ML14133A006
| ML14133A006 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/07/2014 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 14-194 | |
| Download: ML14133A006 (61) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 7, 2014 10 CFR 50.55a United States Nuclear Regulatory Commission Serial No.14-194 Attention: Document Control Desk NL&OS/GDM RO Washington, D. C. 20555 Docket No.
50-281 License No.
DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 FIFTH 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM AND ALTERNATIVE REQUESTS Pursuant to 10 CFR 50.55a(g)(4), Virginia Electric and Power Company (Dominion) submits the Inservice Inspection (ISI) Program for the Fifth 10-Year Inservice Inspection Interval for Surry Power Station (SPS) Unit 2 for Class 1, 2, and 3 Components and Component Supports. The ISI Plan, included in the attachment to this letter, describes the programmatic aspects of inservice examinations of components and component supports.
Dominion plans to utilize a full scope risk-informed application based on Code Case N-716 or Code Case N-716-1 and will address either by request for relief or utilization of the appropriate code case version as approved for use in Regulatory Guide 1.147.
By letter dated April 25, 2012 (Serial No.12-191), Dominion requested approval of Relief Request S2-15-ISI-01, "Fifth 10-year Inservice Inspection Interval ASME Section XI Code of Record," to permit the use of an earlier approved Code Edition, the 2004 Edition (No Addenda), as the Code of Record for the SPS Unit 2 Fifth 10-Year ISI interval. The NRC approved the relief request by letter dated April 29, 2013 [ADAMS Accession No. ML13100A049].
The SPS Unit 2 Fifth 10-Year ISI Interval will begin on May 10, 2014 and complete on May 9, 2024. As allowed by 10 CFR 50.55a(a)(3), alternatives to specific requirements of ASME Section Xl or 10 CFR 50.55a that provide an acceptable level of quality and safety and provide a methodology more conducive to the performance of an examination have been proposed.
Similarly, alternatives have been proposed when compliance with specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The proposed alternatives from specific Section Xl requirements are provided in Section 2 of the attachment. A previously submitted alternative request is also identified along with the associated NRC approval reference.
Serial No.14-194 Docket No. 50-281 Fifth Interval ISI Program and Requests Page 2 of 3 The SPS Unit 2 Fifth 10-Year Interval ISI Program and associated requests for the use of alternatives have been reviewed and approved by the station's Facility Safety Review Committee.
Dominion requests review and approval of the attached requests for the use of alternatives by April 30, 2015.
If you have any questions or require additional information, please contact Mr. Gary D.
Miller at (804) 273-2771.
Respectfully, Mark D. Sartain Vice President - Nuclear Engineering Commitments made in this letter: None
Attachment:
Surry Power Station Unit 2 Inservice Inspection Plan for Components and Component Supports, Fifth 10-Year Inservice Inspection Interval
Serial No.14-194 Docket No. 50-281 Fifth Interval ISI Program and Requests Page 3 of 3 cc:
U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Dr. V. Sreenivas, NRC Project Manager - North Anna and Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station
Serial No.14-194 Docket No. 50-281 Attachment VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN FOR COMPONENTS AND COMPONENT SUPPORTS FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL MAY 10, 2014 - MAY 9, 2024 Revision 0 April 2014
Serial No.14-194 Docket No. 50-281 Attachment TABLE OF CONTENTS Abstract ISI Classification Boundary Drawings Interval 5 ISI Correspondence Section 1 - Inservice Inspection Plan - General Section 2 - Inservice Inspection Plan for Components 2.3 Relief Requests for Components 2.4 Relief Requests for System Pressure Tests Section 3 - Inservice Inspection Plan for Component Supports Section 4 - Miscellaneous Documentation Section 5 - Limited Coverage Relief Requests Section 6 - Code Cases Utilized in the Fifth Inservice Inspection Interval Section 7 - Plan Changes Page Nos.
ii-iii iv-vii viii-ix 1-1 to 1-12 2-1 to 2-16 2-3 to 2-11 2-12 to 2-16 3-1 to 3-2 4-1 to 4-3 5-1 to 5-2 6-1 to 6-11 7-1 to 7-2 SPS U2 15-ISI Plan Revision 0
Serial No.14-194 Docket No. 50-281 Attachment ABSTRACT VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL MAY 10, 2014 THROUGH MAY 9, 2024 As required by 10 CFR 50.55a(g)(4)(ii), Dominion is required to update the Surry Unit 2 (SPS2) 120-month Inservice Inspection (ISI) Program to the latest Edition and Addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, approved by the NRC in 10 CFR 50.55a(b)(2) one year before the start of the new interval.
Relief Request S2-15-ISI-01, "Fifth 10-year Inservice Inspection Interval ASME Section XI Code of Record" was submitted by an April 25, 2012 letter (Serial No.12-191) and was approved by NRC letter dated April 29, 2013 [TAC ME 8775, ML13100A049] which allows an earlier approved Code Edition, the 2004 Edition (No Addenda), to be used as the Code of Record for the SPS2 Fifth 10-year Interval. Hereafter, the 2004 Edition of this Code, the ASME Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," will be referred to as the "2004 Code" or the "Code" in this document. The updated Program is scheduled to commence May 10, 2014 and complete on May 9, 2024.
In cases where the requirements of the 2004 Code have been determined impractical, requests for relief will be developed per 10 CFR 50.55a(g)(5). As allowed by 10 CFR 50.55a(a)(3) alternatives to specific requirements of ASME Section XI or 10 CFR 50.55a that provide an acceptable level of quality and safety and provide a methodology more conducive to the performance of an examination have been proposed. Similarly, alternatives have been proposed when compliance with specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The ISI Program is defined by the ISI Plan and the ISI Schedule. The ISI Plan provides an overview and summary of the SPS2 ISI Program for Subsections IWA, IWB, IWC, IWD, and, IWF of the Code.
To meet the requirements of ASME XI IWA-2420(a)(3), "the classification and identification of the components subject to examination and test," which defines elements to include in the ISI Plan, station controlled ISI Classification Boundary Drawings (CB/CBB/CBM series) have been developed for the Fifth 10-year Inspection Interval. The ISI Program boundaries, component classifications, and the employment of exemptions in IWB-1220, IWC-1220, IWD-1220, and IWF-1230 of the Code are shown on the ISI CB Drawings. The graphic codes, symbols and text used on the CBMs are detailed on 11 548-CB-LS-5, Legends and Symbols Drawing. Two additional sets of drawings are used to implement the ISI Plan: the 11 548-WMKS series and SPS U2 15-ISI Plan ii Revision 0
Serial No.14-194 Docket No. 50-281 Attachment the 11 548-SPB/SPM series. The 11 548-WMKS series identifies the components in the Program and their location in the plant. The locations of welds and supports are shown on these drawings. The ISI Schedule identifies which WMKS drawing is associated with each component in the Program. The 11 548-SPB/SPM series identifies the extent of the test zones used by the System Pressure Test (SPT) Schedule to complete the required surveillance system pressure tests.
The Inservice Inspection Schedule for Components and Component Supports (ISI Schedule) and the System Pressure Test Schedule (SPT Schedule) are provided in separate volumes of the ISI Program. System pressure tests are performed in accordance with the SPT Implementing Schedule. The IWE (Inservice Inspection of Class MC and CC Components) and IWL (Inservice Testing of Class CC Concrete Components) Programs are separate programs and are not included as part of the ISI Program. Steam generator inspections will continue to be performed in accordance with the Surry Plant Technical Specifications.
Components associated with the containment (IWE and IWL) have separate Plan and Schedule documents and are therefore excluded from the ISI Plan.
The Implementation Schedule is comprised of two Dominion documents. The first, the ISI Schedule, is prepared as a separate document from the ISI Plan. The ISI Schedule identifies by drawing the components selected for examination and testing, specifies examination category and item number for each component and the associated Code examination requirements, and provides a description of alternative examination methods and identification of components to be examined using alternative methods. The ISI Schedule also provides a list of examination procedures, identification of calibration blocks used for ultrasonic examination and the schedule for the examinations. The second, the SPT Schedule, details the implementation of the SPT Program. The ISI and the SPT Schedules, jointly, meet the documentation requirements of the Code given in IWA-2420(b) for defining the implementation schedule.
An alternative inspection plan to the ASME Section Xl requirements for the inservice inspection of Class 1, Category B-J and B-F, and Class 2, Category C-F-1 and C-F-2, piping welds has been prepared under the guidance of Code Case N-716, "Alternative Piping Classification and Examination Requirements, Section Xl, Division 1", and will either be submitted for approval by the relief request process or Dominion will adopt the appropriate revision of this Code Case when endorsed by the NRC in Regulatory Guide 1.147.
SPS U2 15-ISI Plan iii Revision 0
Serial No.14-194 Docket No. 50-281 Attachment ISI Classification Boundary Drawings The following is a list of the Classification Boundary Drawings. The component boundaries addressed in the ISI Plan, component classifications, and the employment of specific programmatic exemptions identified in IWB-1 220, IWC-1 220, IWD-1220, IWF-1 230, are shown on the ISI Classification Boundary Drawings (CB/CBB/CBM series). This is accomplished by the use of symbols as well as text on the drawings. The symbols used on these drawings are defined on the Legends and Symbols Drawing, 11 548-CB-LS-5. This drawing series, continuously updated and maintained, provides complete identification and classification of components subject to examination.
Drawing 11548-CB-LS-5, SH-001 11548-CBB-006A-5, SH-001 11548-CBB-047B-5, SH-001 11548-CBM-064A-5, SH-001 11548-CBM-064A-5, SH-002 11548-CBM-064A-5, SH-003 11548-CBM-064A-5, SH-004 11548-CBM-064B-5, SH-001 11548-CBM-066A-5, SH-002 11548-CBM-067A-5, SH-002 11548-CBM-068A-5, SH-001 11548-CBM-068A-5, SH-003 11548-CBM-068A-5, SH-004 11548-CBM-071A-5, SH-002 11548-CBM-071A-5, SH-003 11548-CBM-071B-5, SH-001 11548-CBM-071B-5, SH-002 11548-CBM-072A-5, SH-001 SPS U2 15-ISI Plan Revision 0
System Description
LEGEND & SYMBOLS AIR COOLING & PURGING SYSTEM FIRE PROTECTION MAIN STEAM MAIN STEAM MAIN STEAM MAIN STEAM STEAM GENERATOR NITROGEN CONN AUX STEAM & AIR REMOVAL CONDENSATE FEEDWATER FEEDWATER FEEDWATER CIRCULATING AND SERVICE WATER CIRCULATING AND SERVICE WATER CIRCULATING AND SERVICE WATER CIRCULATING AND SERVICE WATER COMPONENT COOLING WATER iv
Serial No.14-194 Docket No. 50-281 Attachment 11548-CBM-072A-5, SH-002 11548-CBM-072A-5, SH-003 11548-CBM-072A-5, SH-004 11548-CBM-072A-5, SH-005 11548-CBM-072A-5, SH-006 11548-CBM-072A-5, SH-007 11548-CBM-072B-5, SH-001 11548-CBM-072B-5, SH-002 11548-CBM-072B-5, SH-003 11548-CBM-072C-5, SH-001 11548-CBM-072C-5, SH-002 11548-CBM-075B-5, SH-002 11548-CBM-075C-5, SH-001 11548-CBM-075E-5, SH-001 11548-CBM-075J-5, SH-001 11548-CBM-082A-5, SH-002 11548-CBM-082A-5, SH-003 11548-CBM-083A-5, SH-001 11548-CBM-083A-5, SH-002 11548-CBM-083B-5, SH-001 11548-CBM-083B-5, SH-003 11548-CBM-084A-5, SH-001 11548-CBM-084A-5, SH-002 11548-CBM-084A-5, SH-003 11548-CBM-084B-5, SH-001 SPS U2 15-ISI Plan Revision 0 COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPONENT COOLING WATER COMPRESSED AIR COMPRESSED AIR COMPRESSED AIR CONTAINMENT INSTRUMENT AIR SAMPLING SAMPLING VENT AND DRAIN VENT AND DRAIN VENT AND DRAIN VENT AND DRAIN CONTAINMENT SPRAY CONTAINMENT SPRAY CONTAINMENT SPRAY RECIRCULATION SPRAY v
Serial No.14-194 Docket No. 50-281 Attachment 11548-CBM-084B-5, SH-002 11548-CBM-085A-5, SH-001 11548-CBM-085A-5, SH-002 11548-CBM-086A-5, SH-001 11548-CBM-086A-5, SH-002 11548-CBM-086A-5, SH-003 11548-CBM-086B-5, SH-001 11548-CBM-086B-5, SH-002 11548-CBM-086C-5, SH-001 11548-CBM-086C-5, SH-002 11548-CBM-087A-5, SH-001 11548-CBM-087A-5, SH-002 11548-CBM-088A-5, SH-001 11548-CBM-088A-5, SH-002 11548-CBM-088B-5, SH-001 11548-CBM-088B-5, SH-002 11548-CBM-088C-5, SH-001 11548-CBM-088C-5, SH-002 11548-CBM-089A-5, SH-001 11548-CBM-089A-5, SH-002 11548-CBM-089A-5, SH-003 11548-CBM-089B-5, SH-001 11548-CBM-089B-5, SH-002 11548-CBM-089B-5, SH-003 11548-CBM-089B-5, SH-004 SPS U2 15-ISI Plan Revision 0 RECIRCULATION SPRAY CONT VACUUM & LEAKAGE MONITOR CONT VACUUM & LEAKAGE MONITOR REACTOR COOLANT SYSTEM, LOOP-A REACTOR COOLANT SYSTEM, LOOP-B REACTOR COOLANT SYSTEM, LOOP-C REACTOR COOLANT REACTOR COOLANT REACTOR COOLANT REACTOR COOLANT RESIDUAL HEAT REMOVAL RESIDUAL HEAT REMOVAL CHEMICAL & VOLUME CONTROL CHEMICAL & VOLUME CONTROL CHEMICAL & VOLUME CONTROL CHEMICAL & VOLUME CONTROL CHEMICAL & VOLUME CONTROL CHEMICAL & VOLUME CONTROL SAFETY INJECTION SAFETY INJECTION SAFETY INJECTION SAFETY INJECTION SAFETY INJECTION SAFETY INJECTION SAFETY INJECTION vi
Serial No.14-194 Docket No. 50-281 Attachment 11548-CBM-1 18A-5, SH-001 11548-CBM-124A-5, SH-001 11548-CBM-124A-5, SH-002 11548-CBM-124A-5, SH-003 11548-CBM-130A-5, SH-001 11548-CBM-130B-5, SH-001 REACTOR CAVITY PURIFICATION STEAM GEN BLOWDOWN RECIRC & XFER STEAM GEN BLOWDOWN RECIRC & XFER STEAM GEN BLOWDOWN RECIRC & XFER RAD MONITOR CIRC & SERV WTR RAD MONITOR CONT PARTICULATE SPS U2 15-ISI Plan Revision 0 vii
Serial No.14-194 Docket No. 50-281 Attachment Surry Power Station Unit 2, Interval 5 ISI Correspondence Document Identification Status OutgoingiN R t.a Comments Ltr. No.
Date Component Relief Requests S2-15-ISI-01, "Fifth 10-year Inservice Inspection Approved 12-191 4/29/2013 Relief to use the 2004 Edition of Interval ASME Section Xl Code of Record" Section Xl as the Code of Record for fleet commonality.
S2-15-ISI-02, "Pressurizer Surge Nozzle Inner Submitted 14-194 Due to the physical configuration of Radius" the pressurizer, attached electrical equipment and local dose rates, it is not practical to perform the code required UT examinations of the surge nozzle to vessel weld and the associated nozzle-inside radius area.
SPS U2 15-ISI Plan Revision 0 viii
Serial No.14-194 Docket No. 50-281 Attachment Surry Power Station Unit 2, Interval 5 ISI Correspondence (Continued)
Document Identification Status Outgoing NRC Ltr.
Comments Ltr. No.
Date System Pressure Test Relief Requests S2-15-SPT-01, "System Pressure Test of Bottom of Submitted 14-194 It is not practical to perform the Reactor Vessel" VT-2 examinations on reactor vessel partial penetration welds and the bottom of the reactor vessel during a system leakage test.
Miscellaneous Documents Request to Use Subsequent Code 2007 Edition With Submitted 14-194 Category requirement for B-L-1 is 2008 Addenda for B-L-1 dropped from later code editions.
This inspection is no longer required.
Limited Coverage Relief Requests (Reserved for Later Use.)
SPS U2 15-ISI Plan Revision 0 ix
Serial No.14-194 Docket No. 50-281 Attachment Section 1 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN GENERAL FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL SPS U2 15-ISI Plan Revision 0 1-1
Serial No.14-194 Docket No. 50-281 Attachment 1.0 INSERVICE INSPECTION PLAN - GENERAL 1.1 General Information Surry Power Station Unit 2 (SPS2) is located on the James River in Surry County, Virginia.
The plant employs a three loop Pressurized Water Reactor (PWR) Nuclear Steam Supply System provided by Westinghouse Electric Corporation.
1.1.1 Fifth Inservice Inspection Interval As allowed by Title 10, Code of Federal Regulations, Part 50, Section 50.55a (10 CFR 50.55a), paragraph (g)(4)(iv) and approved by the NRC, the SPS2 Fifth 10-year ISI.Plan was updated to the 2004 Section XI Code.
The Fifth ISI Interval begins on May 10, 2014 and will continue through May 9, 2024. The Fifth ISI Interval is scheduled for a period of ten years. The dates for the inspection periods are scheduled as follows:
Period 1: May 10, 2014-May 9, 2017 Period 2: May 10, 2017 - May 9, 2021 Period 3: May 10, 2021 - May 9, 2024 1.1.2 Inservice Inspection Plan Description The ISI Plan contained herein addresses the examination and testing of Class 1, 2, and 3 components and the associated component supports. Applicable requirements of Subsections IWA, IWB, IWC, IWD, IWF and the associated Mandatory Appendices of the 2004 Code Edition are contained in the ISI Plan, ISI Schedule, and the SPT Plan. Additionally, the limitations specified in 10 CFR 50.55a(b)(2) applicable to SPS2 and the 2004 Code Edition have been incorporated into the Program. These requirements are detailed in Section 1.1.3.
This document is not intended to provide specific information on the implementation of the ISI Program. The intent of this document is to provide information on the scope of the SPS2 ISI Plan (e.g., its boundary and compliance with Section XI),
provide alternatives to the requirements of Section XI where appropriate, and identify those Section Xl requirements determined to be impractical.
The ISI and SPT Schedules provide information on the specific components selected for examination and test, including the category and item number, and the SPS U2 15-ISI Plan 1-2 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment examination or test to be performed. Unless stated otherwise, the extent of examination will be 100 percent of the Code required examination or test surface, volume or area.
1.1.2.1 Exclusion of Subsections IWE and IWL Subsections IWE, "Requirements for Class MC Components of Light-Water Cooled Power Plants," and IWL, "Requirements for Class CC Concrete Components of Light-Water Cooled Power Plants," have not been included in this ISI Plan. The programs to satisfy these requirements have been developed and are being implemented as required by the regulations. The implementation of the SPS2 IWE and IWL Programs is controlled separately by other ISI Programs separate from this plan.
1.1.2.2 Inspection Plans and Schedules The inspection plans and schedules required by IWA-2420 are comprised of this document, the ISI Plan, the ISI Schedule and the SPT Schedule.
These documents meet the requirements of IWA-2420.
1.1.2.3 Inspection Program Employed The ISI Plan forSPS2 utilizes the interval format of Inspection Program B, as defined in IWA-2432.
1.1.2.4 Classification and Identification of Components The construction permit for SPS2 was issued on June 25, 1968. At that time, the ASME Boiler and Pressure Vessel Code covered only pressure vessels. Piping, pumps and valves were built primarily to the rules of ASME B31.1, "Power Piping." Essentially, Surry Power Station was designed and constructed prior to the origination of the ASME Code classifications designated ASME Xl Class 1, 2, and 3. Therefore, the system classifications used as a basis for the ISI Program are based on the guidance set forth in 10 CFR 50 and Regulatory Guide 1.26, "Quality Group Classification and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants," and American Nuclear Standard ANSI/ANS-51.1. Pursuant to 10 CFR 50.55a (g)(1), inservice inspection requirements of Section Xl of the ASME Code are then assigned to these components within the constraints of existing plant design.
SPS U2 15-ISI Plan 1-3 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Classification Boundary Drawings (CBB/CBMs) documenting the system classifications were developed to aid in the review and implementation of the subject programs.
1.1.2.5 Components Exempt from Examination The application of the exemptions allowed by IWB-1 220, IWC-1 220, IWD-1220, and IWF-1230, and other paragraphs of the Code is also detailed on the 11 548-CBB/CBM drawings. This is accomplished by the use of symbols as well as text on the drawings. The legend for the symbols is provided on drawing 11548-CB-LS-5.
Additionally, the ISI Schedule and the System Pressure Test Schedule provide the Code Classification in accordance with the information provided on the CBB/CBM drawings.
1.1.2.6 Requests for Relief Where the requirements of ASME Section Xl are determined to be impractical, requests for relief are developed in accordance with 10 CFR 50.55a(g)(5)(iii). Where alternatives to the requirements of Section Xl are proposed, they are developed in accordance with the requirements of 10 CFR 50.55a(a)(3)(i) and/or (ii). Approval to use later code editions can be requested in accordance with 10 CFR 50.55a(g)(4)(iv). Requests for approval to use alternative requirements are presented in sets of requests for relief. There are four categories of requests for relief:
An ISI series for components and nondestructive examination requirements, An SPT series for system pressure testing requirements, An LMT series for limited examinations, and A CC series for Code Cases that are part of the ISI Plan but not approved by the NRC for industry use.
Limited examination requests for relief are necessary because SPS2 was not designed and constructed considering access for examination.
Consequently, it may not be possible to obtain 100 percent coverage for each required examination or test. Therefore, requests for relief seeking approval for limited coverage examinations or tests will be submitted throughout the interval and no later than one year after the interval end SPS U2 15-ISI Plan 1-4 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment date. (Note: Code Case N-460 will be utilized to the extent allowed to accept limited coverage examinations of Class 1 and Class 2 welds.)
1.1.2.7 ASME Section Xl Code Cases As allowed by 10 CFR 50.55a and/or USNRC Regulatory Guide 1.147, latest Revision approved, certain Code Cases have been incorporated into this Program. Additionally, certain Code Cases that have been approved by the Code, but have not yet been approved by the NRC, may be incorporated into the ISI Plan. Approval to use these unapproved Code Cases is requested as part of the request for relief process. Code Cases utilized as part of this ISI Plan are listed in Section 6.
1.1.2.8 Augmented Examinations Augmented examinations resulting from commitments made to the NRC may or may not involve components of the ISI Plan. The implementation of augmented examinations is in accordance with the applicable commitments and is achieved by programs and procedures maintained by either the SPS2 staff or the corporate engineering staff. However, some augmented examinations are part of the ISI Schedule for the purposes of scheduling and tracking the completion of the involved examinations. The inclusion of an augmented examination into the ISI Schedule does not make the examination part of the ISI Plan. Any augmented examination included in the ISI Schedule is identified as an augmented examination. Augmented examinations performed to satisfy commitments outside of Section Xl Code requirements do not require involvement of the Authorized Nuclear Inservice Inspector.
1.1.2 Repair/Replacement Program Repair/Replacement activity will be in accordance with SPS2 administrative procedures, as well as Dominion corporate administrative procedures. Together, these procedures assure compliance with the 2004 Edition of ASME Section XI.
Pressure testing required for ASME Section Xl repair/replacement activity will be conducted in accordance with the Repair/Replacement Program.
1.1.3 Code of Federal Regulations 10 CFR 50.55a Requirements 10 CFR Part 50.55a, Codes and Standards, establishes conditions for implementing this ISI Program. The following Table summarizes conditions, limitations and modifications noted as of the date of original submittal. Changes to this regulation SPS U2 15-ISI Plan 1-5 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment shall be implemented as required to the ISI Program over the course of the 10-year Interval.
CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS 10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications 10 CFR 50.55a(a)(3)
Proposed Alternatives. (3) Proposed alternatives to the requirements of paragraphs (c), (d), (e), (f), (g), and (h) of this section, or portions thereof, may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or Director, Office of New Reactors, as appropriate. Any proposed alternatives must be submitted and authorized prior to implementation. The applicant or licensee shall demonstrate that:
(i) The proposed alternatives would provide an acceptable level of quality and safety; or (ii) Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Quality Assurance. When applying Section XI editions and addenda later than the 1989 Edition, the requirements of NQA-1, "Quality Assurance Requirements for Nuclear Facilities," 1979 Addenda through the 1989 Edition, are acceptable as permitted by IWA-1400 of Section Xl, if the licensee uses its 10 CFR Part 50, Appendix B, quality assurance program, in conjunction with Section Xl requirements. Commitments contained in the licensee's quality assurance program description that are more stringent than those contained in NQA-1 must govern Section Xl activities.
Further, where NQA-1 and Section Xl do not address the commitments contained in the licensee's Appendix B quality assurance program description, the commitments must be applied to Section Xl activities.
Underwater Welding. The provisions in IWA-4660, "Underwater Welding," of Section Xl, 1997 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section, are not approved for use on irradiated material.
SPS U2 15-ISI Plan Revision 0 1-6
Serial No.14-194 Docket No. 50-281 Attachment CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS 10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications 10 CFR 50.55a(b)(2)(xiv)
Appendix VIII personnel qualification. All personnel qualified for performing ultrasonic examinations in accordance with Appendix VIII shall receive 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 on specimens that contain cracks. Licensees applying the 1999 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section may use the annual practice requirements in VII-4240 of Appendix VII of Section Xl 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 provided that the supplemental practice is performed on material or welds that contain cracks, or by analyzing prerecorded data from material or welds that contain cracks. In either case, training must be completed no earlier than 6 months prior to performing ultrasonic examinations at a licensee's facility.
Appendix VIII specimen set and qualification requirements.
Licensees using editions and addenda after 2001 Edition through the 2006 Addenda shall use the 2001 Edition of Appendix VIII, and may elect to comply with all of the provisions in paragraphs (b)(2)(xv)(A) through (b)(2)(xv)(M) of this section, except for paragraph (b)(2)(xv)(F) of this section, which may be used at the licensee's option. {See regulation for all provisions) 10 CFR 50.55a(b)(2)(xvi)
Appendix VIII single side ferritic vessel and piping and stainless steel piping examination. (A) Examinations performed from one side of a ferritic vessel weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. To demonstrate equivalency to two sided examinations, the demonstration must be performed to the requirements of Appendix VIII as conditioned by this paragraph and paragraphs (b)(2)(xv)(B) through (b)(2)(xv)(G) of this section, on specimens containing flaws with non-optimum sound energy reflecting characteristics or flaws similar to those in the vessel being examined.
(B) Examinations performed from one side of a ferritic or stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. To demonstrate equivalency to SPS U2 15-ISI Plan Revision 0 1-7
Serial No.14-194 Docket No. 50-281 Attachment CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS 10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications two sided examinations, the demonstration must be performed to the requirements of Appendix VIII as conditioned by this paragraph and paragraph (b)(2)(xv)(A) of this section.
Certification of NDE personnel. (A) Level I and II nondestructive examination personnel shall be recertified on a 3-year interval in lieu of the 5-year interval specified in the 1997 Addenda and 1998 Edition of IWA-2314, and IWA-2314(a) and IWA-2314(b) of the 1999 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section.
(B) When applying editions and addenda prior to the 2007 Edition of Section X1, paragraph IWA-2316 may only be used to qualify personnel that observe leakage during system leakage and hydrostatic tests conducted in accordance with IWA 5211 (a) and (b).
(C) When applying editions and addenda prior to the 2005 Addenda of Section Xl, licensee's qualifying visual examination personnel for VT-3 visual examination under paragraph IWA-2317 of Section XI, must demonstrate the proficiency of the training by administering an initial qualification examination and administering subsequent examinations on a 3-year interval.
Substitution of alternative methods. The provisions for substituting alternative examination methods, a combination of methods, or newly developed techniques in the 1997 Addenda of IWA-2240 must be applied when using the 1998 Edition through the 2004 Edition of Section Xl of the ASME B&PV Code. The provisions in IWA-4520(c), 1997 Addenda through the 2004 Edition, allowing the substitution of alternative methods, a combination of methods, or newly developed techniques for the methods specified in the Construction Code are not approved for use. The provisions in IWA-4520(b)(2) and IWA-4521 of the 2008 Addenda through the latest edition and addenda approved in paragraph (b)(2) of this section, allowing the substitution of ultrasonic examination for radiographic examination specified in the Construction Code are not approved for use.
SPS U2 15-ISI Plan Revision 0 1-8
Serial No.14-194 Docket No. 50-281 Attachment CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS 10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications 10 CFR 50.55a(b)(2)(xx)
System leakage tests. (B) The NDE provision in IWA-4540(a)(2) of the 2002 Addenda of Section Xl must be applied when performing system leakage tests after repair and replacement activities performed by welding or brazing on a pressure retaining boundary using the 2003 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section.
Table IWB-2500-1 examination requirements. (A) The provisions of Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels, Items B3.40 and B3.60 (Inspection Program A) and Items B3.120 and B3.140 (Inspection Program B) of the 1998 Edition must be applied when using the 1999 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section. A visual examination with 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, 1997 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section, with a limiting assumption on the flaw aspect ratio (i.e., a/1=0.5),
may be performed instead of an ultrasonic examination.
Surface Examination. The use of the provision in IWA-2220, "Surface Examination," of Section Xl, 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section, that allow use of an ultrasonic examination method is prohibited.
Evaluation of Thermally Cut Surfaces. The use of the provisions for eliminating mechanical processing of thermally cut surfaces in IWA-4461.4.2 of Section Xl, 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section are prohibited.
Incorporation of the Performance Demonstration Initiative and Addition of Ultrasonic Examination Criteria. The use of Appendix VIII and the supplements to Appendix VIII and Article 1-3000 of SPS U2 15-ISI Plan Revision 0 1-9
Serial No.14-194 Docket No. 50-281 Attachment CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS 10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications Section Xl of the ASME B&PV Code, 2002 Addenda through the 2006 Addenda is prohibited.
Mitigation of Defects by Modification. The use of the provisions in IWA-4340, "Mitigation of Defects by Modification," Section Xl, 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section are prohibited.
Pressure Testing Class 1, 2, and 3 Mechanical Joints. The repair and replacement activity provisions in IWA-4540(c) of the 1998 Edition of Section Xl for pressure testing Class 1, 2, and 3 mechanical joints must be applied when using the 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section.
Removal of Insulation. When performing visual examination in accordance with IWA-5242 of Section Xl of the ASME B&PV Code, 2003 Addenda through the 2006 Addenda, or IWA-5241 of the 2007 Edition through the latest edition and addenda incorporated in paragraph (b)(2) of this section, insulation must be removed from 17-4 PH or 410 stainless steel studs or bolts aged at a temperature below 1100 °F or 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.
Analysis of flaws. Licensees using ASME B&PV Code, Section Xl, Appendix A shall use the following conditions when implementing Equation (2) in A-4300(b)(1):For R < 0, AKI depends on the crack depth (a), and the flow stress (Of). The flow stress is defined by of = 11/2(Oys + Oult), where cy, is the yield strength and aut is the ultimate tensile strength in units ksi (MPa) and a is in units in. (mm). For -2 < R < 0 and K max - Kmin
< 0.8 x 1.12 of '/(Tra), S = 1 and AKI = Kmax. For R < -2 and Kmax
- Kmin < 0.8 x 1.12 orf /(Tra), S = 1 and AKI = (1 - R) Kmrax/3. For R < 0 and Kmax - Kmin > 0.8 x 1.12 of /(Tra), S = 1 and AKI = Kma.
Kmin.
SPS U2 15-ISI Plan Revision 0 1-10
Serial No.14-194 Docket No. 50-281 Attachment CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS 10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications 10 CFR 50.55a(b)(3)(v)
Subsection ISTD. Article IWF-5000, "Inservice Inspection Requirements for Snubbers," of the ASME B&PV Code, Section Xl, must be used when performing inservice inspection examinations and tests of snubbers at nuclear power plants, except as conditioned in paragraphs (b)(3)(v)(A) and (b)(3)(v)(B) of this section.
(A) Licensees may use Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Power Plants," ASME OM Code, 1995 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section, in place of the requirements for snubbers in the editions and addenda up to the 2005 Addenda of the ASME B&PV Code, Section Xl, IWF-5200(a) and (b) and IWF-5300(a) and (b), by making appropriate changes to their technical specifications or licensee-controlled documents. Preservice and inservice examinations must be performed using the VT-3 visual examination method described in IWA-2213.
(B) Licensees shall comply with the provisions for examining and testing snubbers in Subsection ISTD of the ASME OM Code and make appropriate changes to their technical specifications or licensee-controlled documents when using the 2006 Addenda and later editions and addenda of Section Xl of the ASME B&PV Code.
Inservice Inspection Code Cases: Licensees may apply the ASME Boiler and Pressure Vessel Code Cases listed in Regulatory Guide 1.147 through Revision 16, without prior NRC approval subject to the following:
(i) When a licensee initially applies a listed Code Case, the licensee shall apply the most recent version of that Code Case incorporated by reference in this paragraph.
(ii) If a licensee has previously applied a Code Case and a later version of the Code Case is incorporated by reference in this paragraph, the licensee may continue to apply, to the end of the current 120-month interval, the previous version of the Code SPS U2 15-1SI Plan Revision 0 1-11
Serial No.14-194 Docket No. 50-281 Attachment CODE OF FEDERAL REGULATIONS 10 CFR 50.55a REQUIREMENTS 10 CFR 50.55a Paragraphs Limitations, Modifications, and Clarifications Case as authorized or may apply the later version of the Code Case, including any NRC-specified conditions placed on its use.
(iii) Application of an annulled Code Case is prohibited unless a licensee previously applied the listed Code Case prior to it being listed as annulled in Regulatory Guide 1.147. Any Code Case listed as annulled in any Revision of Regulatory Guide 1.147 which a licensee has applied prior to it being listed as annulled, may continue to be applied by that licensee to the end of the 120-month interval in which the Code Case was implemented.
Impractical for Facility, Demonstrated Limitation. If the licensee has determined that conformance with a code requirement is impractical for its facility, the licensee shall notify the NRC and submit, as specified in § 50.4, information to support the determinations. Determinations of impracticality in accordance with this section must be based on the demonstrated limitations experienced when attempting to comply with the code requirements during the inservice inspection interval for which the request is being submitted. Requests for relief made in accordance with this section must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.
Impractical Code Requirement. Where the licensee determines that an examination required by Code edition or addenda is impractical, the basis for this determination must be submitted for NRC review and approval not later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.
SPS U2 15-ISI Plan Revision 0 1-12
Serial No.14-194 Docket No. 50-281 Attachment Section 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN COMPONENTS FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL SPS U2 15-ISI Plan Revision 0 2-1
Serial No.14-194 Docket No. 50-281 Attachment 2.0 INSERVICE INSPECTION PLAN FOR COMPONENTS 2.1 Program Description 2.1.1 The ISI Program for Class 1, 2 and 3 components meets the requirements of Section XI of the ASME Boiler and Pressure Vessel Code, 2004 Edition. Where these requirements are determined to be impractical, or where alternatives are identified in accordance with 10 CFR 50.55a(a)(3), specific requests for relief have been written and included in this section.
2.1.2 The Repair and Replacement Program uses the ISI boundary classifications from the ISI Program to determine the scope and applicability of the Program. Repair and Replacement activities shall be in accordance with administrative procedures, which assure compliance with the ASME Section Xl, Division 1, 2004 Code Edition.
2.2 Program Summary 2.2.1 For components other than those which are part of the Risk Informed Program, the ISI Plan utilizes tables IWB-2500-1, IWC-2500-1, IWD-2500-1, and IWF-2500-1 of the 2004 Edition of the ASME Section Xl Code to determine the components, component supports, or parts thereof that require examination; the examination requirement(s); the examination method(s); the acceptance standard; and the extent and frequency of examination.
2.2.2 Components selected for examination are identified in the ISI Schedule.
2.2.3 Examination requirements for steam generator tubes are provided in the plant Technical Specifications as directed in Table IWB-2500-1, Category B-Q.
2.2.4 Categories B-P, C-H, and D-B constitute the scheduled 10-year Interval pressure testing requirements. The following guidance will be utilized programmatically concerning pressure testing:
Pressure tests which meet the pressure, temperature, hold time, and VT-2 examination requirements of IWA-5000, IWB-5000, IWC-5000, IWD-5000 will be treated as complete for inspection scheduling purposes.
Pressure tests required for ASME Section XI repairs or replacements will be conducted in accordance with the 2004 Edition of ASME Section Xl or approved alternative.
SPS U2 15-ISI Plan 2-2 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Section 2.3 RELIEF REQUESTS FOR COMPONENTS SPS U2 15-ISI Plan Revision 0 2-3
Serial No.14-194 Docket No. 50-281 Attachment Virginia Electric and Power Company Surry Power Station Unit 2 Fifth 10-year Inservice Inspection Interval ASME Section XI Code of Record Relief Request S2-15-ISI-01 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
- 1. ASME (American Society of Mechanical Engineers) Code Components Affected ASME Section XI Class 1, 2 and 3 components and component supports
2. Applicable Code Edition and Addenda
2004 ASME Section XI Code Edition, No Addenda, for the Fifth 10-year Inservice Inspection (ISI) Interval
3. Applicable Code Requirement
Dominion is required to update the Surry Unit 2 120-month ISI Program to the latest Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section Xl, approved by the NRC in 10 CFR 50.55a(b)(2) one year before the start of the new interval.
10 CFR 50.55a(g)(4)(ii) presently states: "Inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of this section 12 months before the start of the 120-month inspection interval (or the optional ASME Code cases listed in NRC Regulatory Guide 1.147, Revision 16, that are incorporated by reference in paragraph (b) of this section), subject to the conditions listed in paragraph (b) of this section. However, a licensee whose inservice inspection interval commences during the 12 through 18-month period after July 21, 2011 may delay the update of their Appendix VIII program by up to 18 months after July 21, 2011."
Paragraph (b)(2) presently states: "As used in this section, references to Section XI refer to Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, and include the 1970 Edition through the 1976 Winter Addenda, and the 1977 Edition through the 2007 Edition with the 2008 Addenda, subject to the following conditions:"
SPS U2 15-ISI Plan 2-4 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment 4, Reason for Request Four Dominion nuclear operating units have started new 10-year inservice inspection intervals within the last three years:
Millstone Unit 3 Third Interval April 23, 2009 - April 22, 2019 Millstone Unit 2 Fourth Interval April 1, 2010 - March 31, 2020 North Anna Unit 1 Fourth Interval May 1, 2009 - April 30, 2019 North Anna Unit 2 Fourth Interval December 14, 2010 - December 13, 2020 Each of these four units updated their ASME Section XI ISI Programs to the 2004 Edition of ASME Section Xl as this was the latest edition incorporated by reference in the Code of Federal Regulations one year prior to the start of the new intervals.
The 2004 Edition was incorporated into the Final Rule on September 10, 2008, Volume 73, No. 176 of the Federal Register.
By Federal Register Volume 76, No. 119, dated June 21, 2011, the Code of Federal Regulations was amended to incorporate by reference the 2007 Edition with 2008 Addenda for ASME Boiler and Pressure Vessel Code, Section Xl, Division 1, superseding the 2004 Edition of ASME Section XI as the latest edition. Therefore; Dominion would be required to update the Surry Unit 2 Fifth 10-year Interval, which begins on May 10, 2014, to a code edition published at a date later than 2004.
ASME Section XI activities at the Millstone, North Anna and Surry Power Station units are standardized and corporately administered as a fleet operation at Dominion. Dominion ISI and Non-destructive Examination (NDE) personnel assist one another in the planning, performing, reporting and assessing of ISI activities throughout the fleet.
Maintaining a common ASME Section XI Code for the Dominion units and conforming to identical ASME Section XI rules would assist incorporation of industry best standards and would reduce administrative burden and error-likely situations.
A similar relief request is being submitted for Surry Unit 1 (Relief Request S1-15-1SI-01) to facilitate operation of the six units using a common ASME Section Xl Code (i.e., the 2004 ASME Section XI Code).
5, Proposed Alternative and Basis for Use Dominion proposes to use an ASME Section XI Code Edition that was incorporated and referenced in an earlier revision of the Code of Federal Regulations; specifically, the 2004 Edition of ASME Section Xl for the Surry Unit 2 Fifth 10-year ISI Interval and will continue to incorporate all current and future 10 CFR 50.55a conditions, limitations, modifications and augmented requirements.
Dominion will use only those ASME Code Cases applicable to the 2004 Edition of Section XI as listed in the SPS U2 15-ISI Plan 2-5 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment most recent revision of NRC Regulatory Guide 1.147, unless otherwise approved for use by relief from the NRC.
A detailed comparison between the 2004 Edition and the 2007 Edition/2008 Addenda was made. There were no changes noted that ensured or increased an acceptable level of quality and safety, nor were any changes made to address any type of deficiency in the 2004 Edition.
Dominion believes that commonality will improve the level of quality and safety at the fleet units by sharing common knowledge and lessons learned for ISI Programs governed by the same ASME Section Xl rules and will reduce error-likely situations.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), Dominion proposes to use an alternative to the ASME Boiler and Pressure Vessel,Section XI Code edition as specified by 10 CFR 50.55(b)(2) and use an earlier edition, the 2004 Edition with no Addenda, to establish the Surry Unit 2 Fifth 10-year ISI Interval.
As this code edition was previously incorporated and referenced for use by the Code of Federal Regulations and is presently in use at four other Dominion units, the alternative will provide an acceptable level of quality and safety.
6. Duration of Proposed Alternative
Dominion intends to use the 2004 Edition of ASME Section Xl in its entirety, subject to limitations and modifications of 10CFR50.55a, as the Code of Reference for the Surry Unit 2 ISI Program for the entire Fifth 10-Year ISI Interval. The Surry Unit 2 Fifth 10-Year ISI Interval is scheduled to begin May 10, 2014 and end May 9, 2024.
7. Precedents
Similar relief was granted to Entergy Operations, Inc. for Arkansas Nuclear One, Unit 2, by letter dated April 26, 2010, "Arkansas Nuclear One, Unit 2 - Request for Relief ANO2-lSI-003, Alternative to Use 2001 Edition through 2003 Addenda in lieu of the 2004 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section Xl (TAC No. ME1452)." [ML100970659]
SPS U2 15-ISI Plan 2-6 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 2 Fifth 10-year Interval Relief Request S2-15-ISI-02, Pressurizer Surge Nozzle Inner Radius 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 Component Affected Nozzle Inner Radius Section (Pressurizer Surge Nozzle)
Weld #
Component #
Drawing #
Class 15NIR 2-RC-E-2 11548-WMKS-RC-E-2 1
2. Applicable Code Edition and Addenda
ASME Section Xl, 2004 Edition, No Addenda
3. Applicable Code Requirement
The 2004 Edition of Section Xl does not require an examination of the nozzle-inside-radius section of the pressurizer surge nozzle. However, 10 CFR 50.55a(b)(2)(xxi) mandates use of the 1998 Edition of Section Xl for the examination requirements of 15NIR. Category B-D, Item B3.120 of the 1998 Edition requires a volumetric examination of the nozzle inside radius section of the pressurizer surge nozzle. 10 CFR 50.55a(b)(2)(xxi) allows an enhanced visual VT-1 on the inside surface in lieu of the volumetric requirement, which is performed from the outside surface.
4. Reason for Request
The Surry Power Station Unit 2 (SPS2) pressurizer surge line nozzle is integrally cast into the bottom pressurizer lower head. The nozzle is located under the pressurizer skirt and is surrounded by 78 heater penetrations. Interference from the heater penetrations and heater cables, as well as the location of the nozzle under the pressurizer skirt restricts access to the nozzle. This limits the examiner's ability to manipulate the search Unit to examine the nozzle inner radius (Figure 1).
The only viable ultrasonic technique currently available to examine nozzle inner radii involves the fabrication of calibration blocks that closely simulate the outer diameter (O.D.) and inner diameter (I.D.) nozzle geometry. This is necessary so that search units can be produced that will interrogate the inner radius section at precise angles. Also, to obtain meaningful results, the nozzle material grain structure must be such that an adequate signal-to-noise ratio can be obtained over a long metal path distance.
SPS U2 15-ISI Plan 2-7 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Integrally cast nozzles contain limitations such as an irregular O.D. profile, a rough surface condition, and an attenuating grain structure. The irregular surface condition causes the beam angle to vary from point to point around the nozzle. The attenuating grain structure results in a low signal-to-noise ratio at the nozzle inner radius. Limited access to the nozzle, as well as the limitations imposed by the material conditions, area dose rates, and the complicated nature of the examination technique, would make evaluation of any indications very difficult.
Access to the SPS2 pressurizer surge line nozzle is obstructed by insulation and the cables for the pressurizer heaters. Removal of the insulation and cables would be difficult as well as labor and time intensive. The exposure of the workers and technicians needed to perform the tasks is a real and relevant concern. It is almost certain that some, and possibly all, heater cables would have to be disconnected so that the cables can be pulled back to allow access for removing insulation and performing the exam. It is also likely that some cable or heater damage would occur during removal (Picture 1). If it is assumed that all 78 heater cables have to be disconnected and pulled back, the dose estimate is 56 man-rem. While actions would be taken to provide protection against the radiation, the large dose rate gradients in the under-pressurizer area present an unusual challenge. Temporary shielding is considered impractical in this situation because placement of the shielding material would obstruct and potentially preclude accessibility to the examination surface.
Other potential personnel safety concerns with this examination include the increased risk for an unplanned exposure event and the possibility of contamination with personnel wedged between the surge line and the exposed portion of the pressurizer heaters.
Other issues include actual accessibility after removal of the various forms of interference and the likelihood of difficulties in replacing the insulation to its original configuration. Furthermore, the amount of examination coverage would be dependent on the overall accessibility obtained.
In conjunction with license renewal, Westinghouse performed an evaluation to address the impact of operational transients for SPS2 to account for insurge/outsurge transients in addition to design transients in the pressurizer lower head. The results of the evaluation show that the Cumulative Usage Factor (CUF) for the nozzle inner radius is 0.29 (inside surface) and 0.11 (outside surface). These CUFs are considerably less than the design limit of 1.0 and provide insight into the potential for failure in this area.
Additionally, Dominion is unaware of an industry failure involving the inside radius section of the surge-line nozzle in a Westinghouse design pressurizer.
There are several uncertainties regarding an alternative examination of the inside surface of the pressurizer surge line area by use of a remote visual tool. Such an examination requires that a boroscope be fed through the manway and down through openings in the heater support baffles. Adding to the difficulty in performing such an exam, there is a perforated basket diffuser covering the surge nozzle opening on the inside of the pressurizer. The boroscope would need to be positioned through the support plates, and then threaded through a perforation in the basket diffuser, if possible, to the pressurizer surge line area (Figure 1). This examination would also be partially obscured by the thermal sleeve, which extends beyond the inside radius area into the volume of the pressurizer. These obstructions would need to be overcome several times in order to achieve the required examination coverage. Furthermore, the SPS U2 15-ISI Plan 2-8 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment resulting examination would only be of the cladding that covers the inside radius of the nozzle, which is considered to be only marginally beneficial in determining the structural integrity of the nozzle. Performing the visual inspection requires opening the Reactor Coolant System (RCS) and establishing access and foreign material exclusion controls.
The boroscope itself has the potential to become lodged inside the perforated basket diffuser or behind a pressurizer heater support plate. This inspection effort and the significant potential risk associated with it are not commensurate with the limited benefit that may be obtained from the inspection.
5. Proposed Alternative and Basis for Use
The pressurizer surge line nozzle-to-vessel inner radius section will be examined as part of the normally scheduled Class 1 system leakage test each refueling. In addition, the surveillance requirements of Technical Specifications that determine the RCS leak rate and the containment atmosphere radioactivity will be satisfied. These programs ensure that the overall level of plant quality and safety will not be compromised.
Any ultrasonic examination on this nozzle could only be described as "best effort." The benefit gained would not be commensurate with the difficulty and anticipated exposure estimate of 56 man-rem to perform this examination. An alternative examination employing a remote visual technology has very little if any reasonable probability of success. As such, permission to use the proposed alternative is requested per 10 CFR 50.55a(a)(3)(ii) since compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
6. Duration of Proposed Alternative
The proposed alternative to the ASME Code is applicable for the duration of the Fifth 10-year Inservice Inspection Interval at SPS2.
7. Precedents
Similar relief for the following nuclear units has been granted:
North Anna Power Station Unit 1, 2fld ISI Interval, TAC No. M71066 North Anna Power Station Unit 1 3 rd ISI Interval, TAC No. MA5750 North Anna Power Station Unit 2, 2 nd ISI Interval, TAC No. M79147 North Anna Power Station Unit 2, 3 rd ISI Interval, TAC No. MB2280 North Anna Power Station Unit 2, 4 th ISI Interval, TAC No. ME3292 Surry Power Station Unit 1, 3rd ISI Interval, TAC No. M87312 Surry Power Station Unit 2, 3 rd ISI Interval, TAC No. M89085 Surry Power Station Unit 1, 4 th ISI Interval, TAC No. MD3673 Surry Power Station Unit 2, 4 th ISI Interval, TAC No. MD3674 Byron Station Units 1 and 2, 2 nd ISI Interval, TAC Nos. M94830 and M94831 Haddam Neck Plant, 3rd ISI Interval, TAC No. M80457 Beaver Valley Power Station Unit 1, 4th ISI Interval, TAC No. ME1 108 Kewaunee Power Station, 4 th ISI Interval, ML050350225 TAC Nos. MC2497-MC2507, MC2509 North Anna Power Station Unit 1, 4 th ISI Interval TAC No. ME6263 SPS U2 15-ISI Plan 2-9 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment
$2-15-1SI-02 Figure 1 Power Relief and Safety Valve Nozzles Vessel Penetration Nozzle for Spray Line Instrument Nozzles Upper 7
Support Bracket Lifting Trunnion Top View Seismic Lug 78 Heater Elements Heater Support Baffles Bottom View Instrument Nozzles Circular Support Skirt Surge Basket Thermal Diffuser Sleeve Gr**-A KCB1672A PRESSURIZER SPS U2 15-ISI Plan Revision 0 2-10
Serial No.14-194 Docket No. 50-281 Attachment
%-4 C
SPS U2 15-ISI Plan Revision 0 2-11
Serial No.14-194 Docket No. 50-281 Attachment Section 2.4 RELIEF REQUESTS FOR SYSTEM PRESSURE TESTING SPS U2 15-ISI Plan Revision 0 2-12
Serial No.14-194 Docket No. 50-281 Attachment Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 2 Fifth 10-year Interval Relief Request S2-15-SPT-01, System Pressure Test of Bottom of Reactor Vessel Proposed Alternative In Accordance with 10 CFR 10.55a(a)(3)(ii)
-Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety-
- 1.
ASME Code Component Affected The component associated with this request is the Class 1 bottom area of the reactor vessel.
1.1 Category and System Details:
Code Class:
Class 1 System:
Reactor Coolant (RC)
Examination Category:
B-P Item Number:
B15.10 1.2 Component
Description:
Reactor Vessel
- 2.
Applicable Code Edition and Addenda
ASME Section Xl, 2004 Edition, No Addenda
- 3.
AD licable Code Reauirement Category B-P, Item No. B15.10 requires a visual (VT-2) examination of the bottom of the reactor vessel during the system leakage test of IWB-5220.
- 4.
Reason for Reauest To meet the Section Xl pressure and temperature requirements for the system leakage test of the reactor vessel, the reactor containment at Surry Power Station Unit 2 (SPS2) is required to be at sub-atmospheric pressure. Station administrative procedures require that self-contained breathing apparatus be worn for containment entries under these conditions. This requirement significantly complicates the visual (VT-2) examination of the bottom of the reactor vessel during testing. Access to the bottom of the reactor vessel requires the examiner to descend several levels by ladder and navigate a small entrance leading to the reactor vessel. In addition to these physical constraints, the examiner must contend with extreme environmental conditions, such as, elevated air SPS U2 15-ISI Plan 2-13 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment temperatures due to reactor coolant at temperatures above 500 degrees F and limited air circulation in the vessel cubicle.
The hardship arises less from the time constraint created by the use of bottled air or the involved radiation levels, but rather more from conditions that exist during the test. During the test the reactor coolant system is at the operational temperature of
> 500 degrees F and the containment is sub-atmospheric. Performing the examination in these conditions is complicated by the following factors:
The need to use a self-contained breathing apparatus (SCBA) with a full-face respirator.
The need to access the bottom of the vessel under sub-atmospheric conditions which requires the examiner to descend several levels by ladders and to navigate a small hatch wearing the SCBA.
The physical environment caused by the heat generated by a vessel elevated to a temperature of > 500 degrees F coupled with a lack of ventilation.
These factors increase the safety hazard associated with the examination. To place the examiner under this increased risk and burden is not justified. This combination of conditions does not exist during the refueling outage when the proposed alternative examination would take place. The proposed alternative examination would be performed under conditions that are safer and allow for a more thorough examination.
- 5.
Proposed Alternative and Basis for Use Dominion will continue to monitor for potential leakage on the bottom of the reactor vessel with other surveillance requirements and alarms. The applicable Technical Specification requirements will be satisfied through the Fifth 10-year Inspection Interval.
Surry Technical Specification (TS) 3.1.C permits 1 gpm unidentified and 10 gpm identified Reactor Coolant System (RCS) operational leakage; the following discussion is provided in the TS 3.1.C Bases:
Unidentified LEAKAGE - One gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air monitoring and containment sump level monitoring equipment can detect within a reasonable time period. Violation of this LCO [limiting condition for operation]
could result in continued degradation of the RCPB [reactor coolant pressure boundary], if the LEAKAGE is from the pressure boundary.
Identified LEAKAGE - Up to 10 gpm of identified LEAKAGE is considered allowable because LEAKAGE is from known sources that do not interfere with detection of unidentified LEAKAGE and is well within the capability of the RCS Makeup System. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and located sources, but does not include pressure boundary LEAKAGE or controlled reactor coolant pump (RCP) seal leakoff (a normal function not considered LEAKAGE). Violation of this LCO could result in continued degradation of a component or system.
SPS U2 15-ISI Plan 2-14 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Leakage originating from the bottom of the reactor vessel would be collected in the in-core sump room. The in-core sump room sump pump discharges to the containment sump. The in-core sump room sump and the containment sump level switches provide alarm indication and pump control signals. The high level alarm from the in-core sump and containment sump would alert control room operators of a high level condition. In addition, the daily leak rate calculations would identify an increase in unidentified leakage. The sensitivity to changes in leak rates is reflected in the procedure(s) that govern their performance. Leak rates are evaluated and trended on a daily basis.
Leakage exceeding action levels prompts entry into procedure(s) for identifying the source(s) of the increased leakage.
The containment atmosphere is monitored by gaseous and particulate radiation monitors with indication provided in the Main Control Room. Additionally, the containment atmosphere is sampled and analyzed for particulate, iodine, and noble gas on a monthly basis with the results being trended for any adverse indications.
Additionally, a visual examination (VT-2) is performed with the insulation in place for the bottom of the reactor vessel and is conducted in accordance with ASME Section Xl, IWA-5242(a), (b), and (c). This examination is conducted as soon as conditions allow entry into the in-core area during reactor shutdown. Adherence to the code requirements, which are also incorporated into site specific examination procedures, would identify leakage from the bottom of the reactor vessel. If leakage is detected, the appropriate actions in accordance with IWA-5250(a) and (b) would be taken. There are bottom mounted instrumentation penetrations that are included within the examination boundary.
The proposed alternative will ensure the overall level of plant quality and safety will not be compromised and eliminates the burden and hardship in performing the Code requirements.
There has been no Surry plant-specific or Dominion fleet OE regarding potential degradation of the bottom head of the reactor vessel due to known degradation mechanisms that would lead to leakage. Surry conducted voluntary volumetric examinations of the bottom mounted nozzles (BMNs) of Unit 1 in November 2004 and of Unit 2 in May 2005 with no issues identified. The Code Case N-722-1 bare metal examinations that are conducted every other refueling outage have also identified no issues.
The following is a list of primary water stress corrosion cracking (PWSCC) experience in BMNs (from EPRI Materials Reliability Program Document MRP-372).
Takahama Unit 1: A possible indication of PWSCC (< 1 mm) in the base metal of BMN No. 48 was detected through eddy current testing (ET) from the nozzle inner diameter (ID). The ET was performed prior to planned water jet peening of the nozzle ID. There have been no subsequent reports of detected indications in BMNs at Takahama Unit 1 or any other Japanese utility.
South Texas Project Unit 1: Leakage from BMNs No. 1 and 46 was identified during walkdowns to support the utility's Boric Acid Corrosion Control Program.
SPS U2 15-ISI Plan 2-15 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Non-destructive examination (NDE) did not reveal any other indications of PWSCC beyond the cracking in BMNs No. 1 and 46.
Gravelines Unit 1: Indications that are interpreted as PWSCC were detected via ultrasonic testing (UT) from the inside of the nozzles as part of the third 10-year inservice inspection (ISI). There was no evidence of boric acid deposits on the bottom head during the second and third ISIs. Electricit6 De France (EDF) is expanding the requirement for internal UT inspection of BMNs to all reactor vessels in the French fleet.
Palo Verde Unit 3: Leakage was observed at BMN No. 3 during Code Case N-722-1 examinations. Phased Array UT revealed no indications of wastage. The remaining nozzles showed no unacceptable indications.
The above indications or leakage was discovered when the systems were not at normal operating temperature or pressure. The proposed alternative continues performance of the ASME Code system leakage test; however, it will be performed in a habitable environment. Code Case N-722-1, B135.80, Reactor Pressure Vessel (RPV) bottom-mounted instrument penetrations, requires all penetrations to be examined every other refueling outage. The Code Case N-722-1 inspection requirements are fully implemented at SPS2. The required direct visual examination (VE) of the bare metal surface is performed with the insulation removed.
The request for alternative is for IWB-5221. The boundaries are unchanged, thus an alternative to IWB-5222 is not needed.
Therefore, Dominion requests approval of this alternative pursuant to the provisions of 10 CFR 50.55a(a)(3)(ii).
- 6.
Duration of Pronosed Alternative The proposed alternative to the ASME Code is applicable for the Fifth 10-year Interval at SPS2.
- 7.
Precedents Similar relief for the following has been granted:
Surry Unit 1, 4 th ISI Interval, TAC Nos. MB7762, MB7763, MB9528 Surry Unit 2, 4 th Interval, ADAMS Accession No. ML110250671 North Anna Unit 1, 4 th ISI Interval, TAC No. MD9956 North Anna Unit 2, 4 th Interval, TAC Nos. ME3311 through ME3316 SPS U2 15-ISI Plan 2-16 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Section 3 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN COMPONENT SUPPORTS FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL SPS U2 15-ISI Plan Revision 0 3-1
Serial No.14-194 Docket No. 50-281 Attachment 3.0 INSERVICE INSPECTION PROGRAM FOR COMPONENT SUPPORTS 3.1 Program Description The ISI Program for Class 1, 2 and 3 component supports meets the requirements of Section Xl of the ASME Boiler and Pressure Vessel Code, 2004 Edition.
3.2 Component Support Relief Requests Where requirements are determined impractical per 10 CFR 50.55a(g)(5) or where alternatives are identified in accordance with 10 CFR 50.55a(a)(3), specific requests for relief are written. NRC approved component support relief requests are included in this section.
3.3 Repair and Replacements Component supports are included in the Repair and Replacement Program and will comply with the requirements of ASME Section Xl, Division 1, 2004 Code Edition for repair and replacement of supports. The Repair and Replacement Program administrative procedures provide the Program requirements.
SPS U2 15-ISI Plan Revision 0 3-2
Serial No.14-194 Docket No. 50-281 Attachment Section 4 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN MISCELLANEOUS DOCUMENTATION FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL SPS U2 15-ISI Plan Revision 0 4-1
Serial No.14-194 Docket No. 50-281 Attachment Virginia Electric and Power Company (Dominion)
Surry Power Station Unit 2 Fifth 10-year Interval Request for Approval to Use a Subsequent American Society of Mechanical Engineers (ASME) Code Edition and Addenda for Examination Category B-L-1 in the Fifth Inservice Inspection (ISI) Interval Dominion requests NRC approval to use a subsequent ASME Code edition and addenda for the ASME Section Xl, Examination Category B-L-1 in the Fifth ISI Interval for Surry Power Station Unit 2. This request is consistent with NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl."
- 1.
ASME Code Component(s) Affected The affected ASME Section XI components are the Reactor Coolant Pump (RCP) casing welds (Category B-L-1).
- 2.
Applicable Code Edition and Requirements The applicable ASME Section Xl Code of Record for the Fifth ISI Interval for Surry Power Station Unit 2 is the 2004 Edition as approved by NRC letter dated April 29, 2013
[TAC No. ME8775].
- 3.
Proposed Subsequent Code Edition and Requirements The subsequent Code edition and addenda proposed for the Fifth Interval of the ISI Program for Examination Category B-L-1 is ASME Section Xl, 2007 Edition, including 2008 Addenda. The 2008 Addenda of Section XI has been incorporated into the regulations by reference, as published in the Federal Register on June 21, 2011 (76 FR 36232), and became effective July 21, 2011.
ASME Category B-L-1 welds were removed in the ASME Section Xl, 2007 Edition, 2008 Addenda because experience has not identified any failures in RCP casings. RCP casings are the only class 1 pumps at Surry Unit 2 that fall under the B-L-1 category.
The requirement for performing these examinations results in unnecessary radiation exposure for non-destructive examination (NDE) personnel. The RCP casing welds are not alloy 600/82/182 materials, but rather they were fabricated with a 1969 Westinghouse material SA-298 or SA-371.
Therefore, Dominion proposes to use the 2007 Edition through the 2008 Addenda for the Category B-L-1 welds in their entirety.
SPS U2 15-1SI Plan 4-2 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment
- 4.
Related Requirements For the portion of the subsequent Code edition and addenda to be used, there are no related requirements, modifications, or limitations listed in 10CFR50.55a that apply to Examination Category B-L-1, which was deleted from the proposed Code edition and addenda.
- 5.
Duration of Use of Proposed Subsequent Code Edition and Requirements This request is applicable for the Fifth 10-year IS[ Interval for Unit 2, which is scheduled to start May 10, 2014 and end May 9, 2024.
- 6.
Precedent Similar approval for use of a subsequent ASME Code edition and addenda for Examination Category B-L-1 was requested by Palo Verde Nuclear Generating Station Units 1, 2, and 3 in a letter, dated December 29, 2011,
Subject:
Request for Approval to Use a Subsequent ASME Code Edition and Addenda for Examination Categories B-L-1, B-M-1, and C-G in the Third ISI Interval. Approval was granted by an NRC letter, dated September 18, 2012,
Subject:
Palo Verde Nuclear Generating Station Units 1, 2, and 3-Request for Relief to Use a Later Edition of ASME Code, Section Xl, for Examination Categories B-L-1, B-M-1, and C-G (TAC Nos. ME7805, ME7806, and ME7807). Similar approval was also approved for Surry Units 1 and 2 Fourth ISI Intervals by Dominion letter request dated May 1, 2013 and approved by NRC letter dated August 27, 2013 (TAC Nos. MF1 805 and MF1806).
SPS U2 15-ISI Plan Revision 0 4-3
Serial No.14-194 Docket No. 50-281 Attachment Section 5 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN LIMITED COVERAGE RELIEF REQUESTS FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL SPS U2 14-ISI Plan Revision 0 5-1
Serial No.14-194 Docket No. 50-281 Attachment (RESERVED FOR LATER USE)
SPS U2 14-ISI Plan Revision 0 5-2
Serial No.14-194 Docket No. 50-281 Attachment Section 6 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN CODE CASES FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL SPS U2 15-ISI Plan Revision 0 6-1
Serial No.14-194 Docket No. 50-281 Attachment 6.0 CODE CASES 6.1 Mandatory Code Cases required by 10 CFR 50.55a(g)(6)(ii)(D)(1) and (E)(1) to augment the ISl Program:
Case N-729-1 "Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds, Section Xl, Division 1" The following conditions are required:
(1)
Note 9 of ASME Code Case N-729-1 shall not be implemented.
(2)
Instead of the specified 'examination method' requirements for volumetric and surface examinations in Note 6 of Table 1 of Code Case N-729-1, the licensee shall perform volumetric and/or surface examination of essentially 100 percent of the required volume or equivalent surfaces of the nozzle tube, as identified by Figure 2 of ASME Code Case N-729-1. A demonstrated volumetric or surface leak path assessment through all J-groove welds shall be performed. If a surface examination is being substituted for a volumetric examination on a portion of a penetration nozzle that is below the toe of the J-groove weld [Point E on Figure 2 of ASME Code Case N-729-1], the surface examination shall be of the inside and outside wetted surface of the penetration nozzle not examined volumetrically.
(3)
By September 1, 2009, ultrasonic examinations shall be performed using personnel, procedures and equipment that have been qualified by blind demonstration on representative mockups using a methodology that meets the conditions specified in (50.55a(g)(6)(ii)(D)(4)(i) through (50.55a(g)(6)(ii)(D)(4)(iv), instead of the qualification requirements of Paragraph -2500 of ASME Code Case N-729-1. References herein to Section XI, Appendix VIII shall be to the 2004 Edition with no Addenda of the ASME BPV Code.
I.
The specimen set shall have an applicable thickness qualification range of +25 percent to -40 percent for nominal depth through-wall thickness. The specimen set shall include geometric and material conditions SPS U2 15-ISI Plan 6-2 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment that normally require discrimination from primary water stress corrosion cracking (PWSCC) flaws.
II.
The specimen set must have a minimum often (10) flaws which provide an acoustic response similar to PWSCC indications. All flaws must be greater than 10 percent of the nominal pipe wall thickness. A minimum of 20 percent of the total flaws must initiate from the inside surface and 20 percent from the outside surface. At least 20 percent of the flaws must be in the depth ranges of 10-30 percent through wall thickness and at least 20 percent within a depth range of 31-50 percent through wall thickness. At least 20 percent and no more than 60 percent of the flaws must be oriented axially.
Ill.
Procedures shall identify the equipment and essential variables and settings used for the qualification, and are consistent with Subarticle VIII-2100 of Section Xl, Appendix VIII. The procedure shall be requalified when an essential variable is changed outside the demonstration range as defined by Subarticle Vil1-3130 of Section Xl, Appendix VIII and as allowed by Articles VIII-4100, VIII-4200 and VIII-4300 of Section Xl, Appendix VIII. Procedure qualification shall include the equivalent of at least three personnel performance demonstration test sets.
Procedure qualification requires at least one successful personnel performance demonstration.
IV.
Personnel performance demonstration test acceptance criteria shall meet the personnel performance demonstration detection test acceptance criteria of Table VIII-S10-1 of Section Xl, Appendix VIII, Supplement 10. Examination procedures, equipment, and personnel are qualified for depth sizing and length sizing when the root mean square (RMS) error, and the RMS as defined by Subarticle VIII-3120 of Section Xl, Appendix VIII, of the flaw depth measurements, as compared to the true flaw depths, do not exceed % inch (3 mm), and the error of the flaw length measurements, as compared to the true flaw lengths, do not exceed %
inch (10 mm), respectively.
(4)
If flaws attributed to PWSCC have been identified, whether acceptable or not for continued service under Paragraphs -
SPS U2 15-ISI Plan 6-3 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment 3130 or -3140 of ASME Code Case N-729-1, the re-inspection interval must be each refueling outage instead of the re-inspection intervals required by Table 1, Note (8) of ASME Code Case N-729-1.
(5)
Appendix I of ASME Code Case N-729-1 shall not be implemented without prior NRC approval.
Case N-722-1 "Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated With Alloy 600/82/182 Materials, Section Xl, Division 1" NOTE: The inspection requirements of ASME Code Case N-722-1 do not apply to components with pressure retaining welds fabricated with Alloy 600/82/182 materials that have been mitigated by weld overlay or stress improvement.
The following conditions are required:
(1) If a visual examination determines that leakage is occurring from a specific item listed in Table 1 of ASME Code Case N-722-1 that is not exempted by the ASME Code, Section Xl, IWB-1220(b)(1), additional actions must be performed to characterize the location, orientation, and length of crack(s) in Alloy 600 nozzle wrought material and location, orientation, and length of crack(s) in Alloy 82/182 butt welds.
Alternatively, licensees may replace the Alloy 600/82/182 materials in all the components under the item number of the leaking component.
(2) If the actions in paragraph (g)(6)(ii)(E)(2) of this section determine that a flaw is circumferentially oriented and potentially a result of primary water stress corrosion cracking, licensees shall perform non-visual NDE inspections of components that fall under that ASME Code Case N-722-1 item number. The number of components inspected must equal or exceed the number of components found to be leaking under that item number. If circumferential cracking is identified in the sample, non-visual NDE must be performed in the remaining components under that item number.
(3) If ultrasonic examinations of butt welds are used to meet the NDE requirements in paragraphs (g)(6)(ii)(E)(2) or (g)(6)(ii)(E)(3) of this section, they must be performed using SPS U2 15-ISI Plan 6-4 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment the appropriate supplement of Section Xl, Appendix VIII of the ASME Boiler and Pressure Vessel Code.
6.2 Other Code Cases utilized in the Fifth 10-year ISI Interval per Regulatory Guide 1.147:
Case N-432-1 Case N-460 Case N-504-4 "Repair Welding Using Automatic or Machine Gas Tungsten-Arc Welding (GTAW) Temper Bead Technique, Section Xl, Division 1" "Alternative Examination Coverage for Class 1 and Class 2 Welds, Section Xl, Division 1" "Alternative Rules for Repair of Class 1, 2, and 3 Austenitic Stainless Steel Piping,Section XI, Division 1" The following conditions are requirements for use:
The provisions of Section Xl, Nonmandatory Appendix Q, "Weld Overlay Repair of Class 1, 2, and 3 Austenitic Stainless Steel Piping Weldments," must also be met. In addition, the following conditions shall be met: (a) the total laminar flaw area shall not exceed 10% of the weld surface area, and no linear dimension of the laminar flaw area shall exceed the greater of 3 inches or 10% of the pipe circumference; (b) the finished overlay surface shall be 250 micro-in (6.3 micrometers) root mean square or smoother; (c) the surface flatness shall be adequate for ultrasonic examination; and (d) radiography shall not be used to detect planar flaws under or masked by laminar flaws.
"Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping, Section Xl, Division 1" The following condition is a requirement for use:
The repair or replacement activity temporarily deferred under the provisions of this Code Case shall be performed during the next scheduled outage.
Case N-513-3 Case N-516-3 "Underwater Welding, Section Xl, Division 1" The following condition is a requirement for use:
SPS U2 15-ISI Plan Revision 0 6-5
Case N-517-1 Case N-526 Case N-528-1 Case N-532-4 Case N-552 SPS U2 15-ISI Plan Revision 0 Serial No.14-194 Docket No. 50-281 Attachment Licensees must obtain NRC approval in accordance with 10 CFR 50.55a(a)(3) regarding the technique to be used in the weld repair or replacement of irradiated material underwater.
"Quality Assurance Program Requirements for Owners,Section XI, Division 1" "Alternative Requirements for Successive Inspections of Class 1 and 2 Vessels, Section Xl, Division 1" "Purchase, Exchange, or Transfer of Material Between Nuclear Plant Sites, Section Xl, Division 1" The following condition is a requirement for use:
The requirements of 10 CFR Part 21, "Reporting of Defects and Noncompliance" (Ref. 5), are to be applied to the nuclear plant site supplying the material as well as to the nuclear plant site receiving the material that has been purchased, exchanged, or transferred between sites.
"Alternate Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,Section XI, Division 1" "Alternative Methods - Qualification for Nozzle Inside Radius Section from the Outside Surface,Section XI, Division 1" The following conditions are requirements for use:
To achieve consistency with the 10 CFR 50.55a rule change published September 22, 1999 (64 FR 51370), incorporating Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," to Section Xl, add the following to the specimen requirements:
"At least 50 percent of the flaws in the demonstration test set must be cracks and the maximum misorientation must be demonstrated with cracks. Flaws in nozzles with bore diameters equal to or less than 4 inches may be notches."
Add to detection criteria, "The number of false calls must not exceed three."
6-6
Serial No.14-194 Docket No. 50-281 Attachment Case N-566-2 Case N-569-1 Case N-586-1 Case N-593 "Corrective Action for Leakage Identified at Bolted Connections, Section Xl, Division 1" "Alternative Rules for Repair by Electrochemical Deposition of Class 1 and 2 Steam Generator Tubing, Section Xl, Division 1" The following conditions are requirements for use:
NOTES: Steam Generator tube repair methods require prior NRC approval through the Technical Specifications. This Code Case does not address certain aspects of this repair, e.g., the qualification of the inspection and plugging criteria necessary for staff approval of the repair method. In addition, if the user plans to "reconcile," as described in Footnote 2, the reconciliation is to be performed in accordance with IWA-4200 in the 1995 Edition, 1996 Addenda of ASME Section Xl.
"Alternative Additional Examination Requirements for Classes 1, 2, and 3 Piping, Components, and Supports, Section Xl, Division 1,"
"Alternative Examinations Requirements for Steam Generator Nozzle to Vessel Welds, Section Xl, Division 1" The following condition is a requirement for use:
Essentially 100 percent (not less than 90 percent) of the examination volume A-B-C-D-E-F-G-H must be inspected.
"Requirements for Analytical Evaluation of Pipe Wall Thinning, Section Xl, Division 1" The following conditions are requirements for use:
(1) Code Case must be supplemented by the provisions of EPRI Nuclear Safety Analysis Center Report 202L-R2, April 1999, "Recommendations for an Effective Flow Accelerated Corrosion Program," for developing the inspection requirements, the method of predicting the rate of wall thickness. As used in NSAC-202L-R2, the term "should" is to be applied as "shall" (i.e., a requirement).
(2) Components affected by the flow-accelerated corrosion to which this Code Case is applied must be repaired or Case N-597-2 SPS U2 15-1SI Plan Revision 0 6-7
Serial No.14-194 Docket No. 50-281 Attachment replaced in accordance with the construction code of record and Owner's requirements or a later NRC approved edition of Section III, "Rules for Construction of Nuclear Power Plant Components," of the ASME Code prior to the value of tP reaching the allowable minimum wall thickness, tmin, as specified in -3622.1(a)(1) of this Code Case. Alternatively, use of the Code Case is subject to NRC review and approval per 10 CFR 50.55(a)(3).
(3) For Class 1 piping not meeting the criteria of -3221, the use of evaluation methods and criteria is subject to NRC review and approval per 10 CFR 50.55(a)(3).
(4) For those components that do not require immediate repair or replacement, the rate of wall thickness loss is to be used to determine a suitable inspection frequency so that repair or replacement occurs prior to reaching allowable minimum wall thickness, tmin.
(5) For corrosion phenomenon other than flow accelerated corrosion, use of the Code Case is subject to NRC review and approval. Inspection plans and wall thinning rates may be difficult to justify for certain degradation mechanisms such as MIC and pitting.
"Transfer of Welder, Welding Operator, Brazer, and Brazing Operator Qualifications Between Owners,Section XI, Division 1" "Ultrasonic Examination of Penetration Nozzles in Vessels, Examination Category B-D, Item Nos. B3.10 and B3.90, Reactor Nozzle-to-Vessel Welds, Figs. IWB-2500-7(a), (b), and (c),
Section Xl, Division 1" "Successive Inspections, Section Xl, Division 1" "Use of Fracture Toughness Test Data to Establish Reference Temperature for Pressure Retaining Materials, Section Xl, Division 1" "Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique, Section Xl, Division 1" The following conditions are requirements for use:
6-8 Case N-600 Case N-613-1 Case N-624 Case N-629 Case N-638-4 SPS U2 15-ISI Plan Revision 0
Serial No.14-194 Docket No. 50-281 Attachment (1) Demonstration for ultrasonic examination of the repaired volume is required using representative samples which contain construction type flaws.
(2) The provisions of 3(e)(2) or 3(e)(3) may only be used when it is impractical to use the interpass temperature measurement methods described in 3(e)(1), such as in situations where the weldment area is inaccessible (e.g., internal bore welding) or when there are extenuating radiological conditions.
Case N-639 "Alternative Calibration Block Material, Section Xl, Division 1" The following condition is a requirement for use:
Chemical ranges of the calibration block may vary from the materials specification if (1) it is within the chemical range of the component specification to be inspected, and (2) the phase and grain shape are maintained in the same ranges produced by the thermal process required by the material specification.
Case N-641 "Alternative Pressure-Temperature Relationship and Low Temperature Overpressure Protection System Requirements" Case N-643-2 "Fatigue Crack Growth Rate Curves for Ferritic Steels in PWR Water Environment, Section Xl, Division 1" Case N-648-1 "Alternative Requirements for Inner Radius Examination of Class 1 Reactor Vessel Nozzles, Section Xl, Division 1" The following conditions are requirements for use:
In place of a UT examination, licensees may perform 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 of Table IWB-3512-1 with limiting assumptions on the flaw aspect ratio. The provisions of Table IWB-2500-1, Examination Category B-D, continue to apply except that, in place of examination volumes, the surfaces to be examined are the external surfaces shown in the figures applicable to this table (the external surface is from point M to point N in the figure).
SPS U2 15-ISI Plan 6-9 Revision 0
Serial No.14-194 Docket No. 50-281 Attachment Case N-651 Case N-661-1 Case N-666 Case N-686-1 Case N-705 Case N-706-1 Case N-731 Case N-733 Case N-735 Case N-751 SPS U2 15-ISI Plan Revision 0 "Ferritic and Dissimilar Metal Welding Using SMAW Temper Bead Technique Without Removing the Weld Bead Crown for the First Layer,Section XI, Division 1" "Alternative Requirements for Wall Thickness Restoration of Classes 2 and 3 Carbon Steel Piping for Raw Water Service, Section Xl, Division 1" The following conditions are requirements for use:
(1) If the cause of the degradation has not been determined, the repair is only acceptable until the next refueling outage.
(2) When through-wall repairs are made by welding on surfaces that are wet or exposed to water, the weld overlay repair is only acceptable until the next refueling outage.
"Weld Overlay of Class 1, 2, and 3 Socket Welded Connections,Section XI, Division 1,"
"Alternative Requirements for Visual Examinations, VT-1, VT-2, and VT-3, Section Xl, Division 1" "Evaluation Criteria for Temporary Acceptance of Degradation in Moderate Energy Class 2 or 3 Vessels and Tanks, Section Xl, Division 1" "Alternative Examination Requirements of Table IWB-2500-1 and Table IWC-2500-1 for PWR Stainless Steel Residual and Regenerative Heat Exchangers, Section Xl, Division 1" "Alternative Class 1 System Leakage Test Pressure Requirements, Section Xl, Division 1,"
"Mitigation of Flaws in NPS 2 (DN 50) and Smaller Nozzles and Nozzle Partial Penetration Welds in Vessels and Piping by Use of a Mechanical Connection Modification, Section Xl, Division 1" "Successive Inspection of Class 1 and 2 Piping Welds, Section Xl, Division 1" "Pressure Testing of Containment Penetration Piping, Section Xl, Division 1" 6-10
Serial No.14-194 Docket No. 50-281 Attachment The following condition is a requirement for use:
When a 10 CFR 50, Appendix J, Type C test is performed as an alternative to the requirements of IWA-4540 (IWA-4700 in the 1989 edition through the 1995 edition) during repair and replacement activities, nondestructive examination must be performed in accordance with IWA-4540(a)(2) of the 2002 Addenda of Section Xl.
Case N-753 SPS U2 15-ISI Plan Revision 0 "Vision Tests, Section Xl, Division 1" 6-11
V Serial No.14-194 Docket No. 50-281 Attachment Section 7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PLAN PLAN CHANGES FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL SPS U2 15-ISI Plan Revision 0 7-1
f Serial No.14-194 Docket No. 50-281 Attachment 7.0 Plan Changes 7.1 Revision Summary (RESERVED FOR LATER USE)
SPS U2 15-ISI Plan Revision 0 7-2