ML052080006

Relief, Safety Significant Socket Weld Examinations, TAC MC3134

ML052080006
Person / Time
Site:	Surry  (DPR-037)
Issue date:	08/08/2005
From:	Marinos E NRC/NRR/DLPM/LPD2
To:	Christian D Virginia Electric & Power Co (VEPCO)
Monarque, S R, NRR/DLPM, 415-1544
References
TAC MC3134
Download: ML052080006 (14)

Text

August 8, 2005 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711

SUBJECT:

SURRY POWER STATION, UNIT 2 - AMERICAN SOCIETY OF MECHANICAL ENGINEERS SECTION XI RISK-INFORMED INSERVICE INSPECTION INTERVAL UPDATE FOR THE FOURTH 10-YEAR INTERVAL (TAC NO.

MC3134)

Dear Mr. Christian:

By letter dated May 13, 2004, as supplemented by letter dated March 23, 2005, Virginia Electric and Power Company (VEPCO) requested approval to use its risk-informed inservice inspection (RI-ISI) program for the fourth 10-year ISI interval and approval of Relief Request R-1. The licensee, in Relief Request R-1, seeks relief from certain requirements of its RI-ISI program, as required by WCAP-14572, Revision 1-NP-A, Westinghouse Owners Group Application of Risk-Informed Decision Making: Inservice Inspection of Piping, pertaining to high safety significant (HSS) socket weld examinations. The Nuclear Regulatory Commission (NRC) staff has completed its review of these relief requests, and the NRC staffs evaluations and conclusions are contained in the enclosed Safety Evaluation.

For the implementation of the RI-ISI program, the NRC staff concludes that VEPCOs proposed RI-ISI program provides an acceptable level of quality and safety and, therefore, is authorized pursuant to Title 10 of the Code of Federal Regulations Section 50.55a(a)(3)(i) for the fourth 10-year ISI interval at Surry, Unit 2.

Regarding Relief Request R-1, the NRC staff concludes that VEPCOs proposal to perform visual VT-2 examinations during each refueling outage in lieu of the volumetric examinations specified WCAP-14572, Revision 1-NP-A, for the subject HSS socket welds and their associate branch connections nominal pipe size 2 and smaller provides reasonable assurance of structural integrity of the subject pipe welds. In addition, the NRC staff has determined that complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the NRC staff authorizes the proposed alternative pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval at Surry, Unit 2.

The NRC staff is closing out TAC No. MC3134 with this letter.

Sincerely,

/RA/

Evangelos Marinos, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-281

Enclosure:

As stated cc w/encl: See next page The NRC staff is closing out TAC No. MC3134 with this letter.

Sincerely,

/RA/

Evangelos Marinos, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-281

Enclosure:

As stated cc w/encl: See next page Distribution PUBLIC RidsNrrPMSMonarque SMalik PDII-1 R/F RidsNrrLACHawes (Hard Copy)

TChan RidsNrrDlpmLpdii (EHackett)

RidsAcrsAcnwMailCenter MRubin RidsNrrDlpmLpdii1 (EMarinos)

RidsOgcRp RidsNrrDlpmDpr RidsRgn2MailCenter (KLandis)

ADAMS ACCESSION NO.: ML052080006 *No Legal Objection NRR-028 OFFICE PM/PDII-1 LA/PDII-2 SC/SPSB SC/EMCB OGC

• SC/PDII-1 NAME SMonarque EDunnington MRubin TChan KKannler EMarinos DATE 07/26/2005 07/22/2005 06/16/2005 06/16/200 5

07/26/200 5

08/08/2005 OFFICIAL RECORD COPY

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM SURRY POWER STATION, UNIT 2 VIRGINIA ELECTRIC AND POWER COMPANY DOCKET NO. 50-281

1.0 INTRODUCTION

By letter dated May 13, 2004 (Reference 1), as supplemented by a letter dated March 23, 2005 (Reference 2), Virginia Electric and Power Company (the licensee) submitted a request to extend the risk-informed inservice inspection (RI-ISI) program plan from the third to the fourth 10-year inservice inspection (ISI) interval and a request to implement Relief Request R-1. Both relief requests were for Surry Power Station, Unit 2.

In its letter dated April 27, 2000 (Reference 3), as supplemented by letter dated September 27, 2000 (Reference 4), the licensee submitted the RI-ISI program for the third 10-year ISI interval at Surry, Unit 2. The licensees RI-ISI program was developed in accordance with the methodology contained in the Westinghouse Owners Group (WOG) Report WCAP-14572, Revision 1-NP-A, Westinghouse Owners Group Application of Risk-Informed Decision Making:

Inservice Inspection of Piping (Reference 6), which was reviewed and approved by the U.S.

Nuclear Regulatory Commission (NRC) staff. Subsequently, by letter dated January 26, 2001 (Reference 5), the NRC staff approved the licensees RI-ISI program for use in the third 10-year ISI interval at Surry, Unit 2. On June 13, 2002 (Reference 9), the licensee sought relief (Relief Request R-1) from its approved third 10-year RI-ISI program regarding examination of high safety significant (HSS) socket welds. The RI-ISI program Relief Request R-1 was approved by the NRC staff for the third 10-year ISI interval at Surry, Unit 2 on September 23, 2003 (Reference 10).

The licensee proposes to extend the same RI-ISI program, as submitted on April 27, 2000, for the third 10-year ISI interval, to the fourth 10-year ISI interval at Surry, Unit 2. In addition, the licensee requests approval of relief similar to R-1 for the fourth 10-year ISI interval at Surry, Unit 2.

2.0 REGULATORY REQUIREMENTS Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g) specifies that ISI of nuclear power plant components shall be performed in accordance with the requirements of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),

Section XI, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). As stated, in part, in 10 CFR 50.55a(a)(3) alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The Surry, Unit 2 RI-ISI program is an alternative pursuant to 10 CFR 50.55a(a)(3)(i). In its letter dated May 13, 2004, the licensee requested NRC staff authorization to utilize the same RI-ISI program, previously approved for use in the third interval, for use in the fourth ISI interval at Surry, Unit 2. The licensee also requested relief R-1 from the WOG methodology pursuant to 10 CFR 50.55a(a)(3)(ii) regarding the examination of socket welds and their branch connections in piping nominal pipe size (NPS) 2 inches and less. The scope of the RI-ISI program is limited to the inspection of ASME Code Class 1 piping (Categories B-F and B-J welds). The applicable version of the Code for the fourth 10-year ISI interval at Surry, Unit 2 is the 1998 Edition through the 2000 Addenda.

3.0 TECHNICAL EVALUATION

FOR RI-ISI PROGRAM Summary of Proposed Changes By letter dated May 13, 2004, as supplemented by a letter dated March 23, 2005, the licensee submitted a relief request pursuant to 10 CFR 50.55a(a)(3)(i). The licensee sought relief from the requirements of ASME Code,Section XI to utilize an RI-ISI program plan at Surry, Unit 2 to perform ISI inspections during the fourth 10-year ISI interval. An RI-ISI program was reviewed and approved by the NRC staff for the third 10-year ISI interval. In its submittal dated May 13, 2004, the licensee requested approval to utilize the same RI-ISI program for the fourth 10-year ISI interval.

NRC Staff Evaluation

An acceptable RI-ISI program plan is expected to meet the following five key principles discussed in Regulatory Guide (RG) 1.178 (Reference 7), Standard Review Plan 3.9.8 (Reference 8), and the Electric Power Research Institute (EPRI) TR-112657.

1. The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.

2. The proposed change is consistent with the defense-in-depth philosophy.

3. The proposed change maintains sufficient safety margins.

4. When proposed changes result in an increase in core damage frequency (CDF) or risk, the increases should be small and consistent with the intent of the Commissions Safety Goal Policy Statement.

5. The impact of the proposed change should be monitored by using performance measurement strategies.

The first principle is met in this relief request because an alternative ISI program may be authorized pursuant to 10 CFR 50.55a(3)(i) and, therefore, an exemption request is not required. The second and third principles require assurance that the alternative program is consistent with the defense-in-depth philosophy and that sufficient safety margins are maintained, respectively. Assurance that the second and third principles are met is based on the application of the approved methodology and not on the particular inspection locations selected.

The methodology used to develop the fourth 10-year RI-ISI interval program is the WCAP-14572, Revision 1-NP-A methodology. However, in its letter dated March 23, 2005, the licensee stated that the Surry, Unit 2 RI-ISI program deviated from the approved WCAP-14572 methodology.

WCAP-14572, Revision 1-NP-A requires assigning all degradation mechanisms present in a segment to a single weld, resulting in the most limiting failure frequency for the entire segment.

The licensee stated that the Surry, Unit 2 RI-ISI program deviated from the WOG methodology by including 12 multiple pipe size segments in which the most limiting failure frequency was not used for the segment. To resolve this deviation, the licensee reevaluated these segments based on the most limiting failure frequency and conducted a sensitivity study to determine the impact on the risk ranking of the segments.

In its reevaluation, the licensee found that the failure probabilities for two segments increased by about two orders of magnitude, causing these segments to be quantitatively ranked HSS from medium safety significant (MSS). The licensee stated that the increase occurred from the failure probability being based on a socket weld rather than a butt weld as evaluated in the original RI-ISI program. Although these segments were quantitatively classified as MSS in the original evaluation for the third 10-year RI-ISI program, the expert panel had classified these segments as HSS due to a high stress concern and water solid pressurizer concern. Since the reevaluation quantitatively classifies these segments as HSS and they remain in the HSS category, the licensee stated that the categorization of these two segments remains unchanged.

The licensee also reported that, in its reevaluation, the risk reduction worth (RRW) for a segment increased very slightly to just inside the MSS range at 1.001 from a low safety significant (LSS) value. The expert panel unanimously voted to retain the segment as LSS as permitted by the approved methodology. Therefore, the reevaluation did not affect the categorization of this segment.

The risk ranking due to the reevaluation to resolve the deviation from the WOG methodology caused three segments, previously categorized as LSS, to become MSS. The expert panel had previously classified these segments as HSS due to a concern with the single check valve separating these segments from the HSS reactor coolant system (RCS) segments. The expert panel continued to classify these segments as HSS, and they remain in the HSS category.

Therefore, the reevaluation did not affect the categorization of these three segments.

The licensee compared the number and location of ISI inspections developed using its methodology to the number and location of inspections resulting from reevaluation without the deviation. The reevaluation did not result in any changes in the number or location of ISI inspections. The NRC staff concludes that the number of welds selected from inspection under the licensees RI-ISI program is consistent with those produced by the application of WCAP-14572, Revision 1-NP-A. Moreover, the licensees reevaluation of its RI-ISI program resolved the deviation from the approved WOG methodology by using the most limiting failure frequency for a segment. Any RI-ISI program that deviates from an approved methodology will require prior NRC staff review and approval of a request for relief.

The licensee stated in its letter dated May 13, 2004, that the methodology used to develop the fourth 10-year RI-ISI interval program is the approved WCAP-14572, Revision 1-NP-A.

Additionally, in its letter dated March 23, 2005, the licensee stated that the RI-ISI program for the fourth 10-year RI-ISI interval program was reevaluated to resolve a deviation in the third 10-year RI-ISI interval program from the WCAP-14572 methodology. The fourth 10-year RI-ISI interval program is consistent with a program that follows the approved WCAP-14572, Revision 1-NP-A, methodology. Therefore, the second principle (the proposed change is consistent with the defense-in-depth philosophy) and the third principle (the proposed change maintains sufficient safety margins) are met.

The fourth principle (any increase in CDF or risk should be small and consistent with the intent of the Commissions Safety Goal Policy Statement) requires an estimate of the change in risk, and the change in risk is dependent on the location of inspections in the proposed ISI program compared to the location of inspections that would be inspected using the requirements of ASME,Section XI. The licensee stated that, consistent with WCAP-14572, Revision 1-NP-A methodology, new information was incorporated into its RI-ISI analysis as part of its living program. This new information included changes to the probabilistic risk assessment (PRA) model and deterministic information provided to the expert panel. By letter dated May 13, 2004, the licensee stated that re-analysis of the PRA resulted in one segments RRW to be lowered from HSS to MSS. However, the expert panel retained the segment within the HSS category.

The licensee stated that the number and location of the volumetric examinations between the intervals remains the same for Surry, Unit 2.

Relief was granted in January 26, 2001, from selected requirements in the 1989 edition of the ASME Code,Section XI, which was the licensees Code of record when relief was requested.

The licensee stated in its letter dated May 13, 2004, that the Surry, Unit 2 current Code of record is the ASME Section XI 1998 Edition, through the 2000 Addenda. Although the Code of record edition has changed, the accuracy of the change in risk calculations does not warrant recalculating the ASME Section XI risk analysis with the current Code of record. Therefore, the NRC staff finds the comparison of the risk estimate between the current Code of record and the Code of record from which relief was granted in January 26, 2001, appropriate and acceptable.

On May 13, 2004, the licensee reported that the change in risk analysis was re-performed in accordance with WCAP-14572, Revision 1-NP-A to compare the original ASME,Section XI program with the revised fourth 10-year interval RI-ISI program. On March 23, 2005, the licensee added that since the PRA model was updated since the implementation of the original RI-ISI program, the change-in-risk analysis was re-performed to ensure risk neutrality of the program. To maintain total plant risk neutrality, one segment was added. The licensee stated that this resulted in one additional visual VT-2 exam being added to the RI-ISI program. In its letter dated March 23, 2005, the licensee stated that the total change in risk and system level change in risk estimates for the proposed fourth 10-year RI-ISI interval program are within acceptance guidelines in WCAP-14572, Revision 1-NP-A. The NRC staff finds that the change in risk estimate is appropriate and the results provide assurance that the fourth key principle is met. By letter dated May 13, 2004, the licensee stated that consistent with the fifth key principle in RG 1.174, the fourth 10-year RI-ISI interval program is a living program. Maintenance of a living program requires feedback of new relevant information to ensure the appropriate identification of HSS locations. As a result of recent and ongoing issues related to degradation due to pressurized-water stress corrosion cracking (PWSCC) in components that contain Alloy 600/82/182, the NRC staff requested that the licensee provide information regarding any dissimilar metal welds within the RI-ISI program that contain Alloy 82/182 filler metal. The licensee responded (Reference 2) that certain Surry, Unit 2 welds contain Alloy 82/182 filler metal. The RTD bypass line elimination design change implemented on Surry, Unit 2 installed Alloy 600 thermowells. Socket welds used to attach the thermowells to the existing stainless steel scoops inserted into the RCS loop piping. According to the licensee, these socket welds are either 1-inch or 1.5-inch in size and contain Alloy 82/182 filler metal. These welds are periodically examined as part of the augmented boric acid corrosion control program and the corresponding visual inspection program. The welds (12 total) are grouped into three RI-ISI segments based upon the RCS location. The original submittal had not identified these locations as having Alloy 82/182. The licensee states that had Alloy 82/182 material been previously identified, the expert panel would have considered these segments to be HSS, and going forward, these segments will be considered as such. The licensee stated that these welds will be included in an augmented inspection program. The licensee referenced a letter (Reference 11) that provided a supplemental response to NRC Bulletin 2002-01 in which it explained the discovery of these welds and described the licensees augmented inspection program. The augmented inspection program for these welds includes a bare metal visual inspection during every refueling outage. A bare metal visual examination has proven to be a successful method of inspection for locating early stage leakage due to PWSCC. The NRC staff considers the licensees bare metal visual inspection of these components a best effort and therefore acceptable given that a volumetric examination is not possible on the applicable weld joint configuration. However, since the licensees relief request R-1 commits to performing a visual VT-2 exam on all HSS socket welds and their branch connections 2-inch NPS and smaller, it is the NRC staffs expectation that the licensee also conducts a visual VT-2 examination on the aforementioned welds as detailed in its relief request R-1. The NRC staff finds that the licensees placement of the 12 welds in the RCS piping that contain Alloy 82/182 filler metal into the HSS category is consistent with the living program, and therefore, the fifth key principle is met.

Based on the above discussion, the NRC staff finds that the five key principles of risk-informed decisionmaking are ensured by the licensees proposed fourth 10-year RI-ISI interval program plan and, therefore, the proposed program for the fourth 10-year ISI inspection interval is acceptable.

3.1 Conclusion for RI-ISI Program Based on the information provided by the licensee, the NRC staff has determined that the proposed alternative RI-ISI program provides an acceptable level of quality and safety and, therefore, it is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-year ISI interval at Surry, Unit 2.

4.0 RELIEF REQUEST R-1 4.1 The Components for Which Relief is Requested:

ASME Class 1 socket weld connections and their branch connections, nominal pipe size 2 inches (NPS 2) and smaller, identified as being HSS.

4.2 Code Requirement:

The licensee uses an alternative Class 1 RI-ISI program per WCAP-14572, Revision 1-NP-A, instead of ASME,Section XI requirements for piping (Categories B-F and B-J). WCAP-14572, Revision 1-NP-A, Table 4.1-1, requires a volumetric examination of HSS components (including socket welds).

4.3 Licensees Proposed Alternative:

A VT-2 exam will be performed on the subject socket weld connections and their branch connections, NPS 2 and smaller, on a refueling outage frequency while the component is pressurized.

The VT-2 examination and pressure test required by Relief Request R-1 will conform to the requirements of ASME Section XI IWA-2000 & 5000 of the 1998 Edition through 2000 Addenda. Additionally, NRC approved Code Case -498-1 (or later revision as approved by the NRC) may be applied for the end of interval testing.

The following pressure test hold times will apply:

C Insulated components - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> minimum at test pressure C

Non-insulated components - 10 minutes minimum at test pressure A similar relief request was recently approved for Surry Unit 1 (3rd ISI Interval) in an NRC letter to Virginia Electric and Power Company dated September 23, 2003. This precedent is directly applicable to Surry Unit 2.

4.4 Licensees Basis for Requesting Relief:

Pursuant to WCAP-14572, Revision 1-NP-A, certain socket weld connections and their branch connections, NPS 2 and smaller, have been identified as HSS and require volumetric examination for their postulated failure mechanism. Currently only three piping segments have been identified for Surry Unit 2. These volumetric examinations are associated with a postulated thermal fatigue damage mechanism, which is selected as the default mechanism for HSS segments when there is no assumed active mechanism or other postulated mechanism occurring. Performing a volumetric examination on a socket weld connection or the branch connection, NPS 2 and smaller, provides little or no benefit, due to limitations imposed by the joint configuration and the smaller pipe size. The socket welds are partial penetration welds and the branch connections may be partial or full penetration welds. These weld designs and pipe sizes under current Category B-J requirements would only require a surface examination.

The only thermal fatigue that could credibly affect the subject piping would be the low cycle fatigue previously considered in the design. Low cycle fatigue has a very low probability of causing cracking. Furthermore, even if cracking were to occur, it would most likely originate on the inside diameter of the pipe. In addition, the Class 1 RI-ISI program did not identify any locations susceptible to external chloride stress corrosion cracking. The Class 1 piping is not located in areas that are subject to an aggressive environment that would promote external chloride stress corrosion cracking (i.e., there are very low levels of chloride (if any) and moisture is not typically present on the pipe).

No other externally driven damage mechanism can reasonably be postulated for this piping. Consequently, a surface exam would be of negligible benefit.

The ASME Code Committee has recognized the problem this relief request is addressing and has substituted the VT-2 examination method for all damage mechanisms on socket weld connections selected as HSS. ASME Code Case -577-1 has been issued and provides the requested substitution in Note 12 of Table 1 of the Code Case. Incorporation of the branch connection, NPS 2 and smaller, into the Code Case is now under consideration by the committee for similar size and joint configuration limitation reasons.

The industry is evaluating volumetric examination methods for socket welded connections for certain damage mechanisms. Dominion is following this effort and will address these developments as part of the WCAP-14572 living program process, if applicable.

Performing volumetric examinations on socket weld connections or their branch connections, NPS 2 and smaller, would result in unusual difficulty without providing any meaningful results or compensating increase in the level of quality and safety.

Therefore, relief is requested per 10 CFR 50.55a(a)(3)(ii). Substituting a VT-2 examination as an alternative on a refueling outage frequency for these locations ensures reasonable assurance of component integrity.

4.5 NRC Staff Evaluation for Relief Request R-1 The licensee requested to perform a VT-2 examination each refueling outage in accordance with the requirements of ASME,Section XI IWA-2000 and 5000, or Code Case -498-1 on HSS socket welds and their associated branch connections, NPS 2 and smaller, in lieu of the Code-required surface exam or the volumetric exam directed by the WOG methodology in WCAP-14572, Revision 1-NP-A. The licensee indicated that Code Case -577 has been revised to allow the substitution of the VT-2 examination method for all damage mechanisms on socket welds identified as HSS. The licensee requested and received approval from the NRC staff for a similar relief request for the third interval at Surry, Unit 2. The licensee stated (Reference 2) that three segments are addressed by current Relief Request R-1, and for these segments no changes to the number or type of inspections are being requested from the previously approved relief request on socket welds for the Surry, Unit 2 RI-ISI program. Table IWB-2500-1 of the Code requires surface examination, not volumetric examination, at the socket welds. Surface examination (i.e., liquid penetration examination) is an effective method for the identification of outside surface-initiated flaws of specific concern, that is, flaws induced by low-cycle fatigue or by external chloride stress corrosion cracking (ECSCC). Information provided by the licensee in support of its previous relief request indicated that these three piping segments are not located in areas that are subject to an environment-promoting ECSCC or that the piping material is not considered susceptible to ECSCC, and an outside surface initiated flaw has a very low probability of occurrence due to the inclusion of low cycle fatigue in the piping design.

Therefore, the NRC staff finds the proposed alternative reasonable because volumetric examinations are inconclusive due to the geometric limitations imposed by the socket welds and branch connections, and the licensees alternative provides reasonable assurance of structural integrity of the subject piping welds 4.6 Conclusion for Relief Request R-1 Based on the above evaluation, the NRC staff concludes that the proposed visual VT-2 examinations performed during each refueling outage in lieu of the volumetric examinations specified in WCAP-14572, Revision 1-NP-A, for the subject HSS socket welds and their associate branch connections, NPS 2 and smaller, provide reasonable assurance of structural integrity for the subject piping welds. In addition, complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the NRC staff authorizes the proposed alternative pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval at Surry, Unit 2.

5.0 CONCLUSION

S Based on the above evaluations, the NRC staff has determined that the licensees RI-ISI program based on the WOG methodology provides an acceptable level of quality and safety and, therefore, it is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-year ISI inspection interval at Surry, Unit 2. The NRC staff has also determined that the licensees proposed alternative as stated in relief request R-1 to perform visual VT-2 examinations of HSS socket welds and their associate branch connections, NPS 2 and smaller, in lieu of the required volumetric examinations provides reasonable assurance of structural integrity of the subject piping welds. In addition, complying with the specified requirement would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the NRC staff authorizes the proposed alternative pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year ISI interval at Surry, Unit 2. All other requirements of the ASME Code,Section XI for which relief has not been specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

6.0 REFERENCES

1.

Letter from Leslie N. Hartz, Virginia Electric and Power Company, dated May 13, 2004, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company, Surry Power Station Unit 2, ASME Section XI Fourth Inservice Inspection (ISI) Interval Update, Risk Informed Inservice Inspection (RI-ISI) Program.

2.

Letter from William R. Matthews, Virginia Electric and Power Company, dated March 23, 2005, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company, Surry Power Station Unit 2, ASME Section XI Fourth Inservice Inspection (ISI)

Interval Update, Risk Informed Inservice Inspection (RI-ISI) Program, Response to NRC Request for Additional Information.

3.

Letter from Leslie N. Hartz, Virginia Electric and Power Company, dated April 27, 2000, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company, Surry Power Station Unit 2, Risk-Informed Inservice Inspection Program.

4.

Letter from Leslie N. Hartz, Virginia Electric and Power Company, dated September 27, 2000, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company, Surry Power Station Unit 2, Risk-Informed Inservice Inspection Program, Request for Additional Information.

5.

Letter from Richard L. Emch, Jr., U.S. Nuclear Regulatory Commission, dated January 26, 2001, to David A. Christian (Virginia Electric and Power Company), Request to Use an Alternative Risk-Informed Inservice Inspection (RI-ISI) Program at Surry Unit 2 (TAC No. MA8835).

6.

WCAP-14572, Revision 1-NP-A, Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report, February 1999.

7.

NRC Regulatory Guide 1.178, An Approach for Plant-Specific Risk-Informed Decision Making: Inservice Inspection of Piping, September 1998.

8.

NRC NUREG-0800, Chapter 3.9.8, Standard Review Plan for Trial Use for the Review of Risk-Informed Inservice Inspection of Piping, September 1998.

9.

Letter from Leslie N. Hartz, Virginia Electric and Power Company, dated June 13, 2002, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company, North Anna Power Station Units 1 and 2, Surry Power Station Units 1 and 2, Risk-Informed ISI Relief Request R-1.

10.

Letter from John A. Nakoski, U.S. Nuclear Regulatory Commission, dated September 23, 2003, to David A. Christian (Virginia Electric and Power Company), Surry Power Station, Units 1 and 2, and North Anna Power Station, Units 1 and 2 -

Risk-Informed Inservice Inspection Relief Request R-1 (TAC Nos. MB5437, MB5438, MB5439, and MB5440) 11.

Letter from Leslie N. Hartz, Virginia Electric and Power Company, dated January 5, 2002, to U.S. Nuclear Regulatory Commission, Virginia Electric and Power Company, North Anna and Surry Power Stations Units 1 and 2, NRC Bulletin 2002-01 Reactor Pressure Vessel Head Degradation and Reactor Coolant Boundary Integrity Supplemental Response.

Principal Contributors: R. Davis S. Malik Date: August 8, 2005

Surry Power Station, Units 1 & 2 cc:

Ms. Lillian M. Cuoco, Esq.

Senior Counsel Dominion Resources Services, Inc.

Building 475, 5th Floor Rope Ferry Road Waterford, Connecticut 06385 Mr. Donald E. Jernigan Site Vice President Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883-0315 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711