ML102580204

Fourth 10-Year Interval Inservice Inspection Program and Associated Proposed Alternatives and Relief Request

ML102580204
Person / Time
Site:	Millstone
Issue date:	07/29/2010
From:	Price J Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
10-323
Download: ML102580204 (174)

Text

Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, Virginia 23060 Dominiollif Web Address: www.dom.com July 29, 2010 U.S. Nuclear Regulatory Commission Serial No.10-323 Attention: Document Control Desk NSS&L/MLC RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM AND ASSOCIATED PROPOSED ALTERNATIVES AND RELIEF REQUESTS Pursuant to 10 CFR 50.55a(g)(4), Dominion Nuclear Connecticut, Inc. (DNC) submits the Millstone Power Station Unit 2 (MPS2) inservice inspection (ISI) program for the fourth 10-year interval applicable to Class 1, 2, and 3 components and component supports.

The ISI program manual, included as Enclosure 1 to this letter, describes the programmatic aspects of ISI examination of components and component supports. The enclosed ISI program does not address the piping examination requirements that will result from implementation of risk-informed technology. DNC is presently developing a risk-informed program for the examination of piping that will be applicable to Class 1 piping, as a minimum. Upon development of the risk-informed program and required supporting documents, a supplemental submittal to the Fourth 10-Year Interval ISI Program will be provided. This supplemental submittal will address the risk-informed scope and modifications to the examination requirements of affected piping components.

The ISI program has been developed in accordance with the requirements of the 2004 Edition (No addenda) of Section Xl of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. MPS2 will also comply with the limitations and modifications stated in 10 CFR 50.55a(b) as they apply to the implementation of the 2004 ASME Code. The fourth 10-year ISI interval began on April 1, 2010.

Pursuant to 10CFR50.55a(a)(3)(i), 10CFR50.55a(a)(3)(ii), and 10CFR50.55a(g)(5)(iv),

DNC requests the use of alternative examination or testing requirements and requests relief from certain examination or testing requirements of the 2004 ASME Code. The proposed alternatives and relief requests from specific 2004 code requirements are provided in Enclosures 2 through 6. NRC approval is required before the relief requests can be implemented. The MPS2 fourth 10-year interval ISI plan and associated requests for the use of alternatives and relief from specific 2004 ASME Code requirements have been reviewed and approved by the station's Facility Safety Review Committee.

Relief Requests (RRs) RR-04-02 and RR-04-03 were submitted to the NRC in a letter dated March 30, 2010 (Serial No.10-137), to support use of the RRs during the first refueling outage (2R20) of MPS2's fourth 10-year ISI interval. DNC requests review and approval of the remaining relief requests by July 29, 2011. The remaining portions of the Ikl ~-

Serial No.10-323 Docket No. 50-336 MPS2 Fourth 10-Year Interval ISI Plan Page 2 of 3 ISI program are within the provisions of the ASME Boiler and Pressure Vessel Code and require no NRC approval for implementation.

If you have any questions or require additional information, please contact Wanda Craft at (804) 273-4687.

Sincerely, J. rice Vi .e)~resident- Nuclear Engineering

Enclosures:

1. Millstone Power Station Unit 2 Inservice Inspection Program Manual for the Fourth 10-Year Interval

2. Relief Request RR-04-04, Use of Alternative Pressure Testing Criteria for the System Leakage Test Conducted at or Near the End of the Inspection Interval on Class 1 Piping.

3. Relief Request RR-04-05, Use of Alternative Pressure/Flow Testing Requirements for Service Water System Buried Piping Segments.

4. Relief Request RR-04-06, Use of PDI Qualified Procedures, Personnel and Equipment for Non-Appendix VIII RPV Shell-to-Flange Weld.

5. Relief Request RR-04-07, Examination Criteria for Weld Overlays.

6. Relief Request RR-04-08, Alternative Pressure Testing Requirements for the RPV Flange Leak-Off Piping.

Commitments made in this letter:

1. None

Serial No.10-323 Docket No. 50-336 MPS2 Fourth 10-Year Interval IS[ Plan Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 C. J. Sanders NRC Project Manager, Mail Stop 8B3 U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.10-323 Docket No. 50-336 ENCLOSURE 1 MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM MANUAL FOR THE.FOURTH 10-YEAR INTERVAL DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM MANUAL REVISION 3 FOURTH TEN-YEAR INTERVAL DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL ABSTRACT This document describes the Fourth Ten-Year Inservice Inspection (ISI) Program for Millstone Power Station Unit 2 (MPS2). This summary addresses the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code,Section XI, Division 1, 2004 Edition (No Addenda). Additional requirements for augmented inspections are also addressed.

Included are relief requests and tables identifying the components subject to examination by Code Examination Category and Code Item Number.

Pursuant to 10 CFR 50.55a(g)4(ii), Dominion Nuclear Connecticut, Inc. (DNC) is required, as a minimum, to develop this program to ASME Section XI, 2004 Edition (No Addenda). f An alternative to the ASME Section XI requirements for the ISI of Class 1 piping, Categories B-J and B-F were implemented during the third interval based on the risk-informed technology developed in accordance with the Westinghouse Owners Group Topical Report, WCAP-14572, Revision 1-NP-A. The request to use this alternative was submitted to the Nuclear Regulatory Commission on November 10, 2003 with approval received on April 1, 2005. The risk-informed program is being reviewed and updated as necessary for the MPS2 fourth ten-year inspection interval.

The ISI Program does not currently address the piping examination requirements that will result from the implementation of risk-informed technology for the fourth inspection interval. DNC is presently updating the risk-informed program for the examination of piping that will be applicable to Class 1 piping, as a minimum. Upon development of the risk-informed program and required supporting documents, a supplemental submittal for the fourth 10-year ISI Program will be provided. This supplemental submittal will address the risk-informed scope and modifications to the examination requirements of affected piping components.

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE OF CONTENTS

1. INTRODUCTION 1.1 General 1.2 Applicable Editions and Addenda to Section XI 1.3 Historical ISI Program Information 1.4 System Classification 1.5 Inspection Program 1.5.1 Schedule 1.5.2 Additional Examinations 1.6 Responsibilities 1.6.1 Nuclear Engineering, ISllMaterials Group 1.7 Personnel Certification 1.8 Code of Federal Regulations Modifications. Limitations and Augmented Examination Requirements

2. INSPECTION PLAN 2.1 Class 1 Components 2.1.1 Exemption Basis 2.1.2 , Component/Piping Examinations 2.2 Class 2 Components 2.2.1 Exemption Basis 2.2.2 Component/Piping Examinations 2.3 Class 3 Components 2.3.1 Exemption Basis 2.3.2 Component/Piping Examinations 2.4 Component Supports 2.4.1 Exemption Basis 2.4.2 Examinations i

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 2.5 Augmented Examinations 2.5.1 Reactor Coolant Pump Flywheels 2.5.2 Class 2 Excluded Systems 2.5.3 Reactor Vessel Head Penetrations 2.5.4 Additional Examinations for Class 1 Alloy 600/82/182 Pressure Retaining Welds 2.5.5 Examination of Repaired Core Barrel Support Lugs 2.5.6 Visual Examination of 0 Degree Core Barrel Alignment Key Gap 2.6 Description of ISI Schedule Summary 2.6.1 ASME Section XI Inservice Inspection Examination Summary Tables 2.6.2 Risk-Informed Inservice Inspection Examination Summary Table 2.6.3 Augmented Examination Summary Table 2.7 Procedures 2.8 Examination Zone Listing Table 2.1 MPS2 Class 1, 2, 3 Component and Component Support ISI Examination Summary Table 2.2 MPS2 Class 1 Risked-Informed ISI Examination Summary Table 2.3 MPS2 Fourth Interval Augmented Examination Summary Table 2.4 List of Examination Procedures Table 2.5 Examination Zone Listing

3. CODE CASES Table 3.1 Code Case Summary Table

4. EVALUATION CRITERIA AND CALIBRATION STANDARDS 4.1 Class 1 Acceptance Standards 4.2 Class 2 Acceptance Standards 4.3 Class 3 Acceptance Standards 4.4 Acceptance Standards for Component Supports (Classes 1. 2. and 3) 4.5 Calibration Standards ii

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

4. EVALUATION CRITERIA AND CALIBRATION STANDARDS (continued) 4.6 Analytical Evaluation of Flaws 4.7 Unanticipated Operating Events Table 4.1 Class 1 Acceptance Standards Table 4.2 Class 2 Acceptance Standards Table 4.3 Class 3 Acceptance Standards Table 4.4 Calibration Standards

5. SYSTEM PRESSURE TESTS 5.1 General Requirements Table 5.1 System Pressure Test Schedule 5.2 Visual Examination Requirements 5.3 Class I System Pressure Test Requirements 5.4 Class 2 and Class 3 System Pressure Test Requirements 5.5 Repair and Replacement Pressure Test Requirements 5.6 Implementing Instructions 5.7 Corrective Measures

6. REPAIR/REPLACEMENT ACTIVITIES 6.1 Establishment of a Baseline

7. RECORDS AND REPORTS 7.1 Preparation 7.2 Submittal 7.3 Retention iii

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

8. COMMITMENTS 8.1 Tracking[Logging of Correspondence 8.2 Code Cases 8.3 Relief Requests 8.4 Correspondence Tracking Log Table 8.1 MPS2 ISI Correspondence Tracking Log

9. RELIEF REQUESTS 9.1 Alternative Requirements 9.1.1 Code Cases Not Approved for Use 9.1.2 Hardship or Unusual Difficulty 9.2 Impractical Requirements 9.3 Format 9.4 Relief Request Summary Tables Table 9.4-1 Third Interval Relief Request Summary Table Table 9.4-2 Fourth Interval Relief Request Summary Table

10. (Reserved for Future Use)

11. DRAWINGS

12. IMPLEMENTATION OF ASME SECTION XI, APPENDIX VIII iv

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

1. INTRODUCTION 1.1 General 1.1.1 This manual describes the MPS2 Fourth Ten-Year Inservice Inspection Plan.

The inspection plan, which consists of ASME Class 1, Class 2, and Class 3 systems and components (and their supports), has been developed utilizing applicable portions of the following documents:

• 10 CFR 50.2, Definitions

• 10 CFR 50.55a, Codes and Standards 0 ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 2004 Edition, (No Addenda)

• ASME Section III, Rules for Construction of Nuclear Power Plants, 1971 Edition with the Summer 1973 Addenda up to and including the 2004 Edition

• USNRC Standard Review Plan (SRP 6.6, Section 11-7) 0 USNRC Regulatory Guides:

1. RG 1.26, Rev. 3, February 1976

2. RG 1.65, Rev. 0, October 1973

3. RG 1.84 Rev. 34, October 2007

4. RG 1.147, Rev. 15, October 2007

5. RG 1.193, Rev 2, October 2007 o MPS2 FSAR MPS2 Technical Specifications WCAP-14572, Revision 1-NP-A, "Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report."

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MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

• ASME Code Cases:

1. N-432-1

2. N-460

3. N-504-3

4. N-513-2

5. N-526

6. N-532-4

7. N-545

8. N-566-2

9. N-586-1

10. N-600

11. N-613-1

12. N-624

13. N-638-1

14. N-639

15. N-648-1

16. N-651

17. N658

18. N-661

19. N-683

20. N-695

21. N-696

22. N-722

23. N-729-1

24. N-731

25. N-770-1 Note: Code Case details may be found in Section 3.

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MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 1.1.2 The programs listed below are addressed in separate program documents:

• Inservice Testing of Pumps and Valves

• Class MC and Class CC Components (Containment Inservice Inspection Program)

" Examination of Steam Generator Tubing

• Snubber Examination and Testing 1.1.3 Administrative implementing procedures utilized in implementation of the ISI program are listed below:

0 MP-24-ISI-FAPO1, Inservice Inspection Unresolved Indication Reporting

• U2-24-ISI-FAP02.3, ASME Section XI System Pressure Test Program for Unit 2 0 SP21141, Inservice Inspection

• ER-AA-RRM-100, ASME Section XI Repair/Replacement Program Fleet Implementation Requirements

• ER-AA-ISI-10, ASME Section XI Inservice Inspection Program 0 ER-AA-ISI-100, Dominion Inservice Inspection Program

• ER-AA-ISI-101, Dominion Inservice Inspection Program Preparation and Change Control Process

• ER-AA-ISI-102, Dominion Inservice Inspection IDDEAL Software Suite

• ER-AA-SPT-10, ASME Section XI System Pressure Test Program 0 ER-AA-SPT-100, ASME Section XI System Pressure Test Program Fleet Implementation Requirements 9 ER-AA-ISI-RI-10, ASME Section XI Risk-Informed Inservice Inspection Program 0 ER-AA-ISI-RI-100, Dominion Risk-Informed Program

• ER-AA-ISI-RI-101, the Dominion Risk-Informed Period Update Process 1.2 Applicable Editions and Addenda to Section XI 1.2.1 Pursuant to Title 10 of the Code of Federal Regulations, Part 50, Paragraph 50.55a (10 CFR 50.55a), Final Rules dated September 10, 2008 and October 2, 2008, the inspection requirements applicable to nondestructive examination (NDE) are based on the 1-3

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL rules set forth in the 2004 Edition of ASME Section XI, hereinafter referred to as ASME Section XI.

1.2.2 Pursuant toTitle 10 of the Code of Federal Regulations, Part 50, Paragraph 50.55a (10 CFR 50.55a), Final Rules dated September 10, 2008 and October 2, 2008, the implementation of ASME Section XI, Appendix VIII "Performance Demonstration for Ultrasonic Examination, Systems" is based on the 2001 Edition of ASME Section XI.

1.2.3 As permitted by paragraph 50.55a(g)(4)(iv), DNC may elect to meet the requirements set forth in editions and addenda of ASME Section XI which become effective subsequent to the 2004 Edition of ASME Section XI. NRC approval is required prior to implementing these later editions or addenda (Reference NRC Regulatory Issue Summary RIS-2004-12). Editions and Addenda of ASME Section XI or ASME Code Cases that are adopted will be identified in the appropriate sections of this inspection program.

It is the intent of DNC to apply appropriate revisions of ASME Section XI, with NRC approval, which improve the overall quality of MPS2's inspection program. Those changes that are applied will be identified in this Section of the ISI Program.

1.3 Historical ISI Program Information 1.3.1 The first ten-year inspection interval began on December 26, 1975 and ended on December 25, 1985. The base code of record for the first ten-year inspection interval was the 1971 Edition through Summer 1973 Addenda of ASME Section XI.

1.3.2 The second ten-year inspection interval began on December 26, 1985 and ended on March 31, 1999. The base code of record for the second ten-year inspection interval was the 1981 Edition through Winter 1985 Addenda of ASME Section XI.

1.3.3 The third ten-year inspection interval began on April 1, 1999 and ended on March 31, 2010. The NRC was notified of interval/period adjustments per Licensing Letter #B 17684, dated March 5, 1999 and letter SN 07-0340 dated May 3, 2007. The base code of record for the third ten-year inspection interval was the 1989 Edition of ASME Section XI.

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MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM

,FOURTH TEN-YEAR INTERVAL 1.4 System Classification 1.4.1 The construction permit for MPS2 was issued in December 1970.

The operating license was issued in September 1975. Northeast Nuclear Energy Company was the owner ofrecord, and Bechtel was the Architect Engineer and installer of record.

1.4.2 The system classifications for the ISI Plan are based on the requirements of 10 CFR 50 and Regulatory Guide 1.26.

1.4.3 Class 1 system boundaries were developed based on the 10 CFR 50.2, Reactor Coolant Pressure Boundary definition.

1.4.4 Class 2 and Class 3 system boundaries were developed based on Regulatory Guide 1.26.

1.4.5, System boundary diagrams that depict the specific boundaries for the Class 1, Class .2, and Class 3 systems are provided'in Drawing No. 25203-26700 Shts 1 - 34. These are controlled documents in accordance with site procedures.

System pressure test boundaries are described in Section 5.

1.5 Inspection Program 1.5.1 Schedule Examinations for the fourth ten-year inspection interval are scheduled in accordance with Inspection Program B, as described in IWA-2400 of ASME Section XI, for the Class 1, Class 2, and Class 3 systems, components, and supports. Where the original schedule conflicts with other activities during the refueling outage,.

examinations may be rescheduled as long 'as -the requirements of IWX-2412 are met.

The sequence of examinations established for this inspection interval has been scheduled as close as practical to that of the previous inspection intervals. The duration betweenexaminations of the second interval and the third interval may exceed ten years due to the extended down time of the unit and interval extensions.

allowed by IWA-2430..

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MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL The Fourth Inspection Interval began on April 1, 2010 and is scheduled to end March 31, 2020.

The refueling outage schedule and corresponding inspection periods are listed-below:

Refueling Outage Year Scheduled Inspection Period 2R20 Spring 2011 1 2R21 Fall 2012 1 2R22 Spring 2014 2 2R23 Fall 2015 2 2R24 Spring 2017 3 2R25 Fall 2018 3 Examination Period Dates First Period - April 1,.2010 to March 31, 2013.

Second Period - April 1, 2013 to March 31, 2017 Third Period - April 1, 2017 to March 31, 2020 DNC may increase or decrease the inspection interval by as much as one year, provided subsequent inspection intervals are not altered by more than one year from the original pattern, as allowed by ASME Section XI, Article IWA-2400. IWA-2430(d)(2) allows performance of examinations in overlapping intervals, as long as code credit for the given exam is taken for only one of the intervals.

DNC may increase or decrease the inspection period by as much as one year to enable an inspection to coincide within a plant outage as allowed by ASME Section XI, IWA-2430(d)(1).

1.5.2 Additional Examinations NOTE: If in the expansion to perform additional examinations it is found that ASME Section XI requirements cannot be met in the performance of these examinations, then relief shall be sought as specified in Section 9 of this Program Manual.

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MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL A. Class 1 Additional examinations for Class 1 equivalent components (lWB) shall be in accordance with the requirements of IWB-2430 or the alternatiye requirements of Code Case N-586-1 in lieu of those in IWB-2430(a). The additional examination samples are defined as those items (welds, areas, or parts) in a particular examination category and item number. The initial sample is the sample scheduled for examination at a particular outage for ASME Section XI credit.

(1) Examinations performed in accordance with Table IWB-2500- 1, except for Examination Category B-P, that reveal flaws or relevant conditions exceeding the acceptance standards of Table lWB-3410-1 shall be extended to include additional examinations during the current outage. The additional examinations shall include an additional number of welds, areas, or parts included in the inspection item equal to the number of welds, areas, or parts included in the inspection item that were scheduled to be performed during the present inspection period. The additional examinations shall be selected from welds, areas, or parts of similar material and service. This additional selection may require inclusion of piping systems other than the one containing the flaws or relevant conditions.

(2) If the additional examinations required by 1WB-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of Table IWB-3410-1, the examinations shall be further extended to include additional examinations during the current outage. These additional examinations shall include the remaining number of welds, areas, or parts of similar material and service subject to the same type of flaws or relevant conditions.

(3) For the inspection period following the period in which the examinations of IWB-2430(a) or (b) were completed, the examinations shall be performed as originally scheduled' in accordance with IWB-2400.

(4) For steam generator tubing, additional examinations shall be governed by plant technical specifications.

(5) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of 1-7

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Table IWB-3410-1, additional examinations shall be performed, if determined necessary, based on an evaluation by DNC.

B. Class 2 Additional examinations for Class 2 equivalent components (1WC) shall be selected in accordance with IWC-2430 or the alternative requirements of Code Case N-586-1 in lieu of those in IWC-2430(a). The additional examination samples are defined as those items (welds, areas, or parts) in a particular examination category. The initial sample is the sample scheduled for examination at a particular outage for ASME Section XI credit.

(1) Examinations performed in accordance with Table IWC-2500- 1, except for Examination Category C-H, that reveal flaws or relevant conditions exceeding the acceptance standards of Table IWC-3410-1 shall be extended to include additional examinations during the current outage. The additional examinations shall include an additional number of welds, areas, or parts included in the inspection item equal to 20% of the number of welds, areas, or parts included in the inspection item that are scheduled to be performed during the interval. The additional examinations shall be selected from welds, areas, or parts of similar material and service. This additional selection may require inclusion of piping systems other than the one containing the flaws or relevant conditions.

(2). If the additional examinations required by IWC-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of Table IWC-3410-1, the examinations shall be further extended to include additional examinations during the current outage. These additional examinations shall include the remaining number of welds, areas; or parts of similar material and service subject to the same type of flaws or relevant conditions.

(3) For the inspection period following the period in which the examinations of IWC-2430(a) or (b) were completed, the examinations shall be performed as originally scheduled in accordance with IWC-2400.

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MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL (4) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWC-3410-1, additional examinations shall be performed, if determined necessary, based on an evaluation by DNC.

C. Class 3 Additional examinations for Class 3 equivalent components (IWD) shall be selected in accordance with IWD-2430 or the alternative requirements of Code Case N-586-1 in lieu of those in 1WD-2430(a). The additional examination samples are defined as those items (welds, areas, or parts) in a particular examination category. The initial sample is the sample scheduled for examination at a particular outage for ASME Section XI credit.

(1) Examinations performed in accordance with Table IWD-2500-1, except for Examination Category D-B, that reveal flaws or relevant conditions exceeding the acceptance standards of IWD-3000 shall be extended to include additional examinations during the current outage.

The additional examinations shall include an additional number of welds, areas, or parts included in the inspection item equal to 20% of the number of welds, areas, or parts included in the inspection item that are scheduled to be performed during the interval. The additional examinations shall be selected from welds, areas, or parts of similar material and service. This additional selection may require inclusion of piping systems other than the one containing the flaws or relevant conditions.

(2) If the additional examinations required by IWD-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of 1WD-3000, the examinations shall be further extended to include additional examinations during the current outage.. The extent of the additional examinations shall be determined by DNC based upon an engineering evaluation of the root cause of the flaws or relevant conditions. DNC's corrective actions shall be documented in accordance with IWA-6000.

(3) For the inspection period following the period in which the examinations of IWD-2430(a) or (b) were completed, 1-9

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL the examinations shall be performed as originally scheduled in accordance with IWD-2400.

(4) If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of lWD-3000, additional examinations shall be performed, if determined necessary, based on an evaluation by DNC.

D. Component Supports Additional examinations for Class 1, 2, 3 and MC component supports shall be selected in accordance with IWF-2430 or the alternative requirements of Code Case NL 586-1 in lieu of those in IWF-2430(a). The additional examination samples are defined as those component supports in a particular examination category. °The initial sample is the sample scheduled for examination at a particular outage for ASME Section XI credit.

NOTE: When an inservice examination of a component support reveals conditions described in ASME Section XI, and the component support has been analyzed and/or tested to substantiate its integrity for its intended service, and has been found to be acceptable and corrective measures have been performed to restore the support to its original condition, then additional support examinations are not required. (Reference ASME Inquiry XI-1-86-30R2.)

(1) Component support examinations performed in acdordance with Table IWF-2500-1 that reveal flaws or relevant conditions exceeding the acceptance standards of IWF-3400 shall be extended, during the current outage, to include the component supports immediately adjacent to those component supports for which corrective action is required. The additional examinations shall be extended, during the current outage, to include additional supports within the system, equal in number and of the same type and function as those scheduled for examination during the inspection period.

(2) When the additional examinations required by IWF-2430(a) reveal flaws or relevant conditions exceeding the acceptance standards of 1WF-3400, the examinations shall be further extended to include additional examinations during the current outage. These additional examinations 1-10

MILLSTONE POWER STATION UNIT 2 DNSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL shall include the remaining component supports within the system of the same type and function.

(3) When the additional examinations required by IWF-2430(b) reveal flaws or relevant conditions exceeding the acceptance standards of IWF-3400, the examinations shall be extended, during the current outage, to include all nonexempt supports potentially subject to the same failure modes that required corrective actions in accordance with IWF-2430(a) and (b). Also, these additional examinations shall include nonexempt component supports in other systems when the support failures requiring corrective actions indicate non-system-related support failure modes.

(4) When the additional examinations required by IWF-2430(c) reveal flaws or relevant conditions exceeding the acceptance standards of IWF-3400, DNC shall examine, during the current outage, those exempt component supports that could be affected by the same observed failure modes and could affect nonexempt components.

1.6 Responsibilities 1.6.1 Nuclear Engineering, ISI/Materials Group The ISI/Materials Group is responsible for the establishment and implementation of the ISI program. The following procedures detail the current responsibilities related to implementation of the ISI Program:

0 ER-AA-ISI-10, ASME Section XI Inservice Inspection Program e ER-AA-ISI-100, Dominion Inservice Inspection Program

• ER-AA-ISI-101, Dominion Inservice Inspection Program Preparation and Change Control Process 0 ER-AA-ISI-102, Dominion Inservice Inspection IDDEAL Software Suite

• ER-AA-SPT-10, ASME Section XI System Pressure Test Program 0 ER-AA-SPT-100, ASME Section XI System Pressure Test Program Fleet Implementation Requirements e ER-AA-ISI-RI-10, ASME Section XI Risk-Informed Inservice Inspection Program 0 ER-AA-ISI-RI-100, Dominion Risk-Informed Program 1-11

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

• ER-AA-ISI-RI-101, The Dominion Risk-Informed Period Update Process

" ER-AA-RRM-100, ASME Section XI Repair/Replacement Program Fleet Implementation Requirements The ISI Program Owner (DNC) retains primary responsibility for implementation of the ISI program.

1.7 Personnel Certification Personnel shall be qualified and certified to perform NDE in accordance with IWA-2300 and applicable site procedures.

Personnel performing VT-2 examinations shall be certified in accordance with IWA-2300.

1.8 Code of Federal Regulations Modifications. Limitations and Augmented Examination Requirements The following mandatory and optional Code of Federal Regulations Limitations, Modifications and Augmented Examination Requirements are included in 10 CFR 50.55a as published, on September 10, 2008 and amended on October 2, 2008. Only those 10 CFR 50.55a Limitations, Modifications and Augmented Examination Requirements, applicable to the 2004 Edition of Section XI nondestructive examination requirements for Class 1, 2, and 3 components and component supports, are listed.

These Limitations, Modifications and Augmented Examination Requirements were reviewed for inclusion in the ISI Program Manual and dispositioned as follows:

1.8.1 MPS2 will not implement the option in 10 CFR 50.55a(b)(2)(i) to utilize ASME Section XI, 1974 Edition with Addenda through Summer 1975 and ASME Section XI, 1977 Edition with Addenda through Summer 1978.

1.8.2 MPS2 will not utilize the option in 10 CFR 50.55a(b)(2)(ii) to examine Class 1 piping per ASME Section XI, 1974 Edition with the Summer 1975 Addenda.

1.8.3 As allowed by 10 CFR 50.55a(b)(2)(iii), steam generator tubing at MPS2 will be examined in accordance with plant Technical Specification 6.26 in lieu of Article IWB-2000.

1.8.4 MPS2.will not utilize the option in 10 CFR 50.55a(b)(2)(iv) to examine Class 2 piping per ASME Section XI, 1974 Edition with the Summer 1975 Addenda and the 1983 Edition through the Summer 1983 Addenda.

1-12

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 1.8.5 The MPS2 design includes a concrete containment subject to ASME Section XI, Subsection IWL requirements. Therefore the mandatory modification in, 10 CFR 50.55a(b)(2)(viii) applies to MPS2. Subsection IWL requirements and 10 CFR 50.55a requirements are addressed under Containment Inspection Program MP-24-CH-PROG.

1.8.6 The MPS2 design includes a metal containment subject to ASME Section XI, Subsection IWE requirements. Therefore the mandatory modification in 10 CFR 50.55a(b)(2)(ix) applies to MPS2. Subsection IWE requirements and 10CFR50.55a requirements are addressed under Containment Inspection Program MP-24-CII-PROG.

1.8.7 As required by 10 CFR 50.55a(b)(2)(x), MPS2 will apply the station Appendix B Quality Assurance Program of NQA- 1 to Section XI activities.

1.8.8 The requirements for performing underwater welding as stated in 10 CFR 50.55a(b)(2)(xii) are not addressed in the MPS2 ISI Program. Repair Replacement activities are addressed in Dominion Fleet Repair Replacement Program ER-AA-RRM- 100.

1.8.9 As allowed by 10 CFR 50.55a(b)(2)(xiv), for Appendix VIII Qualified Personnel, MPS2 will use the annual practice requirements in VII-4240 of Section XI Appendix VII in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training (when deemed appropriate) as discussed in 10 CFR 50.55a(b)(2)(xiv). When utilizing this option, the annual practice requirements will be performed on material or welds that contain cracks, or by analyzing prerecorded data from material or welds that contain cracks. All training will be completed no earlier than 6 months prior to performing ultrasonic examinations. The implementation of ASME Section XI, Appendix VII requirements is addressed in Section 12 of this ISI Program Manual and Dominion Fleet Procedure No. ER-AA-NDE-121.

1.8.10 MPS2 will not implement the optional Appendix VII specimen set and qualification provisions in paragraphs (b)(2)(xv)(A) to (b)(2)(xv)(M) in accordance with 10 CFR 50.55a(b)(2)(xv). The implementation of ASME Section XI, Appendix VII requirements is addressed in Section 12 of this ISI Program Manual and Dominion Fleet Procedure No. ER-AA-NDE-122. Note that the alternative requirements of Code Case N-695 will be utilized in lieu of those in Appendix VIII, Supplement 10. In addition, the alternative requirements of Code Case N-696 will be utilized in lieu of those in Appendix VIII, Supplements 2, 3 and 10.

1-13

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 1.8.11 As required by 10 CFR 50.55a(b)(2)(xvi)(A) and 10 CFR 50.55a(b)(2)(xvi)(B), MPS2 examinations performed from one side of a ferritic vessel weld and examinations performed from one side of a ferritic or stainless steel pipe will be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. The implementation of ASME Section XI, Appendix VIII requirements is addressed in Section 12 of this ISI Program Manual and Dominion Fleet Procedure No. ER-AA-NDE-122.

1.8.12 As required by 10 CFR 50.55a(b)(2)(xviii)(A), Level I and II NDE personnel at MPS2 will be recertified on a three year interval in lieu of the fiveyear interval specified in IWA-2314(a) and IWA-2314(b) of the 2004 Edition. The certification of visual examination personnel is addressed in Dominion Fleet Procedure No. ER-AA-NDE- 123.

1.8.13 As required by 10 CFR 50.55a(b)(2)(xviii)(B), paragraph IWA-2316 of the 2004 Edition will only be used to qualify personnel that observe for leakage during system leakage and hydrostatic tests conducted in accordance with IWA-521 1(a) and (b). The certification of visual examination personnel is addressed in Dominion Fleet Procedure No. ER-AA-NDE-123.

1.8.14 As required by 10 CFR 50.55a(b)(2)(xviii)(C), when qualifying visual examination personnel for VT-3 visual examinations under paragraph IWA-2317 of the 2004 Edition, the proficiency of the training must be demonstrated by administering an initial qualification examination and administering subsequent examinations on a three year interval. The certification of visual examination personnel is addressed in Dominion Fleet Procedure No. ER-AA-NDE- 123.

1.8.15 As required by 10 CFR 50.55a(b)(2)(xix), MPS2 will apply the rules in IWA-2240 of Section XI, 1997 Addenda in lieu of the IWA-2240 requirements in Section XI, 2004 Edition for the substitution of alternative examination methods.

1.8.16 As required by 10 CFR 50.55a(b)(2)(xx)(B), the NDE provision in IWA-4540(a)(2) of the 2002 Addenda of Section XI will be applied when performing system leakage tests after repair and replacement activities performed by welding or brazing on a pressure retaining boundary using the 2004 Edition of ASME Section XI. Repair Replacement activities are addressed in Dominion Fleet Repair Replacement Program Procedure No. ER-AA-RRM- 100.

1-14

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 1.8.17 As required by 10 CFR 50.55a(b)(2)(xxi)(A), the provisions of Table IWB-2500- 1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels, Item Nos. B3.120 and B3.140 of Inspection Program B in the 1998 Edition will be applied by MPS2.

As an option allowed by 10 CFR 50.55a(b)(2)(xxi)(A), a visual examination with enhanced magnification, that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1, 2004 Edition, with a limiting assumption on the flaw aspect ratio (i.e., a/1 = 0.5),

may be performed in place of an ultrasonic examination.

1.8.18 The requirements of 10 CFR 50.55a(b)(2)(xxi)(B) for Table IWB-2500-1, Examination Category B-G-2, Item B7.80, Pressure Retaining Control Rod Drive (CRD) Housing Bolting are not applicable to MPS2. The MPS2 design has threaded connections with canopy seals rather than Item No. B7.80 CRD bolting.

1.8.19 MPS2 will not implement the provision in IWA-2220, "Surface Examination" that allows the use of an ultrasonic examination method. The use of this provision is prohibited by 10 CFR 50.55a(b)(2)(xxii).

1.8.20 Prohibiting the use of IWA-4461.4.2 for eliminating mechanical processing of thermally cut surfaces as stated in 10 CFR 50.55a(b)(2)(xxiii) is not addressed in the MPS2 ISI Program. Repair Replacement activities are addressed in Dominion Fleet Repair Replacement Program Procedure ER-AA-RRM-100.

1.8.21 MPS2 will comply with 10 CFR 50.55a(b)(2)(xxiv) which prohibits the use of Appendix VIII and the supplements to Appendix VIII and Article 1-3000 in the 2002 Addenda through the 2004 Edition.

1.8.22 Prohibiting the use of IWA-4340 for the mitigation of defects by modification as stated in 10 CFR 50.55a(b)(2)(xxv) is not addressed in the MPS2 ISI Program. Repair Replacement activities are addressed in Dominion Fleet Repair Replacement Program ER-AA-RRM- 100.

1.8.23 Placing restrictions on the pressure testing of replaced components and appurtenances per IWA-4540(c) as stated in 10 CFR 50.55a(b)(2)(xxvi) is not addressed in the MPS2 ISI Program. Repair and replacement activities are addressed in Dominion Fleet Repair Replacement Program, ER-AA-RRM- 100.

1-15

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 1.8.24 10 CFR 50.55a(b)(2)(xxvii) modifies the requirements of 1WA-

.5242 for insulation removal from 17-4 PH or 410 stainless steel studs or bolts aged at a temperature, below 1100'F or those having a Rockwell, Method C hardness value above 30, and from A-286 stainless steel studs or bolts preloaded to 100,000 pounds per square inch or higher. These requirements will be implemented at MPS2.

1.8.25 For MPS2, the examination and testing of snubbers is performed in accordance with the optional criteria of 10 CFR 50.55a(b)(3)(y).

This permits the use of OM Code ISTD 2004 Edition in place of the requirements for snubbers in Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b). 10 CFR 50.55a(b)(3)(v) also requires that when using this permitted alternative that preservice and inservice examination of snubbers must be performed using the VT-3 method specified in IWA-2213.

1.8.26 MPS2 will not implement the option in 10 CFR 50.55a(g)(4)(iii) to perform surface.examinations on High Pressure Safety Injection System welds specified in Table IWB-2500-1, Examination Category B-J, Item'Numbers B9.20, B9.21, and B9.22.

1.8.27 The implementation schedule for ASME Section XI, Appendix VIII as stated in 10 CFR 50.55a(g)(6)(ii)(C) was met during the Third Interval at MPS2.

1.8.28 MPS2 will meet the criteria of 10 CFR 50.55a(g)(6)(ii)(D) for the performance of reactor vessel head inspections.

1.8.29 MPS2 will meet the criteria of 10 CFR 50.55a(g)(6)(ii)(E) for the performance of reactor coolant pressure boundary visual inspections.

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MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

2. INSPECTION PLAN 2.1 Class 1 Components 2.1.1 Exemption Basis The classification basis for Class 1 components is described in Section 1.4. The exemptions of IWB-1220 are then applied to determine the components' subject to the examination requirements of Table 1WB-2500-1. ASME Section XI, IWB-1220 exemptions for Class 1 components are listed below:

0 components that are connected to the reactor coolant system and are part of the reactor coolant pressure boundary, and that are of such a size and shape so that upon postulated rupture the resulting flow of coolant from the reactor coolant system under normal plant operating conditions is within the capacity of makeup systems that are operable from on-site emergency power. The emergency core cooling systems are excluded from the calculation of makeup capacity.

• components and piping segments Nominal Pipe Size (NPS) 1" and smaller, except for steam generator tubing; 0 components and piping segments which have one inlet and one outlet, both of which are NPS 1" and smaller;

• components2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the outside diameter (OD) of NPS 1" pipe 0 reactor vessel head connections and associated piping, NPS 2" and smaller, made inaccessible by control rod drive penetrations

• welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

An alternative to the ASME Section XI requirements for the Inservice Inspection of Class 1 piping, Categories B-J and B-F were implemented during the third interval based on the risk-informed technology developed in accordance with the Westinghouse Owners Group Topical Report, WCAP-14572, Revision 1-NP-A. The request to use this alternative was The exemptions from examination in IWC-1220 may be applied to those components permitted to be Class 2 in lieu of Class I by the regulatory authority having jurisdiction at the plant site.

2 For heat exchangers, the shell side and tube side may be considered separate components.

I 2-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL submitted to the Nuclear Regulatory Commission on November 10, 2003 with approval received on April 4, 2005.

The 1SI Program does not currently address the piping examination requirements that will result from the implementation of risk-informed technology. DNC is presently updating the risk-informed program for the examination of piping that will be' applicable to Class 1 piping, as a minimum. Upon development of the risk-informed program, and required supporting documents, a supplemental submittal to the fourth interval 1SI Program will be provided. This supplemental submittal will address the risk-informed scope and modifications to the examination requirements of affected piping components.

Applicable portions of the systems listed below are included in the Class 1 boundary and are depicted by drawings for Zones 1-01 through 1-40 which are listed in Table 2.5.

System pressure testing of Class 1 components is described in Section 5.0. Zone 999 is used for system pressure tests, but not shown on zone.boundary drawings.

2.1.2 Component/Piping Examinations The examination schedule for Class 1 components during the fourth inspection interval is included in the ISI database. Major Class 1 components and related information is proyided in the following sections.

A. Reactor Pressure Vessel (RPV)

RPV shell examinations are conducted from the internal surfaces utilizing remote examination equipment and techniques. Those areas of the bottom head which are obstructed from a complete inside diameter (ID) examination may be supplemented from the OD as practical. The flange to upper shell weld is examined from the upper shell ID and manually from the flange seal surface. The annular area surrounding the bolt holes is examined manually from the flange mating surface. Closure studs are manually examined utilizing volumetric and; alternative surface techniques, as applicable.. Alternative surface examination of the closure studs is in accordance with Category B-G-1, Note 7.

2-2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Core support lugs and the applicable portions of the vessel ID are examined visually utilizing a remote examination inspection system.

The RPV examinations are performed to meet the requirements of ASME Section XI.,

B. Reactor Pressure Vessel Closure Head The RPV closure head was replaced with a one-piece forging in 2005.

The peripheral control rod drive mechanism (CRDM) welds and extension tube welds and in-core instrumentation nozzle welds will be ultrasonically examined utilizing manual techniques from the OD or will be examined utilizing surface examination methods from the ID.

C. Steam Generators (Primary Side)

Applicable steam generator welds (e.g., the tube sheet to channel head weld and nozzle to vessel welds) are ultrasonically examined utilizing manual techniques from the OD surface. Primary manway bolting is visually examined.

The nozzle inner radius sections are ultrasonically examined utilizing manual techniques from the OD surface.

Alternatively, as allowed by 10 CFR 50.55a(b)(2)(xxi)(A), a visual examination with enhanced magnification may be performed.

Note: Examination Category B-D, Item number B3.140 of ASME Section XI, 1998 Edition applies, as required by 10 CFR 50.55a(b)(2)(xxi)(A).

D. Pressurizer Applicable pressurizer welds are ultrasonically examined utilizing manual techniques from the OD surface. Manway bolting is visually examined.

The support skirt-to-shell weld is examined utilizing surface examination methods. Based on the criteria in the 2004 2-3

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Edition of ASME Section XI, surface examination of the inside surface of the weld is no longer required.

The nozzle-to-shell welds are ultrasonically examined utilizing manual techniques from the OD surface.

The nozzle inner radius sections are ultrasonically examined utilizing manual techniques from the OD surface.

Alternatively, as allowed by 10 CFR 50.55a(b)(2)(xxi)(A), a visual examination with enhanced magnification may be performed.

Note: Examination Category B-D, Item number B3.120 of ASME Section XI, 1998 Edition applies as required by 10 CFR 50.55a(b)(2)(xxi)(A).

E. Pressure Boundary Piping An alternative to the ASME Section XI requirements for the ISIof Class 1 piping, Categories B-J and B-F were implemented during the third interval based on the risk-informed technology developed in accordance with the Westinghouse Owners Group Topical Report, WCAP-14572, Revision 1-NP-A. The request to use this alternative was submitted to the Nuclear Regulatory Commission on November 10, 2003 with approval received on April 1, 2005.

The ISI Program does not currently address the piping.

examination requirements that will result from the implementation of risk-informed technology. DNC is presently updating the risk-informed program for the examination of piping that will be applicable to Class 1 piping, as a minimum.

Upon development of the risk-informed program and required supporting documents, a supplemental submittal to the fourth 10-year 1SI Program will be provided. This supplemental submittal will address the risk-informed scope and modifications to the examination requirements of affected piping components.

MPS2 will meet the criteria of 10 CFR 50.55a(g)(6)(ii)(E) for the performance of reactor coolant pressure boundary visual inspections.

2-4

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL F. Valve Bolting Class 1 valve bolting is less than 2-inches diameter and is examined utilizing visual (VT-1) methods in accordance with Examination Category B-G-2.

Visual examination (VT-3) of the valve internal pressure boundary surfaces will be performed in accordance with Examination Category B-M-2 upon disassembly.

G. Welded Attachments Applicable welded attachments are examined utilizing volumetric or surface examination methods, as appropriate.

H. Reactor Coolant Pumps (RCPs)

The RCP studs and nuts are examined utilizing ultrasonic and visual (VT-1) examination methods, respectively. The pump interior and flange surface require visual examination (VT-3 and VT-i, respectively) in the event the pump is disassembled.

I. Steam Generator Eddy Current Testing (ECT)

The, steam generator tubing surveillance requirements are contained in the MPS2 Technical Specifications. The examination requirements are based on EPRI PWR Steam Generator Examination Guidelines, Rev. 7, dated October 2007.

2.2 Class 2 Components 2.2.1 Exemption Basis The classification basis for Class 2 components is described in Section 1.4. The exemptions of IWC- 1220 are then applied to determine the components subject to the examination requirements of Table IWC-2500-1. ASME Section XI, IWC-1221, IWC-1222 and IWC-1223 exemptions for Class 2 components are listed below:

2-5

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL IWC-1221: Components Within Residual Heat Removal (RHR),

Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) Systems or portions of systems:

a) For systems, except high pressure safety injection systems in pressurized water reactor plants:

• components and piping segments NPS 4" and smaller 0 components and piping segments which have one inlet and one outlet, both of which are NPS 4" and smaller

• components and piping segments which have multiple inlets or multiple outlets, whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4" pipe b) For high pressure safety injection systems in pressurized water reactor plants:

" components and piping segments NPS 11/2/2" and smaller

• components and piping segments which have one inlet and one outlet, both of which are NPS 11/22" and smaller

" components and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 11/22" pipe c) Vessels, piping, pumps, valves, other components, and component connections of any size in statically pressurized, passive (i.e., no pumps) safety injection systems of pressurized water reactor plants.

d) Piping and other components of any size beyond the last shutoff valve in open ended portions of systems that do not contain water during normal plant operating conditions.

IWC-1222: Components Within Systems or Portions of Systems Other Than RHR, ECC, and CHR Systems:

a) For systems, except auxiliary feedwater systems in pressurized water reactor plants:

• components and piping systems NPS 4" and smaller

" components and piping segments which have one inlet and one outlet, both of which are NPS 4" and smaller

" components and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4" pipe 2-6

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL b) For auxiliary feedwater systems in pressurized water reactor plants:

0 components and piping segments NPS 11/2/2" and smaller 0 components and piping segments which have one inlet-and one outlet, both of which are NPS 11/2/" and smaller e components and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional does not exceed the cross-sectional area defined by the OD of NPS 11/22" pipe c) Vessels, piping, pumps, valves, other components, and component connections of any size in systems or portions of systems that operate (when the system function is required) at a pressure equal to or less than 275 psig and at a temperature equal to or less than 200'F.

d) Piping and other components of any size beyond the last shutoff valve in open ended portions of systems that do not contain water during normal plant operating conditions (1) RHR, ECC, and CHR systems are the Residual Heat Removal, Emergency Core Cooling, and Containment Heat Removal Systems, respectively.

(2) For heat exchangers, the shell side and tube side may be considered separate components.

(3) Statically pressurized, passive safety injection systems of pressurized water reactor plants are typically called:

(a) accumulator tank and associated system (b) safety injection tank and associated system (c) core flooding tank and associated system IWC-1223: Inaccessible Welds a) Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by a guard pipe.

Applicable portions of the systems listed below are included in the Class 2 boundary and are depicted by drawings for Zones 2-01 through 2-36 which are listed in Table 2.5.

2-7

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL System pressure testing of Class 2 components is described in Section 5.0. Zone 999 is used for system pressure tests, but not shown on zone boundary drawings.

2.2.2 Component/Piping Examinations The examination schedule for Class 2 components during the fourth inspection interval is included in the ISI database. Major Class 2 components and related information are provided in the following sections.

A. Steam Generators (Secondary Side)

The steam generator welds and nozzle inner radius sections are examined utilizing manual or automated ultrasonic techniques from the vessel OD of one steam generator (SG "A") as permitted by Examination Categories C-A and C-B, (Notes 3 and 4, respectively).

B. Shutdown Heat Exchangers The shutdown heat exchanger welds are examined utilizing surface and ultrasonic examination methods as appropriate.

The examinations may be limited to one vessel ordistributed among the vessels as permitted by Examination Categories C-A and C-B, (Notes 3 and 4, respectively).

C. Pressure Retaining Bolting There are no components subject to the volumetric examination requirements of Examination Category C-D.

D. Pressure Retaining Welds in Piping Circumferential piping system welds are examined utilizing surface and volumetric examination methods as required by Examination Categories C-F-I and C-F-2.

Ultrasonic examination of thin-walled material less than 0.375 inch thickness, is excluded from NDE requirements under ASME Section XI Table IWC-2500-1, but is part of the weld selection count in Table 2.1. A 7.5 percent sample of welds in the High Pressure Safety Injection, Shutdown. Cooling, and 2-8

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Charging systems has been scheduled for examination in accordance with Table 2.3 (see Program Section 2.5.2).

2.3 Class 3 Components 2.3.1 Exemption Basis In accordance with IWD-1210, examination requirements of Subsection IWD only apply to pressure retaining components and their welded attachments on Class 3 systems in support of the following functions:

0 Reactor shutdown 0 Emergency core cooling

• Containment heat removal

• Atmosphere cleanup 0 Reactor residual heat removal

• Residual heat removal for spent fuel storage pool The classification basis for Class 3 components is described in Section 1.4. The exemptions of IWD-1220 are then applied to determine the components subject to the examination requirements of Table IWD-2500-1. ASME Section XI, IWD-1220 exemptions for Class 3 components are listed below:

IWD-1222: Components Exempt from Examination

• components 1 and piping segments NPS 4" and smaller

• components and piping segments which have one inlet and one outlet, both of which are NPS 4" and smaller

• components' and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4" pipe

• components that operate at a pressure of 275 psig or less and at a temperature of 200'F or less in systems (or portions of systems) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling

• welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

For heat exchangers, the shell side and tube side may be considered separate components.

2-9

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Applicable portions of the systems listed below are included in the Class 3 boundary and are depicted by drawings for Zones 3-01 through 3-19 which are listed in Table 2.5.

System pressure testing of Class 3 components is described in Section 5.0. Zone 999 is used for system pressure tests, but not shown on zone boundary drawings.

2.3.2 Component/Piping Examinations The examination schedule for Class 3 components during the fourth inspection interval is included in the ISI database.

Class 3 welded attachments require visual examination (VT-1) in accordance with Table-1WD-2500- 1, Examination Category D-A.

2.4 Component Supports 2.4.1 Exemption Basis Component supports to be examined shall be the supports of the Class 1, Class 2, Class 3 and Class MC components not exempted under IWB-1220, IWC-1220, 1WD-1220 and IWE-1220. Refer to Subsections 2.1 through 2.3' for information related to Class 1, 2, and 3 selection basis. Note that the MPS2 design does not include any Class'MC component supports requiring examination. The exemptions of IWF- 1230 are applied to determine the components subject to the examination requirements of Table 1WF-2500- 1.

ASME Section XI, IWF-1230 exemptions for Component Supports are listed below:

IWF-1230: Supports, Exempt from Examination Supports exempt from the examination requirements of IWF-2000 are those connected to piping and other items exempted from volumetric, surface, or VT-I or VT-3 visual examination by IWB-1220, lWC-1220, IWD-1220, and IWE-1220. In addition, portions of supports that are inaccessible by being encased in concrete, buried underground, or encapsulated by guard pipe are also exempt from the examination requirements of lWF-2000.

2.4.2 Examinations The examination schedule for component supports during the fourth inspection interval is included in the ISI database.

2-10

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Component and piping supports require visual examination (VT-3) in accordance with Table-IWF-2500- 1, Examination Category F-A.

2.5 Augmented Examinations The augmented examinations described in this section are summarized in Table 2.3.

2.5.1 Reactor Coolant Pump Flywheels Reactor coolant pump flywheels are examined in accordance with Technical Specification 6.22 based on the Safety Evaluation Report (SER) for CE Topical Report SIR-94-080A and Amendment No. 264 to the MPS2 Technical Specifications. Based on the recommendations of CE Topical Report SIR-94-080A, each RCP flywheel receives an in-place ultrasonic examination or a surface examination if the flywheel is disassembled, once every 10 years.

2.5.2 Class 2 Excluded Systems Thin wall piping that is excluded from examination by the notes in Table IWC-2500-1 will be examined by MPS2. The examination population is based on a 7 1/2 percent criteria similar to the non-exempt population. This augmented program includes 45 additional welds that will be subjected to a volumetric examination. These welds will be selected on a prorated sampling plan spread out among the High Pressure Safety Injection, Shutdown Cooling that includes the Low Pressure Safety Injection and the Charging System. These systems are referred to in the Code as the Residual Heat Removal, Emergency. Core Cooling and Containment Heat Removal Systems.

2-11

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 2.5.3 Reactor Vessel Head Penetrations Effective December 29, 2008, the mandatory examination requirements of Code Case N-729-1 apply replacing the requirements of NRC Order EA-03-009.

• 100% bare metal visual examination of all penetrations required every third refuel outage or five calendar years, whichever is less. The examination may be performed with the system depressurized.

• Volumetric / Surface examination for all nozzles required every inspection interval (nominally ten calendar years).

2.5.4 Additional Examinations.for Class 1 Alloy 600/82/182 Pressure Retaining Welds Effective January 1,' 2009, the mandatory examination requirements of Code Case N-722 apply. Examination requirements and frequency are identified in Table 1 of this Code Case.

2.5.5 Examination of Repaired Core Barrel Support Lugs Visual (VT-1) examinations will be performed on repaired core barrel support lugs CBSL #4 and CBSL #5. These lugs will be examined during the RPV ten-year vessel examinations.

2.5.6 Visual Examination of 0 Degree Core Barrel Alignment Key Gap Visual examinations will be performed on 0 degree core barrel alignment key gap once every interval in conjunction with the ten-year vessel examination.

2-12

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 2.6 Description of ISI Schedule Summary The fourth ten-year ISI schedule tables contain component examination information for MPS2. The, inspection schedule tables are prepared from the computerized database utilized to schedule and track ASME Section XI and augmented components for examination.

2.6.1 ASME Section XI Inservice Inspection Examination Summary Tables The Class 1, 2 and 3 components and component supports requiring examination per ASME Section XI are shown in Table 2.1. The ASME Section XI Inservice Inspection Examination Summary Table 2.1 provides the following information:

• Examination Category This column lists the examination category as identified in ASME Section XI, Tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

• Item Number This column lists the Code Item No. as identified in ASME Section XI, Tables 1WB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

0 Description of Components Examined This column lists a description of the components examined as identified in ASME Section XI, Tables 1WB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1.

• Number of Components This column lists the total population of components potentially subject to examination. The number of components actually examined during the inspection interval will be based upon the Code requirements for the subject item number.

12-13

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

• Examination Method(s)

The column lists the examination method(s) required by ASME Section XI, Tables 1WB-2500-1, IWC-2500-l, IWD-2500-1, and IWF-2500-1.

Request Number(s)

This column provides a listing of applicable requests for alternatives or relief requests. If a request number is identified, see the corresponding Request for Alternative or Relief Request in Section 9.

2.6.2 Risk-Informed Inservice Inspection Examination Summary Table The Class 1 piping welds which will require examination upon completion of the risk-informed program update are shown in Table 2.2. The-Risk-Informed Inservice Inspection Examination Summary Table 2.2 provides the following information:

• Examination Category This column lists the examination category.

• Item Number This column lists the Code Item No.

• Parts Examined This column provides a description of the elements to be examined, which are classified by their potential degradation mechanism.

• Number of Components This column lists the total population of components that are subject to examination and will be populated upon completion of the risk-informed program update.-

• Examination Method(s)

The column lists the examination method(s) required.

2-14

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Request Number(s)

This column provides a listing of applicable requests for alternatives or relief requests. If a request number is identified, see the corresponding Request for Alternative or Relief Request in Section 9.

2.6.3 Augmented Examination Summary Table MPS2 components requiring augmented examinations are shown in Table 2.3. The Augmented Examination Summary Table 2.3 provides the following information:

Program Section This column lists the section of this ISI plan that addresses the subject augmented examinations.

• Description of Parts or Components Examined This column provides a description of the elements to be examined.

• Database Item No.

This column provides a reference to the Item No. used for the augmented examination in the ISI database.

Examination Method(s)

The column lists the examination method(s) required in accordance with the implementing augmented examination criteria.

System This column provides a reference to the system that the components are in.

2-15

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Zone No. or Size This column provides a reference to the Zone No. that the components are in or the line size.

Total Item Nos.

This column lists the total population of components potentially subject to examination. The number of components actually examined during the inspection interval will be in accordance with implementing augmented examination criteria.

Comments This column provides any comments associated with the item.

2.7 Procedures NDE procedures are listed in Table 2.4. Other NDE procedures may be utilized provided they are reviewed and accepted in accordance with applicable station procedure.

2.8 Examination Zone Listing The inspection plan"has been divided into areas of interest identified as "zones". Each zone is defined by a drawing which identifies and locates the components requiring examination for the subject zone (except Zone.

999 is not shown on drawings, but is discussed in Section 5.0).

A listing of examination zones and their associated drawings is provided in Table 2.5.

2-16

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Shell Welds B 1.1 I Circumferential 2 Volumetric B 1.12 Longitudinal 9 Volumetric B-A Head Welds (see Note 1)

B 1.21 Circumferential 2 Volumetric Retaining B 1.22 Meridional 6 Volumetric Welds in B 1.30 Shell-to-Flange Weld I Volumetric Reactor Vessel B 1.40 Head-to-Flange Weld (see Note 1) 0 Volumetric and Surface B 1.51 Repair Welds in the Beltline Region N/A Volumetric 2-17

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Pressurizer Shell to Head Welds B2.11 Circumferential 2 Volumetric B2.12 Longitudinal 0 Volumetric Pressurizer Head Welds B2.21 Circumferential 0 Volumetric B2.22 Meridional 0 Volumetric Steam Generator (Primary Side) Head Welds B-B B2.31 Circumferential 4 Volumetric Pressure Retaining B2.32 Meridional 0 Volumetric Welds in Vessels Other Than Reactor B2.40 Tubesheet to Head Weld 2 Volumetric Vessels Heat Exchangers (Primary Side) - Head Welds B2.51 Circumferential 0 Volumetric B2.52 Meridional 0 Volumetric Heat Exchangers (Primary Side) - Shell B2.60 Tubesheet-to-Head Welds 0 Volumetric B2.70 Longitudinal Welds 0 Volumetric B2.80 Tubesheet-to-Shell Welds 0 Volumetric 2-18

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

[ Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Reactor Vessel B3.10 Nozzle-to-Vessel Welds N/A Volumetric B3.20 Nozzle Inside Radius Section (Examined with B3.90) N/A Volumetric Pressurizer B3.30 Nozzle-to-Vessel Welds N/A Volumetric B-D B3.40 Nozzle Inside Radius Section N/A. Volumetric/

Full Penetration VT-i Visual Welded Nozzles in Vessels, Steam Generator (Primary Side)

Inspection B3.50 Nozzle-to-Vessel Welds. N/A Volumetric Program A B3.60 Nozzle Inside Radius Section N/A Volumetric/

VT-I Visual Heat Exchangers (Primary-Side)

B3.70 Nozzle-to-Vessel Welds N/A Volumetric B3.80 Nozzle Inside Radius Section N/A Volumetric 2-19

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 21 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Reactor Vessel "

B3.90 Nozzle-to-Vessel Welds 6 Volumetric B3.100 Nozzle Inside Radius Section (Examined with B3.90) 6 Volumetric Pressurizer B3. 110 Nozzle-to-Vessel Welds 0 Volumetric B-D B3.120 Nozzle Inside Radius Section 5 Volumetric!

Full PenetrationVTiisa _ VT-1I Visual Welded (See Note 2)

Nozzles in Vessels, Steam Generator (Primary Side)

Inspection B3.130 Nozzle-to-Vessel Welds 6 Volumetric Program B B3.140 Nozzle Inside Radius Section 6 Volumetric/

VT-i Visual (See Note 2)

Heat Exchangers (Primary Side)

B3.150 Nozzle-to-Vessel Welds 0 Volumetric B3.160 Nozzle Inside Radius Section 0 Volumetric 2-20

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Reactor Vessel B5.10 NPS 4" or Larger, Nozzle-to-Safe End Butt Welds B5.20 Less than NPS 4" Nozzle-to-Safe End Butt Welds B5.30 Nozzle-to-Safe End Socket Welds Pressurizer B-F B5.40 NPS 4" or Larger, Nozzle-to-Safe End Butt Welds See Note 3 See Note 3 Pressure B5.50 Less than NPS 4" Nozzle-to-Safe End Butt Welds and Table 2.2 and Table 2.2 Retaining B5.60 Nozzle-to-Safe End Socket Welds (For All Item (For All Item Dissimilar Numbers) Numbers)

Metal Welds Steam Generator In Vessel B5.70 NPS 4" or Larger, Nozzle-to-Safe End Butt Welds Nozzles B5.80 Less than NPS 4" Nozzle-to-Safe End Butt Welds B5.90 Nozzle-to-Safe End Socket.Welds Heat Exchangers B5.100 NPS 4" or Larger, Nozzle-to-Safe End Butt Welds B5.1 10 Less than NPS 4", Nozzle-to-Safe End Butt Welds B5.120 Nozzle-to-Safe End Socket Welds 2-21

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Reactor Vessel B6.10 Closure Head Nuts 54 VT-1 Visual B6.20 Closure Studs 54 Volumetric B6.40 Threads In Flange 54 Volumetric B6.50 Closure Washers, Bushings 54 VT-1-Visual Pressurizer B-G-1 B6.60 Bolts and Studs 0 Volumetric Pressure Retaining B6.70 Flange Surface, when connection disassembled 0 VT-1 Visual Bolting B6.80 Nuts, Bushings, and Washers 0 VT-1 Visual Greater Than 2 in. In Steam Generators Diameter B6.90 Bolts and Studs 0 Volumetric B6.100 Flange Surface, when connection disassembled 0 VT-I Visual B6.1 10 Nuts, Bushings, and Washers 0 VT-1 Visual Heat Exchangers B6.120 Bolts and Studs 0. Volumetric B6.130 Flange Surface, when connection disassembled 0 VT-1 Visual B6.140 Nuts, Bushings, and Washers 0 VT-1 Visual 2-22

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request-Category Number Components Method(s) Number(s)

Piping B6.150 Bolts and Studs 0 Volumetric B6.160 Flange Surface, when connection is disassembled 0 VT-i Visual B6.170 Nuts, Bushings, and Washers 0 VT- I Visual B-G-1 Pressure Retaining Pumps Bolting B6.180 Bolts and Studs 4 sets of 16 Volumetric 2 in an B6.190 Flange Surface, when connection is disassembled 4 VT-i Visual Diameter (cont'd) B6.200 Nuts, Bushings, and Washers 4 sets of 16 VT-I Visual Valves B6.210 Bolts and Studs 0 Volumetric B6.220 Flange Surface, when connection disassembled 0 VT-I Visual B6.230 Nuts, Bushings, and Washers 0 VT-1 Visual 2-23

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Reactor Vessel B7.10 Bolts, Studs, and Nuts 10 sets VT-1 Visual (40 Studs &

80 Nuts)

Pressurizer B7.20 Bolts, Studs, and Nuts 2 sets (20 Studs VT-i Visual

& Nuts for Manway, B-G-2 10 Studs &

Pressure Nuts for Vent Retaining Port)

Bolting, Steam Generator 2 in. and Less In B7.30 Bolts, Studs, and Nuts 4 sets VT-I Visual Diameter Heat Exchangers B7.40 Bolts, Suds, and Nuts 0 VT-1 Visual Piping B7.50 Bolts, Studs, and Nuts 0 VT-1 Visual Pumps B7.60 Bolts, Studs, and Nuts 4 VT-1 Visual Valves B7.70 Bolts, Studs, and Nuts 60 sets VT-I Visual 2-24

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

NPS 4" or Larger B9.1 I1 Circumferential Welds Less Than NPS 4" See Note 3 See Note 3 B9.21 Circumferential Welds Other Than PWR High Pressure Safety and Table 2.2 and Table 2.2 B-J Injection Systems (For All Item (For All Item Pressure Retaining B9.22 Circumferential Welds of PWR High Pressure Safety Injection Numbers) Numbers)

Welds in Piping Systems Branch Pipe Connection Welds B9.31 NPS 4" or Larger B9.32 Less Than NPS 4" B9.40 Socket Welds Pressure Vessels 10.10 Welded Attachments .3 Surface B-KB Welded Attachments Piping for Class I B I0.20 Welded Attachments Surface Vessels, Piping,. Pumps Pumps, and Valves BI0.30 Welded Attachments 16 Surface Valves B 10.40 Welded Attachments 0 Surface 2-25

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

B-L-1 Pumps Pump Casing Welds B12.10 Pump Casing Welds 8 VT-1 Visual B-L-2 Pumps Pump4VT3Vsa Casings B 12.20 Pump Casing VT-3 Visual B-M-1 Valves Valve Body Welds B 12.30 Valves, Less than NPS 4", Valve Body Welds 0 Surface Valves B-M-2 Valve Body B 12.50 Valves Exceeding NPS 4", Valve Internal Surfaces 3 groups (18 VT-3 Visual valves total)

B-N-1 Reactor Vessel Interior of B13.10 Vessel Interior 7 VT-3 Visual Reactor Vessel 2-26

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Reactor Vessel (BWR)

Interior Attachments Within Beltline Region N/A VT-i Visual B-N-2 B 13.20 Welded Core B 13.30 Interior Attachments Beyond Beltline Region N/A VT-3 Visual Support Structures B 13.40 Core Support Structure N/A VT-3 Visual and Interior Attachments to Reactor Vessel (PWR)

Reactor Vessels B 13.50 Interior Attachments Within Beltline Region 12 VT-I Visual B 13.60 Interior Attachments Beyond Beltline Region 10 VT-I Visual B-N-3 Reactor Vessel RemSuppor B 13.70 Core Support Structure 33 VT-3 Visual Core Support Structures Reactor Vessel (BWR)

B-O B14.10 Welds in CRD Housing N/A Volumetric

.or Surface Pressure Retaining Reactor Vessel (PWR)

Welds in Control Rod B 14.20 Welds in CRD Housing 28 Volumetric Housings Peripheral or Surface Housings

-B 14.21 Welds in In-Core Instrumentation Nozzle Housings >NPS 2" 8 Volumetric or Surface 2-27

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

B-P All Pressure B15.10 Pressure Retaining Components Class 1 VT-2 Visual RR-04-02 Retaining Pressure RR-04-04 Components Boundary RR-04-08 N/A Volumetric B-Q B 16.10 Steam Generator Tubing in Straight Tube Design Steam Generator B 16.20 Steam Generator Tubing in U-Tube Design 2 Steam Volumetric TS 6.26 Tubing Generators C-A CI.10 Shell Circumferential Welds 12 Volumetric Pressure Retaining Welds C1.20 Head Circumferential Welds 4 Volumetric in Pressure Vessels C1.30 Tubesheet-to-Shell Weld 4 Volumetric 2-28

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination '] Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Nozzles in Vessels < 1/2in. Nominal Thickness C2.11 Nozzle-to-Shell (Nozzle to Head or Nozzle toNozzle) Weld 0 Surface Nozzles Without Reinforcing Plate in Vessels > 11/2 in.

Nominal Thickness C2.21 Nozzle-to Shell (Nozzle to Head or Nozzle to Nozzle) Weld 8 Volumetric C-B and Surface Pressure Retaining C2.22 Nozzle Inside Radius Section 4 Volumetric Nozzle Welds in Vessels Nozzles With Reinforcing Plate in Vessels > 1/2 in. Nominal Thickness C2.31 Reinforcing Plate Welds to Nozzle and Vessel 0 Surface C2.32 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) Welds 0 Volumetric When Inside of Vessel is Accessible C2.33 Nozzle-to-Shell (Nozzle to Head or Nozzle to Nozzle) Welds 0 VT-2 Visual When Inside of Vessel'is Inaccessible 2-29

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Pressure Vessels C-C C3.10 Welded Attachments 16 Surface Welded Attachments Ppn C3.20 Welded Attachments 37 Surface for Class 2 Vessels, Pumps Vessels, C3.30 Welded Attachments 0 Surface Piping, Pumps, Vle and Valves Valves C3.40 Welded Attachments 0 Surface Pressure Vessels C4.10 Bolts and Studs 0 Volumetric C-D Piping Pressure Retaining C4.20 Bolts and Studs 0 Volumietric Bolting Greater than 2 Pumps in. In Diameter C4.30 Bolts and Studs 0 Volumetric Valves C4.40 Bolts and Studs 0 Volumetric 2-30

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT iSI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Piping Welds > 3/8 in. Nominal Wall Thickness for Piping >

NPS 4" C5.11 Circumferential Weld 752 Volumetric C-F-I and Surface Pressure Retaining Piping Welds > 1/5 in. Nominal Wall Thickness Welds in for Piping > NPS 2" and < NPS 4" Austenitic C5.21 Circumferential Weld 108 Volumetric Stainless SteelanSufc and Surface or High Alloy Piping C5.30 Socket Welds 147 Surface Piping Branch Connections of Branch Piping > NPS 2" C5.41 Circumferential Weld 17 Surface 2-31

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

Pipin2 Welds > 3/8 in. Nominal Wall Thickness for Piping >

NPS 4" C5.51 Circumferential Weld 215 Volumetric and. Surface C-F-2 Pressure Piping Welds > 1/5 in. Nominal Wall Thickness for Piping >

Retaining NPS 2" Welds C5.61 Circumferential Weld 0 Volumetric in Carbon or and Surface Low Alloy Steel Piping

• C5.70 Socket Welds 0 Surface Pipe Branch Connections of Branch Piping > NPS 2" C5.81 Circumferential Weld 22 Surface 2-32

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

C-G Pumps Pressure C6.10 Pump Casing Welds 0 Surface Retaining Welds in Valves Pumps and Valves C6.20 Valve Body Welds 0 Surface C-H All Pressure C7.10 Pressure Retaining Components Class 2 VT-2 Visual Retaining Pressure Components Boundary Pressure Vessels D1.10 Welded Attachments 0 VT-1 Visual D-A Welded ping Attachments D1.20 Welded Attachments 0 VT-I Visual for Class 3 Vessels, Pumps Piping, Pumps D1.30 Welded Attachments VT-1 Visual and Valves Valves D 1.40 Welded Attachments 0 VT-1 Visual 2-33

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.1 MPS2 CLASS 1, 2, 3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Examined Number of Examination Request Category Number Components Method(s) Number(s)

D-B All Pressure D2.10 Pressure Retaining Components Class 3 VT-2 Visual Retaining Pressure Components Boundary Fl .10 Class I Piping Supports 201. VT-3 Visual F-A F1.20 Class 2 Piping Supports 366 VT-3 Visual Supports (See Note 4) F1.30 Class 3 Piping Supports 851 VT-3 Visual )

F1.40 Supports Other Than Piping Supports 71 VT-3 Visual (Class 1, 2, 3, and MC)

Notes:

1. The MPS2 RPV head was replaced with a one-piece forging in 2005.

2. In accordance with 10 CFR 50.55a(b)(2)(xxi)(A), the 1998 Edition of ASME Section XI without Addenda must beapplied for Examination Category B-D, Item Nos. B3.120 and B3.140. Although the 1999 Addenda eliminated Code Item Nos. B3.120 and B3.140, these Code Item Numbers were still active in the 1998 Edition, and therefore are included in the MPS2 ISI Program Plan. However, per 10 CFR 50.55a(b)(2)(xxi)(A), a visual examination with enhanced magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw criteria in Table IWB-3512-1 may be performed in place of an ultrasonic examination.

.3. During the third ten-year interval, MPS2 implemented a risk-informed inservice inspection program for Class 1 piping welds (i.e.,

Examination Categories B-F and B-J). The risk-informed program is currently being updated and Table 2.2 will be populated upon completion of this update.

4. The examination and testing of snubbers is performed in accordance with the 2004 OM Code ISTD as permitted by 10CFR50.55a(b)(3)(v).

Preservice and inservice examination of snubbers is performed utilizing the VT-3 examination method specified in IWA-2213.

2-34

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.2 MPS2 CLASS 1 RISK-INFORMED ISI EXAMINATION

SUMMARY

Examination Item Number, of Examination Request Category Number Ptx nComponents Method(s) Number To be populated Vlmti R1.11 Elements Subject to Thermal Fatigue following Volumetric completion of Risk-RI. 12- ' Fatigue Subject to High CycleMechanical Elements Informed Program Visual, VT-2

_Update R1.13 Elements Subject to Erosion Cavitation Volumetric R1.14 Elements Subject to Crevice Corrosion Volumetric R14 Cracking R 1.15 Elements Subject to Primary Water Stress Volumetric Corrosion Cracking (PWSCC)

Elements Subject to Intergranular or R-A R1.16 Transgranular Stress Corrosion Cracking Volumetric (IGSCC, TGSCC)

Elements Subject to Localized Visual, Ri.17 Microbiological Corrosion VT-3 on Internal

[Microbiologically-Induced Corrosion Surfaces,

• (MIC) or Pitting] or Volumetric Elements Subject to Flow Accelerated R1.18 Corrosion (FAC) Per FAC Program Elements Subject to External Chloride R1. 19 Surface

- -_StressCorrosion Cracking (ECSCC)

R1.20 Elements Not Subject to a Damage Volumetric Mechanism 2-35

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.3 MPS2 FOURTH INTERVAL AUGMENTED EXAMINATION

SUMMARY

Program Description of Parts or Database Exam System Zone No. Total No. Comments Section Components Examined Item No. Method or Size Items Section 2.5.1 Reactor Coolant Pump Flywheels RG 1.14 Volumetric RCS 1-36, 1-37, 5 T.S. 6.22 or Surface 1-38, 1-39 Section 2.5.2 Class 2 Excluded Piping Welds C5.11 Volumetric HSI, Various 647 SDC, CHG Section 2.5.3 Reactor Vessel Head Penetrations B4.30 Bare Metal RPV 1-2 1 (RPV Head) Code Case Visual (VE) N-729-1 B4.40 Vol. & 78 (Penetrations)

Surface Section 2.5.4 Class 1 Alloy 600/82/182 B 15.100 Visual (VE) RCS 1-01, 1-03, 3 (B 15.100) Code Case Pressure Retaining Welds B 15.135 1-04, 1-05 8 (B 15.135) N-722 B15.205 and 1-07 12 (B15.205)

B15.210 through 1 (B 15.210)

B15.215 1-14 9 (B 15.215) 33 (Total)

Section 2.5.5 Examination of Repaired Core N/A Visual RCS 1-01 2 Barrel Support Lugs (VT- 1)

Section 2.5.6 Visual Examination of 0 Degree Aug Visual RPV 1-01 1 Core Barrel Alignment Key Gap 2-36

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.4 LIST OF EXAMINATION PROCEDURES Procedure No. Application ER-AA-NDE-PT-300 Liquid Penetrant Examination ER-AA-NDE-MT-200 Magnetic Particle Examination ER-AA-NDE-VT-600 Enhanced VT- I Visual Examination of Nozzle Inside Radius Sections of Steam Generator Nozzles ER-AA-NDE-VT-601 VT-i Visual Examination MP-VE-2 VT-2 Visual Examination ER-AA-NDE-VT-602 VT-2 Visual Examination ER-AA-NDE-VT-603 VT-3 Visual Examination ER-AA-NDE-VT-607 VE Examination of Class 1 Alloy 600/82/182 Welds MP-VE-4 Remote Visual Examination of the Reactor Vessel Internals ER-AA-NDE-UT-702 Ultrasonic Examination Ferritic Vesel Welds Greater than 2" in Thickness ER-AA-NDE-UT-703 Ultrasonic Examination of Vessel Welds 2" and Less in Thickness ER-AA-NDE-UT-800 Appendix VIII Qualified Equipment Tables for PDI ER-AA-NDE-UT-801 Ultrasonic Examination of Ferritic Piping Welds ER-AA-NDE-UT-802 Ultrasonic Examination of Austenitic Piping Welds ER-AA-NDE-UT-803 Ultrasonic Through Wall Sizing of Pipe welds ER-AA-NDE-UT-805 Ultrasonic Straight Beam Examination of Studs and Bolts.

ER-AA-NDE-UT-808 Ultrasonic Examination of Weld Overlaid Welds ER-AA-NDE-UT-810 Ultrasonic Examination of Dissimilar Metal Welds ER-AA-NDE-UT-816 Manual Phased Array Examination of Weld Overlays MP-PDI-UT-4 Ultrasonic Examination of Studs from the Heater Hole MP-XT-4 Weld Marking Datum Points and Identifications MP-UT-6 Ultrasonic Examination of RCP Flywheels MP-UT-42 Ultrasonic Examination of Reactor Coolant Loop Stop Valve Stems 2-42

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.4 LIST OF EXAMINATION PROCEDURES Procedure No. Application MP-UT-46 Ultrasonic Examination of Steam Generator Primary Nozzle and Feedwater Nozzle Inner Radius Sections.

VPROC-NDE02-012 (Vendor) Ultrasonic Examination of Pressurizer Spray, Relief and Safety Nozzle Inner Radius Sections VPROC- ISIO1-001 (Vendor) Radiographic Examination of Welds 2-43

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.5 EXAMINATION ZONE LISTING Zone Class 1 Systems Isometric Drawing No.

No. R 1-01 Reactor Pressure Vessel 25203-29523, 29525, 29526, and 29527 Sh 1 1-02 RPV Closure Head 25203-29527 Sh 2 1-03 Steam Generator 1 Primary Side 25203-29527 Sh 3 1-04 Steam Generator 2 Primary Side 25203-29527 Sh 4 1-05 Hot Leg, Stm. Gen. #1 to RPV 25203-29527 Sh 5 1-06 Hot Leg, Stm. Gen. #2 to RPV 25203-29527 Sh 6 1-07 Cold Leg. Stm. Gen #1 to RCP IA 25203-29527 Sh 7 1-08 Cold Leg, RCP IA to RPV 25203-29527 Sh 8 1-09 Cold Leg, Stm. Gen. #1 to RCP 1B 25203-29527 Sh 9 1-10 Cold Leg, RCP 1B to RPV 25203-29527 Sh 10 1-11 Cold Leg, Stm. Gen. #2 to RCP 2A 25203-29527 Sh 11 1-12 Cold Leg, RCP 2A to RPV 25203-29527 Sh 12 1-13 Cold Leg, Stm. Gen. #2 to RCP 2B 25203-29527 Sh 13 1-14 Cold Leg, RCP 2B to RPV 25203-29527 Sh 14 1-15 Pressurizer Weld Designations 25203-29527 Sh 15 1-16 Pressurizer Surge Line 25203-29527 Sh 16 1-17 Loop IA Safety Injection System 25203-29527 Sh 17 (inside containment) 1-18 Loop lB Safety Injection System 25203-29527 Sh 18 1-19 Loop.2A Safety Injection System 25203-29527 Sh 19 1-20 Loop 2B Safety Injection System 25203-29527 Sh 20 1-21 Shutdown Cooling 25203-29527 Sh 21 1-22 Loop 1B Pressurizer Spray 25203-29527 Sh 22 1-23 Loop IA Pressurizer Spray 25203-29527 Sh 23 1-24 Pressurizer Spray at Pressurizer 25203-29527 Sh 24 1-25 Pressurizer Safety Valve Piping 25203-29527 Sh 25 26 Pressurizer Relief Valve Piping 25203-29527 Sh 26 1-27 Auxiliary Pressurizer Spray 25203-29527 Sh 27 1-28 Charging Line to Loop 2A 25203-29527 Sh 28 1-29 Letdown Line 25203-29527 Sh 29 1-30 Loop lB Cold Leg Drain 25203-29527 Sh 30 1-31 Loop 1 Hot Leg Drain 25203-29527 Sh 31 1-32 Loop 1A Cold Leg Drain 25203-29527 Sh 32 1-33 Loop 1A Charging Line 25203-29527 Sh 33 1-34 Loop 2A Cold Leg Drain 25203-29527 Sh 34 1-35 Loop 2B Cold Leg Drain 25203-29527 Sh 35 2-44

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.5 EXAMINATION ZONE LISTING Zone Class 1 Systems Isometric Drawing No.

No. _

1-36 Reactor Coolant Pump lA 25203-29527 Sh 36 1-37 Reactor Coolant Pump 1B 25203-29527 Sh 37 1-38 Reactor Coolant Pump 2A 25203-29527 Sh 38 1-39 Reactor Coolant Pump 2B 25203-29527 Sh 39 1-40 Letdown, Charging & Spray Lines from 25203-29527 Sh 40 Regenerative Heat Exchanger 999 System Pressure Test (See Section 5.0) 2-45

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.5 EXAMINATION ZONE LISTING (continued)

Zone Class 2 Systems.. Isometric Drawing No.

No.

2-01 Steam Generator No. 1 25203-20163 2-02 Steam Generator No. 2 25203-20164 2-03 Shutdown Heat Exchanger X-23A 25203-20165 2-04 Shutdown Heat Exchanger X-23B 25203-20166 2-05 Shutdown Cooling 25203-20155 Sh 1 2-06 Shutdown Cooling 25203-20155 Sh 2 2-07 Shutdown Cooling 25203-20155 Sh 3 2-08 Shutdown Cooling 25203-20155 Sh 4 2-09 Shutdown Cooling 25203-20155 Sh 5 2-10 Shutdown Cooling 25203-20155 Sh 6 2-11 Shutdown Cooling 25203-20155 Sh 7 2-12 Shutdown Cooling 25203-201.55 Sh 8 2-13 Shutdown Cooling 25203-20155 Sh 9 2-14 Main and Aux. Feedwater from Isolation 25203-20158 Sh 1 Valves to Stm Gen No. 1 2-15 HP Safety Injection System 25203-20160 2-16 Main Steam from Stm Gen No. 1 to Isolation 25203-20167 Sh 1

___Valve 2-17 Main Steam from Stm Gen No. 2 to Isolation 25203-20167 Sh 2 Valve 2-18 RBCCW System Containment Penetrations 25203-20155Sh 10

1. 27, #28, #32 & #33 2-19 RBCCW System Containment Penetrations 25203-20155 Sh 1I

1. 25, #26, #30 & #31 2-20 RBCCW System Containment Air Coolers 25203-20155 Sh 12 Containment Penetration #24 2-21 -RBCCW System Containment Penetrations 25203-20155 Sh 13

1. 53 & #54 2-22 RBCCW System Return from Reactor 25203-20155 Sh 14 Coolant Pump Containment Penetration #29 2-23 Hydrogen Purge System Containment 25203-20155 Sh 15 Penetrations #82 and #83 2-24. Containment Purge System Containment 25203-20155 Sh 16 Penetration #39 2-25 Containment Purge System Containment 25203-20155 Sh 17 Penetration #40 I

2-46

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.5 EXAMINATION ZONE LISTING (continued)

Zone Class 2 Systems Isometric Drawing No.

No.1 2-26 HP Safety Injection Suction from RWST and 25203-20155 .Sh 26 CNTMT Sump to HPSI Pump #P-4 1A 2-27 HP Safety Injection Suction from RWST and 25203-20155 Sh 27 CNTMT Sump to HPSI Pump #P-41C' 2-28 HP Safety Injection Suction from RWST and 25203-20155 Sh 28 CNTMT Sump to HPSI Pump #P-41B 2-29 Refueling Water Storage Tank Supply to 25203-20155 Sh 29 Chemical Volume Control System 2-30 HP Safety Injection Small Bore Piping 25203-20155 Sh 30 2-31 HP Safety Injection Small Bore Piping 25203-20155 Sh 31 2-32 HP Safety Injection Pump Discharge 25203-20155 Sh 32 2-33 Shutdown Cooling 25203-20155 Sh 33 2-34 Shutdown Cooling 25203-20155 Sh 34 2-35 Shutdown Cooling 25203-20155 Sh 35 2-36 Shutdown Cooling 25203-20155 Sh 36 999 System Pressure Test (See Section 5.0) 2-47

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 2.5 EXAMINATION ZONE LISTING (continued)

Zone Class 3 Systems Isometric Drawing No.

No.

3-01 RBCCW Supply and Return to CNTMT Air 25203-20156 Sh 1 Recirc. X35A & X35C 3-02 RBCCW Supply and Return to CNTMT Air 25203-20156 Sh 2 Recirc. X35B & X35D 3-03 RBCCW to Car Coolers B and D 25203-20156 Sh 3 3-04 RBCCW to Car Coolers A and C 25203-20156 Sh 4 3-05 RBCCW to SFP Heat Exchangers and 25203-20156 Sh 5 Quench Tanks 3-06 RBCCW to Shutdown Heat Exchangers 25203-20156 Sh 6 3-07 RBCCW to Shutdown Heat Exchanger to 25203-20156 Sh 7 RBCCW Pump Suction 3-08 RBCCW Pumps to RBCCW Heat 25203-20156 Sh 8 Exchangers 3-09 RBCCW Return from SFP Heat Exchangers 25203-20156 Sh 9 and Quench Tanks 3-10 Connection from RBCCW Surge Tanks to' 25203-20156 Sh 10 RBCCW Suction Header 3-11 Auxiliary Feedwater from Pumps to Main 25203-20158 Sh 2 Feedwater Heater 3-12 Spent Fuel Pool Cooling 25203-20159 Sh 1 3-13 Spent Fuel Pool Cooling 25203-20159 Sh 1 3-14 Service Water for RBCCW Heat Exchangers 25203-20161 3-15 Diesel Cooling 25203-20162 Sh 1 3-16 Diesel Cooling 25203-20162 Sh 2 3-17 Service Water Screen Well House 25203-20168 Sh 1 3-18 Service Water Screen Well House to Turbine 25203-20168 Sh 2 and Auxiliary Building 3-19 Auxiliary Feedwater, Large Bore Piping - 25203-20168 Sh 3 Main Feedwater System 3-20 Auxiliary Feedwater, Small Bore Piping - 25203-20168 Sh 4 Main Feedwater System 999 System Pressure Test (See Section 5.0) 2-48

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

3. CODE CASES Code Cases approved for use in revisions to Regulatory Guide 1.147 that are issued during the inspection interval may be used for the duration of the inspection interval without specific written NRC approval subject to the limitations provided in the Regulatory Guide.

Code Cases that are not approved for use in revisions to Regulatory Guide 1.147 that are issued during the inspection interval shall require specific written NRC approval prior to use. Requests for approval to use Code Cases not listed in Regulatory Guide 1.147 shall be submitted to the NRC in accordance with 10 CFR 50.55a(a)(3)(i) or (ii).

Code Cases shown in Table 3.1 form an integral part of this program and are identified with either the revision of Regulatory Guide 1.147 in which they were approved for use, or the NRC SER letter that provided approval to use the Code Case.

As Code Cases are applied, they are referenced in the appropriate Sections of this manual.

TABLE 3.1 CODE CASE

SUMMARY

TABLE Code Title Documentation Notes Case N-432- 1 Repair Welding Using Automatic or Code Case N-432-1 is listed as acceptable Machine Gas Tungsten-Arc Welding to the NRC in Rev. 15 of Regulatory Guide (GTAW) Temper Bead Technique 1.147.

N-460 Alternative Examination Coverage for Code Case N-460 is listed as acceptable to Class 1 and Class 2 Welds the NRC in Rev. 15 of Regulatory Guide 1.147.

N-504-3 Alternative Rules for Repair of Class 1, Code Case N-504-3 is listed as 2, and 3 Austenitic Stainless Steel conditionally acceptable in Rev. 15 of Piping Regulatory Guide 1.147.

N-513-2 Evaluation Criteria For Temporary Code Case N-513-2 is listed as acceptable Acceptance of Flaws in Moderate to the NRC in Rev. 15 of Regulatory Guide Energy Class 2 or 3 Piping 1.147, but ASME Section XI inadvertently limited the applicability of the Code Case to the 2003 Addenda. As a result, in order to apply Code Case N-513-2 to the 2004 Edition it is addressed in Relief Request RR-04-03.

3-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 3.1 CODE CASE

SUMMARY

TABLE Code Title Documentation / Notes Case N-526 Alternative Requirements for Successive Code Case N-526 is listed as acceptable to Inspections of Class 1 and 2 Vessels the NRC in Rev. 15 of Regulatory Guide 1.147.

N-532-4 Alternative Requirements to Repair and Code Case N-532-4 is listed as acceptable Replacement Documentation to the NRC in Rev. 15 of Regulatory Guide Requirements and Inservice Summary 1.147.'

Report Preparation and Submission as Requested by IWA-4000 and IWA-6000 N-545 Alternative Requirements for Conduct Code Case N-545 is listed as acceptable to of Performance Demonstration the NRC in Rev. 15 of Regulatory Guide Detection Test of Reactor Vessel 1.147.

N-566-2 Corrective Action for Leakage Identified Code Case N-566-2 is listed as acceptable at Bolted Connections to the NRC in Rev. 15 of Regulatory Guide 1.147:

N-586-1 Alternative Additional Examination Code Case N-586-1 is listed as acceptable Requirements for Class 1, 2, and 3 to the NRC in Rev. 15 of Regulatory Guide Piping, Components, and Supports 1.147.

N-600 Transfer of Welder, Welding Operator, Code Case N-600 is listed as acceptable to Brazer and Brazing Operator the NRC in Rev. 15 of Regulatory Guide Qualifications Between Owners 1.147.

N-613-1 Ultrasonic Examination of Penetration Code Case N-613-1 is listed as acceptable Nozzles in Vessels, Examination to the NRC in Rev. 15 of Regulatory Guide Category B-D, Item Nos. B3.10 and 1.147.

B3.90, Reactor Nozzle to Vessel Welds, Figs. IWB-2500-7(a), (b), and (c).

N-624 Successive Inspections Code Case N-624 is listed as acceptable to the NRC in Rev. 15 of Regulatory Guide 1.147.

N-638-1. Similar and Dissimilar Metal Welding Code Case N-638-1 is listed as Using Ambient Temperature Machine conditionally acceptable to the NRC in Gas Tungsten-Arc Welding (GTAW) Rev. 15 of Regulatory Guide 1.147 Temper Bead Technique N-639 Alternative Calibration Block Material Code Case N-639 is listed as conditionally acceptable to the NRC in Rev. 15 of Regulatory Guide 1.147 3-2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 3.1 CODE CASE

SUMMARY

TABLE Code Title Documentation / Notes Case N-648-1 Alternative Requirements for Inner Code Case N-648-1 is listed as Radius Examination of Class 1 Reactor conditionally acceptable to the NRC in Vessel Nozzles Rev. 15 of Regulatory Guide 1.147.

N-651 Ferritic and Dissimilar Metal Welding Code Case N-65.1 is listed as acceptable to Using SMAW Temper Bead Technique the NRC in Rev. 15 of Regulatory Guide Without Removing the Weld Bead 1.147.

Crown of the First Layer N-658 Qualification Requirements for Code Case N-658 is listed as acceptable to Ultrasonic Examination of Wrought the NRC in Rev. 15 of Regulatory Guide Austenitic Piping Welds 1.147.

Note: code case applicability ends after the 2001 Edition, however 10 CFR 50.55a(b)(2)(xxiv) prohibits the use of the 2002 Addenda and later Editions and Addenda of ASME Section XI for Appendix VIII and Supplements to Appendix VIII and Article 1-3000 of Section XI. As such, the code case applicability is still valid.

N-661 Alternative Requirements for Wall Code Case N-661 is listed as conditionally Thickness Restoration For Class 2 and 3 acceptable to the NRCin Rev., 15. of Carbon Steel Raw Water Service Regulatory Guide 1.147.

N-683 Method for Determining Maximum Code Case N-683 is listed as acceptable to Allowable False Calls When Performing the NRC in Rev. 15 of Regulatory Guide Single Sided Access Performance 1.147.

Demonstration in Accordance With Note: code case applicability ends after the Appendix VIII, Supplements 4 and 6 2002 Addenda, however 10 CFR 50.55a(b)(2)(xxiv) prohibits the use of the 2002 Addenda and later Editions and Addenda of ASME Section XI for Appendix VIII and Supplements to Appendix VIII and Article 1-3000 of Section XI. As such, the code case applicability is still valid.

3-3

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 3.1 CODE CASE

SUMMARY

TABLE Code Title Documentation / Notes Case N-695 Qualification Requirements for Code. Case N-695 is listed as acceptable to Dissimilar Metal Piping Welds the NRC in Rev. 15 of Regulatory Guide 1.147.

Note: code case applicability ends after the 2003 Addenda, however 10 CFR 50.55a(b)(2)(xxiv) prohibits the use of the 2002 Addenda and later Editions and Addenda of ASME Section XI for Appendix VIII and Supplements to Appendix VIII and Article 1-3000 of Section XI. As such, the code case applicability is still valid.

N-696 Qualification Requirements for Code Case N-696 is listed as acceptable to Appendix VIII Piping Examinations the NRC in Rev. 15 of Regulatory Guide Conducted From the Inside Surface 1.147.

Note: code case applicability ends after the 2003 Addenda, however 10 CFR 50.55a(b)(2)(xxiv) prohibits the use of the 2002 Addenda and later Editions and Addenda of ASME Section XI for Appendix VIII and Supplements to Appendix VIII and Article 1-3000 of Section XI. As such, the code case applicability is still valid.

N-722 Additional Examinations for PWR The use of Code Case N-722 is mandated Pressure Retaining Welds in Class 1 by 10 CFR 50.55a(g)(6)(ii)(E). Additional Components Fabricated With Alloy conditions apply.

600/82/182 Materials N-729-1 Alternative Examination Requirements The use of Code Case N-729-1 is mandated for PWR Reactor Vessel Upper Heads by 10 CFR 50.55a(g)(6)(ii)(D). Additional With Nozzles Having Pressure- conditions apply.

Retaining Partial Penetration Welds N-731 Alternative Class 1 System Leakage The applicable criteria of Code Case N-731 Test Pressure Requirements have been incorporated into Relief Request RR-04-04.

3-4

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 3.1 CODE CASE

SUMMARY

TABLE Code Title Documentation / Notes Case N-770-1 Alternative Examination Requirements The applicable criteria of Code Case N-and Acceptance Standards for Class 1 770-1 have been incorporated into Relief PWR Piping and Vessel Nozzle Butt Request RR-04-07.

Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities 3-5

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

4. EVALUATION CRITERIA AND CALIBRATION STANDARDS 4.1 Class 1 Acceptance Standards Class 1 acceptance standards are listed in Table 4.1 4.2 Class 2 Acceptance Standards Class 2 acceptance standards are listed in Table 4.2 4.3 Class 3 Acceptance Standards Class 3 acceptance standards are listed in Table 4.3.

4.4 Acceptance Standards for Component Supports (Classes 1. 2. and 3)

Acceptance standards to verify component support structural integrity will be in accordance with 1WF-3400.

4.5 Calibration Standards Calibration blocks and standards are listed in Table 4.4.

4.6 Analytical Evaluation of Flaws Flaws exceeding the size of allowable flaws defined in IWX-3500 may be evaluated in accordance with IWB-3600 to determine acceptability for continued service. Flaws which meet the acceptance criteria of lWB-3600 shall be re-examined during the next three inspection periods per 1WB-2420(b). If the flaw indications remain essentially unchanged, during the next three inspection periods, the component examination schedule may revert to the original schedule of successive inspections.

NOTE: Per IWF-3122.3(b), when an inservice examination of a component support reveals conditions described in 1WF-3410(a),

and the component support has been analyzed and/or tested to substantiate its integrity for its intended service, and has been found to be acceptable, and corrective measures to restore the*

support to its original condition have been performed, then successive support examinations are not required.

4-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 4.7 Unanticipated Operating Events IWB-3720 requires an engineering evaluation to be performed following an operating event outside the normal operating pressure and temperature limits defined in MPS2 Plant Technical Specifications. ASME Section XI, Appendix E, may be utilized to evaluate the event. The evaluation procedures are subject to acceptance by the regulatory authority.

TABLE 4.1 CLASS 1 ACCEPTANCE STANDARDS Examination Category Components and Parts Examined Acceptance Standard B-A Welds in Reactor vessel IWB-3510 B-B Welds in other vessels IWB-3510 B-D Nozzle welds in vessels IWB-3512 B-F Rx vessel dissimilar -metal welds See Exam. Cat. R-A B-G-1 Class 1 Bolting >2" IWB-3515, 1WB-3517 B-G-2 Class 1 Bolting _2" VWB-3517 B-J Welds in piping See Exam. Cat. R-A B-K Welded attachments 1WB-3516 B-L-1 Welds in pump casings IWB-3518 B-L-2 Pump casings IWB-3519 B-M-1 Welds in valve bodies IWB-3518 B-M-2 Valve bodies IWB-3519 B-N-1 Reactor vessel interior IWB-3520.2 B-N-2 Reactor vessel integrally welded core IWB-3520. 1, IWB,-3520.2 support structures B-N-3 Reactor vessel removable core support IWB-3520.2 structures B-O Welds in CRD housings IWB-3523 B-P Pressure Retaining Components IWB-3522 R-A Risk-Informed Piping Examinations 1WB-3142, IWB-3514 (will be addressed in the RI-ISI Application) 4-2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 4.2 CLASS 2 ACCEPTANCE STANDARDS Examination Category Components and Parts Examined Acceptance Standard C-A Welds in pressure vessels IWC-3510 C-B Nozzle welds in vessels IWC-3511 Welded attachments for Class 2 Pressure C-C vessels, Piping, Pumps, and Valves IWC-3512 C-D Class 2 Bolting >2" in Diameter IWC-3513 Welds in austenitic stainless steel or high C-F-I alloy piping IWC-3514 (IWB-3514)

C-F-2 Welds in carbon or low alloy steel piping IWC-3514 (IWB-3514)

C-G Welds in Pumps and Valves IWC-3515 (lWB-3518)

C-H Pressure Retaining Components 1WC-3516 (IWB-3522)

TABLE 4.3 CLASS 3 ACCEPTANCE STANDARDS Examination Category Components and Parts Examined Acceptance Standard Welded Attachments for Vessels, Piping, D-A Pumps, and Valves IWD-3000 (IWC-3500)

D-B All Pressure Retaining Components IWD-3000 (IWC-3500) 4-3

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 4.4 CALIBRATION STANDARDS Std. No. Description Use MP2-UT- 1 11" thick clad RPV Upper Shell MP2-UT-2 9" thick clad RPV Middle and Lower Shell MP2-UT-3 7" thick clad RPV Lower Head MP2-UT-4 5" thick clad S/G Primary Weld MP2-UT-5 3" thick Clad PZR top and bottom Head Welds MP2-UT-6 3.6"clad flat Primary Loop Piping (Do Not Use) piping block MP2-UT-7A 3" flat block SG / PZR Support Skirt MP2-UT-8 11"thick clad RPV Flange Ligament Block MP2-UT-9 1I"thick clad RPV Inlet Nozzle MP2-UT-10 1l"thick clad RPV Outlet Nozzle MP2-UT-15 36" dia. 3.125T Cold Leg RCP Safe End MP2-UT-16 12" dia. PZR Nozzle to Safe End MP2-UT-17 6" dia. PZR Nozzle to Safe End MP2-UT-18 4.5" dia. PZR Nozzle to Safe End MP2-UT-19 3" dia Primary Piping Nozzle to Safe End MP2-UT-23 12" Sch. 160 Cast Surge Line Piping Block MP2-UT-25 2.5" Sch. 160 Piping Block MP2-UT-26 3" Sch. 160 Piping Block MP2-UT-27 4" Sch. 120 Piping Block MP2-UT-28 6" Sch. 120 Piping Block MP2-UT-29 12" Sch. 140 Piping Block MP2-UT-32A 4.5" dia. RCP Stud MP2-UT-34 5" thick unclad SG Secondary Side Block MP2-UT-41 6" Sch. 120 ' SI Piping Block MP2-UT-42 12" Sch. 120 MS Piping Block MP2-UT-43 6" Sch. 60 MS Piping Block UT-44 36" dia. 1.014T MS Piping Block 4-4

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 4.4 CALIBRATION STANDARDS Std. No. Description Use UT-45 35" 1.780T MS Piping Block UT-46 34" 1.006T MS Piping Block UT-47 18" Sch. 60 FW Piping Block MP2-UT-49 6" Sch. 80 HPSI Piping Block MP2-UT-50 6" Sch. 160 HPSI Piping Block MP2-UT-51 18" Sch. 60 FW Piping Block MP2-UT-52 .940 thick c/s Shutdown heat Exchanger clad MP2-UT-55 3.3" thick clad SG Vessel Block MP2-UT-56 5.5" thick Curved Vessel Block MP2-UT-57 5" thick SG Vessel Block MP2-UT-58 5" thick SG Vessel Block MP2-UT-59 3" thick SG Vessel Block MP2-UT-60 4" thick clad SG Loop Piping Block MP2-UT-61 6" thick clad SG Vessel Block MP2-UT-62 5" thick unclad SG Loop Piping Block 01-6677 ASME Carbon Steel piping welds Alternative Block 01-6678 ASME Carbon Steel piping welds Alternative Block 01-6679 ASME 304 Stainless piping welds Alternative Block 01-6680 ASME 304 Stainless piping welds Alternative Block 01-6681 ASME 316 Stainless piping welds Alternative Block 4-5

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 4.4 CALIBRATION STANDARDS Std. No. Description I Use 01-6682 ASME 316 Stainless piping welds Alternative Block 9C-040 3" Contour Circ Weld Overlays 9C-041 3" Contour Weld Overlays Axial CB-04-170 4" Contour Circ Weld overlays CB-04-171 4" Contour Weld overlays Axial MEUXE015A PDI Block RCP Pump Suction and Discharge Welds (LMT Block)

DMW-5 MEUXE017A PDI Block RCP Pump Suction and Discharge Welds (LMT Block)

DMW-7 MEUXE019A PDI Block Weld Overlays ( LMT Block)

DMW-9 CB-02-45 ASME Pressurizer Surge Nozzle to Safe-end Weld Alternative Block 9016763 ASME Pressurizer Vessel Welds and Nozzle Inner Radius Alternative Block 6039035 7.5" Contour Pressurizer Vessel Welds and Nozzle Inner Radius Block 6039038 7.5" Contour Pressurizer Vessel Welds and Nozzle Inner Radius Block 6039039 15" Contour Pressurizer Vessel Welds and Nozzle Inner Radius Block 6039042 15" Contour Pressurizer Vessel Welds and Nozzle Inner Radius Block 4-6

MILLSTONE-POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

5. SYSTEM PRESSURE TESTS 5.1 General Requirements Pressure retaining components within Class 1, Class 2 and Class 3 system boundaries are subject to system pressure tests in accordance with the following portions of ASME Section XI:

Classification Applicable Code Requirements General IWA-5000 Class 1 1WB-2500-1 (Examination Category B-P) and IWB-5000.

Clas~s 2 IWC-2500-1 (Examination Categories: C-B

[Item No. C2.33] and C-H) and IWC-5000 Class 3 IWD-2500-1 Examination Category D-B and 1WD-5000.

Table 5.1, System Pressure Test Schedule, lists each system within the scope of this program along with the required test type and schedule.

The Class 1, Class 2 and Class 3 boundaries shown on the applicable piping and instrumentation diagrams (P&IDs) shall be used in determining test boundaries.

When pressure testing is performed at normal operating conditions, the Operations department shall be responsible for verification that system conditions are normal. Generally, the normal operating conditions are satisfied when the system is operating in a normal alignment with system pump(s) pressurizing the system.

System pressure tests have been designated as Zone 999 in the ISI database (see Section 2.8) and are not shown on Zone boundary drawings.

ASME Section XI, Table IWA-5210-1, lists applicable references to determine the appropriate type of system pressure test and related test parameters for each Code Class system. Typical system pressure test parameters are: pressure (as determined by type of test), temperature, holding time, and test boundary. System hydrostatic pressure testing, if required, will be performed on a case-by-case basis in accordance with the applicable code of record and site procedure, EN 21219, Elevated Pressure Test.

5-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Buried components require a pressure loss, change in flow, or unimpaired flow test in accordance with the requirements of IWA-5244. In some instances, it is impractical to perform pressure loss or change in flow tests on buried Class 2 and 3 piping segments bounded by butterfly valves. Relief Request No. RR-04-05 proposes that a verification of unimpaired flow test be performed for these piping segments.

Records of the visual examination conducted during a system leakage test shall include the procedure documenting the system test condition and system pressure boundary. Any source of leakage or evidence of structural distress shall be itemized, and the location and corrective action documented.

Ferritic steel components shall meet the test temperature requirements specified by fracture prevention criteria or determined by DNC, as applicable. Austenitic steel components do no require test temperature restrictions.

5-2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period 25203-26005 Sht. 2 X Aux Feed 2 SP 21160 1 25203-26011 Sht. 1 Leakage 25203-26005 Sht. 2 Leakage Aux Feed 2 SP 21160 2 25203-26011 Sht. 1 Main 25203-26005 Sht. 2 Leakage Feed 2 SP 21160 3 25203-26011 Sht. 1 25203-26017 Sht. 1 Leakage 25203-26017 Sht. 3 X Charging 2 SP 21162 1 25203-26031 Sht. 1 25203-26017 Sht. 1 Leakage 25203-26017 Sht. 3 X Charging 2 SP 21162 2 25203-26031 Sht. 1 25203-26017 Sht. 1 Leakage 25203-26017 Sht. 3 X Charging 2 SP 21162 3 25203-26031 Sht. 1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE (continued)

System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period 25203-26017 Sht.. I Leakage 25203-26017 Sht. 3 x Charging 2 SP 21162 4 25203-26031 Sht. 1 25203-26017 Sht. 1 Leakage 25203-26017 Slit. 3 x Charging 2 SP 21162 5 25203-26031 Sht. 1 25203-26017 Sht. 1 Leakage 25203-26017 Sht. 3 X Charging 1 SP 21162 6 25203-26031 Sht. 1 Leakage Chilled x Water 3 SP 21161 1 25203-26027 Sht. 2 Leakage Chilled x Water 3 SP21161 2 25203-26027 Sht. 2 Leakage Ctmt x Spray 2 SP 21198 1 25203-26015 Sht. 1 Leakage Ctmt x Spray 2 SP 21198 2 25203-26015 Sht. 1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE (continued)

System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period 25203-26015 Sht. 1 Leakage 25203-26015 Sht. 2 X 25203-26015 Sht. 3 HPSI 2 SP 21157 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2 HPSI 2 SP 21157 2 25203-26015 Sht. 1 x Leakage 25203-26015 Sht. 2 25203-26015 Sht. 3 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2 25203-26015 Sht. 1 Leakage 25203-26015 Sht. 2 X HPSI 2 SP 21157 3 25203-26015 Sht. 3 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE (continued)

System' ASME Surveillance Segment P&ID Frequency Test Type Code Procedure Class Each Each RFO Period HPSI 2 SP 21157 25203-26015 Sht. 1 x Leakage 4 25203-26015 Sht. 2 25203-26015 Sht. 3 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2 HPSI 2 SP 21157 25203-26015 Sht. 1 x Leakage 5 25203-26015 Sht. 2 25203-26015 Sht. 3 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2 25203-26015 Sht. 1 Leakage 25203-26015 Sht. 2 25203-26015 Sht. 3 HPSI 2 SP 21157 6A 25203-26017Xht. 1 x 25203-26017 Sht. 3 25203-26023 Sht. 2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE (continued)

System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period 25203-26015 Sht. 1 Leakage 25203-26015 Sht. 2 HPSI 2 SP 21157 6B 25203-26015 Sht. 3 X 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2 25203-26015 Sht. 1 Leakage 25203-26015 Sht. 2 HPSI 2 SP 21157 7A 25203-26015 Sht. 3 X 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2 25203-26015 Sht. 1 Leakage 25203-26015 Sht. 2 HPSI 2 SP 21157 7B 25203-26015 Sht. 3 X 25203-26017 Sht. 1 25203-26017 Sht. 3 25203-26023 Sht. 2 HPSI 2 SP 21157 8 25203-26015 Sht. 2 X Leakage HPSI 2 SP 21157 9 25203-26015 Sht.2 X Leakage

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE (continued)

System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period LPSIISDC 2 SP 21199 25203-26015 Sht. 1 X Leakage 1 25203-26015 Sht. 2 25203-26015 Sht. 3 _

LPSI/SDC 2 SP 21199 25203-26015 Sht. 1 x Leakage 2 25203-26015 Sht. 2 25203-26015 Sht. 3 Main 25203-26002 Sht. 1 Leakage SP 21159 1 25203-26002 Sht. 2 X Steam 2 Main 25203-26002 Sht. 1 Leakage SP 21159 2 25203-26002 Sht. 2 X Steam 2 RBCCW '3 SP 21156 1 25203-26022 Sht. 1 x Leakage 25203-26022 Sht. 2 25203-26022 Sht. 3 25203"26022 Sht. 4 25203-26022 Sht. 5 25203:26022 Sht. 6

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE (continued)

System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period RBCCW SP 21156 2 25203-26022 Sht. 1 x Leakage 25203-26022 Sht. 2 25203-26022 Sht. 3 25203-26022 Sht. 4 25203-26022 Sht. 5 25203-26022 Sht. 6 RBCCW 2 SP 21156 3 25203-26022 Sht. 1 x Leakage 25203-26022 Sht. 2 25203-26022 Sht. 3 25203-26022 Sht. 4 25203-26022 Sht. 5 25203-26022 Sht. 6 RBCCW 3 SP 21156 4 25203-26022 Sht. 1 x Leakage 25203-26022 Sht. 2 25203-26022 Sht. 3 25203-26022 Sht. 4 25203-26022 Sht. 5 25203-26022 Sht. 6

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST-SCHEDULE (continued)

System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period 1 25203-26014 Sht. 1 Leakage RCS 1 5P 21238 25203-26014 Sht.2 L 25203-26015 Sht. 3 25203-26017 Sht. 1 25203-26017 Sht. 2 Service 25203-26008 Sht. 1 Leakage Water SP21155 S3 1 25203-26008 Sht. 2 X 25203-26008 Sht. 3 25203-26008 Sht. 1 Leakage Service 25203-26008 Sht. 2 Water 3 SP 21155 2 25203-26008 Sht. 3 X Service 25203-26008 Sht. 1 Leakage Water 3 SP 21155 3 25203-26008 Sht. 2 X 25203-26008 Sht. 3 Service 25203-26008 Sht. 1 Leakage Water 3 SP21155 4 25203-26008 Sht. 2 x 25203-26008 Sht. 3

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 5.1 SYSTEM PRESSURE TEST SCHEDULE (continued)

System ASME Surveillance Segment P & ID Frequency Test Type Code Procedure Class Each Each RFO Period Service 25203-26008 Sht. 1 Leakage Water 3 SP 21155 5 25203-26008 Sht. 2 X 25203-26008 Sht. 3 3 SP 21155 6 25203-26008 Sht. I Leakage Service 25203-26008 Sht. 2 X Water 25203-26008 Sht. 3 25203-26015 Sht. 1 SFC 3 SP 21154 1 25203-26023 Sht. 2 Leakage 25203-26015 Sht. 1 SFC 3 SP 21154 2 25203-260235Sht. X Leakage 25203-26015 Sht. 1 SFC 3 SP 21154 3 25203-26023 Sht. 2XLekg 25203-26015 Sht. 1 X Leakage SFC 3 SP 21154 4 25203-26023 Sht. 2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 5.2 Visual Examination ReQuirements Personnel performing VT-2 examinations shall be certified in accordance with 1WA-2300. The VT-2 visual examination is conducted to locate the evidence of leakage from pressure retaining components, or abnormal leakage from components with or without leakage collection systems. The requirements of IWA-5240 are applicable for performance of VT-2 visual examination.

5.3 Class 1 System Pressure Test Requirements Class 1 systems are subject to system leakage tests per 1WB-5220.

Specific leakage testing requirements are as follows:

• Test Pressure shall be in accordance with IWB-522 1:

(a) The system leakage test shall be conducted at a pressure not less than the pressure corresponding to 100% rated reactor power.

(b) The system test pressure and temperature shall be attained at a rate in accordance with the heat-up limitations specified for the system.

" Test Boundaries shall be in accordance with IWB-5222:

(a) The pressure retaining boundary during the system leakage test shall correspond to the reactor coolant boundary, with all valves in the position required for normal reactor operation startup. The visual examination shall, however, extend to and include the second closed valve at the boundary extremity.

(b) The pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the system boundary.

For some piping segments it is impractical to extend the Class 1 pressure testing boundaries during this system leakage test. The applicable piping segments and proposed alternatives for conducting the system pressure tests are addressed in Relief Request RR-04-04.

" Test Temperature shall be in accordance with IWB-5240:

(a) The minimum test temperature for either the system leakage or system hydrostatic test shall not be lower than the minimum temperature for the associated pressure specified in the plant Technical Specifications.

(b) The system test temperature shall be modified as required by the results obtained from each set of material surveillance specimens withdrawn from the reactor vessel during the service lifetime.

(c) For tests of systems or portions of systems constructed entirely of austenitic steel, test temperature limitations are not required to meet

' fracture prevention criteria. In cases wherethe components of the 5-6

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL system are constructed of ferritic and austenitic steels that are nonisolable from each other during a system leakage or system hydrostatic test, the test temperature shall be in accordance with 1WB-5230(a).

Refer to Table 5.1 for information related to system pressure testing of Class 1 components.

5.4 Class 2 and Class 3 System Pressure Test Requirements Class 2 and Class 3 systems, are subject to system leakage tests per 1WC-5220 and IWD-5220, respectively. Specific leakage testing requirements are as follows:

'Test Pressure shall be in accordance with IWC-5221 and IWD-5221, respectively.

(a) The system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating fu'ncti6n or at the system pressure developed during a test conducted to verify system operability (e.g., to demonstrate system safety function or satisfy technical specification surveillance requirements).

Test Boundaries shall bein accordance with IWC-5222 and 1WD-5222, respectively.

(a) The pressure retaining boundary includes only those portions, of the system required to operate or support the safety function up to and including the first normally closed valve (including a safety or relief valve) or valve'capable of automatic closure when the safety function is required.

(b) Items outside the boundaries of (a), and open ended discharge piping, are excluded from the examination requirements.

Test Temperature shall be in accordance with IWC-5240 and IWD-5221, respectively.

(a) In systems containing ferritic steel components for which fracture toughness requirements were neither specified nor required in the construction of the, components,,the system test temperature shall be determined by DNC.

(c) No limit on system test temperature is required for systems comprised of components constructed entirely of austenitic steel materials.

Refer to Table 5.1 for information related to system pressure testing of Class 2 and Class 3 components.

5-7

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL' 5.5 Repair and Replacement Pressure Test Requirements The MPS2 repair and replacement program is performed in accordance with Dominion Fleet Repair Replacement Program Procedure ER-AA-RRM-100. System pressure tests followingrepair and replacement-activities are in accordance with IWA-5214 and IWA-4540.

5.6 Impiementing Instructions System pressure tests are performed in accordance with plant approved procedures or approved work orders.

The procedure or work order shall include the following:

• a drawing or description of the test boundary

• test method and techniques test pressure and temperature holding time

• method for documentation The individual responsible for test performance shall ensure the following, as required:

• certification of test personnel

• preparation of pressurizing equipment 0 calibration of test equipment

• preparation of components/systems 5.7 Corrective Measures The sources of leakage detected during the performance of.a system pressure test shall be located and evaluated for corrective measures as follows:

• buried components with leakage losses in excess of limits acceptable for continued service shall be repaired or replaced

• if leakage occurs at a bolted connection, the bolting shall be evaluated for joint integrity in accordance with the requirements of Code Case N-566-2

• repairs or replacements of components shall be performed in accordance with Dominion Fleet Repair Replacement Program Procedure ER-AA-RRM- 100.

5-8

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

6. REPAIR/REPLACEMENT ACTIVITIES Repair/replacement activities associated with pressure retaining components and their supports shall be performed in accordance with Dominion Fleet Repair Replacement Program Procedure ER-AA-RRM-100.

6.1 Establishment of a Baseline A preservice examination following repair/replacement activities shall be performed prior to the return of the system to operation to establish a baseline and to provide data on initial conditions supplementing comparison with subsequent examinations. The preservice examination of the item(s) used for the replacement or repair, including any applicable joints connecting the item to the system shall be made in accordance with IWX-2200. This examination shall therefore make use of the same methods, techniques, and types of equipment as those which are planned to be used later on.

Shop and field examinations performed during construction may form part of the baseline examinations where examination after final installation and testing is not practical, provided that:

1. Such examinations are conducted under similar conditions and with equipment and techniques equivalent to those that are planned to be employed during subsequent inservice examinations.

2. Examinations conducted before a hydrostatic (or pneumatic) pressure test is followed by a confirmatory examination after the test on a sample of inspection areas to demonstrate that no significant change has occurred.

3. In the case of components classified as pressure vessels only, examinations are performed after the hydrostatic (or pneumatic) test.

4. The shop and field examination records are docuniented and identified in a form consistent with this manual and the planned records of subsequent inservice inspections.

When improvements are made in the methods, techniques, or new equipment used in the inservice inspection program, a new baseline shall be established. The new baseline shall be developed for a particular component or portion of a component when the next scheduled examination of the component occurs. To the extent feasible, a correlation between the new and previous baseline shall be established using calibration data and component examination data.

6-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

7. RECORDS AND REPORTS DNC will maintain adequate inspection, examination, test, flaw evaluation, and repair/replacement activity records such as radiographs, diagrams, drawings, calculations, examination and test data, description of procedures used, and evidence of personnel qualifications in accordance with lWA-1400(k) and TWA-6000.

DNC will retain all inspection, examination, test, and repair and replacement records for the service lifetime of the component or system in accordance with, lWA- 1400(1).

7.1 Preparation 7.1.1 Plans and Schedules DNC will prepare plans and schedules for inservice examinations and tests to meet the requirements. of IWA-6000.

7.1.2 Examinations 7.1.2.1 Analytical Evaluations Analytical evaluations for acceptance of flaws found by volumetric, surface or visual examinations shall be prepared in accordance with IWA-6340(e), IWB-3132.3, IWB-3142.4, IWC-3122.3, or IWC-3132.3.

7.1.2.2 Summary Reports Inservice inspection summary reports will be prepared at the completion of each inspection conducted during a refueling outage. The summary report shall contain the information required by Code Case N-532-4.

7.1.3 Tests DNC will prepare records of visual examinations conducted during a system leakage test as required by IWA-5300 7-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 7.1.4 Repair/Replacement Activities Reports and Records required by Code Case N-532-4 shall be prepared by DNC under Dominion Fleet Repair Replacement Program Procedure ER-AA-RRM- 100.

7.1.5 Unresolved Indications Unresolved Indications will be reported in accordance with MP-24-ISI-FAP01.

7.2 Submittal 7.2.1 Plans and Reports In accordance with IWA- 1400(c), DNC will file with the enforcement and regulatory authorities plans and reports for inservice examinations and tests prepared as described in 7.1.1.

7.2.2 Inservice Inspection Summary Reports In accordance with Code Case N-532-4, at the completion of the inservice. inspection conducted during each refueling outage, DNC shall file with the enforcement and regulatory authorities an inservice inspection summary report prepared as described in 7.1.2.2. This report shall be submitted within 90 days following the completion of each refueling outage.

7.2.3 Analytical Evaluations In accordance with IWB-3134(b), IWB-3144(b), 1WC-3125(b), and 1WC-3134(b), DNC shall submit to the regulatory authority, analytical evaluations of examination reports prepared as described in 7.1.2.1.

7-2

MILLSTONE POWER STATION UNIT 2

• INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 7.3 Retention 7.3.1 Inspection Records and Reports DNC shall retain inspection records and reports in accordance with Code Case N-532-4, and the Dominion Quality Assurance Topical Report, DOM-QA-1.

7.3.2 Items Subject to Review by Authorities DNC shall retain records which are subject to review by enforcement and regulatory authorities in accordance with the following Articles:

lWA-4150 Repair/Replacement plan required by IWA-4150(c).

IWB-3134 Repair program and reexamination results for flaws found by volumetric and surface examinations and accepted by repair in Class 1 components.

IWB-3144 Repair program and reexamination results for flaws found by visual examinations and accepted by repair in Class 1 components.

IWC-3125 Repair program and reexamination results for flaws found by volumetric and surface examinations and accepted by repair in Class 2 components.

IWC-3134 Replair program and reexamination results for flaws found by visual examinations and accepted by repair in Class 2 components.

7-3

MILLSTONE POWER STATION UNIT2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

8. COMMITMENTS This program addresses the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 2004 Edition. In addition to meeting those requirements, the Program also addresses examinations that are performed to specific approved code cases, and Augmented Examinations identified in regulatory commitments to the NRC. DNC will document those examinations performed in lieu of the code (Code Case), and those exams performed in addition to the code (NRC Commitments).

8.1 Tracking/Logging of Correspondence A summary of correspondence for the fourth ISI inspection interval shall be maintained in the MPS2 ISI Correspondence Tracking Log, Table 8.1.

8.2 Code Cases Section 3 of this document provides guidance in the application of code cases. Upon the decision to apply a specific code case, if NRC approval is required, a copy of all correspondence leading to approval shall be placed in the MPS2 ISI Correspondence Tracking File and a summary added to Table 8.1.

83 Relief Requests Section 9 of this document provides guidance in the utilization and submittal of relief requests.

Upon submittal of a relief request to the NRC, a copy of the correspondence package shall be placed in the MPS2 ISI Correspondence Tracking File and a summary added to Table 8.1.

When a response is received from the NRC, a copy of the correspondence shall be placed into the MPS2 ISI Correspondence Tracking File and a summary added to Table 8.1.

8.4 Correspondence Tracking Lo2 Examinations that are performed outside of the scope of Section XI requirements shall be referredto as Augmented Examinations. These Augmented Examinations might come at the direction of the regulatory authority, or might be a result of developing industry issues.

8-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL All fourth interval correspondence leading to the addition of Augmented Examinations shall be placed in the MPS2 ISI Correspondence Tracking File and a summary added to Table 8.1.

8-2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 8.1 MPS2 ISI CORRESPONDENCE TRACKING LOG (Sheet I of 1)

File No. Date Orig. Description Compliance Verification S/N 10-137 03/30/2010 DNC RR-04-02 , Alternative VT-2 pressure testing requirements for the lower portion of the reactor pressure vessel, and RR-04-03, Alternative evaluation criteria for Code Case N-513-2, Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping I I *1-

• I

• I. I I

i. i i .

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

9. RELIEF REQUESTS 9.1 Alternative Requirements 9.1.1 Code Cases Not Approved for Use ASME publishes code cases which explain the intent of Code rules or provide for alternative requirements under special circumstances. Section 3 of this document describes the use of approved code cases. If it is determined that it would be beneficial to utilize code cases which-provide alternative requirements to the inspection requirements of ASME Section XI as documented in this program manual which have not been approved for use in Regulatory Guide 1.147, relief requests will be filed in accordance with 10 CFR 50.55a(a)(3).

9.1.2 Hardship or Unusual Difficulty During Inservice Inspection, there are cases where compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. An example of this is encountering significant radiation exposure during the performance of an examination. If such circumstances are identified, relief requests will be filed in accordance with 10 CFR 50.55a(a)(3).

9.2 Impractical Reiuirements During Inservice Inspection, there are cases where component configuration and/or interferences prohibit coverage of the code required volume or surfaces. In each case where such limitations have been encountered the details afe documented in a relief request. If additional conditions are encountered where the inspection requirements of ASME Section XI as documented in this program manual cannot be met, relief requests will be filed in accordance with 10 CFR 50.55a(g)(5)(iii).

9-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 9.3 Format Relief requests are numbered sequentially, with relief requests issued during the fourth interval indicated by the number "4", i.e., RR-04-XX.

Each relief request will be formatted in accordance with the Nuclear Energy Institute (NEI) Standard Format for Requests Pursuant to 10 CFR 50.55, Revision 1, dated June 7, 2004.

9.4 Relief Request Summary Tables 9.4.1 Relief requests which were submitted during the Third Interval ISI Program are listed in Table 9.4-1 and are included as historical information.

9.4.2 Relief requests applicable to the Fourth Interval ISI Program are listed in Table 9.4-2. Copies of relief requests are in Attachment 2.

Additional relief requests, as deemed necessary, will be submitted pursuant to the requirements of 10 CFR 50.55a(a)(3) or 10 CFR 50.55a(g)(5)(iii).

9-2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Relief Exam. System or Volume or Area To Be LicenseeDate Request Title Cat. Item No. Component Examined Required Method Proposed Status Ated

_ Alternative Approved RR-89-01 RPV Circumferential B-A B13.21 RPV Circumferential RPV Head Volumetric Visual, VT-2 Approved 07/22/98 Head Welds Weld Reference Document TAC No. M96200 RR-89-02 RPV Meridional Head B-A B13.22 RPV Meridional RPV Head Volumetric Visual, VT-2 Approved 07/22/98 Welds Weld Reference Document TAC No. M9.6200 RR-89-03 RPV Welds B-A B1.11, RPV RPV Shell Welds Volumetric Volumetric, Limited Approved 07/22/98 B1.12, Circumferential and Coverage 81.21, Longitudinal 81.22 RPV Bottom Head Welds Circumferential and Meridional Reference Document TAC No. M96200 RR-89-04 RPV Nozzle to Shell B-D B3.90, RPV RPV Nozzle-to-Shell welds Volumetric Volumetric, Approved 07/22/98 Welds 13.100 Deferral to End of Interval Reference Document TAC No. M96200 RR-89-05 RPV Closure Head B-G-1 B6.10 RPV RPV Closure Head Nuts Surface Visual, VT-1 Approved 07/22/98 Nuts Reference Document TAC No. M96200 RR-89-06 Pressure Retaining B-J B9.11, Various RCS piping welds (16) Volumetric and Volumetric (full Approved 07/22/98 Welds in Piping 89.12 Surface volume)

Reference Document TAC No. M96200 9-3

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM' FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Relief Exam. System or Volume or Area To Be Licensee Date Request Title Cat. Item No. Component Examined Required Method Proposed Status Approved Alternative RR-89-07 Pressure Retaining B-0 B14.10 RPV CRD housing welds Volumetric or VT-2 examination Approved 07/22/98 Welds in Control Rod Surface of the lower weld Housings (W weld).

Reference Document Tac No. M96200 RR-89-08 System Pressure B-P, .C-H, Article Various Removal of Bolting IWA- VT-3 of removed Evaluate leaking Approved 07/22/98 Testing D-A, D-B, IWA-5250 5250(a)(2) bolting connection to and D-C determine scope of VT-3 Reference Document Tac No. M96200 RR-89-09 Not N/A submitted Reference Document RR-89-10 Steam Generator B-D B3.130 Steam Steam Generator Nozzle- Volumetric 100% Volumetric with Approved 07/22/98 Nozzle-to-Shell Generator to-Vessel weld (nozzle-to- limited coverage Welds nozzle extension)

Reference Document Tac No. M96200 RR-89-11 Pressurizer Nozzle B-D B3.120 Pressurizer Pressurizer nozzle inner Volumetric 100% Volumetric with Approved 07/22/98 Inner Radius radius limited coverage Reference Document TAC No. M96200 RR-89-12 Steam Generator B-D B3.140 Steam Steam Generator nozzle Volumetric 100% Volumetric with Approved 07/22/98 Nozzle Inner Radius Generator inner radius limited coverage Reference Document TAC No. M96200 9-4

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Relief Exam. System or Volume or Area To Be Licensee Date Request Requst

• Ct.

Cat. ompoent Component  :* xamnedAlternative Examined Required Method Proposed Status Approved RR-89-13 Not N/A submitted Reference Doc~ument N/A RR-89-14 Steam Generator B-B B2.31 Steam Steam Generator Volumetric 100% Volumetric with Approved -07/22/98 Circumferential Generator Circumferential Head limited coverage Head Welds Welds Reference Document TAC No. M96200 RR-89-15 Not N/A submitted Reference Document N/A RR-89-16 Vessel Heater B-E 84.10, Pressurizer VT-2 examination during VT-2 VT-2 tracked under Approved 07/22/98 Penetration Welds B4.20 system pressure testing Examination CategoryB-P Reference Document TAC No. M96200 RR-89-17 Bolted Connection N/A, N/A Various IWA-5242 removal of VT-2 VT-2 with Approved 07/22/98.

- Insulation Removal insulation for VT-2 insulation in place, .(Class 1 examination Also VT-2 during only) refueling outage at static head or zero pressure Reference Document TAC No. M96200 9-5

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Licensee Relief Title Exam. Item No. System or Volume or Area To Be Required Method Proposed Status Date Request Cat. Component Examined Alternative Approved RR-89-18 CRD Bolting B-G-2 B7.80 RPV CRD Bolting VT-1 VT-1 of reused Approved 07/22/98 bolting, VT-2 exam Reference Document TAC No. M96200 RR-89-19 Snubbers N/A N/A Various Inspection and functional OM Part 4 Perform snubber Approved 07/01/98 "testing of snubbers 1987a88 inspection and testing per TS 3/4.7.8 Reference Document TAC No. M96200 RR-89-20 Relief Valves N/A N/A Various Relief valve removal for Repair/replacemen Code Case N-508- Approved 07/01/98 testing t plan 1 for rotation from stock Reference Document TAC No. M96200 RR-89-21 Repair/ Replacement N/A N/A Various Repair/replacement plan Repair/replacemen Code Case N-544 Denied N/A of Small items required for items NPS 1" t plan or smaller items Reference Document TAC No. M96200 (denied 7/22/98)

RR-89-22 Summary Reports N/A N/A Various Preparation of Code IWA-6000 (NIS-1 Code Case N-532 Approved 03/24/00 summary reports for -.and NIS-2 forms) (OAR and NIS-2a examination and testing forms)

Reference Document TAC No. MA6961 RR-89-23 Withdrawn N/A Reference Document S/N B18079 (w/d 04/12/00) 9-6

MILLSTONE POWER STATION UNIT 2 INSER VICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Licensee Dt Relief T Exam Item No. System or Volume or Area To Be Required Method Proposed Status Date Request Title Cat. Component Examined Alternative S Alternative Approved RR-89-24 RPV Shell-to-Flange B-A B1.30, RPV 100% of RPV Shell-to- N/A Code Case N-623 Approved 03/15/00 and Head-to-Flange B13.40 Flange and Head-to-Flange welds with partial deferral to end of interval Reference Document TAC No. MA6916 RR-89-25 Not N/A through RR- submitted 89-29 Reference Document N/A RR-89-30 RPV Longitudinal and B-A B1.10, RPV Use of Appendix VIII, Volumetric 100% Volumetric using PDI Approved 01/26/01 Circumferential Shell B1.20 Supplement 4 for length sizing Welds and RPV Head Welds Reference Document TAC No. MA9857 RR-89-31 Withdrawn N/A Reference Document S/N B18253 (w/d 11/08/00)

RR-89-32 Annual NDE training N/A N/A Various Appendix Vll, Subarticle 10-hours annual 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> annual Approved 01/26/01 VII-4240 requires 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> ultrasonic.training training in annual ultrasonic training accordance with 10 CFR 50.55a (b)(2)(xiv)

Reference Document TAC No. MA9857 9-7

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Relief Exam. System or Volume or Area To Be Licensee Date Request Title Cat. Item No. Component Examined Required Method Proposed Status Approved Alternative RR-89-33 Ultrasonic N/A N/A Various IWA-2300 qualification CP-189 SNT-TC-1A, 1984 Approved 01/26/01 Qualification requirements in qualification for UT certificatioh/re-Requirements accordance with CP-1 89 examiners certification till August 1,2001.

Reference Document TAC No. MA9857 RR-89-34R1 Alternate welding and N/A N/A RPV Head Code repair of flaws in Code Repair in Alternate welding Approved Verbal auth.

PWHT of Reactor Reactor Vessel Head accordance with qualification and on 03/22/02 Vessel Head Penetrations "1989 Section XI PWHT and written Penetrations and Construction requirements approval on Code 10/02/02 Reference Document TAC No. MB4223 RR-89-35 MSNA Clamps N/A N/A Pressurizer Use of MSNA clamps as a Permanent Code Use of temporary Approved 03/22/02 temporary repair to Repair clamping device pressurizer heater until pressurizer penetration nozzles replacement.

Reference Document TAC No. MB4039 RR-89-36 CEDM Repairs and N/A N/A RPV Head Characterize existing flaws Determine flaw Bound flaw size Approved Verbal auth.

IWB-3600 Analysis in accordance with IWA- size and perform and perform on 03/22/02 3300 and IWB-3420 IWB-3600 analysis structural analysis and written approval on 10/02/02 Reference Document TAC No. MB4223 RR-89-37 Not N/A submitted Reference Document N/A 9-8

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Licensee Dt Relief Exam. Item No. System or Volume or Area To Be Required Method Proposed Status Date Request Title Cat. Componenit Examined Alternative Alter'native RR-89-38 and Not RR-89-39 submitted Reference Document N/A RR-89-40 Risk-informed ISI B-F, B-J Various Various 100% of welds selected for Surface and/or Volumetric in Approved 04/01/05 Program WCAP- examination in accordance Volumetric, as accordance with 14572-A with ASME Section XI applicable Risk-Informed ISI Reference Document TAC No. MCG1284 S/N 05-205 RR-89 Risk-Informed ISI R-A N/A Various 100% of socket weld or Volumetric VT-2 Approved 04/01/05 Alternative for Socket - branch connection weld Welds and Branch Piping Reference Document TAC No. MC1284 S/N 05-205 RM-89-42 RPV Bottom Head B-P B15.10, RPV VT-2 examination of the VT-2 VT-2 examination Approved 10/22/03 VT-2 examination B15.11 bottom head at NOP/NOT during refueling outage (not NOP/NOT)

Reference Document TAC No. MC0282 RR-89-43 Use of MNSA on N/A N/A . Pressurizer Perform permanent Code N/A Install temporary Approved 10/28/03 Pressurizer Heater repair/replacement of mechanical nozzle Sleeves degraded component seal assembly (MNSA)

Reference Document TAC No. MC0279 9-9

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Relief Exam. System or Volume or Area To Be Licensee Date Request Title Cat. Item No. Component Examined Required Method Proposed Status Approved Alternative RR-89-44 Alternative welding Withdrawn N/A for Alloy 600 small bore half nozzle repair Reference Document S/N B 19026 (w/d 12/12/03)

RR-89-45 Alternative welding Withdrawn N/A for Alloy 600 small

- bore half nozzle repair Reference Document S/N B19026 (w/d 12/12/03)

RR-89-46 Use Code Case N- Withdrawn N/A 597-1 for wall thinning analysis Reference Document S/N B19006 (w/d 10/28/03)

RR-89-47 Relaxation request N/A N/A RPV Head RPV Head Penetration Volumetric or Combination of Approved 10/14/03 for Reactor Head Nozzle areas as described surface volumetric and Vent line nozzle in the NRC rule examination surface inspection examination Reference Document TAC No. MC0619 A15957 RR-89-48 Relaxation request N/A N/A RPV Head RPV Head Penetration Volumetric or Reduction of Approved 11/21/03 for Reactor Head Nozzle areas as described surface examination area Vent line nozzle in the NRC rule examination based on flaw inspection analysis Reference Document TAC No. MC0942 Al 5965 9-10

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE LicenseeRDate Relief Title Exam. Item No. System or Volume or Area To Be Required Method Proposed Status Request Cat. Component Examined Alternative Approved RR-89-49 Request to use Code C-F-i, C5.10 Various Perform volumetric and Volumetric and Volumetric Approved 05/04/04 Case N-663 C-F-2 through surface examination of Surface Examination only-C5.42 and selected welds Examination provided no C5.50 external through degradation C5.82 mechanism Reference Document TAC No. MC2523 S/N 04-315 -

RR-89-50 Altemative Temper N/A N/A Pressurizer N/A ASME Code Alternate temper Approved 04/08/05 Bead welding for Repair bead weld process Pressurizer weld pad deposits Reference Document TAC No. MC3585 S/N 05-233 RR-89-51 Use of Annulled N/A N/A CEDM N/A ASME Code Use of annulled Denied N/A Code Case N-2 Repair/ Code Case N-2 Replacement Reference Document TAC No. MC3859 (denied 8/13/04)

RR-89-52 This number was inadvertently used for Millstone 3 N/A Reference Document N/A RR-89-53 Use of Code Case N- N/A N/A CEDM N/A ASME Code Use Code Case Approved 01/10/05 4-12 Repair/ N-4-12 Replacement Reference Document TAC No. MC4906 S/N 05-018 9-11

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Exam. System or Volume or Area To Be Licensee Date Relief Title Item No. Component Examined Required Method Proposed Alternative Status Approved RR-89-54 Alternate acceptance B-E B4.13 RPV N/A Remove flaws or Alternate Approved 04/08/05 standards for Alloy B-P B15.20 Pressurizer analyze them to acceptance 600 small bore 815.21 RCS RC IWX-3600 standards without nozzles 115.50 flaw removal for B15.51 Alloy 600 small bore nozzles Reference Document TAC No. MC6022 S/N 05-233 RR-89-55 Not N/A Submitted Reference Document N/A RR-89-56 Use of alternate B-P 815.51 Class 1 piping VT-2 examination during VT-2 Alternate pressure Approved 09/27/07 Class 1 pressure test B 15.71, - - NOP/NOT test provisions for requirements specified piping segments Reference Document TAC No. MD2866 S/N 07-0676 RR-89-57 Alternate pressure D-B D2.10 Service Water Measure flow between Measure flow Demonstrate un- Approved 07/10/08 test provisions for System ends of buried piping impaired flow in buried piping subject piping Reference Document TAC No. MD7732 S/N 08-437 RR-89-58 Request to use R-A R1.20 RCS 100% of subject welds Volumetric Use RMSE for Approved 05/01/07 Alternate Sizing using RMSE for depth depth sizing of Criteria sizing of 0.125 inches 0.224 inches.

Reference Document N TAC No. MD1715 S/N 07-366 9-12

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Relief Exam. System or Volume or Area To Be Licensee Date Request Title Cat. item No. Component Examined Required Method Proposed Status Approved Alternative RR-89-59 Request to use R-A R1.20 RCS Appendix VIII for Volumetric Use Code Case N- Approved 05/02/07 Code Case N-696 supplements 2, 3 and 10 696 in lieu of Appendix VIII for supplements 2, 3, and 10 Reference Document TAC No. MD1717 S/N 07-369 RR-89-60 Request to use PDI B-A B13.30 RPV Perform examinations in Volumetric Use Appendix VIII, Approved 05/01/07 for RPV Shell-to- accordance with Section 5, supplements 4 and Flange Weld Article IV 6 for ultrasonic examinations Reference Document TAC No. MD1719 S/N 07-368 RR-89-61, Request to use Weld N/A N/A Various Perform repair/replacement N/A Perform weld Approved 05/08/08 Rev. 1 Overlay Repair activity to remove flaw or overlay of flawed Technique reduce to an acceptable weld or for size mitigation Reference Document TAC No. ME 1765 S/N 07-555 RR-89-61, Alternative Repair N/A N/A Various Perform repair/replacement N/A Perform weld Submitted N/A Rev.2 and Mitigation activity to remove flaw or overlay of flawed Requirements for reduce to an acceptable weld or for Weld Overlays size mitigation Reference Document TAC No. ME1765 S/N 09-376 &

376A (07/23/09 & 10/09/09)

RR-89-62 Request to use Code Not N/A Case N-523-4 Submitted Reference Document N/A 9-13

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Relief Exam. System or Volume or Area To Be Licensee Date Requef Title Item No. Soptem Required Method Proposed Status Approved Request Title Cat. Component Examined Alternative RR-89-63 Request to use N/A N/A Various Perform design in N/A Use Code Case N- Approved 02/25/2008 Section IIICode accordance with ASME 757. for alternate (Code Case Cases N-756 and N- Section IIII valve design N-757 only).

757 Reference Document TAC No. MD6144 S/N 08-111 (Code Case N-756 was withdrawn from consideration S/N 07-416B)

RR-89-64 One-sided R-A R1.15 RCS Examine essentially 100% Volumetric Reduce coverage Approved 09/09/08 Examination Tech of the specified weld based on one-volume sided access and cast austenitic stainless steel material.

Reference Document TAC No. MD6911 S/N 08-0578B RR-89-65 Non-Code Repair on N/A N/A Service Water Perform repair N/A Perform non-Code Approved 07/08/09 "A" EDG Jacket System repair.

Water Heat Emergency Exchanger Diesel Generator Jacket Water Heat Exchanger*

X-45A Reference Document TAC No. ME0440 S/N 09-454 9-14

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-1 THIRD INTERVAL RELIEF REQUEST

SUMMARY

TABLE Licensee ReifEa.System or or Area To Be VolumeExamined LieseDate Relief Title Exam. Item No. Compor Required Method Proposed Status Approved Request Cat. Component Examined Alternative RR-89-66 Non-Code Repair on N/A N/A Service Water Perform repair N/A Perform non-Code Approved 07/08/09 "B" EDG Air Cooler System repair Heat Exchanger Emergency Diesel Generator Air

-Cooler Heat Exchanger X-83B Reference Document TAC No. ME0441 S/N 09-454 RR-89-67 Non-Code Repair on N/A N/A Reactor Coolant Perform repair N/A Perform non-Code Approved Verbal auth.

"A" RCP Seal Cooler Pump P40A repair on 11/10/09 Return Tubing Seal Cooler and written Return Tubing approval 04/26/10 Reference Document TAC No. ME2296 S/N 10-294 RR-89-68 Request use of Code N/A N/A RCS N/A N/A N/A Submitted N/A Case N-722-1 Reference Document TAC No. ME2309 S/N 09-622 (10/01/09) 9-15

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-2 FOURTH INTERVAL RELIEF REQUEST

SUMMARY

TABLE 2)

(Sheet 1 of Exam. System or Volume or Area To Be Required Licensee Proposed Status Date Relief Request Title Cat. Item No. Component Examined Method Alternative Approved RR-04-01 Snubber Testing Not N/A and Examination -submitted Reference Documenit RR-04-02 Performance of B-P B15.10 RPV VT-2 examination of the VT-2 VT-2 examination Submitted "

VT-2 Pressure bottom head at NOP/NOT during refueling Testing Under outage (not the RPV NOP/NOT)

Reference Document S/N 10-137 RR-04-03 Evaluation N/A N/A Moderate energy Evaluate flaws in moderate N/A Evaluate flaws in Submitted Criteria for Class 2 and 3 piping energy Class 2 or 3 piping moderate energy Temporary Class 2 or 3 piping Acceptance of -, using Code Case N-Flaws in 513-2 Moderate Energy Class 2 or 3 Piping (Code Case N-513-2)

Reference Document S/N 10-137 RR-04-04 Use of B-P B15.10 Class 1 piping VT-2 examination during VT-2 Perform alternate Submitted Alternative NOP/NOT pressure test Pressure provisions for Testing Criteria specified piping for the System segments Leakage Test Conducted at or Near the End of the Inspection Interval Reference Document S/N 10-323 9-16

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL TABLE 9.4-2 FOURTH INTERVAL RELIEF REQUEST

SUMMARY

TABLE (Sheet 2 of 2)

Exam. System or Volume or Area To Be Required Licensee Proposed Status Date Relief Request Title Cat. Item No. Component Examined Method Alternative Approved RR-04-05 Use Of D-B D2.10 Service Water Measure flow between ends Measure flow Demonstrate un- Submitted Alternative System of buried piping impaired flow in Pressure/Flow subject piping Testing Requirements For Service Water System Buried Piping Segments Reference Document S/N 10-323 RR-04-06 Use Of PDI B-A B1.30 Reactor Pressure Reactor pressure vessel Volumetric Examine RPV shell- Submitted Qualified Vessel shell-to-flange weld to-flange weld using Procedures, qualification Personnel And requirements of Equipment For Appendix VIII, Non-Appendix Supplements 4 and VIII RPV Shell- 6 To-Flange Weld Reference Document S/N 10-323 RR-04-07 Examination for R-A RI.11, Reactor Coolant Dissimilar metal Alloy 82/182 Volumetric Perform volumetric Submitted Weld Overlays Ri. 15 System welds and adjacent welds examinations per the that have had a full structural alternative weld overlay applied provisions described in the Relief Request Reference Document S/N 10-323 RR-04-08 Alternative B-P B15.10 Reactor Pressure Reactor pressure vessel VT-2 Perform visual Submitted Pressure Testing Vessel flange leak-off piping examinations and Requirements for monitoring on the the RPV Flange unpressurized piping Leak-Off Piping Reference Document S/N 10-323 9-17

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

10. Reserved for Future Use 10-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

11. DRAWINGS The applicable zone drawings for component welds and supports, and their associated Program Plan listings are maintained on site as part of the Inservice Inspection Program Manual.

11-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL

12. IMPLEMENTATION OF ASME SECTION XI, APPENDIX VIII Program Basis 10 CFR 50.55a, as amended by the Federal Register Published September 22, 1999, Volume 64, Number 183 (Final Rule) required expedited implementation of Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems". The effective date for the expedited implementation was November 22, 1999.

Effective Code DNC will implement Appendix VIE1, "Performance Demonstration for Ultrasonic Examination Systems" in accordance with ASME Section XI, 2001 Edition for the 4th Inspection Interval of MPS2.

Implementation Schedule DNC has implemented Appendix VIII in accordance with the following schedule as defined in 10 CFR 50.55a:

IMPLEMENTATION SUPPLEMENT QUALIFICATION REQUIREMENTS DATE 1

Evaluating Electronic Characteristics of May 22, 2000 Ultrasonic Systems 2 Wrought Austenitic Piping Welds May 22, 2000 3 Ferritic Piping Welds May 22, 2000 4 Clad/Base Metal Interface of Reactor Vessel November 22, 2000 5 Nozzle Inside Radius Section November 22, 2002 6 Reactor Vessel Welds Other Than Clad/Base November 22, 2000 Metal Interface 7 Nozzle-to-Vessel Welds November 22, 2002 8 Bolts and Studs May 22, 2000 9 Cast Austenitic Piping (In Course of N/A Preparation) 10 Dissimilar Metal Welds Novembe'r 22, 2002 11 Full Structural Overlaid Wrought Austenitic November 22, 2001 Piping Welds 12 Coordinated Implementation of Selected November 22, 2002 Aspects of Supplements 2, 3, 10 and 11 13 Coordinated Implementation of Selected November 22, 2002 Aspects of Supplements 4, 5, 6 and 7 14 Supplement 14: Qualification Requirements for November 22, 2002 Coordinated Implementation of Supplements 10, 2, and 3 for Piping Examinations Performed from the Inside Surface 12-1

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Performance Demonstration Program DNC will utilize personnel qualified through the Performance Demonstration Initiative (PDI) Program. PDI is an organization comprised of all the US nuclear utilities formed to provide an efficient, cost effective and technically sound implementation of Appendix VIII performance demonstration requirements.

Performance Demonstration Program Administrator DNC will utilize the EPRI NDE Center as the Performance Demonstration Administrator (PDA) in accordance with the PDI Program Description Document (PDD), Revision 4 1.

Supplement 1: Evaluating Electronic Characteristics of Ultrasonic Systems This Supplement defines the steps necessary to interchange the pulsars and/or receivers in an ultrasonic examination system without the need for requalification.

The PDI Program does not support this activity, but PDI will supply DNC with technical guidance as required on a case-by-case basis.

Supplement 2: Qualification Requirements for Wrought Austenitic Piping Welds The PDI Program is in full compliance with Supplement 2 as modified by 10 CFR 50.55a for examinations conducted from outside the piping. The PDI Program does not address examinations conducted from inside the pipe except for RPV nozzle-to-pipe welds. These examinations are included in Supplement 14, which is described later. Welds containing corrosion-resistant cladding (CRC) that is part of the pressure-retaining boundary, such as that typically applied to mitigate cracking are excluded. A recent Code inquiry indicates that these welds should be examined in accordance with Appendix HI until qualification requirements are developed.

Supplement 3: Qualification Requirements for Ferritic Piping Welds The PDI Program is in full compliance with Supplement 3 as modified by 10 CFR 50.55a for examinations conducted from outside the pipe. The PDI Program does not address examinations conducted from inside the pipe except for RPV nozzle-to-pipe welds.

Supplement 4: Qualification Requirements for the Clad/Base Metal Interface of Reactor Vessel The PDI Program is in full compliance with Supplement 4 as modified by 10 CFR 50.55a.

Supplement 5: Qualification Requirements for Nozzle Inside Radius Section The PDI Program is in full compliance with Supplement 5 as modified by 10CFR50.55a for examinations conducted from inside the reactor vessel.

The PDI Program is in full compliance with Code Case N-552 as modified by Regulatory Guide 1.147. For examinations conducted from outside the reactor 12-2

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL vessel. Code Case N-552 is applicable to both the nozzle inside radius region and the inner 15% of nozzle-to-shell welds when scanning for flaws oriented transverse to the weld. Code Case N-552 requires that all nozzles be modeled, including the inner 15% of the nozzle-to-vessel weld, and introduces maximum metal path and maximum misorientation angles as new essential variables that must be qualified. Code Case N-552 is identified as an acceptable alternative in Regulatory Guide 1.147 and shouldbe identified in the ISI Program. Modeling will be the responsibility of DNC.

Supplement 6: Qualification Requirements for Reactor Vessel Welds Other Than Clad/Base Metal Interface The PDI Program is in full compliance with Supplement 6 as modified by 10 CFR 50.55a. In addition, the PDI Program considers that demonstrations conducted on clad vessel specimens in accordance with Supplement 4 exceed the requirements of Supplement 6 and may be used for examination of the inner 10%

of unclad components without a relief request. Demonstrations performed on unclad vessel specimens, however, may not be used for the examination of clad vessels.

Supplement 7: Qualification Requirements for Nozzle-to-Vessel Welds The PDI Program is in full compliance with Supplement 7 as modified by 10 CFR 50.55a. The title of this Supplement is somewhat misleading: originally intended as a stand-alone Supplement, the examination coverage requirements of 10 CFR 50.55a have resulted in this Supplement being applicable only to examinations conducted from the nozzle bore (for example, PWR inlet and outlet nozzles). Examinations of the inner 15% conducted from the outside for flaws oriented transverse to the weld are qualified according to Supplement 5 using, Code Case N-552 as above. Otherwise, Supplement 4 and 6 are applicable.

Supplement 8: Qualification Requirements for Bolts and Studs The PDI Program provides personnel only demonstrations for bolting. This demonstration covers a range of bolting types and sizes, using the typical equipment and other essential variables. Other variables to be used in each examination shall be demonstrated during calibration, prior to the examination.

Supplement 9: Qualification Requirements for Cast Austenitic Piping Welds In accordance with Appendix VIHI, specific qualification requirements are in the course of preparation, and the requirements of Appendix III are applicable.

Supplement 10: Qualification Requirements for Dissimilar Metal Piping Welds The PDI Program is not in compliance with Supplement 10. PDI qualifications are conducted in accordance with Code Case N-695. This Code Case is identified in RG 1.147, as acceptable and should be included in the ISI Program. A relief request will be required if the examination procedure is incapable of depth sizing flaws to an accuracy of 0.125 root mean square (RMS).

12-3

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL Supplement 11: Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds The PDI Program is in compliance with Supplement 11.

Supplement 12: Requirements for Coordinated Implementation of Selected Aspects of Supplements 2, 3, 10, and 11 The PDI Program is in full compliance with Supplement 12 as modified by 10 CFR 50.55a for the coordinated implementation of Supplements 2 and 3 for examinations conducted from the outside. It does not support the coordinated implementation of Supplements 10 and 11; these are performed on an individual basis. Supplement 14 is appropriate on a limited basis for examinations conducted from the inside surface.

Supplement 13: Requirements for Coordinated Implementation of Selected Aspects of Supplements 4, 5, 6, and 7 The PDI Program does not support this Supplement. Supplements 4, 5, 6, and 7 qualifications are performed on an individual basis.

Supplement 14: Qualification Requirements for Coordinated Implementation of Supplements 10, 2, and 3 for Piping Examinations Performed from the Inside Surface Supplement 14 is functionally applicable only to PWR vessels. It is a new Supplement established by the PDI Program for a coordinated implementation of the qualifications required for the typical examinations performed from the ID of PWR nozzles. Supplement 14 uses the more technically stringent Supplement 10 qualification as a base and then incorporates a limited number of Supplement 2

'and Supplement 3 samples. Qualification requirements for examination conducted from the inside surface are conducted in accordance with Code Case N-696.

Single Sided Access for Austenitic Welds The Final Rule requires that if access is available, the weld shall be scanned in each of the four directions (parallel and perpendicular to the weld) where required.

Coverage credit may be taken for single sided exams on ferritic piping. However, for austenitic piping, a procedure must be qualified with flaws on the inaccessible side of the weld. There are currently no qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to US nuclear applications.

The PDI Program conforms with the Final Rule regarding single side access for piping. PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the 12-4

MILLSTONE POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL best available technology.

When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B) and full coverage credit may not be claimed.

DNC will document the affected austenitic welds for which best effort one sided exams are encountered and the percentage of the weld examined.

DNC will submit a request for relief of one sided examination of austenitic welds.

Credit will be taken for single sided access for ferritic welds and the weld shall be scanned in each of the four directions (parallel and perpendicular to the weld) where accessible.

Responsibilities The Unit ISI Program Owner (DNC) is responsible for implementing the Appendix VIII program.

The Site Level EIl is responsible for certification and proficiency maintenance of NDE personnel.

12-5

Serial No.10-323 Docket No. 50-336 ENCLOSURE 2 RELIEF REQUEST RR-04-04 USE OF ALTERNATIVE PRESSURE TESTING CRITERIA FOR THE SYSTEM LEAKAGE TEST CONDUCTED AT OR NEAR THE END OF THE INSPECTION INTERVAL ON CLASS 1 PIPING DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Docket No. 50-336 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i) and 10 CFR 50.55a(a)(3)(ii)

--Alternative Provides Acceptable Level of Quality and Safety and Compliance with the Specified Requirements Results in a Hardship without a Compensating Increase in the Level of Quality and Safety--

1. ASME Code Components Affected ASME Code Class: Code Class 1

References:

ASME Section XI, Table 1WB-2500-1 and 1WB-5222(b)

Examination Category: B-P Item Number: B15.10

Description:

Use of alternative pressure testing criteria for the system leakage test conducted at or near the end of the inspection interval on Class 1 piping Systems: Pressurizer Auxiliary Spray Pressurizer Spray Pressurizer Relief Reactor Head Vent Refuel Level Indication Reactor Coolant Charging Letdown Low Pressure Safety Injection Shutdown Cooling Component(s): Thirty-three Reactor Coolant Pressure Boundary (RCPB) piping segments primarily- consisting of small bore < 2" Nominal Pipe Size (NPS) piping vents,, drains, and branch (VTDB) lines and connections. Additional segments are portions of larger diameter piping, 6"and 12" NPS, located between check valves and isolated, required to be isolated at operation or otherwise continually under pressure and monitored for pressure loss.

Details related to these piping segments are provided in Tables 1 through 3 of Section 4.0 and Attachment 1.

2. Applicable Code Edition and Addenda

ASME Section XI, 2004 Edition (No Addenda)

Page 1 of 9

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 (Continued) Docket No. 50-336

3. Applicable Code Requirement

IWB-2500, Table IWB-2500-1, Code Category B-P, Item Number B 15.10 requires that all Class 1 pressure retaining components be Visual, VT-2 examined each refueling outage. The required system leakage test is performed at a pressure not less than the pressure corresponding to 100% rated reactor power. Per IWB-5222(a), during the system leakage test, the pressure retaining boundary shall correspond to the RCPB, with all valves in the position required for normal reactor startup. The visual examination shall, however, extend to and include the second closed valve at the boundary extremity. Per IWB-5222(b), during the system leakage test conducted at or near the end of the interval, the pressureretaining boundary shall extend to all Class 1 pressure retaining components within the system boundary.

4. Reason for Request

The IWB-5222(b) system pressure test which is performed once per ten-year interval is the subject of this request. The IWB-5222(b) test requires that portions of the Class 1,system which are not normally pressurized to the reactor coolant system (RCS) pressure associated with 100% rated reactor power, be pressurized to that pressure. Reasons for this request are grouped in Component Groups 1 through 3 and described in Sections 4.1 through 4.3. The following is a summary list of names for these groups of piping segments.

Group Piping Segment Summary Name 1 Small bore < 2" NPS piping vents, drains, and branch (VTDB) lines and connections 2 Low Pressure Safety Injection (LPSI) header pipe segments 3 Shutdown Cooling (SDC) return line to the LPSI suction bypass line and SDC return line relief Page 2 of 9

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 (Continued) Docket No. 50-336 4.1 Component Group 1: "Small bore < 2" NPS piping vents, drains, and branch (VTDB)

.lines and connections in the Pressurizer (PZR)Spray, Pressurizer Auxiliary Spray and Relief, Reactor Coolant, Reactor (RX) Head Vent, Refueling Water Level Indication, Charging, Letdown, Low Pressure Safety Injection (LPSI)and Shutdown Cooling (SDC)

Systems" - The component Group 1 piping segments (1 through 23, 25, 27, 29, 31 and

33) are shown in Table 1. Additional details are in Attachment 1, Table 1.

Table 1: Affected Piping Segments of Group 1 Segment Description

() 1 Dia. Length Segment BoundaryI (in) (ft)

M2-1 PZR Spray Line Drain 2-RC-036A to,2-RC-037A 3/4 <1 M2-2 PZR Spray Line Drain 2-RC-036B to 2-RC-037B 3/4 < 1 RX Head Vent to Enclosure M2-3 2-RC-039 to 2-RC-413

• 3/4 < 1 Building Filtration System M2-4 Refuel Level Indication 2-RC-214 to 2-RC-433 3/4 <1 M2-5 Loop IA Hot Leg Drain 2-RC-215 to 2-RC-040 2 2 M2-6 Loop 2B RCP Suction Drain 2-RC-232 to 2-RC-035D 2 2 M2-7 Loop 2A RCP Suction Drain 2-RC-233 toW2-RC-035C .2 4i M2-8 Loop 1A Drain to Primary 2-RC-234 to 2-RC-035A 2 Drain Tank (PDT)

M2-9 Loop lB Drain to PDT. 2-RC-235 to 2-RC-035B 2 2 M2-10 RX Head Vent 2-RC-414 to 2-RC-415 1 <1 M2-11 RX Head Vent 2-RC-416 to 2-RC-417 1 1 M2-12 RX Head Vent Header Drain, 2-RC-426 to 2-RC-427 3/4 2 M2-13 PZR Spray line Vent 2-RC-015.io 2-RC-014 / 030 3/4 2 M2-14 PZR Relief Line Vent 2-RC-050 to 2-RC-051 3/4 2 M2-15 Loop 1A Charging Header 2-CH-679 to 2-CH-680 3/4 8 Vent M2- 16 Loop IA Charging Header 2-CH-681 to 2-CH-682 Drain M2-17 Loop 2A Charging Header 2-CH-684 to 2-CH-683 3/4 < 1 Vent M2-18 Loop 2A Charging Header 2-CH-685 to 2-CH-686 1 Drain M2-19 Aux Spray Line Charging 2-CH-699 to 2-CH-700 3/4 1 Header Drain I_ I_ _ 1 Page 3 of 9

is 10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 (Continued) Docket No. 50-336 Table 1: Affected Piping Segments of Group 1 Segment Description Segment Boundary () Dia.n) L th M2--20 Auxilia.ry Spray Line 2-CH-431 to 2-CH-697, 517 2,1 61 M2___20_ Auxiliary____Spray __Line _ and 752 M2-21 Letdown Dan2-CH-656Line Inlet Header to 2-CH-657 1< 1 Drain M2-22 Letdown Line Inlet Header 2-CH-652 to 2-CH-653 1< 1 Drain M2-23 Letdown Line Inlet Header 2-CH-654 to 2-CH-655 1< 1 Drain M2-25 Loop lA LPSI Header Drain 2-SI-024A to 024B 1 <1 M2-27 Loop 1B LPSI Header Drain 2-SI-013A to 2-SI-013B 1 <1 M2-29 Loop 2A LPSI Header Drain 2-SI-713A to 2-SI-713B 1 <1 M2-31 Loop 2B LPSI Header Drain 2-SI-712A to 2-SI-712B 1 <1 M2-33 SDC Return Line Drain 2-SI-1OOB to 2-SI-100A 1 2 NOTE: 1. The segment boundaries are described in terms of valve-to-valve.

Each of these VTDB lines and connections are equipped with at least one manual valve which provides an isolation point to obtain double isolation of the RCPB. These valves are generally maintained closed during normal operation. The piping outboard of the first isolation valve is not normally pressurized. Under normal operating conditions, these VTDB lines and connections, except for the LPSI VTDB lines and connections, are subject to RCS pressures and temperatures only if leakage through the inboard valves occurs. For the LPSI VTDB lines and connections, leakage at inboard valves will only result in pressures associated with the pressure of the safety injection tanks.

Because these VTDB lines and connections typically do not have test connections that allow them to be individually pressure tested without design modifications, it will be necessary to open the inboard valves to pressurize these VTDB lines and connections to perform the IWB-5222(b) system pressure test.. Pressurization by this method defeats the double isolation feature and presents significant personnel safety concerns for the personnel performing the test on the valves that are at normal RCS pressure and temperature.

Performing this test with the inboard isolation valves open requires several man-hours to position or cycle these valves for the test and restore the valves after the test is complete.

Most of these valves are located in close proximity to the RCS loop piping and thus require personnel entry into high radiation areas within containment. Based on previous As Low As Reasonably Achievable (ALARA) data, approximately 0.404 man-Rem of additional radiation exposure is expected from cycling the valves for testing. Since this test is performed near the end of an outage when all RCPB work has been completed, the time required opening and closing the valves on these VTDB lines and connections could impact the outage schedule.

Page 4 of 9

10 CFR 50.55a Relief Request RR-04-04, Serial No.10-323 (Continued) Docket No. 50-336 C

4.2 Comonent Group) 2: "Low Pressure Safety Injection (LPSI) header pipe segments" -

The component Group 2 piping segments (24, 26, 28 and 30) are shown in Table 2.

Additional details are in Attachment 1, Table 2.

Table 2: Affected Piping Segments of Group 2 Description Segment Boundary (1) Dia. Length Segment (in) (ft) 2-SI-706A to 2-SI-215, 12 40 M2-24 Loop 1A LPSI Header 2-SI-217, 2-SI- 618, and 6 169 2-SI-024B 1 76 1 <1 2-SI-706B to 2-SI-225, 12 45 M2-26 Loop 1B LPSI Header 2-SI-227, 2-SI-628, and 6 136 2-SI-013B 1 70 1 <1 2-SI-706C to 2-SI-235, 12 41 M2-28 Loop 2A LPSI Header 2-SI-237, 2-SI-638, and 6 24 2-SI-713B 1 60 1 <1 2-SI-706D to 2-SI-245, 12 49 M2-30 Loop 2B LPSI Header 2-SI-247, 2-SI-648, and 6 41 2-SI-712B 1 62 1 <1 NOTE: 1. Segment boundary is described in terms of valve-to-valve.

The pipe segments of Group 2 are part of the LPSI system at Millstone Power Station Unit 2 (MPS2) and are continuously pressurized because they are in the injection flow path from the safety injection'tanks.

In order to perform the IWB-5222(b) system pressure test on these pipe segments it would be necessary to connect jumpers circumventing the inboard check valve boundaries from the RCS. This is a significant personnel safety hazard that also results in unnecessary personnel radiation exposure.

Page 5 of 9

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 (Continued) Docket No. 50-336 4.3 Component Group 3: "Shutdown Cooling (SDC) Return Line to the LPSI Bypass Line and SDC Return Line Relief' - The component Group 3 Piping Segment (32) is shown in Table 3. Additional details are in Attachment 1, Table 3.

Table 3: Affected Piping Segments of Group 3 Segment Boundary _ _Dia* Length_

Segment Description (in) (ft)

SDC Return Line to LPSI 2-SI-651 to 2-SI-652, 12 36 M2-32 Suction Bypass Line and 2-SI-1OOB and RO-3664 3/4 9 SDC Return Line Relief 1 14 NOTE: 1. Segment boundary is described in terms of valve-to-valve unless otherwise annotated.

Piping Segment 32 is part of SDC. It cannot be pressurized to full RCPB pressure because of the pressure interlock and alarm that is associated with the SDC isolation valve 2-SI-652. Opening this valve is prevented when the RCS pressure exceeds 300 psig.

5. Proposed Alternative and Basis for Use The alternatives and basis for the MPS2 request are organized by component group discussions in the balance of this section. The provisions of 10 CFR 50.55a(a)(3)(i) permit requests for alternatives in some of these component groups because the request provides for an acceptable level of quality and safety. For other component groups, the provisions of 10 CFR 50.55a(a)(3)(ii) permit alternative requests when the specified requirements result in a hardship without a compensating increase in the level of quality and safety. The following list summarizes the application of these provisions in this request for relief. Refer to Tables 1 through 3 of both Section 4.0 and Attachment 1 for additional details regarding piping segment component groups and requested alternatives.

Group ' 10 CFR 50.55a Provision Section 1 (a)(3)(ii) 5.1 2 (a)(3)(i) 5.2 3 (a)(3)(ii) 5.3 5.1 Alternative and Basis for Component Group 1 MPS2 Group I Segmnents (1 through 23, 25, 27, 29, 31 and 33) are VTDB lines and connections that are equipped with manual valves, which provide double isolation of the RCPB. As an alternative to the IWB-5222(b) system pressure test requirements for these RCPB pipe segments, this request proposes to perform an ASME Code Section XI, Table IWB-2500-1 and IWB-522 1 system leakage test with the isolation valves in the normally Page 6 of 9

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 (Continued) Docket No. 50-336 closed position. This examination will be performed at the nominal operating pressure associated with 100% reactor power after satisfying the ASME Code required hold time.

Basis for approval of this alternative includes the following information:

5.1.1. The non-isolable portion of the RCPB VTDB lines and connections will be pressurized and will be visually examined as required. Only the isolable portion of these small diameter VTDB lines and connections will not be pressurized, but a VT-2 examination will still be performed in these cases.

5.1.2. A typical VTDB line and connection includes two manual valves or one manual valve, separated by a short piece of pipe or a pipe nipple, which is connected to the RCPB via another short pipe nipple. These connections are typically socket welded and the welds receive a surface examination after installation. The piping and valves are normally heavy-walled. The VTDB lines and connections are not subject to high or cyclic loads and design ratings are greater than RCPB operating pressure.

5.1.3. MPS2 uses the ASME Code Section XI, 2004 Edition (No Addenda) for itsSection XI Repair/Replacement program activities, but the requirements exclude components or connections NPS 1" and smaller from the pressure test requirement after welded repairs. Therefore, requiring a pressure test and visual examination of the NPS 1" and smaller of Group 1 Class 1 RCPB VTDB lines and connections once each 10-year interval is unwarranted considering that pressure testing a repair weld on the same connections is not required by the ASME Code,Section XI.

Considering this information and the personnel safety and radiation exposure ramifications that would result from meeting the ASME Code Section XI, 2004 Edition pressure test requirements, compliance with the pressure test requirements for Groups 1 RCPB VTDB lines and connections results in an unnecessary hardship without a sufficient compensating increase in the level of quality and safety. Therefore, DNC requests approval of this alternative pursuant to 10CFR50.55a(a)(3)(ii).

5.2 Alternative and Basis for Component Group 2 Group 2 Segments (24, 26, 28 and 30) are part of the LPSI system and are continuously pressurized and monitored for pressure loss because they are in the open injection flow path from the safety injection tanks. As an alternative to the pressure test requirements for these RCPB pipe segments, DNC proposes to use the pressure associated with the statically pressurized passive safety injection system.

The basis for approval of this alternatiVe includes the following information. On February 22, 2005, ASME approved Code Case N-73 1, "Alternative Class 1 System Leakage Test Pressure RequirementsSection XI, Division 1,," (see Attachment 2).

ASME concluded that detection of leakage from a through-weld or through-wall flaw is affected by pressure, temperature, and time, with time being the controlling factor.

Application of Code Case N-731 is limited to safety injection systems that must be under pressure for an entire operating cycle. Use of the pressure associated with the statically Page 7 of 9

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 (Continued) Docket No. 50-336 passive pressurized safety injection system is sufficient to prove leakage integrity for this piping. Because this alternative for Group 2 is specific to the LPSI piping at MPS2 that is continuously under pressure for the entire operating cycle, continually monitored for loss of pressure, and is included in the scope of the ASME approved Code Case N-73 1, use of this alternative provides an acceptable level of quality and safety. Therefore, DNC requests approval to use Code Case N-731 pursuant to 10 CFR 50.55a(a)(3)(i).

5.3 Alternative and Basis for Component Group 3 The MPS2 Class 1 RCPB pipe Segment 32 in Group 3 is part of the SDC system and is prevented from exceeding 280 psig by a pressure interlock on valve 2-SI-652. Additional protection is provided by a relief valve with a set point of 300 psig within the piping segment. The alternative to the IWB-5220 pressure is to examine this pipe segment at its normal operating pressure.

The basis for approval of this alternative is included in the following information:

The pressure interlock on valve 2-SI-652 and relief valve located within this pipe segment protect the SDC system from being over-pressurized by the RCS. To attempt to pressurize this segment to RCS pressure would require defeating the SDC system over-pressure protection, potentially endangering the plant.

Considering this information, the pressure testing requirements for Group 3 piping Segment 32 result in an unnecessary hardship without a sufficient compensating increase in the level of quality and safety. Therefore, DNC requests approval of this alternative pursuant to 10 CFR 50.55a(a)(3)(ii).

6.0 Duration of Proposed Alternative This relief is requested for the duration of the fourth inservice inspection (ISI) interval, which began on April 1, 2010, and is scheduled to end on March 31, 2020.

7.0 Precedents A similar Relief Request RR-89-56 was approved for MPS2 for use during the third inspection interval on September 27, 2007 (ADAMS Accession No. ML072620318).

A similar alternative to the ASME Code Section XI, 1989 Edition, IWB-5222 hydrostatic test requirements was approved for Indian Point Units 2 and 3 on December 7, 2005 (ADAMS Accession No. ML053110525). Additionally, a similar alternative to the 1998 Edition with the 2000 Addenda, IWB-5220 leakage test pressure for the 10-year ISI interval, was approved for Surry Units 1 and 2 on November 1, 2005 (ADAMS Accession No. ML052930032). Neither Indian Point nor Surry requested use of Code Case N-731 and the ASME Code edition differs for each request. However, the requirements of the ASME Code editions are similar and the requests resulted in not having to pressure test portions of the Class 1 RCPB to full RCS pressure and allowed reduced pressures for other piping segments.

Page 8 of 9

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 (Continued), Docket No. 50-336 8.0 References

1. 2004 Edition, ASME Code,Section XI, (No Addenda).

2. ASME Code Case N-73 1, "Alternative Class 1 System Leakage Test Pressure RequirementsSection XI, Division 1".

Page 9 of 9

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment 1 Docket No. 50-336 ATTACHMENT 1 ALTERNATIVE REGUEST RR-04-04 USE OF ALTERNATIVE CLASS 1 PRESSURE TEST REOUIREMENTS PIPE SEGMENT DETAILS OF COMPONENT GROUPS 1 THROUGH 3 Attachment 1, Page 1 of 7

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment 1 (Continued) Docket No. 50-336 TABLE 1- COMPONENT GROUP 1 PIPING DETAILS (4)

Dose Segment (2) Other ISI Savings Number (1) Drawing Line Number Examinations Request (3) Estimate (MR)

Relief is from using valve 2-RC-036A to M2-1 26014 sh. 1 3/4"-CCA-1 1 None pressurize downstream pipe and outboard 50 valve Relief is from using valve 2-RC-036B to M2-2 26014 sh. 1 3/4"-CCA-11 None pressurize downstream pipe and outboard 50 valve Relief is from using valve 2-RC-039 to M2-3 26014 sh. 1 3/4"-CCA-18 None pressurize downstream pipe and outboard 8 valve Relief is from using valve 2-RC-214 to M2-4 26014 sh. 1 3/4"-CCA-14 None pressurize downstream pipe and outboard 33 valve Relief is from using valve 2-RC-215 to M2-5 26014 sh. 1 2"-CCA-14 None pressurize downstream pipe and outboard 25 valve Relief is from using valve 2-RC-232 to M2-6 26014 sh. 1 2"-CCA-14 None pressurize downstream pipe and outboard 5 valve Relief is from using-valve 2-RC-233 to M2-7 26014 sh. 1 2"-CCA-14 None pressurize downstream pipe and outboard 17 valve Relief is from using valve 2-RC-234 to M2-8 26014 sh. 1 2"-CCA-14 None pressurize downstream pipe and outboard 7 valve Relief is from using valve 2-RC-235 to M2-9 26014 sh. 1 2"-CCA-14 None pressurize downstream pipe and outboard 5 valve Attachment 1, Page 2 of 7

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment I (Continued) Docket No. 50-336 TABLE 1 - COMPONENT GROUP 1 PIPING DETAILS (4)

Dose Segment(1)

Number Drawing Line Number (2) Other ISI Exmiaton Request Savings Estmat (MR)

Relief is from using valve 2-RC-414 to M2-10 26014 sh. 1 I"-CCA-18 None pressurize downstream pipe and outboard 10 valve Relief is from using valve 2-RC-416 to M2-11 26014 sh. 1 I"-CCA-18 None pressurize downstream pipe and outboard 0 valve Relief is from using valve 2-RC-426 to M2-12 26014 sh. 1 3/4"-CCA-18 None pressurize downstream pipe and outboard 10 valve Relief is from using valve 2-RC-015 to M2-13 26014 sh. 1 3/4"-CCA- 11 None pressurize downstream pipe and outboard 10 valve Relief is from using valve 2-RC-050 to M2-14 26014 sh. 2 3/4"-BCA-3 None pressurize downstream pipe and outboard 2 valve Relief is from using valve 2-CH-680 to M2-15 26017 sh. 1 3/4"-CCA-13 None pressurize downstream pipe and outboard 33 valve Relief is from using valve 2-CH-681 to M2-16 26017 sh. 1 I"-CCA-13 None pressurize downstream pipe and outboard 3 valve Relief is from using valve 2-CH-684 to M2-17 26017 sh. I 3/4"-CCA-13 None pressurize downstream pipe and outboard 42 valve Relief is.from using valve 2-CH-685 to M2-18 26017 sh. 1 I"-CCA-13 None pressurize downstream pipe and outboard 3 valve Attachment 1, Page 3 of 7

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment I (Continued) Docket No. 50-336 TABLE 1 - COMPONENT GROUP 1 PIPING DETAILS Segment (2) Other ISI Savings Number (1) Drawing Line Number Examinations Request )Estimate (MR)

Relief is from using valve 2-CH-699 to M2-19 26017 sh. 1 3/4"-CCA-12 None pressurize downstream pipe and outboard 17 valve 12-20 26017 sh. I 2"-CCA-12 None Relief is from using valve 2-CH-517 to 0 1 "-CCA-12 pressurize downstream pipe and valve.

Relief is from using valve 2-CH-656 to M2-21 26017 sh. 2 1"-CCA-16 None pressurize downstream pipe and outboard 17 valve Relief is from using valve 2-CH-652 to M2-22 26017 sh. 2 I"-CCA-16 None pressurize downstream pipe and outboard 20 valve Relief is from using valve 2-CH-654 to M2-23 26017 sh. 2 1'-CCA-16 None pressurize downstream pipe and outboard 3 valve Relief is from using valve 2-SI-024A to M2-25 26015 sh. 3 1'-CCA-6 None pressurize downstream pipe and outboard 10.

_valve Relief is from using valve 2-SI-013B to M2-27 26015 sh. 3 1"-CCA-6 None pressurize downstream pipe and outboard 8 valve Relief is from using valve 2-SI-713B to M2-29 26015 sh. 3 1"-CCA-6 None pressurize downstream pipe and outboard 5 valve Relief is from using valve 2-SI-712B to M2-31 26015 sh. 3 1 "-CCA-6 None pressurize downstream pipe and outboard 2 IValve Attachment 1, Page 4 of 7

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment I (Continued) Docket No. 50-336 TABLE 1 - COMPONENT GROUP 1 PIPING DETAILS Dose (4)

Segment Other ISI Savings Number (1) Drawing Line Number (2) Osther RSqe(MR (MR)

Relief is from using valve 2-SI-100A to M2-33 26015 sh. 3 1"-CCA-i0 None pressurize downstream pipe and outboard 5 valve NOTES

1. Schedule 160 is used for piping segments in Group 1. Piping segments are austenitic stainless steel, ASTM A-376, Type 316.

2. DesignPressure is 2485 psig; design temperature varies between 600F to 700F; Normal Operating Pressure: None - remains normally isolated.

3. Proposed Test Pressure: None

4. The estimated accumulated dose savings for the use of alternative requirements in all component groups from Request RR-04-04 is a total of 0.404 man-Rem at MPS2.

Attachment 1, Page 5 of 7

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment 1 (Continued) Docket No. 50-336 TABLE 2 - COMPONENT GROUP 2 PIPING DETAILS Dose (4)

Segment Drawing Line Number (1), (2) Other ISI Examinations Request (3) Savings Number Estimate (MR) 12"-CCA-5, 12"-CCB-11 (5) Welds BSI-C-1013, 1019, 1025, 1027, 1029 6"-CCA-6 (6) None Request IAW with M2-24 26015 sh. 3 None Code Case N-731 1"-CCA-5 None 1"-CCA-6 12"-CCA-5, 11 (5) 12"-CCB- Welds BSI-C-3012, 3016 M2-26 26015 sh. 3 6"-CCA-6 (6) None Request IAW with None Code Case N-731 I"-CCA-5 None I"-CCA-6 12"-CCA-5, 12"-CCB- Weld BSI-C-2011 11 (5) 6"-CCA-6 (6) Welds BSI-C-2031, 2033, 2037, 2039 Request IAW with M2-28 26015 sh. 3 Code Case N-731 I "-CCA-5 None None 1"-CCA-6 12"-CCA-5, 12"-CCB-11 (5) Weld BSI-C-4012 6"-CCA-6 (6) Welds BSI-C-4042,4044 Request IAW with M2-30 26015 sh. 3 None Code Case N-731 1"-CCA-5 None 1I-CCA-6 NOTES:

1. Schedule 160 is used for piping segments in Group 2, unless annotated otherwise by Note 5 (Schedule 140 piping), and Note 6 (Schedule 120 piping). Piping segments are austenitic stainless steel, ASTM A-376, Type 316.

2. Design Pressure is 2485 psig; design temperature is 600F; Normal Operating Pressure is 225 psig.

3. Proposed Test Pressure: 225 psig (approximated)

4. The estimated accumulated dose savings for the use of alternative requirements in all the component groups from Request RR-04-04 is a total of 0.404 man-Rem at MPS2.

5. 12" - Schedule 140 piping is used for these lines in Group 2.

6. 6" - Schedule 120 piping is used for these lines in Group 2.

Attachment 1, Page 6 of 7

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment I (Continued) Docket No. 50-336 TABLE 3 - COMPONENT GROUP 3 PIPING DETAILS (4)

Dose Segment Drawing Line Number (), (2) Other ISI Examinations Request (3) Savings Number Estimate (MR) 12"-CCA-10 (5)

M2-32 26015 sh. 3 3/4"-CCA-10 None Request to test at lower pressure I"-CCA-10 NOTES:

1. Schedule 160 piping is used, unless annotated otherwise by Note 5. Piping segments are austenitic stainless steel, ASTM A-376, Type 316.

2. Design Pressure is 2485 psig; design temperature is 650F; Normal Operating Pressure is 190 psig.

3. Proposed Test Pressure: 190 psig (approximated)

4. The estimated accumulated dose savings for the use of alternative- requirements in all the component groups from Request RR-04-04 is a total of 0.404 man-Rem at MPS2.

5. 12" - Schedule 140 piping is used for this line in Group 3.

Attachment 1, Page 7 of 7

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment 2 Docket No. 50-336 ASME CODE CASE N-731*, ALTERNATIVE CLASS 1 SYSTEM LEAKAGE TEST PRESSURE REOUIREMENTS SECTION XI. DIVISION 1*

(1 PAGE)

DOMINION MILLSTONE POWER STATION UNIT 2

• Reprinted from ASME 2007 BPVC, Code Cases, Nuclear Components, by permission of The American Society of Mechanical Engineers. All rights reserved.

Attachment 2, Page 1 of 2

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment 2 Docket No. 50-336 (Continued)

CASE CASES OF ASME BOILER AND PRESSURE VESSEL CODE N-731 Approval Date: February 22, 2005 The ASME Boiler and Pressure Vessel Standards Committee took action to eliminate Code Case expiration dates effective March 11, 2005. This means that all Code Cases listed in this Supplement and beyond will remain available for use until annulled by the ASME Boiler and Pressure Vessel Standards Committee.

Case N-731 injection system of a pressurizcd water. reactor, in lieu of Alternative Class 1 System Leakage Test Pressure the requirements of IWB-5221(a)?

RequirementsSection XI, Division I Reply: It is the opinion of the Committee that, for por-Inquiry: What alternative Class I system leakagc test tions of Class I safety injection systems that are continu-pressure requirements may be used for portions of Class ously pressurized during an operating cycle, the pressure I systems that are continuously pressurized during an associated with a statically-pressurized passive safety operating cycle by a statically-pressurized passive safety injection system of a pressurized water reactormay be used.

The Commlttee's function is to establish rules of safety, relating only to pressure integrity, governing tho construction of boilers. pressure vessols, transport tanks and nuclear components, and insorvsce Inspection for pressure Integrity-of nuclear components and transport tanks, and to interpret those rules when questions atise regarding their intent. This Code does not address other safety Issues relating to the construction of boilers, pressure vessels, transport tanks and nuclear components, and the Insarvice inspection Of nuclear components end transport tanks. The user of the Code should refer to other pertinent codes, standards, laws. regulations or other relevant documents.

I (N-731)

Attachment 2, Page 2 of 2

10 CFR 50.55a Relief Request RR-04-04 Serial No.10-323 Attachment 3 Docket No. 50-336 RELIEF REQUEST RR-04-04 USE OF ALTERNATIVE CLASS 1 PRESSURE TEST REQUIREMENTS PIPING AND INSTRUMENTATION DIAGRAMS Attachment 3, Page 1 of 6

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Serial No.10-323 Docket No. 50-336 ENCLOSURE 3 RELIEF REQUEST RR-04-05 USE OF ALTERNATIVE PRESSUREIFLOW TESTING REQUIREMENTS FOR SERVICE WATER SYSTEM BURIED PIPING SEGMENTS DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

10 CFR 50.55a Request Number RR-04-05 Serial No.10-323 Docket No. 50-336 Proposed Alternative In 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 Components Affected ASME Code Class: Code Class 3

Reference:

ASME Section XI, IWA-5244(b)

Examination Category: D-B Item Number: D2.10

Description:

MPS2 buried piping segments consist of two trains of buried 24" Service Water System (SWS) supply piping from the intake structure to the turbine building. This piping is cement lined, cast ductile-iron material with an additional epoxy lining applied utilizing an in-situ form process to enhance long-term life.

Components: The applicable piping line number is identified as follows: 24"-

KE-1 (Reference P&ID 25203-26008, Sheet 2. An excerpt of the P&ID drawing is provided in Attachment 1 for information only).

2. Applicable Code Edition and Addenda

ASME Section XI, 2004 Edition (No Addenda)

3. Applicable Code Reuuirement The 2004 Edition of ASME Section XI requires that for "Buried Components" the pressure test requirements of IWA-5244(b) will be applied as follows:

For buried components where a VT-2 visual examination cannot be performed, the examination requirement is satisfied by the following:

(1) The system pressure test for buried components that are isolable by means of valves shall consist of a test that determines the rate of pressure loss. Alternatively, the test may determine the change inflow between the ends of the buried components. The acceptable rate of pressure loss orflow shall be establishedby the Owner.

(2) The system pressure test for nonisolable buried components shall consist of a test to confirm thatflow during operation is not impaired.

(3) Test personnel need not be qualifiedfor VT-2 visual examination.

Page 1 of 3

10 CFR 50.55a Request Number RR-04-05 Serial No.10-323 (Continued) Docket No. 50-336

4. Reason for Request

An alternative is requested from performing the pressure test using the pressure loss or change in flow methods described in IWA-5244(b)(1) for the buried piping segments of the Millstone Power Station Unit 2 (MPS2) SWS on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The buried piping segments of the MPS2 Class 3 SWS piping are bounded by butterfly valves that are not designed or expected to provide an adequate leak tight boundary that is necessary for an accurate pressure decay test. Extensive maintenance or system modification would be required to conduct this test. For example, the valves would need to be replaced with valves that have better leakage control characteristics, or the valves would need to be removed from the system and blind flanges installed.

The configuration of the piping segments do not provide for a sufficient straight length of pipe to properly install a flowmeter for accurate flow measurement at the ends of the buried pipe segments. Therefore, it is not possible to compare a change in flow between the ends.of the buried components.

There is no annulus provided in which the areas at the ends of the buried components could be visually examined and there is no access to the buried sections without excavation.

5. Proposed Alternative and Basis for Use 5.1 Proposed Alternative Dominion Nuclear Connecticut, Inc. (DNC) proposes to use, as an alternative to the requirements of 1WA-5244(b)(1); a verification of unimpaired flow in accordance with IWA-5244(b)(2) to provide an acceptable level of quality and safety. For each segment of the subject buried pipe, periodic flow, testing will be 'performed in accordance with Inservice Test (IST) Program surveillarnce procedures. These surveillance procedures require flow to' be measured, recorded and compared to established acceptance criteria to provide the assurance that flow is not impaired during operation.

5.2 Basis for Use Flow testing of the three MPS2 SWS pumps is performed quarterly and will use the established minimum flow rate specified in the ISTprocedures as the acceptance criteria for the pressure testing of the associated SWS buried pipe segments. The flow rate is currently specified as 10300 gallons per minute (gpm).

If during the IST surveillances the minimum flows cannot be achieved, the pump(s) would be declared inoperable and a condition report initiated in accordance with the Millstone Power Station Corrective Action Program with further corrective actions, as required, to restore the pump(s) and/or system to an operable. status; Additionally, internal visual inspection is performed on the buried pipe segments periodically during plant refueling outages to ensure' the piping and lining are not Page 2 of 3

10 CFR 50.55a Request Number RR-04-05 Serial No.10-323 (Continued) Docket No. 50-336 experiencing unacceptable degradation. For MPS2 this visual inspection is currently performed on alternating trains each refueling outage.

5.3 Discussion on Acceptable Level of Quality or Safety or Hardship Without A Compensating Increase in the Level of Quality or Safety Based on the hardship described above and the use of inservice flow testing to verify that flow through the buried piping is unimpaired, and in conjunction with the periodic internal visual inspections, this alternative provides an acceptable level of quality and safety.

The hardship is considered to be without a compensating increase in the level of quality or safety for the following reasons:

. These surveillance procedures require flow to be measured, recorded and compared to established acceptance criteria to provide the assurance that flow is not impaired during operation.

Internal visual inspections ensure the piping or lining is not experiencing unacceptable degradation.

The verification of unimpaired flow in accordance with IWA-5244(b)(2) provides an acceptable level of quality and safety considering the proposed alternative and its basis for use.

6. Duration of Proposed Alternative This relief is requested for the duration of the fourth inservice inspection interval, which began on April 1, 2010, and is scheduled to end on March 31, 2020.

7. Precedents A similar relief request for the third interval at MPS2 (RR-89-57) was approved in a letter dated July 10, 2008 (Serial No. 08-0437), (ADAMS Accession No. ML081720069).

In addition, a similar request for relief of buried Service Water piping was previously approved for Byron Station, Units 1 and 2 (Relief 13R-07) and Braidwood Station Units 1 and 2 (Relief 12R-46) by letter dated January 16, 2007, (ADAMS Accession No. ML063260074).

Page 3 of 3

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- 13 I12 i. l 10 9 Attachment 1, Page 1 of 1

Serial No.10-323 Docket No. 50-336 ENCLOSURE 4 RELIEF REQUEST RR-04-06 USE OF PDI QUALIFIED PROCEDURES, PERSONNEL AND EQUIPMENT FOR NON-APPENDIX VIII RPV SHELL-TO-FLANGE WELD DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

10 CFR 50.55a Relief Request RR-04-06 Serial No.10-323 Docket No. 50-336 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

1. ASME Code Components Affected ASME Code Class: Code Class 1

References:

ASME Section XI, Table IWB-2500-1 ASME Section XI, Appendix VIII, Supplements 4 and 6, 10 CFR 50.55a(b)(xv).

Examination Category: B-A Item Number: B11.30

Description:

Implementation of Appendix VIII, Supplements 4 and 6 - Use of PDI Qualified Procedures, Personnel and Equipment for Non-Appendix VIII Reactor Pressure Vessel (RPV) Shell-to-Flange Weld Component: RPV Shell-to-Flange Weld No. FS- 1

2. Applicable Code Edition and Addenda

ASME Section XI, 2004 Edition (No Addenda).

ASME Section XI, 2001 Edition (No Addenda) for Appendix VIII per 10CFR50.55a(b)(2)(xv).

3. Applicable Code Requirement

The 2001 Edition (No Addenda) of the ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," Subsection IWA-2232, requires ultrasonic testing (UT) examinations be performed in accordance with Mandatory Appendix I.

Paragraph 1-21 10(b) of Mandatory Appendix I requires examination of the RPV shell-to-flange weld to be in accordance with ASME Code,Section V, Article 4.

4. Reason for Request

The use of this alternative will allow the use of Performance Demonstration Initiative (PDI) qualified procedures for performance of the UT examination of the RPV shell-to7flange weld from the vessel side of the weld in accordance with ASME Code,Section XI, Division 1, 2001 Edition (No Addenda), Appendix VIII, Supplements 4 and 6. This alternative would be used in lieu of Article 4 of Section V requirements.

Page 1 of 2

10 CFR 50.55a Relief Request RR-04-06 Serial No.10-323 (Continued) Docket No. 50-336

5. Proposed Alternative and Basis for Use Dominion Nuclear Connecticut, Inc. (DNC) proposes to perform UT examinations of the RPV shell-to-flange weld using procedures, personnel, and equipment that have been demonstrated and qualified in accordance with ASME Section XI, 2001 Edition (No Addenda), Appendix VIII, Supplements 4 and 6 as amended by 10 CFR 50.55a and the PDI Program. Since the examination will be performed from a single side due to the weld configuration, all procedures, personnel, and equipment will be qualified for single side access for examination of this weld.

Appendix VIII requirements were developed and adopted to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous, item-specific performance demonstration containing flaws of various sizes, locations, and orientations. The PDI process has established with a high degree of confidence, the capability of personnel, procedures, and equipment to detect and characterize flaws that could be detrimental to the structural integrity of the RPV. The PDI approach has demonstrated that for detection and characterization of flaws in the RPV, the UT examination techniques are equal to or surpass the requirements of the ASME Section V, Article 4 UT examination requirements. Though Appendix VIII is not required for the RPV shell-to-flange weld examination, the use of Appendix VIII, Supplements 4 and 6 criteria for detection and sizing of flaws in this weld will be equal to or exceed the requirements of ASME Section V, Article 4. Therefore, the use of the proposed alternative will continue to provide an acceptable level of quality and safety, and approval is requested pursuant to 10 CFR 50.55a(a)(3)(i).

6. Duration of Proposed Alternative This relief is requested for the duration of the fourth inservice inspection interval, which began on April 1, 2010, and is scheduled to end on March 31, 2020.

7. Precedents A similar Relief Request, RR-89-60, was approved for Millstone Power Station Unit 2 for use during the third interval in a letter from the NRC dated May 1, 2007 (ADAMS Accession No. ML070740465). In addition, a similar relief request (RR ISI-30) was approved for Union Electric Company for Callaway Plant, Unit 1 on April 7, 2004 (ADAMS Accession No. ML041.000516).

Page 2 of 2

Serial No.10-323 Docket No. 50-336 ENCLOSURE 5 RELIEF REQUEST RR-04-07 EXAMINATION CRITERIA FOR WELD OVERLAYS DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 Docket No. 50-336 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

1. ASME Code Components Affected ASME Code Class: Code Class 1

References:

WCAP- 14572, Revision 1-NP-A, Third Interval Relief Request RR-89-6 1, Revision 2 Examination Category: R-A Item Numbers: R1. 11 (Safe End-to-Pipe Welds)

RI. 15 (Nozzle-to-Safe End Welds)

Description:

Examination of Weld Overlays Components: Dissimilar metal piping welds with Alloy 82/182 weld metal and adjacent welds which have had a full structural weld overlay applied. See below for list of welds.

1. Weld No. BPS-C-1001: Weld overlay encapsulating 12-inch Loop 1 hot leg surge nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BPS-C-1003). Weld overlay applied during the spring 2008 refueling outage (2R18).

2. Weld No. BSD-C-2001: Weld overlay encapsulating 12-inch Loop 2 hot leg shutdown cooling nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BSD-C-2003). Weld overlay applied during the spring 2008 refueling outage (2R18).

3. Weld No. BSI-C-1001: Weld overlay encapsulating 12-inch Loop IA cold leg safety injection nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BSI-C-1003). Weld overlay applied during the fall 2009 refueling outage (2R19).

4. Weld No. BSI-C-2001: Weld overlay encapsulating 12-inch Loop 2A cold leg safety injection nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BSI-C-2003). Weld overlay applied.during the spring 2008 refueling outage (2R18)

5. Weld No: BSI-C-3000: Weld overlay encapsulating 12-inch Loop 1B cold leg safety injection nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BSI-C-3002). Weld overlay applied during the fall 2009 refueling outage (2R19).

6. Weld No. BSI-C-4000: Weld overlay encapsulating 12-inch Loop 2B cold leg safety injection nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BSI-C-4002). Weld overlay applied during the fall 2009 refueling outage (2R19).

Page 1 of 6

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 (continued) Docket No. 50-336

7. Weld No. BCH-C-1001: Weld overlay encapsulating 2-inch Loop IA cold leg charging nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BCH-C-1003). Weld overlay applied during the spring 2008 refueling outage (2R18).

8. Weld No. BCH-C-2001: Weld overlay encapsulating 2-inch Loop 2A cold leg charging nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BCH-C-2003). Weld overlay applied during the fall 2009 refueling outage (2R19).

9. Weld No. BPY-C-1001: Weld overlay encapsulating 3-inch Loop IA cold leg spray line nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BPY-C-1003). Weld overlay applied during the fall 2009 refueling outage (2R19).

10. Weld No. BPY-C-3000: Weld overlay encapsulating 3-inch Loop lB cold leg. spray line nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BPY-C-3002). Weld overlay applied during the fall 2009 refueling outage (2R19).

11. Weld No. BCD-C-1017: Weld overlay encapsulating 2-inch Loop 1A cold leg drain line nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BCD-C-1019). Weld overlay applied-during the fall 2009 refueling outage (2R19).

12. Weld No. BCD-C-2001: Weld overlay encapsulating 2-inch Loop 2A cold leg drain line nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BCD-C-2003). Weld overlay applied during the fall 2009 refueling outage (2R19).

13. Weld No. BCD-C-3000: Weld overlay encapsulating 2-inch Loop lB cold leg drain line nozzle-to-safe end dissimilar metal weld and the adjacent safe end-to-pipe weld (Weld No. BCD-C-3002). Weld overlay applied during the fall 2009 refueling outage (2R19).

2. Applicable Code Edition and Addenda

ASME Section XI, 2004 Edition (No Addenda)

3. Applicable Code Requirement

The inservice inspection of the subject welds was initially performed in accordance with ASME Section XI, IWB-2500, Examination Categories B-F and B-J.

An alternative to the ASME Section XI requirements for the inservice inspection (ISI) of Class 1 piping, Category B-J and B-F welds, was implemented during the third interval based on the risk-informed technology developed in accordance with the Westinghouse Owners Group Topical Report "WCAP-14572, Revision 1-NP-A." The request to use this alternative was submitted to the Nuclear Regulatory Commission (NRC) on November 10, 2003, with, approval received on April 1, 2005.

During the third interval, full structural weld overlays were applied to the'subject welds. ISI for the weld overlays was performed in accordance with Relief Request RR-89-6 1, Revision 2.

Note that all of the weld overlays addressed by this request have a minimum design life of 10 years.

Page 2 of 6

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 (continued) -Docket No. 50-336

4. Reason for Request

Currently, there are no NRC-approved, comprehensive criteria for a licensee for the

• performance of inservice examinations of'weld overlays, which have been applied as a repair or for preemptive measures, due to susceptibility of the underlying weld to primary water stress corrosion cracking (PWSCC).

The applications of the weld overlays at Millstone Power Station Unit 2 (MPS2) were performed in accordance with one time Relief Request RR-89-6 1, Revision 2, in the third interval based on the guidance of Code Cases N-504-3, N-638-1 and N-740. For the fourth interval, the subsequent examination of the weld overlays needs to be considered. Dominion Nuclear Connecticut, Inc. (DNC) proposes- to address the examination criteria for the weld overlays identified in Relief Request RR-89-6 1, Revision 2, as described below.

5. Proposed Alternative and Basis for Use 5.1 Each weld overlay that was applied during the spring 2008 refueling outage (2R 18) was examined during the fall 2009 refueling outage (2R19). The weld overlay examinations showed no indication of crack growth or new cracking. The weld overlays have been placed into a unique population within the ISI Program to be examined on a sample basis. Similarly, each weld overlay that was applied in the fall 2009 refueling outage (2R19) will be examined during the first or second refueling outage following the overlay application. If the weld overlay examinations show no indication of crack growth, they will likewise be placed into this unique population within the ISI Program and be examined on a sample basis. The weld overlay population will be added to the ISI Program as new welds in accordance with IWB-2412(b) and a 25 percent sample will be inspected. These new welds will be reclassified as examination category R-A, Item Number R 1.20 For weld overlays on cast austenitic stainless steel, the preservice and inservice examinations cannot be performed for the entire weld examination volume in accordance with ASME Section XI, Appendix VIII, Supplement 11. For these weld overlays, after the first inservice examination, the required examination volume will be ultrasonically examined each inspection interval until such time as ultrasonic examination is qualified to examine the cast austenitic stainless steel portion of the required inspection volume. The inspection of these weld overlays shall not be credited to satisfy the 25% inspection sample.

5.2 The 25% sample shall consist of the same welds in the same sequence during successive intervals to the extent practical provided the 25% sample contains the welds that experience the highest operating temperature in the inspection item. If hot leg and cold leg welds are included in the same inspection item, the initial 25% sample does not need to include the cold leg welds. Those welds not included in the 25% sample shall be examined prior to the end of the mitigation evaluation period.

Page 3 of 6

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 (continued) Docket No. 50-336 5.3 The examinations shall be volumetric (ultrasonic) and shall meet the applicable requirements of Appendix VIII. The requirements for the examination volume and required thicknesses shall be as described in Attachment 1, Figures 1(a), "Examination Volume in Full Structural Weld Overlays," and 1(b), "Definition of Thickness tj and t2 for Application of IWB-3514 Acceptance Criteria."

5.4 Acceptance Criteria 5.4.1 General 5.4.1.1 The volumetric examinations shall be evaluated by comparing the examination results with the acceptance standards in 5.4.2.

5.4.1.2 Volumetric examination results shall be compared with recorded results of the preservice examination and prior inservice examinations. Acceptance of welds for continued service shall be in accordance with 5.4.2.

5.4.2 Acceptance 5.4.2.1 Acceptance by Volumetric Examination 5.4.2.1.1 A weld whose volumetric examination confirms the absence of flaws shall be acceptable for continued service.

5.4.2.1.2 Flaws shall meet the acceptance standards of IWB-3514 or be accepted for continued service in accordance with 5.4.2.2 or 5.4.2.3.

5.4.2.1.3 A weld with new planar surface flaws or unexpected or unacceptable growth of existing flaws shall be accepted for continued service in accordance with the provisions of 5.4.2.2 or 5.4.2.3.

• 5.4.2.2 Acceptance by Repair/Replacement Activity 5.4.2.2.1 A weld whose volumetric examination reveals a flaw not acceptable for continued service in accordance with the provisions of 5.4.2.3 is unacceptable for continued service until the additional examinations of 5.4.3 are satisfied and the weld is corrected by repair/replacement activity. in accordance with IWA-4000.

5.4.2.2.2 For weld overlay examination volumes (Figure I (a)) with unacceptable indications in accordance with 5.4.2.3.2, the weld overlay shall be removed, including the original defective weld, and the weld shall be corrected by repair/replacement activity in accordance with'IWA-4000.

Page 4 of 6

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 (continued) Docket No. 50-336 5.4.2.3 Acceptance by Evaluation 5.4.2.3.1 Previously evaluated flaws that were mitigated by the full structural weld overlay need not be reevaluated nor have additional successive or additional examinations performed if new planar flaws have not been identified or the previously evaluated flaws have remained essentially unchanged.

5.4.2.3.2 A weld overlay whose volumetric examination detects planar flaw growth or new planar flaws that exceed the acceptance standards of IWB-3514 is acceptable for continued service without repair/replacement activity if the weld overlay meets the acceptance criteria of IWB-3600 and the additional examinations of 5.4.3 are performed in the current outage. The weld containing the flaw shall be reexamined in accordance with Table I of Code Case N-770-1. If a planar flaw is.detected in the outer 25% of the original weld/base metal thickness for the examination volume it, is acceptable for continued service if the crack growth calculations and structural design and sizing calculations required for original weld overlay acceptance show or are revised to show acceptability of the detected flaw. Any indication in the weld overlay material characterized as stress corrosion cracking is unacceptable.

5.4.3 Additional Examinations 5.4.3.1 Examinations of additional weld overlays during the current outage are required if unacceptable planar flaws are detected in the weld overlay thickness, or this examination reveals crack growth into the examination volume larger than predicted by the previous 5.4.2.3 analysis, or examination volumes reveal axial crack growth beyond the specified examination volume.

The number of additional weld examinations shall be equal to the number of weld overlays originally scheduled to be performed during the present inspection period. The additional examinations shall be selected from welds of similar materials, construction and the same or higher operating

'temperature.

5.4.3.2 If the additional examinations required by 5.4.3.1 reveal unacceptable flaws (5.4.2.3.2), the remaining weld overlays shall be volumetrically examined during the current outage.

6. Duration of Proposed Alternative This relief is requested for the duration of the fourth inservice inspection interval, which began on April 1, 2010, and is scheduled to end on March 31, 2020.

Page 5 of 6

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 (continued) Docket No. 50-336

7. Precedents A similar relief request (IR-3-05) to use the criteria in Code Case N-770 for ISI of weld overlays was approved for the third 10-year interval for Millstone Power Station Unit 3 on June 11, 2010 (ADAMS Accession No. ML101470099). The alternative requirements proposed in this request are derived from Code Case N-770- 1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities,Section XI, Division 1." Code Case N-770-1 has been approved by ASME. Only those requirements pertinent to the ISI of full structural weld overlays were used (Code Case N-770- 1, Table 1, Item F).

8. References 8.1 ASME Code,Section XI 2004 Edition, (No Addenda).

8.2 ASME Code Case N-770- 1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities,Section XI, Division 1" (Approved by ASME December 25, 2009).

8.3 Dominion Relief Request RR-89-6 1, Revision 2, "Supplement to Request RR-89-61 Revision 2, Alternative Repair and Mitigation Requirements for Structural Weld Overlays", dated October 9, 2009 (ADAMS Accession No. ML092890626).

8.4 NRC Letter, "Millstone Power Station Unit No. 2 - Relief Request RR-89-61, Revision 2, Regarding the Use of Weld Overlays as an Alternative Repair (TAC NO. ME 1765)",

dated October 15, 2009 (ADAMS Accession No. ML092870739):

8.5 NRC Letter, "Millstone Power Station Unit No. 2 - Relief Request RR-89-61 Regarding the Use of Weld Overlays as an Alternative Repair and Mitigation Technique (TAC NO.

MD6965)", dated May 8, 2008 (ADAMS Accession No. ML081150692).

8.6 Dominion Request for Relief RR-89-61 "Alternative Request RR-89-6 1, Use of Weld Overlays as an Alternative Repair and Mitigation Technique," dated October 4, 2007 (ADAMS Accession No. ML072780147).

8.7 Dominion Request for Relief IR-3-05, "Exam of Weld Overlays," dated April 28, 2009 (ADAMS Accession No. ML091310666).

Page 6 of 6

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 Attachment 1 Docket No. 50-336 Inservice Inspection Requirements For Full Structural Weld Overlay.

(Figures 1(a) and 1(b) are shown on the next page.)

(a) The weld overlay examination volume in Fig. 1(a) shall be ultrasonically examined to determine the acceptability of the weld overlay and to determine.if any new or existing cracks have propagated into the outer 25% of the original weld or base material or into the overlay. The angle beam shall be directed perpendicular and parallel to the piping axis, with scanning performed in four directions.

(b) The weld overlay shall meet the'inservice examination standards of IWB-3514. In applying the acceptance standards to planar indications, the thickness tl or t 2 , defined in Fig. 1(b), shall be used as the nominal wall thickness in IWB-3514, provided the base material beneath the flaw (i.e., safe end, nozzle, or piping material) is not susceptible to PWSCC. For susceptible material, tj shall be used. If the acceptance standards of IWB-

'3514 cannot be met, the weld overlay shall meet the acceptance standards of IWB-.3600.

Any indication characterized as stress corrosion cracking in the weld overlay material is unacceptable.

(c) As an alternative to (a) for inservice inspection, the weld examination volume in ASME Section XI, Figure IWB-2500-8(c) may be ultrasonically examined. If cracking is detected extending beyond the weld examination volume, the weld examination of (a) and (b) above shall be performed to determine the acceptability of the weld overlay.

(d) If inservice examinations of (a); (b), or (c) reveal crack growth, new cracking in the weld overlay, or outer 25% of original weld/base material meeting the acceptance standards, the weld overlay examination volume shall be reexamined during the first or second refueling outage following discovery of the crack growth or new cracking. The weld overlay examination volume shall be subsequently examined two additional times at the period of one or two refuelingoutages (i.e., a total of 3 examinations within 6 refueling outages).

(e) If the examinations required by (d) reveal that the'flaws remain essentially unchanged for three successive examinations, the weld examination schedule may revert to the sample and schedule of examinations identified in 5.1.

Attachment 1, Page 1 of 2

10 CFR 50.55a Relief Request RR-04-07 Serial No.10-323 Attachment 1 Docket No. 50-336

.(Continued)

Fig. 1(a): Examination Volume in Full Structural Weld Overlays Minimum 1,12 in.. (13 min) Mininmum 112 in. (13 nmm) (Nte 1)

Examination Volume A-B-C-D GENERAL NOTE: The weld includes the nozzle or safe end butter where applied.

NOTE 1: For axial and circumferential flaws, the axial extent of the examination volume shall extend at least /2 in.

(13 mm.) beyond the as-found flaw and at least 1/22 in. (13 mm.) beyond the toes of the original weld, including weld end butter, where applied, plus any PWSCC-susceptible base material in the nozzle and safe-end.

Fig. 1(b): Definition of Thickness tl and t2 for Application of IWB-3514 Acceptance Standards tiF G

t2 NOTES:

4 (a) Dimension "x" or "y" is equivalent to the nominal thickness of the nozzle end preparation or the pipe, respectively, being overlaid.

(b) The nominal wall thickness is t1 for flaws in E-F-G-H and t 2 for flaws outside E-F-G-H.

(c) For flaws that are in E-F-G-H and extend outside this volume, the thickness of t1 shall be used.

(d) The weld includes the nozzle or safe end butter, where applied, plus any PWSCC-susceptible base material in the nozzle and safe-end.

Attachment 1, Page 2 of 2

Serial No.10-323 Docket No. 50-336 ENCLOSURE 6 RELIEF REQUEST RR-04-08 ALTERNATIVE PRESSURE TESTING REQUIREMENTS FOR THE RPV FLANGE LEAK-OFF PIPING DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

10 CFR 50.55a Relief Request RR-04-08 Serial No.10-323 Docket No. 50-336 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)

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

1. ASME Code Components Affected ASME Code Class: Code Class 1

References:

ASME Section XI, Table IWB-2500-1 and IWB-5222 Examination Category: B-P (All Pressure Retaining Components)

Item Number: B 15.10

Description:

Alternative Pressure Testing Requirements for the Reactor Pressure Vessel (RPV) Flange Leak-Off Piping Components: NPS 3/4" RPV Flange Seal Leak-Off Piping

2. Applicable Code Edition and Addenda

ASME Section XI, 2004 Edition (No Addenda)

3. Applicable Code Requirement

IWB-2500, Table IWB-2500-1, Code Category B-P, Item Number B 15.10 requires that all Class 1 pressure retaining components be Visual, VT-2 examined each refueling outage. The required system pressure test can be either a hydrostatic test or a system leakage test. The system leakage test is performed at a pressure not less than the pressure corresponding to 100% rated reactor power. Per IWB-5222(a), the pressure retaining boundary during the system leakage test shall correspond to the reactor coolant boundary, with all valves in the position required for normal reactor operation startup. The visual examination shall, however, extend to and include the second closed valve at the boundary extremity. Per IWB-5222(b), the pressure retaining boundary during the system leakage test conducted at ornear the end of the interval shall extend to all Class 1 pressure retaining components within the system boundary.

4. Reason for Request

As discussed in Section 3, "Applicable Code Requirements," ASME Section XI, 2004 Edition (No Addenda) requires that Class 1 pressure boundary piping shall be pressure tested after each refueling outage. The RPV head flange seal leak detection piping is shown in Attachment 1. The piping is separated from the reactor coolant pressure boundary by one passive membrane, which is an o-ring located on the inner vessel flange. A second o-ring is located on the outside of the tap in the vessel flange. Failure of the inner o-ring is the only Page 1 of 3

10 CFR 50.55a Relief Request RR-04-08 Serial No.10-323 (Continued) Docket No. 50-336 condition under which this line is pressurized. Therefore, the line is not expected to be pressurized during the system pressure test following a refueling outage.

The configuration of this piping precludes system pressure testing while the vessel head is removed because the configuration of the vessel tap coupled with the high test pressure prevents the tap in the flange from being temporarily plugged or connected to other piping.

The opening in the flange is smooth walled, making the effectiveness of a temporary seal very limited. Failure of a temporary test seal could possibly cause ejection of the device used for plugging or connecting to the vessel flange.

The configuration also precludes pressurizing the line externally with the head installed. The top head of the vessel contains two grooves that hold the o-rings. The o-rings are held in place by a series of retainer clips that are housed in recessed cavities in the flange face. If a pressure test were to be performed with the head on, the inner o-ring would be pressurized in a direction opposite to its design function. This test pressure would result in a net inward force on the inner o-ring that would tend to push it into the recessed cavity that houses the retainer clips. The thin o-ring material would likely be damaged by the inward force.

Purposely failing or not installing the inner o-ring in order to perform a pressure test would require purchasing a new o-ring set. The time and radiation exposure associated with removing and reinstalling the RPV head to replace the o-rings would be an undue hardship.

Considering this information, compliance with the JWB-5222(b) system pressure test requirements results in unnecessary hardship without a sufficient compensating increase in the level of quality and safety.

5. Proposed Alternative and Basis for Use In lieu of the requirements of IWB-5222(b), a VT-2 visual examination will be performed each outage on the unpressurized subject piping as part of the Class 1 leakage test. If the inner o-ring should leak during the operating cycle it is identified by an increase in temperature of the leak-off line above ambient temperature. This high temperature actuates an alarm in the control room, which is closely monitored. Procedurally controlled operator actions allow identification of any further compensatory actions required. This leakage is collected in the primary drain transfer tank.

Additionally, the flange seal leak-off line is essentially a leakage collection/detection system and the line would only function as a Class 1 pressure boundary if the inner 0-ring fails, thereby pressurizing the line. If any significant leakage does occur in the leak-off line piping itself during this time of pressurization then it would clearly exhibit boric acid accumulation and be discernable during the proposed VT-2 visual examination that will be performed unpressurized as proposed in this request.

6. Duration of Proposed Alternative This relief is requested for the duration of the fourth inservice inspection interval, which began on April 1, 2010, and is scheduled to end on March 31, 2020.

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10 CFR 50.55a Relief Request RR-04-08 Serial No.10-323 (Continued) Docket No. 50-336

7. Precedents North Anna Power Station Unit 1 Relief Request SPT-013, "Examination Category B-P Pressure Retaining Components in the Reactor Coolant System," was approved by NRC letter dated February 9, 2006 (ADAMS Accession No. ML060450517).

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10 CFR 50.55a Relief Request RR-04-08 Serial No.10-323 Attachment 1 Docket No. 50-336 Relief Request RR-04-08 Reactor Pressure Vessel Seal Leak-Off Details DOMINION Millstone 2 Page 1 of 3

10 CFR 50.55a Relief Request RR-04-08 Serial No.10-323 Attachment 1 Docket No. 50-336 (Continued)

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Figure 1:

REACTOR PRESSURE VESSEL HEAD FLANGE LEAK-OFF LINE CONFIGURATION Page 2 of 3

10 CFR 50.55a Relief Request RR-04-08 Serial No.10-323 Attachment 1 Docket No. 50-336 (Continued)

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