Wulf Ratbane
Adventurer
Also, there's the Gray Render Zombie problem, with it's 20 HD, 133 hp, and CR 6. Unturnable before level 16 in standard 3.5, and while the 9d6 turning damage (~32) of a 9th level cleric would hurt it, turning won't be any more effective than simply beating it to (re)death.
In Trailblazer, a 6th level cleric can actually turn one of those. You won't destroy it until level 40, but at least you can make it go away when it's still level-appropriate.
Yeah, I reckon you should get him about half the time.
For me, turning vs. damaging was an important thematic distinction, and that's why I came down where I did (despite having some good leads on the damage route).
I spent a long time, actually, wondering whether the inevitable HD-driven turn-immunity of non-intelligent undead was a bug or a feature. It just didn't make any sense to me that the cleric should have an easier time turning the lich than turning the lich's skeletons and zombies (Huge though they may be).