Surry, Unit 1 - Fifth 10-Year Interval Inservice Inspection Program … · 2013-12-10 · SPS Ul...

10 CFR 50.55aVIRGINIA ELECTRIC AND POWER COMPANY

RICHMOND, VIRGINIA 23261

November 26, 2013

United States Nuclear Regulatory Commission Serial No. 13-611Attention: Document Control Desk NL&OS/GDM RI'Washington, D. C. 20555 Docket No. 50-280

License No. DPR-32

VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNIT 1FIFTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAMAND ALTERNATIVE REQUESTS

Pursuant to 10 CFR 50.55a(g)(4), Virginia Electric and Power Company (Dominion)submits the Inservice Inspection (ISI) Program for the Fifth 10-Year Inservice InspectionInterval for Surry Power Station (SPS) Unit 1 for Class 1, 2, and 3 components andcomponent supports. The ISI Plan, included in the attachment to this letter, describesthe programmatic aspects of inservice examinations of components and componentsupports. Dominion plans to utilize a full scope Risk Informed application based onCode Case N-716 or Code Case N-716-1 and will address either by relief application orutilization of the appropriate code case version as approved for use in RegulatoryGuide 1.147.

By letter dated April 25, 2012 letter (Serial No. 12-191), Dominion requested approval ofRelief Request S1-15-ISI-01, "Fifth 10-year Inservice Inspection Interval ASME SectionXl Code of Record," to permit the use of an earlier approved Code Edition, the 2004Edition (No Addenda), as the Code of Record for the SPS Unit 1 fifth ISI interval. TheNRC approved the relief request by letter dated April 29, 2013 [TAC ME 8774,ML13100A049].

The SPS Unit 1 Fifth 10-Year ISI Interval will begin on December 14, 2013 andcomplete on October 13, 2023. As allowed by 10 CFR 50.55a(a)(3), alternatives tospecific requirements of ASME Section Xl or 10 CFR 50.55a that provide an acceptablelevel of quality and safety and provide a methodology more conducive to theperformance of an examination have been proposed. Similarly, alternatives have beenproposed when compliance with specified requirements would result in hardship orunusual difficulty without a compensating increase in the level of quality and safety.The proposed alternatives from specific Section Xl requirements are provided in Section2 of the attachment. Previously submitted similar relief requests are identified alongwith the NRC approval reference, where applicable.

The SPS Unit 1 Fifth 10-Year Interval ISI Program and associated requests for the useof alternatives have been reviewed and approved by the station's Facility Safety ReviewCommittee.

Serial No. 13-611Docket No. 50-280

Fifth Interval ISI Program and Requests of 2

Dominion requests review and approval of the attached requests for the use ofalternatives by December 31, 2014.

If you have any questions or require additional information, please contact Gary D.Miller at (804) 273-2771.

Respectfully,

Mark D. SartainVice President - Nuclear Engineering and Development

Commitments made in this letter: None

Attachment: Surry Power Station Unit 1 Inservice Inspection Plan for Components andComponent Supports, Fifth 10-Year Inservice Interval

cc: U.S. Nuclear Regulatory Commission, Region IIMarquis One Tower245 Peachtree Center Avenue NE, Suite 1200Atlanta, Georgia 30303-1257

NRC Senior Resident InspectorSurry Power Station

Ms. K. R. Cotton-Gross, NRC Project Manager - SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852

Dr. V. Sreenivas, NRC Project Manager - North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852

Mr. R. A. SmithAuthorized Nuclear InspectorSurry Power Station


VIRGINIA ELECTRIC AND POWER COMPANY

(DOMINION)

SURRY POWER STATION

UNIT I

INSERVICE INSPECTION PLAN FOR

COMPONENTS AND COMPONENT SUPPORTS

FIFTH 10-YEAR INSERVICE INTERVAL

December 14, 2013 - October 13, 2023

Revision 0November, 2013


TABLE OF CONTENTSPage Nos.

ii - iiiAbstract

ISI Classification Boundary Drawings

Interval 5 ISI Correspondence

Section 1 - Inservice Inspection Plan - General

iv - viii

Section 2 - Inservice Inspection Plan for Components

2.3 Relief Requests for Components

2.4 Relief Requests for System Pressure Tests

Section 3 - Inservice Inspection Plan for Component Supports

Section 4 - Miscellaneous Documentation

Section 5 - Limited Coverage Relief Requests

Section 6 - Code Cases Utilized in the Fifth Inservice Inspection Interval

Section 7 - Plan Changes

ix - x

1-1 - 1-12

2-1 - 2-16

2-3-2-12

2-13-2-16

3-1 - 3-2

4-1 - 4-3

5-1 - 5-2

6-1 -6-10

7-1 - 7-2

SPS Ul 15-ISI Plan Revision 0


ABSTRACT


(DOMINION)

SURRY POWER STATION UNIT I

INSERVICE INSPECTION PLAN

FIFTH 10-YEAR INSPECTION INTERVAL

DECEMBER 14, 2013 THROUGH OCTOBER 13, 2023

As required by 10 CFR 50.55a(g)(4)(ii), Dominion is required to update the Surry Unit 1 (SPS1)120-month Inservice Inspection (ISI) Program to the latest Edition and Addenda of the AmericanSociety of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI,approved by the NRC in 10 CFR 50.55a(b)(2) one year before the start of the new interval.Relief Request S-15-ISI-01, "Fifth 10-year Inservice Inspection Interval ASME Section Xl Codeof Record" was requested by an April 25, 2012 letter (Serial No. 12-191) and was approved bythe NRC by letter dated April 29, 2013 [TAC ME 8774, ML13100A049] which allows an earlierapproved Code Edition, the 2004 Edition (No Addenda), to be used as the Code of Record forthe SPS1 Fifth 10-year Interval. Hereafter; the 2004 Edition of this Code, the ASME Boiler andPressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear Power PlantComponents," will be referred to as the "2004 Code" or the "Code" in this document. Theupdated Program is scheduled to commence December 14, 2013 and complete onOctober 13, 2023.

In cases where the requirements of the 2004 Code have been determined to be impractical,requests for relief will be developed per 10 CFR 50.55a(g)(5). As allowed by10 CFR 50.55a(a)(3), alternatives to specific requirements of ASME Section XI or10 CFR 50.55a, that provide an acceptable level of quality and safety and provide amethodology more conducive to the performance of an examination have been proposed.Similarly, alternatives have been proposed when compliance with specified requirements wouldresult in hardship or unusual difficulty without a compensating increase in the level of qualityand safety.

The ISI Program is defined by the ISI Plan and the ISI Schedule. The ISI Plan, provides anoverview and summary of the SPS1 ISI Program for Subsections IWA, IWB, IWC, IWD, and,IWF of the Code.

To meet the requirements of ASME XI IWA-2420(a)(3) "the classification and identification ofthe components subject to examination and test" which defines elements to include in the ISIPlan; station controlled ISI Classification Boundary Drawings (CBMs) have been developed for

SPS Ul 15-ISI Plan ii Revision 0


the Fifth Inspection Interval. The ISI Program boundaries, component classifications, and theemployment of exemptions in IWB-1 220, IWC-1 220, IWD-1 220, and IWF-1 230 of the Code areshown on the ISI Classification Boundary Drawings (CBMs). The graphic codes, symbols andtext used on the CBMs are detailed on 11448-CB-L&S-5, Legends and Symbols Drawing. Twoadditional sets of drawings are used to implement the ISI Plan: the 11448-WMKS series andthe 11448-SPB/SPM series. The 11448-WMKS series identifies the components in the Programand their location in the plant. The locations of welds and supports are shown on thesedrawings. The ISI Schedule identifies which WMKS drawing is associated with each componentin the Program. The 11448-SPB/SPM series identifies the extent of the test zones used by theSystem Pressure Test (SPT) Schedule to complete the required surveillance system pressuretests.

The Inservice Inspection Schedule for Components and Component Supports (ISI Schedule)and the System Pressure Test Schedule (SPT Schedule) are provided in separate volumes ofthe ISI Program. System pressure tests are performed in accordance with the SPTImplementing Schedule. The IWE (Inservice Inspection of Class MC and CC Components) andIWL (Inservice Testing of Class CC Concrete Components) Programs are separate programsand are not included as part of the ISI Program. Steam generator inspections will continue tobe performed in accordance with the Surry Plant Technical Specifications.

Components associated with the containment (IWE and IWL), have separate Plan andSchedule documents, and are therefore excluded from the ISI Plan.

The Implementation Schedule is comprised of two Dominion documents. The first, the ISISchedule, is prepared as a separate document from the ISI Plan. The ISI Schedule identifies bydrawing the components selected for examination and testing, specifies examination category

and item number for each component and the associated Code examination requirements, andprovides a description of alternative examination methods and identification of components tobe examined using alternative methods. The ISI Schedule also provides a list of examinationprocedures, identification of calibration blocks used for ultrasonic examination and the schedulefor the examinations. The second, the SPT Schedule, details the implementation of the SPTProgram. The ISI and the SPT Schedules, jointly, meet the documentation requirements of theCode given in IWA-2420(b), for defining the implementation schedule.

An alternative inspection plan to the ASME Section Xl requirements for the inservice inspection

of Class 1, Category B-J and B-F, and Class 2, Category C-F-1 and C-F-2, piping welds hasbeen prepared under the guidance of Code Case N-716, "Alternative Piping Classification andExamination Requirements, Section Xl, Division 1,", and will either be submitted for approval bythe relief request process or Dominion will adopt the appropriate revision of this Code Casewhen endorsed by the NRC in Regulatory Guide 1.147.

SPS U1 15-ISI Plan iii Revision 0


ISI Classification Boundary Drawings

The following is a list of the Classification Boundary Drawings. The component boundariesaddressed in the ISI Plan, component classifications, and the employment of specificprogrammatic exemptions identified in IWB-1 220, IWC-1 220, IWD-1 220, IWF-1 230, are shownon the ISI Classification Boundary Drawings (CBB/CBM series). This is accomplished by theuse of symbols as well as text on the drawings. The symbols used on these drawings aredefined on the Legends and Symbols Drawing, 11448-CBM-L&S-4. This drawing series,continuously updated and maintained, provide complete identification and classification ofcomponents subject to examination.

Drawing

11448-CB-L&S-5, SH-001

11448-CBB-006A-5,

11448-CBB-041A-5,

11448-CBB-041A-5,

11448-CBB-041A-5,

11448-CBB-047B-5,

11448-CBM-064A-5,

SH-001

SH-001

SH-002

SH-003

SH-001

SH-001

11448-CBM-064A-5, SH-002

11448-CBM-064A-5, SH-003

11448-CBM-064A-5, SH-004

11448-CBM-064B-5, SH-001

11448-CBM-066A-5, SH-002

11448-CBM-066B-5, SH-001

11448-CBM-067A-5, SH-001

11448-CBM-067A-5, SH-002

11448-CBM-067B-5, SH-001

11448-CBM-067B-5, SH-002

System Description

LEGEND & SYMBOLS

AIR COOLING & PURGING SYSTEM

CHILLED WATER

CHILLED WATER

CHILLED WATER

FIRE PROTECTION

MAIN STEAM

MAIN STEAM

MAIN STEAM

MAIN STEAM

STEAM GENERATOR NITROGEN CONN

AUX STEAM & AIR REMOVAL

AUX STEAM SYSTEM - PRIMARY PLANT

CONDENSATE

CONDENSATE

CONDENSATE

CONDENSATE

SPS Ul 15-ISI Plan iv Revision 0


11448-CBM-068A-5, SH-001

11448-CBM-068A-5, SH-002

11448-CBM-068A-5, SH-003

11448-CBM-068A-5, SH-004

11448-CBM-069A-5, SH-002

11448-CBM-070A-5, SH-001

11448-CBM-070A-5, SH-003

11448-CBM-071A-5, SH-001

11448-CBM-071A-5, SH-002

11448-CBM-071A-5, SH-003

11448-CBM-071A-5, SH-004

11448-CBM-071B-5, SH-001

11448-CBM-071B-5, SH-002

11448-CBM-071D-5, SH-001

11448-CBM-071D-5, SH-002

11448-CBM-072A-5, SH-001

11448-CBM-072A-5, SH-002

11448-CBM-072A-5, SH-003

11448-CBM-072A-5, SH-004

11448-CBM-072A-5, SH-005

11448-CBM-072A-5, SH-006

11448-CBM-072A-5, SH-007

11448-CBM-0728-5, SH-001

11448-CBM-072B-5, SH-002

11448-CBM-072B-5, SH-003

FEEDWATER

FEEDWATER

FEEDWATER

FEEDWATER EMERGENCY MAKE-UP

MOISTURE SEPARATOR & HP HTR DR & V

LP HEATER DRAINS & VENTS

LP HEATER DRAINS & VENTS

CIRCULATING AND SERVICE WATER







CIRCULATING & SERVICE WATER

COMPONENT COOLING WATER










SPS Ul 15-ISI Plan V Revision 0

11448-CBM-072C-5, SH-001

11448-CBM-072C-5, SH-002

11448-CBM-072C-5, SH-003

11448-CBM-072C-5, SH-004

11448-CBM-072D-5, SH-001

11448-CBM-072D-5, SH-002

11448-CBM-072D-5, SH-003

11448-CBM-072E-5, SH-001

11448-CBM-072E-5 SH-002

11448-CBM-072G-5, SH-001

11448-CBM-074A-5, SH-001

11448-CBM-075C-5, SH-001

11448-CBM-075G-5, SH-001

11448-CBM-075J-5, SH-001

11448-CBM-079A-5, SH-002

11448-CBM-079C-5, SH-001

11448-CBM-079D-5, SH-001

11448-CBM-081A-5, SH-001

11448-CBM-082A-5, SH-001

11448-CBM-082B-5, SH-002

11448-CBM-083A-5, SH-001

11448-CBM-083A-5, SH-002

11448-CBM-083B-5, SH-001

11448-CBM-083B-5, SH-003

11448-CBM-084A-5, SH-001












VACUUM PRIMING

COMPRESSED AIR

COMPRESSED AIR

CONTAINMENT INSTRUMENT AIR

BORON RECOVERY

BORON RECOVERY

BORON RECOVERY

FUEL PIT

SAMPLING

SAMPLING

VENT AND DRAIN

VENT AND DRAIN

VENT AND DRAIN

VENT AND DRAIN

CONTAINMENT SPRAY

SPS Ul 15-ISI Plan vi Revision 0


11448-CBM-084A-5, SH-002

11448-CBM-084A-5, SH-003

11448-CBM-084B-5, SH-001

11448-CBM-084B-5, SH-002

11448-CBM-085A-5, SH-001

11448-CBM-085A-5, SH-002

11448-CBM-086A-5, SH-001

11448-CBM-086A-5, SH-002

11448-CBM-086A-5, SH-003

11448-CBM-086B-5, SH-001

11448-CBM-086B-5, SH-002

11448-CBM-086C-5, SH-001

11448-CBM-086C-5, SH-002

11448-CBM-087A-5, SH-001

11448-CBM-087A-5, SH-002

11448-CBM-088A-5, SH-001

11448-CBM-088A-5, SH-002

11448-CBM-088A-5, SH-003

11448-CBM-088A-5, SH-004

11448-CBM-088B-5, SH-001

11448-CBM-088B-5, SH-002

11448-CBM-088C-5, SH-001

11448-CBM-088C-5, SH-002

11448-CBM-089A-5, SH-001

11448-CBM-089A-5, SH-002

CONTAINMENT SPRAY

CONTAINMENT SPRAY

RECIRCULATION SPRAY

RECIRCULATION SPRAY

CONT VACUUM & LEAKAGE MONITOR

CONT VACUUM & LEAKAGE MONITOR

REACTOR COOLANT SYSTEM, LOOP-A

REACTOR COOLANT SYSTEM, LOOP-B

REACTOR COOLANT SYSTEM, LOOP-C

REACTOR COOLANT

REACTOR COOLANT

REACTOR COOLANT

REACTOR COOLANT

RESIDUAL HEAT REMOVAL

RESIDUAL HEAT REMOVAL

CHEMICAL & VOLUME CONTROL








SAFETY INJECTION

SAFETY INJECTION

SPS U1 15-ISI Plan vii Revision 0


11448-CBM-089A-5, SH-003

11448-CBM-089B-5, SH-001

11448-CBM-089B-5, SH-002

11448-CBM-089B-5, SH-003

11448-CBM-089B-5, SH-004

11448-CBM-090C-5, SH-001

11448-CBM-1 18A-5, SH-002

11448-CBM-124A-5, SH-001

11448-CBM-124A-5, SH-002

11448-CBM-124A-5, SH-003

11448-CBM-124A-5, SH-004

11448-CBM-130A-5, SH-001

11448-CBM-130B-5, SH-001

SAFETY INJECTION

SAFETY INJECTION

SAFETY INJECTION

SAFETY INJECTION

SAFETY INJECTION

CONTAINMENT HYDROGEN ANALYZER

REACTOR CAVITY PURIFICATION

STEAM GEN BLOWDOWN RECIRC & XFER




RAD MONITOR CIRC & SERV WTR

RAD MONITOR CONT PARTICULATE

SPS Ul 15-ISI Plan viii Revision 0


Surry Power Station Unit 1, Interval 5ISI Correspondence

Outgoing NRC Ltr.

Document Identification Status Ltr. No. No. Comments

Component Relief Requests

S-15-ISI-01, "Fifth 10-year Inservice Inspection Approved #12-191 #13-288 Relief to use the 2004 Edition ofInterval ASME Section Xl Code of Record" Section XI as the Code of Record for

fleet commonality

S1-15-ISI-02, "Pressurizer Surge Nozzle Inner Submitted #13-611 Due to the physical configuration ofRadius" the pressurizer, attached electrical

equipment and local dose rates, it isnot practical to perform the coderequired UT examinations of thesurge nozzle to vessel weld and theassociated nozzle-inside radius area.

SPS U1 15-ISI Plan ix Revision 0


Surry Power Station Unit 1, Interval 5ISI Correspondence (Continued)

Outgoing NRC Ltr.Document Identification Status Ltr. No. No. Comments

System Pressure Test Relief Requests

S1-15-SPT-01, "System Pressure Test of Bottom of Reactor Submitted #13-611 It is not practical to perform theVessel" VT-2 examinations on reactor

vessel partial penetration weldsand the bottom of the reactorvessel during a system leakagetest.

Miscellaneous Documents

Request to Use Subsequent Code 2007 Edition With Submitted #13-611 Category requirement for B-L-1 is2008 Addenda for B-L-1 dropped from later code editions.

This inspection is no longerrequired.

Limited Coverage Relief Requests

(Reserved for Later Use.)

SPS Ul 15-ISI Plan X Revision 0


Section 1


(DOMINION)

SURRY POWER STATION

UNIT 1


GENERAL

FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL

SPS U1 15-ISI Plan 1-1 Revision 0


1.0 INSERVICE INSPECTION PLAN - GENERAL

1.1 General Information

Surry Power Station Unit 1 is located on the James River in Surry County, Virginia.The plant employs a three loop Pressurized Water Reactor (PWR) Nuclear SteamSupply System provided by Westinghouse Electric Corporation.

1.1.1 Fifth Inservice Inspection Interval

As allowed by Title 10, Code of Federal Regulations, Part 50, Section 50.55a(10 CFR 50.55a), paragraph (g)(4)(iv) and approved by the NRC, the SPS1 Fifth10-year ISI Plan was updated to the 2004 Section Xl Code.

The Fifth ISI Interval begins on December 14, 2013 and will continue throughOctober 13, 2023. The Fifth ISI Interval is scheduled for a period of nine yearsand ten months to maintain previous Third and Fourth 10- year Interval startdate sequencing. The dates for the inspection periods are scheduled as follows:

Period 1: December 14, 2013 through December 13, 2016

Period 2: December 14, 2016 through October 13, 2020

Period 3: October 14, 2020 through October 13, 2023

Period dates have been selected to allow two refueling outages in each period.

1.1.2 Inservice Inspection Plan Description

The ISI Plan contained herein addresses the examination and testing of Class 1,2, and 3 components and the associated component supports. Applicablerequirements of Subsections IWA, IWB, IWC, IWD, IWF and the associatedMandatory Appendices of the 2004 Code Edition are contained in the ISI Plan,ISI Schedule, and the SPT Plan. Additionally, the limitations specified in10 CFR 50.55a(b)(2) applicable to SPS1 and the 2004 Code Edition have beenincorporated into the Program. These requirements are detailed inSection 1.1.3.

This document is not intended to provide specific information on theimplementation of the ISI Program. The intent of this document is to provideinformation on the scope of the SPS1 ISI Plan (e.g., its boundary andcompliance with Section XI), provide alternatives to the requirements of

SPS Ul 15-ISI Plan 1-2 Revision 0


Section XI where appropriate, and identify those Section Xl requirementsdetermined to be impractical.

The ISI and SPT Schedules provide information on the specific componentsselected for examination and test, including the category and item number, andthe examination or test to be performed. Unless stated otherwise, the extent ofexamination will be 100 percent of the Code required examination or testsurface, volume or area.

1.1.2.1 Exclusion of Subsections IWE and IWL

Subsections IWE, "Requirements for Class MC Components of Light-Water Cooled Power Plants," and IWL, "Requirements for Class CCConcrete Components of Light-Water Cooled Power Plants," have notbeen included in this ISI Plan. The programs to satisfy theserequirements have been developed and are being implemented asrequired by the regulations. The implementation of the SPS1 IWE andIWL Programs is controlled separately by other ISI Programs separatefrom this plan.

1.1.2.2 Inspection Plans and Schedules

The inspection plans and schedules required by IWA-2420 arecomprised of this document, the ISI Plan, the ISI Schedule and the SPTSchedule. These documents meet the requirements of IWA-2420.

1.1.2.3 Inspection Program Employed

The ISI Plan for SPS1 utilizes the interval format of Inspection ProgramB, as defined in IWA-2432.

1.1.2.4 Classification and Identification of Components

The construction permit for SPS1 was issued on June 25, 1968. At thattime, the ASME Boiler and Pressure Vessel Code covered onlypressure vessels. Piping, pumps and valves were built primarily to therules of ASME B31.1, "Power Piping". Essentially, Surry Power Stationwas designed and constructed prior to the origination of the ASMECode classifications designated ASME XI Class 1, 2, and 3. Therefore,the system classifications used as a basis for the ISI Program arebased on the guidance set forth in 10 CFR 50 and Regulatory Guide1.26, "Quality Group Classification and Standards for Water-, Steam-,and Radioactive-Waste-Containing Components of Nuclear PowerPlants", and American Nuclear Standard ANSI/ANS-51.1. Pursuant to



10 CFR 50.55a (g)(1), inservice inspection requirements of Section XIof the ASME Code are then assigned to these components within theconstraints of existing plant design.

Classification Boundary Drawings (CBB/CBMs) documenting thesystem classifications were developed to aid in the review andimplementation of the subject programs.

1.1.2.5 Components Exempt from Examination

The application of the exemptions allowed by IWB-1220, IWC-1220,IWD-1 220, and IWF-1230, and other paragraphs of the Code is alsodetailed on the 11448-CBB/CBM drawings. This is accomplished by theuse of symbols as well as text on the drawings. The legend for thesymbols is provided on drawing 11448-CBM-L&S-5.

Additionally, the ISI Schedule and the System Pressure Test Scheduleprovide the Code Classification in accordance with the informationprovided on the CBB/CBM drawings.

1.1.2.6 Requests for Relief

Where the requirements of ASME Section Xl are determined to beimpractical, requests for relief are developed in accordance with10 CFR 50.55a(g)(5)(iii). Where alternatives to the requirements ofSection Xl are proposed, they are developed in accordance with therequirements of 10 CFR 50.55a(a)(3)(i) and/or (ii). Approval touse later code editions can be requested in accordance with10 CFR 50.55a(g)(4)(iv). Requests for approval to use alternativerequirements are presented in sets of requests for relief. There are fourcategories of requests for relief:

* An ISI series for components and nondestructive examinationrequirements,

" An SPT series for system pressure testing requirements,

" An LMT series for limited examinations, and

* A CC series for Code Cases that are part of the ISI Plan but notapproved by the NRC for industry use.

Limited examination requests for relief are necessary because SPS1was not designed and constructed considering access for examination.



Consequently, it may not be possible to obtain 100 percent coverage foreach required examination or test. Therefore, requests for reliefseeking approval for limited coverage examinations or tests will besubmitted throughout the interval and no later than one year after theinterval end. (Note: Code Case N-460 will be utilized to the extentallowed to accept limited coverage examinations of Class 1 and Class 2welds.)

1.1.2.7 ASME Section Xl Code Cases

As allowed by 10 CFR 50.55a and/or USNRC Regulatory Guide 1.147,latest Revision approved, certain Code Cases have been incorporatedinto this Program. Additionally, certain Code Cases that have beenapproved by the Code, but have not yet been approved by the NRC,may be incorporated into the ISI Plan. Approval to use theseunapproved Code Cases is requested as part of the request for reliefprocess. Code Cases utilized as part of this ISI Plan are listed inSection 6.

1.1.2.8 Augmented Examinations

Augmented examinations resulting from commitments made to the NRCmay or may not involve components of the ISI Plan. The implementationof augmented examinations is in accordance with the applicablecommitments and is achieved by programs and procedures maintainedby either the SPS1 staff or the corporate engineering staff. However,some augmented examinations are part of the ISI Schedule for thepurposes of scheduling and tracking the completion of the involvedexaminations. The inclusion of an augmented examination into the ISISchedule does not make the examination part of the IS[ Plan. Anyaugmented examination included in the ISI Schedule is identified as anaugmented examination. Augmented examinations performed to satisfycommitments outside of Section Xl Code requirements do not requireinvolvement of the Authorized Nuclear Inservice Inspector.

1.1.3 Repair/Replacement Program

Repair/Replacement activity will be in accordance with SPS1 administrativeprocedures, as well as Dominion corporate administrative procedures. Together,these procedures assure compliance with the 2004 Edition of ASME Section XI.Pressure testing required for ASME Section Xl repair/replacement activity will beconducted in accordance with the Repair/Replacement Program.



1.1.4 Code of Federal Regulations 10 CFR 50.55a Requirements

10 CFR Part 50.55a, Codes and standards, establishes conditions forimplementing this ISI Program. The following Table summarizes conditions,limitations and modifications noted as of the date of original submittal. Changesto this regulation shall be implemented as required to the ISI Program over thecourse of the 10-year Interval.

CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS

10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications

10 CFR 50.55a(a)(3) Proposed Alternatives. (3) Proposed alternatives to therequirements of paragraphs (c), (d), (e), (f), (g), and (h) of thissection, or portions thereof, may be used when authorized bythe Director, Office of Nuclear Reactor Regulation, or Director,Office of New Reactors, as appropriate. Any proposedalternatives must be submitted and authorized prior toimplementation. The applicant or licensee shall demonstratethat:

(i) The proposed alternatives would provide an acceptablelevel of quality and safety; or

(ii) Compliance with the specified requirements of this sectionwould result in hardship or unusual difficulty without acompensating increase in the level of quality and safety.

10 CFR 50.55a(b)(2)(x) Quality Assurance. When applying Section Xl editions andaddenda later than the 1989 Edition, the requirements ofNQA-1, "Quality Assurance Requirements for NuclearFacilities," 1979 Addenda through the 1989 Edition, areacceptable as permitted by IWA-1400 of Section Xl, if thelicensee uses its 10 CFR Part 50, Appendix B, qualityassurance program, in conjunction with Section Xlrequirements. Commitments contained in the licensee's qualityassurance program description that are more stringent thanthose contained in NQA-1 must govern Section Xl activities.Further, where NQA-1 and Section Xl do not address thecommitments contained in the licensee's Appendix B qualityassurance program description, the commitments must beapplied to Section Xl activities.

10 CFR 50.55a(b)(2)(xii) Underwater Welding. The provisions in IWA-4660, "UnderwaterWelding," of Section Xl, 1997 Addenda through the latestedition and addenda incorporated by reference in paragraph(b)(2) of this section, are not approved for use on irradiatedmaterial.





10 CFR 50.55a(b)(2)(xiv) Appendix VIII personnel qualification. All personnel qualified forperforming ultrasonic examinations in accordance withAppendix VIII shall receive 8 hours of annual hands-on trainingon specimens that contain cracks. Licensees applying the 1999Addenda through the latest edition and addenda incorporatedby reference in paragraph (b)(2) of this section may use theannual practice requirements in VII-4240 of Appendix VII ofSection XI in place of the 8 hours of annual hands-on trainingprovided that the supplemental practice is performed onmaterial or welds that contain cracks, or by analyzingprerecorded data from material or welds that contain cracks. Ineither case, training must be completed no earlier than 6months prior to performing ultrasonic examinations at alicensee's facility.

4.

10 CFR 50.55a(b)(2)(xv) Appendix VIII specimen set and qualification requirements.Licensees using editions and addenda after 2001 Editionthrough the 2006 Addenda shall use the 2001 Edition ofAppendix VIII, and may elect to comply with all of the provisionsin paragraphs (b)(2)(xv)(A) through (b)(2)(xv)(M) of this section,except.for paragraph (b)(2)(xv)(F) of this section, which may beused at the licensee's option. {See regulation for all provisions.)

4.

10 CFR 50.55a(b)(2)(xvi) Appendix VIII single side ferritic vessel and piping and stainlesssteel piping examination.

(A) Examinations performed from one side of a ferritic vesselweld must be conducted with equipment, procedures, andpersonnel that have demonstrated proficiency with single sideexaminations. To demonstrate equivalency to two sidedexaminations, the demonstration must be performed to therequirements of Appendix VIII as conditioned by this paragraphand paragraphs (b)(2)(xv)(B) through (b)(2)(xv)(G) of thissection, on specimens containing flaws with non-optimum soundenergy reflecting characteristics or flaws similar to those in thevessel being examined.

(B) Examinations performed from one side of a ferritic orstainless steel pipe weld must be conducted with equipment,procedures, and personnel that have demonstrated proficiencywith single side examinations. To demonstrate equivalency totwo sided examinations, the demonstration must be performedto the requirements of Appendix VIII as conditioned by thisparagraph and paragraph (b)(2)(xv)(A) of this section.





10 CFR 50.55a(b)(2)(xviii) Certification of NDE personnel.

(A) Level I and II nondestructive examination personnel shall berecertified on a 3-year interval in lieu of the 5-year intervalspecified in the 1997 Addenda and 1998 Edition of IWA-2314,and IWA-2314(a) and IWA-2314(b) of the 1999 Addendathrough the latest edition and addenda incorporated byreference in paragraph (b)(2) of this section.

(B) When applying editions and addenda prior to the 2007Edition of Section Xl, paragraph IWA-2316 may only be used toqualify personnel that observe leakage during system leakageand hydrostatic tests conducted in accordance with IWA5211 (a) and (b).

(C) When applying editions and addenda prior to the 2005Addenda of Section X1, licensee's qualifying visual examinationpersonnel for VT-3 visual examination under paragraph IWA-2317 of Section Xl, must demonstrate the proficiency of thetraining by administering an initial qualification examination andadministering subsequent examinations on a 3-year interval.

i

10 CFR 50.55a(b)(2)(xix) Substitution of alternative methods. The provisions forsubstituting alternative examination methods, a combination ofmethods, or newly developed techniques in the 1997 Addendaof IWA-2240 must be applied when using the 1998 Editionthrough the 2004 Edition of Section XI of the ASME B&PVCode. The provisions in IWA-4520(c), 1997 Addenda throughthe 2004 Edition, allowing the substitution of alternativemethods, a combination of methods, or newly developedtechniques for the methods specified in the Construction Codeare not approved for use. The provisions in IWA-4520(b)(2) andIWA-4521 of the 2008 Addenda through the latest edition andaddenda approved in paragraph (b)(2) of this section, allowingthe substitution of ultrasonic examination for radiographicexamination specified in the Construction Code are notapproved for use.

10 CFR 50.55a(b)(2)(xx) System leakage tests.

(B) The NDE provision in IWA- 4540(a)(2) of the 2002 Addendaof Section Xl must be applied when performing system leakagetests after repair and replacement activities performed bywelding or brazing on a pressure retaining boundary using the2003 Addenda through the latest edition and addendaincorporated by reference in paragraph (b)(2) of this section.

SPS UL1 15-ISI Plan 1-8 Revision 0




10 CFR 50.55a(b)(2)(xxi) Table IWB-2500-1 examination requirements.

(A) The provisions of Table IWB-2500-1, Examination CategoryB-D, Full Penetration Welded Nozzles in Vessels, Items B3.40and B3.60 (Inspection Program A) and Items B3.120 andB3.140 (Inspection Program B) of the 1998 Edition must beapplied when using the 1999 Addenda through the latest editionand addenda incorporated by reference in paragraph (b)(2) ofthis section. A visual examination with magnification that has aresolution sensitivity to detect a 1-mil width wire or crack,utilizing the allowable flaw length criteria in Table IWB-3512-1,1997 Addenda through the latest edition and addendaincorporated by reference in paragraph (b)(2) of this section,with a limiting assumption on the flaw aspect ratio (i.e., a/1=0.5),may be performed instead of an ultrasonic examination.

10 CFR 50.55a(b)(2)(xxii) Surface Examination. The use of the provision in IWA-2220,"Surface Examination," of Section XI, 2001 Edition through thelatest edition and addenda incorporated by reference inparagraph (b)(2) of this section, that allow use of an ultrasonicexamination method is prohibited.

10 CFR 50.55a(b)(2)(xxiii) Evaluation of Thermally Cut Surfaces. The use of the provisionsfor eliminating mechanical processing of thermally cut surfacesin IWA-4461.4.2 of Section Xl, 2001 Edition through the latestedition and addenda incorporated by reference in paragraph(b)(2) of this section are prohibited.

10 CFR 50.55a(b)(2)(xxiv) Incorporation of the Performance Demonstration Initiative andAddition of Ultrasonic Examination Criteria. The use of AppendixVIII and the supplements to Appendix VIII and Article 1-3000 ofSection XI of the ASME B&PV Code, 2002 Addenda through the2006 Addenda is prohibited.

10 CFR 50.55a(b)(2)(xxv) Mitigation of Defects by Modification. The use of the provisionsin IWA-4340, "Mitigation of Defects by Modification," Section Xl,2001 Edition through the latest edition and addendaincorporated by reference in paragraph (b)(2) of this section areprohibited.





10 CFR 50.55a(b)(2)(xxvi) Pressure Testing Class 1, 2, and 3 Mechanical Joints. Therepair and replacement activity provisions in IWA-4540(c) of the1998 Edition of Section Xl for pressure testing Class 1, 2, and 3mechanical joints must be applied when using the 2001 Editionthrough the latest edition and addenda incorporated byreference in paragraph (b)(2) of this section.

10 CFR 50.55a(b)(2)(xxvii) Removal of Insulation. When performing visual examination inaccordance with IWA-5242 of Section Xl of the ASME B&PVCode, 2003 Addenda through the 2006 Addenda, or IWA-5241of the 2007 Edition through the latest edition and addendaincorporated in paragraph (b)(2) of this section, insulation mustbe removed from 17-4 PH or 410 stainless steel studs or boltsaged at a temperature below 1100 'F or having a RockwellMethod C hardness value above 30, and from A-286 stainlesssteel studs or bolts preloaded to 100,000 pounds per squareinch or higher.

10 CFR 50.55a(b)(2)(xxviii) Analysis of flaws. Licensees using ASME B&PV Code, SectionXl, Appendix A shall use the following conditions whenimplementing Equation (2) in A-4300(b)(1):For R < 0, AKIdepends on the crack depth (a), and the flow stress (of). Theflow stress is defined by af = 1A(ays + Cult), where oys is the yieldstrength and Oult is the ultimate tensile strength in units ksi(MPa) and a is in units in. (mm). For -2 5 R < 0 and K max - Kmin< 0.8 x 1.12 of /(Tra), S = 1 and AKI = K max. For R < -2 and Kmax- Kmin < 0.8 x 1.12 of /(Tra), S = 1 and AKI = (1 - R) Kmax/3. ForR < 0 and Kmax - Kmin > 0.8 x 1.12 o'f /(Tra), S = 1 and AKI = Kmax- Kmin.

10 CFR 50.55a(b)(3)(v) Subsection ISTD. Article IWF-5000, "Inservice InspectionRequirements for Snubbers," of the ASME B&PV Code, SectionXI, must be used when performing inservice inspectionexaminations and tests of snubbers at nuclear power plants,except as conditioned in paragraphs (b)(3)(v)(A) and (b)(3)(v)(B)of this section.

(A) Licensees may use Subsection ISTD, "Preservice andInservice Examination and Testing of Dynamic Restraints(Snubbers) in Light-Water Reactor Power Plants," ASME OMCode, 1995 Edition through the latest edition and addendaincorporated by reference in paragraph (b)(2) of this section, inplace of the requirements for snubbers in the editions andaddenda up to the 2005 Addenda of the ASME B&PV Code,





Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b), bymaking appropriate changes to their technical specifications orlicensee-controlled documents. Preservice and inserviceexaminations must be performed using the VT-3 visualexamination method described in IWA-2213.

(B) Licensees shall comply with the provisions for examiningand testing snubbers in Subsection ISTD of the ASME OMCode and make appropriate changes to their technicalspecifications or licensee-controlled documents when using the2006 Addenda and later editions and addenda of Section X1 ofthe ASME B&PV Code.

10 CFR 50.55a(b)(5) Inservice Inspection Code Cases: Licensees may apply theASME Boiler and Pressure Vessel Code Cases listed inRegulatory Guide 1.147 through Revision 16, without prior NRCapproval subject to the following:

(i) When a licensee initially applies a listed Code Case, thelicensee shall apply the most recent version of that Code Caseincorporated by reference in this paragraph.

(ii) If a licensee has previously applied a Code Case and a laterversion of the Code Case is incorporated by reference in thisparagraph, the licensee may continue to apply, to the end of thecurrent 120-month interval, the previous version of the CodeCase as authorized or may apply the later version of the CodeCase, including any NRC-specified conditions placed on its use.

(iii) Application of an annulled Code Case is prohibited unless alicensee previously applied the listed Code Case prior to it beinglisted as annulled in Regulatory Guide 1.147. Any Code Caselisted as annulled in any Revision of Regulatory Guide 1.147which a licensee has applied prior to it being listed as annulled,may continue to be applied by that licensee to the end of the120-month interval in which the Code Case was implemented.

'10 CFR 50.55a(g)(5)(iii) Impractical for Facility, Demonstrated Limitation. If the licensee

has determined that conformance with a code requirement isimpractical for its facility, the licensee shall notify the NRC andsubmit, as specified in § 50.4, information to support thedeterminations. Determinations of impracticality in accordancewith this section must be based on the demonstrated limitationsexperienced when attempting to comply with the coderequirements during the inservice inspection interval for whichthe request is being submitted. Requests for relief made inaccordance with this section must be submitted to the NRC no





later than 12 months after the expiration of the initial orsubsequent 120-month inspection interval for which relief issought.

10 CFR 50.55a(g)(5)(iv) Impractical Code Requirement. Where the licensee determinesthat an examination required by Code edition or addenda isimpractical, the basis for this determination must be submittedfor NRC review and approval not later than 12 months after theexpiration of the initial or subsequent 120-month inspectioninterval for which relief is sought.



Section 2


(DOMINION)

SURRY POWER STATION

UNIT 1


COMPONENTS




2.0 INSERVICE INSPECTION PLAN FOR COMPONENTS

2.1 Program Description

2.1.1 The ISI Program for Class 1, 2 and 3 components meets the requirements ofSection Xl of the ASME Boiler and Pressure Vessel Code, 2004 Edition. Wherethese requirements are determined to be impractical, or where alternatives areidentified in accordance with 10 CFR 50.55a(a)(3), specific requests for reliefhave been written and included in this section.

2.1.2 The Repair and Replacement Program uses the ISI boundary classifications fromthe ISI Program to determine the scope and applicability of the Program. Repairand Replacement activities shall be in accordance with administrativeprocedures, which assure compliance with the ASME Section Xl, Division 1,2004 Code Edition.

2.2 Program Summary

2.2.1 For components other than those which are part of the Risk Informed Program,the ISI Plan utilizes the tables IWB-2500-1, IWC-2500-1, IWD-2500-1, andIWF-2500-1 of the 2004 Edition of the ASME Section XI Code to determine thecomponents, component supports, or parts thereof that require examination; theexamination requirement(s); the examination method(s); the acceptancestandard; and the extent and frequency of examination.

2.2.2 Components selected for examination are identified in the ISI Schedule.

2.2.3 Examination requirements for steam generator tubes are provided in the plantTechnical Specifications as directed in Table IWB-2500-1, Category B-Q.

2.2.4 Categories B-P, C-H, and D-B constitute the scheduled 10-year Interval pressuretesting requirements. The following guidance will be utilized programmaticallyconcerning pressure testing:

" Pressure tests which meet the pressure, temperature, hold time, and VT-2

examination requirements of IWA-5000, IWB-5000, IWC-5000, and IWD-5000 will be treated as complete for inspection scheduling purposes.

* Pressure tests required for ASME Section Xl repairs or replacements will beconducted in accordance with the 2004 Edition of ASME Section XI orapproved alternative.



Section 2.3

RELIEF REQUESTS

FOR

COMPONENTS



Virginia Electric and Power CompanySurry Power Station Unit 1

Fifth 10-year Inservice Inspection Interval ASME Section Xl Code of RecordRelief Request S1-15-ISI-01

Proposed Alternativein Accordance with 10 CFR 50.55a(a)(3)(i)

1. ASME (American Society of Mechanical Engineers) Code ComponentsAffected

ASME Section XI Class 1, 2 and 3 components and component supports

2. Applicable Code Edition and Addenda

2004 ASME Section XI Code Edition, No Addenda, for the Fifth 10-year InserviceInspection (ISI) Interval

3. Applicable Code Requirement

Dominion is required to update the Surry Unit I 120-month ISI Program to the latestEdition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI,approved by the NRC in 10 CFR 50.55a(b)(2) one year before the start of the newinterval.

10 CFR 50.55a(g)(4)(ii) presently states: "Inservice examination of components andsystem pressure tests conducted during successive 120-month inspection intervalsmust comply with the requirements of the latest edition and addenda of the Codeincorporated by reference in paragraph (b) of this section 12 months before the startof the 120-month inspection interval (or the optional ASME Code cases listed inNRC Regulatory Guide 1.147, Revision 16, that are incorporated by reference inparagraph (b) of this section), subject to the conditions listed in paragraph (b) of thissection. However, a licensee whose inservice inspection interval commences duringthe 12 through 18-month period after July 21, 2011 may delay the update of theirAppendix VIII program by up to 18 months after July 21, 2011."

Paragraph (b)(2) presently states: "As used in this section, references to Section XIrefer to Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, andinclude the 1970 Edition through the 1976 Winter Addenda, and the 1977 Editionthrough the 2007 Edition with the 2008 Addenda, subject to the followingconditions: .



4. Reason for Request

Four Dominion nuclear operating units have started new 10-year inserviceinspection intervals within the last three years:

Millstone Unit 3 Third Interval April 23, 2009 - April 22, 2019Millstone Unit 2 Fourth Interval April 1, 2010 - March 31, 2020North Anna Unit 1 Fourth Interval May 1, 2009 - April 30, 2019North Anna Unit 2 Fourth Interval December 14, 2010 - December 13, 2020

Each of these four units updated their ASME Section Xl ISI Programs to the2004 Edition of ASME Section Xl as this was the latest edition incorporated byreference in the Code of Federal Regulations one year prior to the start of the newintervals. The 2004 Edition was incorporated into the Final Rule onSeptember 10, 2008, Volume 73, No. 176 of the Federal Register.

By Federal Register Volume 76, No. 119, dated June 21, 2011, the Code of FederalRegulations was amended to incorporate by reference the 2007 Edition with2008 Addenda for ASME Boiler and Pressure Vessel Code, Section Xl, Division 1,superseding the 2004 Edition of ASME Section Xl as the latest edition. Therefore,Dominion would be required to update the Surry Unit 1 Fifth 10-year Interval, whichbegins on October 14, 2013, to a code edition published at a date later than 2004.

ASME Section Xl activities at the Millstone, North Anna, and Surry Power Stationunits are standardized and corporately administered as a fleet operation atDominion. Dominion ISI and Non-destructive Examination (NDE) personnel assistone another in the planning, performing, reporting, and assessing of ISI activitiesthroughout the fleet. Maintaining a common ASME Section XI Code for theDominion units and conforming to identical ASME Section Xl rules would assistincorporation of industry best standards and would reduce administrative burden anderror-likely situations.

A similar relief request is being submitted for Surry Unit 2 (ReliefRequest S2-15-ISI-01) to facilitate operation of the six units using a common ASMESection Xl Code (i.e., the 2004 ASME Section XI Code).

5. Proposed Alternative and Basis for Use

Dominion proposes to use an ASME Section Xl Code Edition that was incorporatedand referenced in an earlier revision of the Code of Federal Regulations; specifically,the 2004 Edition of ASME Section Xl for the Surry Unit 1 Fifth 10-year ISI Intervaland will continue to incorporate all current and future 10 CFR 50.55a conditions,



limitations, modifications, and augmented requirements. Dominion will use onlythose ASME Code Cases applicable to the 2004 Edition of Section Xl as listed in themost recent revision of NRC Regulatory Guide 1.147, unless otherwise approved foruse by relief from the NRC.

A detailed comparison between the 2004 Edition and the2007 Edition/2008 Addenda was performed. There were no changes identified thatensured or increased an acceptable level of quality and safety, nor were anychanges made to address any type of deficiency in the 2004 Edition.

Dominion believes that commonality will improve the level of quality and safety at thefleet units by sharing common knowledge and lessons learned for ISI Programsgoverned by the same ASME Section Xl rules and will reduce error-likely situations.

Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), Dominion proposes to use analternative to the ASME Boiler and Pressure Vessel, Section Xl Code edition asspecified by 10 CFR 50.55(b)(2) and use an earlier edition, the 2004 Edition with noAddenda, to establish the Surry Unit 1 Fifth 10-year ISI Interval. As this code editionwas previously incorporated and referenced for use by the Code of FederalRegulations and is presently in use at four other Dominion units, the alternative willprovide an acceptable level of quality and safety.

6. Duration of Proposed Alternative

Dominion intends to use the 2004 Edition of ASME Section Xl in its entirety, subjectto limitations and modifications of 10 CFR 50.55a, as the Code of Reference for theSurry Unit 1 ISI Program for the entire Fifth 10-Year ISI Interval. The Surry Unit 1Fifth 10-Year ISI Interval is scheduled to begin October 14, 2013 and endOctober 13, 2023.

7. Precedents

Similar relief was granted to Entergy Operations, Inc. for Arkansas Nuclear One,Unit 2, by letter dated April 26, 2010, "Arkansas Nuclear One, Unit 2 - Request forRelief ANO2-ISI-003, Alternative to Use 2001 Edition through 2003 Addenda in lieuof the 2004 Edition of the American Society of Mechanical Engineers Boiler andPressure Vessel Code, Section Xl (TAC No. ME1452)." [ML100970659]



Virginia Electric and Power Company(Dominion)

Surry Power Station Unit IFifth 10-year Inservice Inspection Interval

Relief Request SI-15-1SI-02, Pressurizer Surge Nozzle Inner Radius

Proposed Alternativein Accordance with 10 CFR 50.55a(a)(3)(ii)

-Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety-

1. ASME Code Comoonent Affected

Nozzle Inner Radius Section (Pressurizer Surge Nozzle)

Weld # Component # Drawing # Class

23NIR 1-RC-E-2 11448-WMKS-RC-E-2 1

2. Applicable Code Edition and Addenda

ASME Section Xl, 2004 Edition, No Addenda

3. Applicable Code Requirement

The 2004 Edition of ASME Section Xl does not require an examination of thenozzle-inside-radius section of the pressurizer surge nozzle. However,10 CFR 50.55a(b)(2)(xxi) mandates use of the 1998 Edition of Section Xl for theexamination requirements of 23NIR. Category B-D, Item B3.120 of the 1998 Editionrequires a volumetric examination of the nozzle inside radius section of the pressurizersurge nozzle. 10 CFR 50.55a(b)(2)(xxi) allows an enhanced visual VT-1 on the insidesurface in lieu of the volumetric requirement, which is performed from the outsidesurface.

4. Reason for Request

The Surry Unit 1 (SPS1) pressurizer surge line nozzle is integrally cast into the bottompressurizer lower head. The nozzle is located under the pressurizer skirt and issurrounded by 78 heater penetrations. Interference from the heater penetrations andheater cables, as well as the location of the nozzle under the pressurizer skirt, restrictsaccess to the nozzle. This limits the examiner's ability to manipulate the search unit toexamine the nozzle inner radius (Figure 1).



The only viable ultrasonic technique currently available to examine nozzle inner radiiinvolves the fabrication of calibration blocks that closely simulate the outer diameter(O.D.) and inner diameter (I.D.) nozzle geometry. This is necessary so that search unitscan be produced that will interrogate the inner radius section at precise angles. Also, toobtain meaningful results, the nozzle material grain structure must be such that anadequate signal-to-noise ratio can be obtained over a long metal path distance.

Integrally cast nozzles contain limitations such as an irregular O.D. profile, a roughsurface condition, and an attenuating grain structure. The irregular surface conditioncauses the beam angle to vary from point to point around the nozzle. The attenuatinggrain structure results in a low signal-to-noise ratio at the nozzle inner radius. Limitedaccess to the nozzle, as well as the limitations imposed by the material conditions, areadose rates, and the complicated nature of the examination technique, would makeevaluation of any indications very difficult.

Access to the SPS1 pressurizer surge line nozzle is obstructed by insulation and thecables for the pressurizer heaters. Removal of the insulation and cables would bedifficult as well as labor and time intensive. The exposure of the workers andtechnicians needed to perform the tasks is a real and relevant concern. It is almostcertain that some, and possibly all, heater cables would have to be disconnected so thecables can be pulled back to allow access for removing insulation and performing theexam. It is also likely that some cable or heater damage would occur during removal(Picture 1). If it is assumed that all 78 heater cables have to be disconnected and pulledback, the dose estimate is 56 man-rem. While actions would be taken to provideprotection against the radiation, the large dose rate gradients in the under-pressurizerarea present an unusual challenge. Temporary shielding is considered impractical inthis situation because placement of the shielding material would obstruct and potentiallypreclude accessibility to the examination surface.

Other potential personnel safety concerns with this examination include the increasedrisk for an unplanned exposure event and the possibility of prevention of contaminationwith personnel wedged between the surge line and the exposed portion of thepressurizer heaters. Other issues include actual accessibility after removal of thevarious forms of interference and the likelihood of difficulties in replacing the insulation toits original configuration. Furthermore, the amount of examination coverage would bedependent on the overall accessibility obtained.

In conjunction with license renewal, Westinghouse performed an evaluation to address

the impact of operational transients for SPS1 to account for insurge/outsurge transientsin addition to design transients in the pressurizer lower head. The results of theevaluation show that the Cumulative Usage Factor (CUF) for the nozzle inner radius is0.29 (inside surface) and 0.11 (outside surface). These CUFs are considerably lessthan the design limit of 1.0 and provide insight into the potential for failure in this area.



Additionally, Dominion is unaware of an industry failure involving the inside radiussection of the surge-line nozzle in a Westinghouse design pressurizer.

In addition, there are several uncertainties regarding an alternative examination of theinside surface of the pressurizer surge line area by use of a remote visual tool. Such anexamination requires that a boroscope be fed through the manway and down throughopenings in the heater support baffles. Adding to the difficulty in performing such anexam, there is a perforated basket diffuser covering the surge nozzle opening on theinside of the pressurizer. The boroscope would need to be positioned through thesupport plates, and then threaded through a perforation in the basket diffuser, ifpossible, to the pressurizer surge line area (Figure 1). This examination would also bepartially obscured by the thermal sleeve, which extends beyond the inside radius areainto the volume of the pressurizer. These obstructions would need to be overcomeseveral times to achieve the required examination coverage. Furthermore, the resultingexamination would only be of the cladding that covers the inside radius of the nozzle,which is considered to be only marginally beneficial in determining the structural integrityof the nozzle. Furthermore, performing the visual inspection requires opening theReactor Coolant System (RCS) and establishing access and foreign material exclusioncontrols. The boroscope itself has the potential to become lodged inside the perforatedbasket diffuser or behind a pressurizer heater support plate. This inspection effort andthe significant potential risk associated with it are not commensurate with the limitedbenefit that may be obtained from the inspection.


The pressurizer surge line nozzle-to-vessel inner radius section will be examined as partof the normally scheduled Class 1 system leakage test each refueling. In addition, thesurveillance requirements of Technical Specifications that determine the RCS leak rateand the containment atmosphere radioactivity will be satisfied. These programs ensurethe overall level of plant quality and safety will not be compromised.

Any ultrasonic examination on this nozzle could only be described as "best effort." Thebenefit gained would not be commensurate with the difficulty and anticipated exposureestimate of 56 man-Rem to perform this examination. An alternative examinationemploying a remote visual technology has very little if any reasonable probability ofsuccess. As such, permission to use the proposed alternative is requested per 10 CFR50.55a(a)(3)(ii) since compliance with the specified requirements would result inhardship or unusual difficulties without a compensating increase in the level of qualityand safety.




The proposed alternative to the ASME Code is applicable for the duration of the Fifth10-year Inservice Inspection Interval at SPS1.

7. Precedents

Similar relief for the following-nuclear units has been granted:

North Anna Power Station Uniti, 2 nd ISI Interval, TAC NO. M71066

North Anna Power Station Unit 1 3 rd ISI Interval, TAC NO. MA5750

North Anna Power Station Unit 2, 2 nd ISI Interval, TAC NO. M79147

North Anna Power Station Unit 2, 3 rd ISI Interval, TAC NO. MB2280

North Anna Power Station Unit 2, 4 th ISI Interval, TAC NO. ME3292

Surry Power Station Unit 1, 3 rd ISI Interval, TAC NO. M87312

Surry Power Station Unit 2, 3 rd ISI Interval, TAC NO. M89085

Surry Power Station Unit 1, 41h SI Interval, TAC NO. MD3673

Surry Power Station Unit 2, 4 th ISI Interval, TAC NO. MD3674

Byron Station Units 1 and 2, 2nd ISI Interval, TAC NOs. M94830 and M94831

Haddam Neck Plant, 3 rd ISI Interval, TAC NO. M80457

Beaver Valley Power Station Unit 1, 4 th ISI Interval, TAC NO. ME1 108

Kewaunee Power Station, 4 th ISI Interval, ML050350225 TAC NOs. MC2497-MC2507,MC2509

North Anna Power Station Unit 1, 4th ISI Interval TAC NO. ME6263



Power Relief andSafety Valve Nozzles

InstrumentNozzles

Upper jSupportBracket

Vessel PenetrationNozzle for Spray Line

N4- Manway

Angle IronInsulation

Bands

Top View

LiftingTrunnion

Seismic Lug

OperatingWaterLevel

78 HeaterElements

HeaterSupportBaffles

Bottom ViewInstrument

Nozzles

CircularSupport

Skirt

SurgeNozzle Basket Thermal

Diffuser SleeveGr,Vhwv?- to. CBIb71A

PRESSURIZER

S1-15-ISI-02 Figure 1



Ij



Section 2.4

RELIEF REQUESTS

FOR

SYSTEM PRESSURE TESTING




Surry Power Station Unit IFifth 10-year Inservice Inspection Interval

Relief Request SI-15-SPT-01, System Pressure Test of Bottom of Reactor Vessel

Proposed Alternativein Accordance with 10 CFR 10.55a(a)(3)(ii)

-Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety-

1. ASME Code Comnonent Affected

The component associated with this request is the Class 1 bottom area of the reactorvessel.

1.1 Category and System Details:

Code Class: Class 1System: Reactor Coolant (RC)Examination Category: B-PItem Number: B15.10

1.2 Component Description:

Reactor Vessel

2. Annlicable Code Edition and Addenda

ASME Section XI, 2004 Edition, No Addenda

3. Applicable Code Reuirement

Category B-P, Item No. B15.10 requires a visual (VT-2) examination of the bottomof the reactor vessel during the system leakage test of IWB-5220.

4. Reason for Reauest

To meet the Section Xl pressure and temperature requirements for the system leakagetest of the reactor vessel, the reactor containment at Surry Power Station (SPS) Unit 1 isrequired to be at a sub-atmospheric pressure. Station administrative procedures requirethat self-contained breathing apparatus be worn for containment entries under theseconditions. This requirement significantly complicates the visual (VT-2) examinationof the bottom of the reactor vessel during testing. Access to the bottom of thereactor vessel requires the examiner descend several levels by ladder and navigate asmall entrance leading to the reactor vessel. In addition to these physical constraints,



the examiner must contend with extreme environmental conditions, such as, elevated airtemperatures due to reactor coolant at temperatures above 500 degrees F and limitedair circulation in the vessel cubicle.

The hardship arises less from the time constraint created by the use of bottled air orthe involved radiation levels, but rather more from conditions that exist during thetest. During the test the reactor coolant system is at the operational temperature of> 500 degrees F, and the containment is sub-atmospheric. Performing the examinationin these conditions is complicated by the following factors:

* The need to use a self-contained breathing apparatus (SCBA) with a full-face respirator.

• Having to access the bottom of the vessel under sub-atmospheric conditionswhich requires the examiner to descend several levels by ladders and tonavigate a small hatch wearing the SCBA.

" The physical environment caused by the heat generated by a vessel elevated to atemperature of > 500 degrees F coupled with a lack of ventilation.

These factors increase the safety hazard associated with the examination. To placethe examiner under this increased risk and burden is not justified. This combination ofconditions does not exist during the refueling outage when the proposed alternativeexamination would take place. The proposed alternative examination would beperformed under conditions that are safer and allow for a more thorough examination.


Dominion will continue to monitor leakage on the bottom of the reactor vessel with othersurveillance requirements and alarms. The applicable Technical Specificationrequirements will be satisfied through the Fifth 10-year Inservice Inspection Interval.The in-core sump room has a level alarm in the control room; alarm annunciationrequires operator action. In the event of a leak, these actions would identify anyintegrity concerns associated with the area. Additionally, a VT-2 examination will beconducted when containment is at atmospheric conditions each refueling for evidence ofboric acid corrosion. These proposed alternatives will ensure the overall level of plantquality and safety will not be compromised and eliminates the burden and hardship inperforming the Code requirements.

Therefore, Dominion requests approval of this alternative pursuant to the provisions of10 CFR 50.55a(a)(3)(ii).




The proposed alternative to the ASME Code is applicable for t h e F i ft h 10-yearInservice Inspection Interval at SPS1.

7. Precedents

Similar relief for the following nuclear units has been granted:

Surry Unit 1, 4 th ISI Interval, TAC NOs. MB7762, MB7763, MB9528North Anna Unit 1, 4th ISI Interval, TAC NO. MD9956



Section 3


(DOMINION)

SURRY POWER STATION

UNIT 1


COMPONENT SUPPORTS




3.0 INSERVICE INSPECTION PROGRAM FOR COMPONENT SUPPORTS

3.1 Program Description

The ISI Program for Class 1, 2 and 3 component supports meets the requirements ofSection Xl of the ASME Boiler and Pressure Vessel Code, 2004 Edition.

3.2 Component Support Relief Requests

Where requirements are determined impractical per 10 CFR 50.55a(g)(5) or wherealternatives are identified in accordance with 10 CFR 50.55a(a)(3), specific requestsfor relief are written. NRC approved component support relief requests are included inthis section.

3.3 Repair and Replacements

Component supports are included in the Repair and Replacement Program and willcomply with the requirements of ASME Section Xl, Division 1, 2004 Code Edition forrepair and replacement of supports. The Repair and Replacement Programadministrative procedures provide the Program requirements.



Section 4


(DOMINION)

SURRY POWER STATION

UNIT 1


MISCELLANEOUS DOCUMENTATION





Surry Power Station Unit 1Fifth 10-year Inservice Interval

Request for Approval to Use a Subsequent American Society of Mechanical Engineers(ASME) Code Edition and Addenda for Examination Category B-L-1

in the Fifth Inservice Inspection (ISI) Interval

Virginia Electric and Power Company (Dominion) requests NRC approval to use asubsequent ASME Code edition and addenda for the ASME Section XI, ExaminationCategory B-L-1 in the Fifth ISI Interval for Surry Power Station Unit 1. This request isconsistent with NRC Regulatory Issue Summary 2004-12, "Clarification on Use of LaterEditions and Addenda to the ASME OM Code and Section XI."

1. ASME Code Component(s) Affected

The affected ASME Section Xl components are the Reactor Coolant Pump (RCP) casingwelds (Category B-L-1).

2. Applicable Code Edition and Requirements

The applicable ASME Section XI Code of Record for the Fifth 10-year ISI Interval forSurry Power Station Unit 1 is the 2004 Edition as allowed by approved NRC letter datedApril 29, 2013 [TAC ME 8774].

3. Proposed Subsequent Code Edition and Requirements

The subsequent Code edition and addenda proposed for the Fifth Interval of the ISIProgram, Examination Category B-L-1 is ASME Section XI, 2007 Edition, including 2008Addenda. The 2008 Addenda of Section XI has been incorporated into the regulationsby reference, as published in the Federal Register on June 21, 2011 (76 FR 36232), andbecame effective July 21, 2011.

ASME Category B-L-1 welds were removed in the ASME Section XI, 2007 Edition, 2008Addenda because experience has not identified any failures in RCP casings. RCPcasings are the only class 1 pumps at Surry Unit 1 that fall under the B-L-1 category.The requirement for performing these examinations results in unnecessary radiationexposure for non-destructive examination (NDE) personnel. The RCP casing welds arenot alloy 600/82/182 materials, but were fabricated with a 1969 Westinghouse materialSA-298 or SA-371.



Therefore, Dominion proposes to use the 2007 Edition through the 2008 Addendafor theCategory B-L-1 welds in entirety.

4. Related Requirements

For the portion of the subsequent Code edition and addenda to be used, there are norelated requirements, modifications, or limitations listed in 10CFR50.55a that apply toExamination Category B-L-1, which was deleted from the proposed code edition andaddenda.

5. Duration of Use of Proposed Subsequent Code Edition and Requirements

This request is applicable for the Fifth 10-year ISI Interval for Unit 1, which is scheduledto start December 14, 2013 and end October 13, 2023.

6. Precedents

Similar relief for the following nuclear units has been granted:

Palo Verde Nuclear Generating Station Units 1, 2, and 3, 3 rd ISI Interval, TAC Nos.ME7805, ME7806, and ME7807

Surry Units 1 and 2, 4th ISI Intervals, TAC NOs. MF1805 and MF1806



Section 5


(DOMINION)

SURRY POWER STATION

UNIT 1


LIMITED COVERAGE RELIEF REQUESTS




(RESERVED FOR LATER USE)



Section 6


(DOMINION)

SURRY POWER STATION

UNIT 1


CODE CASES




6.0 CODE CASES

6.1 Mandatory Code Cases required by 10 CFR 50.55a(g)(6)(ii)(D)(1) and (E)(1) toaugment the ISI Program:

Case N-729-1 "Alternative Examination Requirements for PWR Reactor VesselUpper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds, Section Xl, Division 1"

The following conditions are required:

(1) Note 9 of ASME Code Case N-729-1 shall not beimplemented.

(2) Instead of the specified 'examination method' requirementsfor volumetric and surface examinations in Note 6 of Table1 of Code Case N-729-1, the licensee shall performvolumetric and/or surface examination of essentially 100

percent of the required volume or equivalent surfaces ofthe nozzle tube, as identified by Figure 2 of ASME CodeCase N-729-1. A demonstrated volumetric or surface leakpath assessment through all J-groove welds shall be

performed. If a surface examination is being substituted fora volumetric examination on a portion of a penetrationnozzle that is below the toe of the J-groove weld [Point Eon Figure 2 of ASME Code Case N-729-1], the surfaceexamination shall be of the inside and outside wettedsurface of the penetration nozzle not examinedvolumetrically.

(3) By September 1, 2009, ultrasonic examinations shall beperformed using personnel, procedures and equipmentthat have been qualified by blind demonstration onrepresentative mockups using a methodology that meetsthe conditions specified in (50.55a(g)(6)(ii)(D)(4)(/) through(50.55a(g)(6)(ii)(D)(4)(iv), instead of the qualificationrequirements of Paragraph -2500 of ASME Code CaseN-729-1. References herein to Section Xl, Appendix VIIIshall be to the 2004 Edition with no Addenda of the ASMEBPV Code.I. The specimen set shall have an applicable thickness

qualification range of +25 percent to -40 percent fornominal depth through-wall thickness. The specimenset shall include geometric and material conditionsthat normally require discrimination from primarywater stress corrosion cracking (PWSCC) flaws.



II. The specimen set must have a minimum of ten (10)flaws which provide an acoustic response similar toPWSCC indications. All flaws must be greater than10 percent of the nominal pipe wall thickness. Aminimum of 20 percent of the total flaws must initiatefrom the inside surface and 20 percent from theoutside surface. At least 20 percent of the flaws mustbe in the depth ranges of 10-30 percent through wallthickness and at least 20 percent within a depthrange of 31-50 percent through wall thickness. Atleast 20 percent and no more than 60 percent of theflaws must be oriented axially.

Ill. Procedures shall identify the equipment and essentialvariables and settings used for the qualification, andare consistent with Subarticle VIII-2100 of SectionXl, Appendix VIII. The procedure shall be requalifiedwhen an essential variable is changed outside thedemonstration range as defined by Subarticle VilI-3130 of Section XI, Appendix VIII and as allowed byArticles VIII-4100, VIII-4200 and VIII-4300 ofSection Xl, Appendix VIII. Procedure qualificationshall include the equivalent of at least three

personnel performance demonstration test sets.Procedure qualification requires at least onesuccessful personnel performance demonstration.

IV. Personnel performance demonstration testacceptance criteria shall meet the personnelperformance demonstration detection testacceptance criteria of Table VIII-S10-1 of SectionXl, Appendix VIII, Supplement 10. Examinationprocedures, equipment, and personnel are qualifiedfor depth sizing and length sizing when the RMSerror, as defined by Subarticle VIII-3120 of SectionXl, Appendix VIII, of the flaw depth measurements,as compared to the true flaw depths, do not exceed% inch (3 mm), and the root mean square (RMS)error of the flaw length measurements, as comparedto the true flaw lengths, do not exceed % inch (10mm), respectively.

(4) If flaws attributed to PWSCC have been identified, whetheracceptable or not for continued service under Paragraphs -3130 or -3140 of ASME Code Case N-729-1, the re-inspection interval must be each refueling outage instead


i


of the re-inspection intervals required by Table 1, Note (8)of ASME Code Case N-729-1.

(5) Appendix I of ASME Code Case N-729-1 shall not beimplemented without prior NRC approval.

Case N-722-1 "Additional Examinations for PWR Pressure Retaining Welds inClass 1 Components Fabricated With Alloy 600/82/182Materials, Section Xl, Division 1"

NOTE: The inspection requirements of ASME Code Case N-722-1 do not apply to components with pressure retaining weldsfabricated with Alloy 600/82/182 materials that have beenmitigated by weld overlay or stress improvement.

The following conditions are required:

(1) If a visual examination determines that leakage is occurringfrom a specific item listed in Table 1 of ASME Code CaseN-722-1 that is not exempted by the ASME Code, SectionXl, IWB-1220(b)(1), additional actions must be performed tocharacterize the location, orientation, and length of crack(s)in Alloy 600 nozzle wrought material and location,orientation, and length of crack(s) in Alloy 82/182 butt welds.Alternatively, licensees may replace the Alloy 600/82/182materials in all the components under the item number of theleaking component.

(2) If the actions in paragraph (g)(6)(ii)(E)(2) of this sectiondetermine that a flaw is circumferentially oriented andpotentially a result of primary water stress corrosioncracking, licensees shall perform non-visual NDEinspections of components that fall under that ASME CodeCase N-722-1 item number. The number of componentsinspected must equal or exceed the number of componentsfound to be leaking under that item number. If circumferentialcracking is identified in the sample, non-visual NDE must beperformed in the remaining components under that itemnumber.

(3) If ultrasonic examinations of butt welds are used to meet theNDE requirements in paragraphs (g)(6)(ii)(E)(2) or(g)(6)(ii)(E)(3) of this section, they must be performed usingthe appropriate supplement of Section Xl, Appendix VIII ofthe ASME Boiler and Pressure Vessel Code.



6.2 Other Code Cases utilized in the Fifth 10-year ISI Interval per RegulatoryGuide 1.147:

Case N-432-1

Case N-460

Case N-504-4

"Repair Welding Using Automatic or Machine Gas Tungsten-ArcWelding (GTAW) Temper Bead Technique, Section Xl,Division 1"

"Alternative Examination Coverage for Class 1 and Class 2Welds, Section Xl, Division 1"

"Alternative Rules for Repair of Class 1, 2, and 3 AusteniticStainless Steel Piping, Section Xl, Division 1"

The following conditions are requirements for use:

The provisions of Section XI, Nonmandatory Appendix Q, "WeldOverlay Repair of Class 1, 2, and 3 Austenitic Stainless SteelPiping Weldments," must also be met. In addition, the followingconditions shall be met: (a) the total laminar flaw area shall notexceed 10% of the weld surface area, and no linear dimensionof the laminar flaw area shall exceed the greater of 3 inches or10% of the pipe circumference; (b) the finished overlay surfaceshall be 250 micro-in (6.3 micrometers) root mean square orsmoother; (c) the surface flatness shall be adequate forultrasonic examination; and (d) radiography shall not be used todetect planar flaws under or masked by laminar flaws.

"Evaluation Criteria for Temporary Acceptance of Flaws inModerate Energy Class 2 or 3 Piping, Section Xl, Division 1"

The following condition is a requirement for use:

The repair or replacement activity temporarily deferred under theprovisions of this Code Case shall be performed during the nextscheduled outage.

Case N-513-3

Case N-516-3 "Underwater Welding, Section Xl, Division 1'"


Licensees must obtain NRC approval in accordance with10 CFR 50.55a(a)(3) regarding the technique to be used in theweld repair or replacement of irradiated material underwater.

SPS Ul 15-ISI PlanR 6-5 Revision 0


Case N-517-1

Case N-526

Case N-528-1

Case N-532-4

Case N-552

"Quality Assurance Program Requirements for Owners, SectionXl, Division 1"

"Alternative Requirements for Successive Inspections of Class 1and 2 Vessels, Section Xl, Division 1"

Purchase, Exchange, or Transfer of Material Between NuclearPlant Sites, Section Xl, Division 1"


The requirements of 10 CFR Part 21, "Reporting of Defects andNoncompliance" (Ref. 5), are to be applied to the nuclear plantsite supplying the material as well as to the nuclear plant sitereceiving the material that has been purchased, exchanged, ortransferred between sites.

"Alternate Requirements to Repair and ReplacementDocumentation Requirements and Inservice Summary ReportPreparation and Submission as Required by IWA-4000 andIWA-6000, Section XI, Division 1"

"Alternative Methods - Qualification for Nozzle Inside RadiusSection from the Outside Surface, Section XI, Division 1"


To achieve consistency with the 10 CFR 50.55a rule changepublished September 22, 1999 (64 FR 51370), incorporatingAppendix VIII, "Performance Demonstration for UltrasonicExamination Systems," to Section XI, add the following to thespecimen requirements:

"At least 50 percent of the flaws in the demonstration test setmust be cracks and the maximum misorientation must bedemonstrated with cracks. Flaws in nozzles with bore diametersequal to or less than 4 inches may be notches."

Add to detection criteria, "The number of false calls must notexceed three."

"Corrective Action for Leakage Identified at Bolted Connections,Section Xl, Division 1"

"Alternative Rules for Repair by Electrochemical Deposition ofClass 1 and 2 Steam Generator Tubing, Section Xl, Division 1"

Case N-566-2

Case N-569-1




NOTES: Steam Generator tube repair methods require priorNRC approval through the Technical Specifications. This CodeCase does not address certain aspects of this repair, e.g., thequalification of the inspection and plugging criteria necessary forstaff approval of the repair method. In addition, if the user plansto "reconcile," as described in Footnote 2, the reconciliation is tobe performed in accordance with IWA-4200 in the 1995 Edition,1996 Addenda of ASME Section Xl.

Case N-586-1 "Alternative Additional Examination Requirements for Classes 1,2, and 3 Piping, components, and Supports, Section Xl,Division 1"

Case N-593 "Alternative Examinations Requirements for Steam GeneratorNozzle to Vessel Welds, Section Xl, Division 1"


Essentially 100 percent (not less than 90 percent) of theexamination volume A-B-C-D-E-F-G-H must be inspected.

Case N-597-2 "Requirements for Analytical Evaluation of Pipe Wall Thinning,

Section Xl, Division 1"


(1) Code Case must be supplemented by the provisions of EPRINuclear Safety Analysis Center Report 202L-R2, April 1999,"Recommendations for an Effective Flow Accelerated

Corrosion Program," for developing the inspectionrequirements, the method of predicting the rate of wallthickness. As used in NSAC-202L-R2, the terms "should" isto be applied as "shall" (i.e., a requirement).

(2) Components affected by the flow-accelerated corrosion towhich this Code Case are applied must be repaired orreplaced in accordance with the construction code of recordand Owner's requirements or a later NRC approved editionof Section III 'Rules for Construction of Nuclear Power PlantComponents" of the ASME Code prior to the value of tp

reaching the allowable minimum wall thickness, tmin, as

specified in -3622.1 (a)(1) of this Code Case. Alternatively,


Case N-600

Case N-613-1

Case N-624

Case N-629

Case N-638-4


use of the Code Case is subject to NRC review and approvalper 10 CFR 50.55(a)(3).

(3) For Class 1 piping not meeting the criteria of -3221, the useof evaluation methods and criteria is subject to NRC reviewand approval per 10 CFR 50.55(a)(3).

(4) For those components that do not require immediate repairor replacement, the rate of wall thickness loss is to be usedto determine a suitable inspection frequency so that repair orreplacement occurs prior to reaching allowable minimumwall thickness, trin.

(5) For corrosion phenomenon other than flow acceleratedcorrosion, use of the Code Case is subject to NRC reviewand approval. Inspection plans and wall thinning rates maybe difficult to justify for certain degradation mechanismssuch as MIC and pitting.

"Transfer of Welder, Welding Operator, Brazer, and BrazingOperator Qualifications Between Owners, Section XI, Division 1"

"Ultrasonic Examination of Penetration Nozzles in Vessels,Examination Category B-D, Item Nos. B3.10 and B3.90, ReactorNozzle-to-Vessel Welds, Figs. IWB-2500-7(a), (b), and (c),Section Xl, Division 1"

"Successive Inspections, Section Xl, Division 1"

"Use of Fracture Toughness Test Data to Establish ReferenceTemperature for Pressure Retaining Materials, Section XI,Division 1"

"Similar and Dissimilar Metal Welding Using AmbientTemperature Machine GTAW Temper Bead Technique, SectionXI, Division 1"


(1) Demonstration for ultrasonic examination of the repairedvolume is required using representative samples whichcontain construction type flaws.

(2) The provisions of 3(e)(2) or 3(e)(3) may only be used when itis impractical to use the interpass temperature measurementmethods described in 3(e)(1), such as in situations wherethe weldment area is inaccessible (e.g., internal borewelding) or when there are extenuating radiologicalconditions.



Case N-639

Case N-641

Case N-643-2

Case N-648-1

"Alternative Calibration Block Material, Section Xl, Division 1"


Chemical ranges of the calibration block may vary from thematerials specification if (1) it is within the chemical range of thecomponent specification to be inspected, and (2) the phase andgrain shape are maintained in the same ranges produced by thethermal process required by the material specification.

"Alternative Pressure-Temperature Relationship and LowTemperature Overpressure Protection System Requirements"

"Fatigue Crack Growth Rate Curves for Ferritic Steels in PWRWater Environment, Section Xl, Division 1"

"Alternative Requirements for Inner Radius Examination ofClass 1 Reactor Vessel Nozzles, Section XI, Division 1"


In place of a UT examination, licensees may perform a visualexamination with enhanced magnification that has a resolutionsensitivity to detect a 1-mil width wire or crack, utilizing theallowable flaw length criteria of Table IWB-3512-1 with limitingassumptions on the flaw aspect ratio. The provisions of TableIWB-2500-1, Examination Category B-D, continue to applyexcept that, in place of examination volumes, the surfaces to beexamined are the external surfaces shown in the figuresapplicable to this table (the external surface is from point M topoint N in the figure).

"Ferritic and Dissimilar Metal Welding Using SMAW TemperBead Technique Without Removing the Weld Bead Crown forthe First Layer, Section Xl, Division 1"

"Alternative Requirements for Wall Thickness Restoration ofClasses 2 and 3 Carbon Steel Piping for Raw Water Service,Section Xl, Division 1"


(1) If the cause of the degradation has not been determined, therepair is only acceptable until the next refueling outage.

Case N-651

Case N-661-1


Case N-666

Case N-686-1

Case N-705

Case N-706-1

Case N-731

Case N-733

Case N-735

Case N-751


(2) When through-wall repairs are made by welding on surfacesthat are wet or exposed to water, the weld overlay repair isonly acceptable until the next refueling outage.

"Weld Overlay of Class 1, 2, and 3 Socket Welded Connections,Section Xl, Division 1"

"Alternative Requirements for Visual Examinations, VT-1, VT-2,and VT-3, Section Xl, Division 1"

"Evaluation Criteria for Temporary Acceptance of Degradation inModerate Energy Class 2 or 3 Vessels and Tanks, Section Xl,Division 1"

"Alternative Examination Requirements of Table IWB-2500-1and Table IWC-2500-1 for PWR Stainless Steel Residual andRegenerative Heat Exchangers, Section XI, Division 1"

"Alternative Class 1 System Leakage Test PressureRequirements, Section Xl, Division 1"

"Mitigation of Flaws in NPS 2 (DN 50) and Smaller Nozzles andNozzle Partial Penetration Welds in Vessels and Piping by Useof a Mechanical Connection Modification, Section XI, Division 1"

"Successive Inspection of Class 1 and 2 Piping Welds,Section XI, Division 1"

"Pressure Testing of Containment Penetration Piping,Section Xl, Division 1"


When a 10 CFR 50, Appendix J, Type C test is performed as analternative to the requirements of IWA-4540 (IWA-4700 in the1989 edition through the 1995 edition) during repair andreplacement activities, nondestructive examination must beperformed in accordance with IWA-4540(a)(2) of the 2002Addenda of Section Xl.

Case N-753 "Vision Tests, Section Xl, Division 1,"


Section 7


(DOMINION)

SURRY POWER STATION

UNIT 1


PLAN CHANGES


SPS U1 15-1SI Plan 7-1 Revision 0

7.0 Plan Changes

7.1 Revision Summary

(RESERVED FOR LATER USE)


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