, 4-and common suction piping 314 in. A376 TP316 750A, 4-750B, 4-750C and 4-1/2 in. SMLS Sch. 160 10 ft. 750D.1 in.Valve CV-4-310B to remain closedPiping downstream of CV A376 TP316 5614-M-3047 313B SMLS Sch. 160 48 ft. B-P 5 -3 to avoid pressurizing downstream piping up to check valve 4-312B L-2013-288, Enclosure 2Page 11 of 11Table 1Relief Request No.12Turkey Point Unit 4 Affected Class 1 Pressure Retaining Components Affected Line or Component Code Pipe Pipe Approx Exam Categorý Drawing No. Boundary Exception(s)

Class Diameter Schedule LengthA376 TP316 Check valves 4-874A and 4-874B2 in. 140 ft.SMLS Sch. 160 to remain closed to avoidSafety Injection check valves 5614-M-3062 disassembly or other temporary 4-874A, 4-874B and B-P Sh. 1 configurations required to achieveupstream piping 3/4 in. A376 TP316 test pressures at upstream piping1 in. SMLS Sch. 160 and valves MOV-4-866A and B, 4-941C and D, and 4-957iA376TP316 Valve 4-568 remains closed toPrssrierSpaylie ran 1 3/4 in. SMSSh10 1 ft. B-P 51M341avoid pressurizing downstream valve and cap SL c.10Sh. 2 pipe piece and capPressurizer Spray line drain A376 TP316 5614-M-3041 Valve 4-569 remains closed to1 3/4 in. <1 ft. B-P avoid pressurizing downstream valve and cap SMLS Sch. 160 Sh. 2 aid presrng dnr____________________

___________

_________

___ ___ ___ pipe piece and capValve 4-201A remains closedoetedrain le and3/4 in. A3L6 T3160 1 ft. B-P 5614-M-3047 to avoid pressurizing outlet drain line and flange SMLS Sch. 160 Sh. 1 downstream pipe piece andflange