ML15293A124

ASME Section XI Inservice Inspection Program Relief Requests for Limited Coverage Examinations Performed in the Fourth 10-Year Inservice Inspection Interval

ML15293A124
Person / Time
Site:	Surry
Issue date:	10/09/2015
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
15-446
Download: ML15293A124 (78)

Text

• i*'.'VIRGINIA ELECTRIC AND POWER COMPANY

-(q , RICHMOND, VIRGINIA 23261 October 9, 201510CR55a U.S. Nuclear Regulatory Commission Serial No.15-446 Attention: Document Control Desk SPS-LIC/CGL RI Washington, DC 20555 Docket No. 50-280 License No. DPR-32 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 ASME SECTION Xl INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONS PERFORMED IN THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL Virginia Electric and Power Company (Dominion) performed inservice inspection (ISI) examinations at Surry Power Station Unit I for the fourth 10-year ISI interval, which began on October 14, 2003 and ended on October 13, 2014. A one-year extension was applied to the end date of the fourth interval as allowed by ASME Section XI, IWA-2430(d). [

Reference:

Dominion letter Serial No.13-639 dated December 9, 2013 and NRC approval dated May 28, 2014]. Examinations of certain components conducted during the fourth interval received less than the required examination coverage.

Pursuant to 10 CFR 50.55a(g)(5)(iii), Dominion requests relief for limited examinations on the basis that the required examination coverage was impractical due to physical obstructions and limitations imposed by design, geometry and materials of construction of the subject components. Attachments 1 through 5 contain the specific relief requests and the basis for each request. These relief requests have been reviewed and approved by the station's Facility Safety Review Committee.

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

Si nce rely, Mark D. Sartain Vice President - Nuclear Engineering Commitments made in this letter: None

.a Serial No.15-446

• ', Docket No. 50-280 t* Relief Requests for Fourth Interval Limited Coverage Examinations Page 2 of 2 Attachments:

1. Relief Request LMT-R01, Category R-A, Risk Informed Piping Welds on Stainless Steel Piping

2. Relief Request LMT-R02, Category R-A, Risk Informed Piping Welds on Carbon Steel Piping

3. Relief Request LMT-R03, Category R-A, Risk Informed Dissimiliar Metal Welds on Steam Generator Nozzle to Safe-Ends

4. Relief Request LMT-P01, Category C-F-I and C-F-2, Preservice Weld Examinations

5. Relief Request LMT-C01, Category B-B, Pressurizer Shell to Head Circumferential and Longitudinal Welds 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 Ms. K. R. Cotton-Gross, NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Dr. V. Sreenivas, NRC Project Manager - North Anna 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

,I Serial No.15-446 Docket Nos. 50-280

'I Attachment I Relief Request LMT-RO1, Category R-A, Risk Informed Piping Welds on Stainless Steel Piping Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

• Serial No.15-446

~Docket No. 50-280

,* Relief Request LMT-R01 Attachment 1, Page 1 of 35 Relief Request LMT-R0I Risk Informed Pipe Welds Stainless Steel: Non-Alloy 600182/182 Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class 1 and 2 Examination Category: R-A, Risk Informed Piping Examinations Item Numbers: RI .11, Elements Subject to Thermal Fatigue RI1.16, Elements Subject to lntergranular Stress Corrosion Cracking Component Identification: Refer to Specific Table Material: Refer to Specific Table

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. Applicable Code Requirement

The examination requirements for piping welds for the Surry Power Station Unit 1 (SPS1) fourth 10-year inservice inspection interval were governed by the Risk Informed (RI) Inservice Inspection (ISI) Program as approved by NRC letter dated December 16, 1998. The SPSI fourth interval RI ISI Program is a full scope program covering ASME Section Xl Class 1, 2, and 3 components.

The pipe welds addressed by the RI ISI Program are assigned to a specific segment. The pipe segment definition includes the following considerations: 1) system, 2) pipe size, 3) flow junctions, 4) pipe failure consequence, and 5) isolation points for pipe breaks. The number of welds per segment varies. Examination is mandatory for some welds in a segment regardless of whether limited coverage will be attained. Other welds are sample selections, and an alternative weld may be chosen to replace the sample weld if the alternative weld could provide greater

,9 Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 2 of 35 examination coverage. Although not required by the RI 1SI Program, additional welds on the segment may be examined, in addition to the number of welds required by the risk informed analysis, to provide supplemental information for the segment.

The welds discussed in this section were selected for volumetric examination by the RI ISI Program due to the assigned item numbers: R1.11 for thermal fatigue or RI1.16 for intergranular stress corrosion cracking.

Neither the approved relief request nor the NRC Safety Evaluation for the RI ISI Program addressed an alternative for limited examination coverage. Therefore, the rules for ASME Section Xl shall apply when limitations are encountered due to the design, geometry and materials of construction of the component. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

10 CER 50.55a(b)(2)(xv)(A) requires the following examination coverage criteria when applying Supplement 2 to Appendix VIII:

(1) Piping must be examined in two axial directions. When examination in the circumferential direction is required, the circumferential examination must be performed in two directions provided access is available.

(2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full .coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.

10 CFR 50.55a(b)(2)(xvi)(B) requires that 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-sided examinations.

To demonstrate equivalency to two-sided examinations, the demonstration must be performed in accordance with the requirements of Appendix VIII as modified by 10 CFR 50.55a(b)(2)(xvi)(B) and §50.55a(b)(2)(xv)(A).

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%

volumetric examination coverage requirements for the subject austenitic welds due to the geometric configurations which limit the volumetric coverage that can be obtained.

When the examination area is limited to one side of an austenitic weld, examination

• Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 3 of 35 coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B). Therefore, full coverage credit may not be claimed.

The subject welds were examined with a manual ultrasonic (UT) technique using pulse echo ultrasonic instruments and search units to achieve the maximum practical examination coverage. Personnel, equipment and procedures were qualified in accordance with ASME Section Xl, Appendix VIII as implemented by the Performance Demonstration Initiative (PDI).

There are currently no PDI qualified single-sided examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to U.S. nuclear applications.

PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single-sided examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single-side qualification to demonstrate that the examiners' qualification and the subsequent weld examination is based on application of the best available technology.

In some of the earlier UT examinations performed in the first period of the fourth interval at SPS1 (October 14, 2003 - October 13, 2006), reporting "Best Effort" coverage when encountering single-sided limitations on austenitic steel material was not routine practice. Refracted longitudinal (RL) wave was typically used to investigate the far side of the weld to the greatest extent possible if the thickness of the pipe was greater than 0.5 inches. For piping 0.5 inches in thickness or less, a 70 degree examination angle is used to interrogate the far side of the weld. Any indications seen with the RL or the additional angle used would have been noted and investigated.

The required examination volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative techniques or advanced technologies were considered feasible and/or capable of obtaining complete coverage of the examination volume.

a. The 1-12 welds are the reactor coolant pump (RCP) to pipe welds for the three RCPs. Details are provided in Table 4a. The 1-12 welds fall within High Safety Significance (HSS) RI segments RC-010, RC-O011, RC-012 for Loops A, B and C, respectively, with a postulated failure mechanism of thermal fatigue. For each of the three segments, one sample weld (1-12) is required. Only one alternate weld exists on each of the individual segments, weld 1-13, which is a pipe to motor operated valve weld. The UT scanning area would also be restricted to one side

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 4 of 35 of weld 1-13 due to the pipe to valve configuration and would provide approximately 50% coverage similar to the 1-12 weld coverage. Due to the excessively high dose rates in this area, it is not feasible to attempt examination of the 1-13 welds which would offer, at best, only 50% coverage.

During the earlier years of the first period in the fourth 10-year inspection interval, scan diagrams were not prepared at the time of examination. Data was only recorded in tabular format as shown in Figure 4a of this attachment.

There were no recordable indications (NRI).

TABLE 4a Reactor Coolant Pump to Pipe Welds Drawing / Line# / IDI Weld System I Class Pipe PpDi.Tckes Coverage Limitation I Fig. No. /

Risk Informed Material PpDi.Tckes Achieved Results Pg. No.

Segment (Nominal) 48%

11448-WMKS-O100AZ-1 ASTM 45 and 60 Single-sided, 27.5"-RC-3-2501R /1-12 A-376, 2." .5" degree pipe to pump 4a Reactor Coolant / I Type 2.".5" shear wave I Segment RC-010 316 used, 60 NRI degree RL also used 48%

11448-WMKS-0101AZ-1 ASTM 45 and 60 Single-sided, 27.5"-RC-6-2501 R / 1-12 A-376, 27.5" 2.56" degree pipe to pump 4a Reactor Coolant /I Type shear wave 2 Segment RC-011 316 used, 60 NRI degree RL also used 48%

11448-WMKS-0102AZ-1 ASTM 45 and 60 Single-sided, 27.5"-RC-9-2501 R / 1-12 A-376, 27.5" 2.56" degree pipe to pump 4a Reactor Coolant/I1 Type shear wave 3 Segment RC-012 316 used, 60 NRI degree RL also used

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 5 of 35

b. The pipe welds discussed in this section were examined volumetrically by UT method for thermal fatigue concerns (item R1.11). Pipe weld description, examination and limitation descriptions are provided in Table 4b.

Segment RC- 017 The original requirements for Segment RC-017 of the RI ISI Program specified one mandatory examination, weld 2-08, and one sample weld, 2-03. The mandatory weld 2-08 exam was a single-sided, limited exam due to the piping configuration, valve to a pipe elbow. Full required coverage was achieved on weld 2-03. An additional weld was selected to supplement the limited coverage on weld 2-08. Weld 2-05 on segment RC-017 was also examined to meet full coverage requirements and to provide additional data for the segment. There were no indications noted on any of the examination areas.

Segment RC-018 The original requirements for Segment RC-018 of the RI ISI Program specified one mandatory examination, weld 1-08, and one sample weld, 1-05. The mandatory weld 1-08 exam was a single-sided, limited exam due to piping configuration, valve to a pipe elbow. Full required coverage was achieved on weld 1-05. An additional weld was selected to supplement the limited coverage on weld 1-08. Weld 1-03 was also examined, meeting full coverage requirements. There were no indications noted on any of the examination areas.

Segment ECC-005 Weld 1-09 is a mandatory selection for the RI ISI Program. Weld 1-10 is a sample selection. These are the only two welds on the segment. Weld examinations were limited as shown in Figure 4b2. No alternative weld selection exists. No indications were discovered on these welds.

Segment ECC-007 The two examinations of welds 1-09 and 1-10 on segment ECC-007 were performed in 2006 before the "good practice" of documenting best effort. Both weld examinations were limited as shown in Figure 4b3. An indication was found on weld 1-10. The indication was fully investigated and confirmed to be a construction related, geometric reflector and therefore not a flaw.

Weld 1-09 is a mandatory weld selection. There were no indications on weld 1-09. Weld 1-10 falls into the sampling risk informed region. These are the only two welds on the segment. No alternative weld selection exists.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 A

Attachment 1, Page 6 of 35 Segment R0-042 Two welds required examination on this segment. Weld 1-04 is a mandatory selection. Weld 1-02 is a sample selection. Both examinations were limited as shown in Figure 4b4. Weld 1-01BC on this segment was added as a supplemental examination with limited coverage obtained. No indications were found on any of these examinations.

Segment RC-043 Two welds required examination on this segment. Weld 1-03A is a mandatory selection. Weld 1-02 is a sample selection. Both examinations were limited as shown in Figure 4b5. Weld 1-01BC on this segment was added as a supplemental examination with limited coverage obtained. No indications were found on any of these examinations.

The pipe lines discussed in Section 4b are currently analyzed and inspected by the guidelines of the Materials Reliability Program (MRP-146) for the management of thermal fatigue on normally stagnant non-isolable reactor coolant system branch lines. This Program is part of the Surry Augmented Inspection Program under which select welds and pipe areas receive periodic examination as required by the MRP guidelines. The MRP-146 Program did not exist when the initial RI 1SI Program was developed for SPSI. Therefore, no credit was allocated for the MRP-146 Program.

TABLE 4b Risk Informed Pipe Welds, Stainless Steel, MRP 146 Drawing/ILine# / IDI System I Class Pipe Pipe Weld Coverage Limitation I Results Fig. No. I Risk Informed Material Dia. Thickness Achieved Pg. No.

Segment I11448-WMKS-0122K1 Typ 1 0 igesdd av

/ -C1 -8 Stainless 6" 0.797" to elbow 4bl Reactor Coolant / I Ste10 R Segment RC-017 Best Effort NR I11448-WMKS-0122J1 Type 316 50% Single-sided, valve

/ 6-RC-21 / 1-080.6"telo4b Reacor Colan /1 RatrCoat/1 Stainless Steel 6" 056"telo4b 15.56%

(Nominal) 2 Segment RC-018 Best Effort NRI I11448-WMKS-0122H1 Tye3650% Single-sided, pipe

/ 6-RC-16 / 1-09 Type6316to valve 4b2 Reacor Colan /1 RatrCoat/1 Stainless Steel 6" 052 (Nominal) 3.5%1 Segment ECC-005 Best Effort NRI

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 7 of 35 Drawing I Line# / IDI System I Class Pipe Pipe Weld Coverage Limitation I Results Fg o Risk Informed Maeil Da hcns civdPg. No.

1 1448-WMKS-0122H1 Type 316 50% Single-sided, valve

/6-RC-16 / 1-10 Sanes 6" 0.750" to pipe 4b2 Reactor Coolant / 1 ins 3.5% 2 SteelBetEfr Segment ECC-005 BsEfotNRI 50%

I11448-WMKS-0122J1 Type 316 Examination Single-sided, pipe to

/ 6-RC-21 / 1-09 0.6" promdvalve 4b3 Colan I i Reacor Stainless 6" 052 efre RatrCoat/1 Steel (Nominal) prior to1 Segment ECC-007 practice of NRI recording Best Effort 50%

Single-sided, pipe to 11 448-WMKS-0 122J 1 Tye36Examination valve 6ReatrCoolan/ 1- Stainless 6" 0.562" performed4b RatrCoat/1 Steel (Nominal) prior to Geometric indication 2 Segment ECC-007 practice of occurred during recording original construction Best Effort 1 1448-WM KS-0127J2 50% Single-sided, elbow

/ 6-RC-19 / 1-02 Type 316 6" 0.522" (1) to weldolet 4b4 Reactor Coolant /I Stainless 1% 1 Segment RC-042 Steel Best Effort NRI 1 1448-WMKS-0127J2 Type 316 50% Single-sided, valve

/ 6-RC-19 / 1-04 to elbow 4b4 Reactor Coolant / 1 Stainless 6" 0.735" (1) 3%2 Segment RC-042 Steel Best Effort NRI 1 148-WMS-017J26" pipe to 27.5" cold

/6R-9 -IC Type 316 5%leg branch 4b4 ReactorCoolan / 1-0B Stainless 6" 1.85" connection3 SegmerColnt /C1 Steel (Nominal) 23.7%3 Semn C02Best EffortNR 1 148-WMS-027J350% 6" pipe to 27.5" cold Type-WKS03163 0%leg branch

/ 6-RC-20 / 1-01BC Tye3618"cncto4b RatrCoat/1 Stainless 6" 18"cneto b ReacorColnt /C-0I Steel (Nominal) 23.7% 1 Segmnt R-043Best Effort NRI

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 8 of 35 Drawing I Line# I ID/

System / Class Pipe Pipe Weld Coverage Limitation!/ Results Fig. No. /

Risk Informed Material Dia. Thickness Achieved Pg. No.

Segment 1 1448-WMKS-0127J3 Tye3650% Single-sided, pipe to

/ 6-RC-20 / 1-02 Tye36branch connection 4b5 Reactor Coolant /I Stainless 6" 0.528" (1) 1.5% weld 2 Segment RC-043 SelBest EffortNR 11448-WMKS-0127J3 Type 316 50% Single-sided, valve

/ 6-RC-20 / 1-03A Stils " 0.562" to elbow 4b5 Reactor Coolant/i1 Steel (Nominal) 4.83% 3 Segment RC-043 Best Effort NRI (1) Actual measured thickness obtained from NDE records not provided in this relief request; this value differs from the nominal value shown in the referenced figure.

c. The pipe welds addressed in this section were ultrasonically examined for thermal fatigue (ASME Item R1.11) or intergranular stress corrosion cracking (ASME Item R1.16). Details are provided in Table 4c and in the referenced figures.

Segment EGG-006 Only two welds exist on this segment. Weld 2-09 falls within the mandatory examination region for the RI ISI Program, and weld 2-10 is categorized as a sample selection. The welds were examined ultrasonically for thermal fatigue (ASME Item R1.11). Both welds were examined to the fullest extent possible as detailed in Table 4c and Figure 4c1. No indications were discovered during either examination.

Segments RS-004A, 003A Only one weld exists on each of these segments: piping from the containment sump (wall) to the Outside Recirculation Spray (ORS) Pump suction motor operated valves. Weld 1-06 on segment RS-004A and weld 1-03 on segment RS-003A were examined ultrasonically for intergranular stress corrosion cracking (ASME Item R1.16). Both welds of this configuration for each of the ORS Pumps were examined to the fullest extent possible. No indications were discovered on either weld.

Segment HHI-011 Weld 5-AF is the only weld on this segment of piping from the High Head Safety Injection containment penetration to the first check valve inside containment.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 D

Attachment 1, Page 9 of 35 The weld was ultrasonically inspected for thermal fatigue to the greatest extent possible. There were no indications.

Segments LHI-004A, 003A Only one weld exists on each of these segments, piping from the containment sump (wall) to the Low Head Safety Injection (LHSI) Pump suction motor operated valves. Weld 1-13 on segment LHI-004A and weld 1-15 on segment LHI-003A were examined ultrasonically for intergranular stress corrosion cracking (ASME Item R1.16). Both welds of this configuration for each of the LHSI Pumps were examined to the fullest extent possible. No indications were discovered on either weld.

Segment RH-013 Two welds on this segment required ultrasonic examination for intergranular stress corrosion cracking, welds 3-02 and 3-03. The examinations on both of these welds were limited. The branch connection weld 3-01 BC on this segment was added to supplement the data from the two limited examinations.

Weld 3-01 BC was examined with the liquid penetrant method obtaining full coverage. No meaningful UT coverage could be obtained on branch connection weld 3-01BC. No additional selections exist on this segment. No indications were discovered during any of the examinations.

TABLE 4c Risk Informed Pipe Welds, Stainless Steel Drawing / Line# I ID/

System I Class Pipe Pipe Weld Coverage Limitation / Results Fg o Risk Informed Material Dia. Thickness Achieved Fig. No.I Segment I11448-WMKS-0122K1 Type 316 50% Single-sided, pipe to I 6-SI-48 / 2-09 Stainless 6" 0.562" valve 4cl Safety Injection/I1 Steel (Nominal) 1% 1 Segment ECC-006 Best Effort NRI I11448-WMKS-0122K1 Type 316 50% Single- sided, valve

/6-SI-48 /2-10 Stainless 6" 0.610" (1) 1% topp2c Safety Injection/I1 SteelBetEfr2 Segment ECC-006 BsEfotNRI I11448-WMKS-1101A5 Type 304 46.3% Single- sided, pipe

/12-RS-7/1-06 Stainless 12" 0.510" 11.9% tovlv 1 Recirculation Spray I 2 Steel Best Effort NRI Segment RS-004A

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 10 of 35 Drawing I Line# / ID/

System I Class Pipe Pipe Weld Coverage LitaonIRslsFgNoI RsInomd Material Dia. Thickness Achieved LiiainPRslsFg. No.I Segment 50%

11448-WMKS-1101A5 Examination Single-sided, valve

/ 12-RS-8 / 1-03 Type 304 performed to elbow 4c2 Recirculation Spray / 2 Stils 2 .1"prior to 2 SgetR-0A Steel practice of NRI Segmnt R003Arecording Best Effort 50%

1 1448-WMKS-1 106A4 Examination Single-sided, pipe to I 3-SI-70 / 5-AF Type 304 performed valve 4c3 SftIneto/2 Stainless 3" 0.520" prior to 1 HI-11practice Steel of NRI Segmet 1recording HHI01 Best Effort 50%

1 1448-WMKS-1 106A7 Tye34Examination Single-sided, elbow

/ 12-SI-I / 1-13 Tye34performed to valve 4c4 SaeyIjcin/2 Stainless 12" 0.490" prior to 1 Segment LHI-004A Selpractice of NRI recording Best Effort 50%

11448-WMKS-1106A7 Tye34Examination Single-sided, pipe to

/ 12-SI-2 / 1-15 Tye34performed valve 4c4 Stainless 12" 0.487" prior to2 Safety Injection / 2 Steel2 Segment LHI-003A practice of NRI recording Best Effort 11448-WMKS-0122A1 5% Snl-iebac

/ 3-RH-13 / 3-02 Type 304 5%Snl-iebac Residual Heat Stainless 3" 0.375" connection to pipe 4c5 Removal / 2 Steel (Nominal) 9% 1 Segment RH-013 Best Effort NRI 11448-WMKS-0122A1 I 3-RH-13 / 3-03 Type 304 50% Single-sided, pipe to Residual Heat Stainless 3" 0.420" flange 4c5 Removal / 2 Steel (Nominal) 10% 2 Segment RH-013 Best Effort NRI (1) Actual measured thickness obtained from NDE records not provided in this relief request; this value differs from the nominal value shown in the referenced figure.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 11 of 35

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option to rebuild components is considered impractical and would cause unnecessary radiation exposure. Furthermore, plant equipment could be impacted in a detrimental manner.

6. proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques. With the incorporation of the PDI for Supplement 2, demonstration for best effort coverage was made for single-sided examination from the accessible side of the weld. Additionally, these components are monitored for through wall leakage as part of the ASME Xl System Pressure Test Program and receive visual (VT-2) examination as required by Section Xl, Table IWB-2500-1, Category B-P for Class 1 components and IWC-2500-1 Category C-H for Class 2 components.

None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. There are no known failures of the welds discussed in this section at SPS1. Any indications were recorded and dispositioned as geometric or construction related.

No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results, the visual (VT-2) examinations performed routinely and the fact that additional welds were examined to supplement the requirements, it is reasonable to conclude that service induced degradation would have been detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds. Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inservice inspection interval for SPS1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 12 of 35 Figure 4a (Page 1 of 3)

/ Dominion' STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 1 1448-WMKS-0100AZ-1 Mark Number 1-12 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME USRA (1STLEG) _ _ _ _ _ _ _

450 EXAMINATION VOLUME ( 2 nd LEG) _______

450 EXAMINATION VOLUMEW(STRLEG)AM _____

450 EXAMINATION VOLUME DWSRA

____________ ~~~(

2n LEG) _________

450 EXAMINATION VOLUME (2w 50G 450 EXAMINATION VOLUME CCW 50 600 EXAMINATION VOLUME UPSTREA UPSTREAM 600 EXAMINATION VOLUME (ind LEG) 0 DOPSTREAM 600 EXAMINATION VOLUME (2ST LEG) 92 600 EXAMINATION VOLUME DOWNTRLEAM9 UPWSTREAM 700 EXAMINATION VOLUME (1ST LEG) _______

DOWSTREAM 700 EXAMINATION VOLUME (S E) ______

UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 92 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TO TAL PER CENT 48 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 13 of 35 Figure 4a (Page 2 of 3)

S~Dominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 1 1448-WMKS-0101AZ-1 Mark Number 1-12 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM 450o EXAMINATION VOLUME (1nt LEG) 450 EXAMINATION VOLUME (2st LEG) 450 EXAMINATION VOLUME DOWSTRLEAM 450 EXAMINATION VOLUME (2W' 50G 450 EXAMINATION VOLUME CCW 50 UPSTREAM 600 EXAMINATION VOLUME (1s* LEG) 0 UPSTREAM 600 EXAMINATION VOLUME ( 2 nd LEG) 0 DOWNSTREAM 600 EXAMINATION VOLUME (1st LEG) 92 DOWNSTREAM 600 EXAMINATION VOLUME ( 2fld LEG)

UPSTREAM 700 EXAMINATION VOLUME (1st LEG) 7Q0 7°EXAMINATION VOLUME DOWNSTREAM (1st LEG)

UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 92 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TO TAL PERCENT 48 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 14 of 35 Figure 4a (Page 3 of 3)

SDominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 11 448-WMKS-010O2AZ-1 Mark Number 1-12 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM 45° XAMIATIN VOUME(1st LEG)

UPSTREAM 450 EXAMINATION VOLUME ( 2fld LEG)

DOWNSTREAM 450 EXAMINATION VOLUME (1st LEG) 450 XAMIATIN VOUMEDOWNSTREAM 45_____ EXMNTO OUE( 2fld LEG) 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 600o EXAMINATION VOLUME UPSTRLEAM UPSTREAM 600 EXAMINATION VOLUME (2fld LEG) 0 DOWNSTREAM 600 EXAMINATION VOLUME (1 st LEG) 92 600 EXAMINATION VOLUME (2DOWSTEAM UPSTREAM 700 EXAMINATION VOLUME (1st LEG) _______

7Q0 EXAMINATION VOLUME (1st LEG) _______

UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 92 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TOTAL PERCENT 48 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 15 of 35 Figure 4bl (Page 1 of 2)

Weld Number 2-08 Weld Width 0.75" Weld Length 21 .625" 2I l , 1 2 I I, i .... I.. I.,. I ....

. . . . I I I r I I J. " . . . . . . . . . . . . . . . . . . .

FLOW 2 CL 45 VALVE ELBOW 0.188" HT X.875"' WIDTH =0.165 SQ. IN REQUIRED VOLUME UPSTAND DNST SIDE EXAMINED 100% DNST AX AND C1RC DIRECTION EXAMINED 0.07 SQ IN,UPST AX DIRECTION 0,071.165 = 0.42 X 100 = 42% BEST EFFORT UPST AX DIRECTION NO EXAM CIRO DIRECTION UPST SIDE Examination Volume Dimensions:- Heloht: 0.188" Length: 21.625" Width 1.75" Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage)

ANGLE UpSt-Ax UpSt-Circ DnSt-Ax DnSt-Circ 45 _________0% ________ 100%

60 _________ ________100%

60L *42% __________,________.________, ___

Code Coverage Total I 50%

100+1 00+0+42=2421400=60

• Best Effort Coverage (Max 25%) Total 10%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 16 of 35 Figure 4b1 (Page 2 of 2)

Weld Number: 1-08 Weld Length: 20.8" Weld Width: 0.6" Flow Box Dimensions: H =0.22", L = 1.5" Valve-Best Effort Coverage:

UpSt Exam Area = 0.22" x 0.75" =0.165 in2 Examined (0.22 x 0.15) + (0.22 x 0.4)/2 =0.077 in2 0.077 10.165 = 46.67%

46.67% 13 UpSt Scans = 15.56%

_______Coverage Summary Required Scans (each scan has a weighing factor of 100 for complete coverage)

Angle UpSt - Ax UpSt - OW UpSt - CCW DnSt Ax- DnSt. - W DnSt -. CCW 45160 0% 0% 0% 100% 100% 100%

60 RL 46.67% __________ __________ ______

Code Coverage Total 50%

Best Effort.Coverage (Max 50%) Total . 15.56%/,

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 17 of 35 Figure 4b2 (Page 1 of 2)

Weld Number: 1-09 Weld Length: 21" Weld Width: 0,9" Flow Box Dimensions: H = 0.19", L= 1.9" Pipe Best Effort Coverage:

DnSt Exam Area =0.19" x 0.95" =0.181 in2 Examined (0.15 x 0.25)/2 = 0.019 in2 0.019 /0.181 = 10,5%

10.5% 13 DnSt Scans =3.5%

Reqire Sans(eah Canhsv e iaghingmfactry o 0 o oplt oeae Angle U~pSt -Ax UpSt -CW .UpSt-CCW -- DnSt -Ax DnSt -CW DnSt -CCW 60 100% 100% 100% 0% 0% 0%

60RL ______ ______ 10,5% _______

Code Coverage Total 50%

Best Effort Coverage (Max 50%) Total 3.5%

Notes:.

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix Viii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 18 of 35 Figure 4b2 (Page 2 of 2)

Weld Number: 1-10 Weld Length: 20.8" Weld Width: 0,9"' FRow Box Dimensions: H= 0.19", L =1.9" Valve r--

Best Effort Coverage:

DnSt Exam Area = 0.19" x 0.95" = 20.181 in2 Examined (0.15x 0.25)/2 = 0.019in 0.019 10.181= 10.5%

10.5% 1 3 DnSt Scans =3.5%

Coverage Summary Angle Required Scans (each scan has a weighing factor of 100 for comn lete coverage)

UpSt -Ax UpSt -CW UpSt -CCW DnSt -Ax DnSt- CW DnSt- CCW 45 /60 0% 0% 0% 100% 100% 100%

60RL 10.5% ________________ ____________

Code Coverage Total 50%./

,j...... ... . Best Effort Coverage (Max 50%) Total 3.5%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 19 of 35 Figure 4b3 (Page 1 of 2)

Dominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 1 1448-WMKS-0122J1 Mark Number 1-09 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME UlSTRLEAM NA 450 EXAMINATION VOLUME UPST LEA) NA 450 ~DOWNSTREAM N 4°EXAMINATION VOLUME ( 15t LEG) N

,450 EXAMINATION VOLUME DOWNSTREAM NA 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 600 EXAMINATION VOLUME UP STREAM NA 600 EXAMINATION VOLUME UPSTR EAM NA 600 EAMINAION VLUMEDOWNSTREAM N

___0__ EXMNTO OUE(I st LEG) N DOWNSTREAM 600 EXAMINATION VOLUME ( 2 rndLEG) NA 70° EXAMINATION VOLUME UPSTRLEAM 100 700 EXAMINATION VOLUME DOWNSTREAM)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50

________________________ TOTAL-PERCENT 50 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 20 of 35 Figure 4b3 (Page 2 of 2)

STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number I11448-WMKS-01 22J1 Mark Number 1-10 ANGLE SCAN AREA SCAN SIDE SCAN %

45 EAMNAIO VLUEUPSTREAM NA 4__EXAINTIOVOUM (Ist LEG) 45° XMNTINVLM UPSTREAM N EXAMINATION VOLUME (2DOWSTEA) NA 450 EXMNTO OUEDOWNSTREAM N 40EXAMINATION VOLUME C1 50LG)N 450 XAMNATON OLUEDOWNSTE0 600 EXAMINATION VOLUME (Is! LEG) N 60EXAMINATION VOLUME CWTRA 50 60EXAMINATION VOLUME DOWNSRA 100 600 EXAMINATION VOLUME DOWNTREAM NA 700 EXAMINATION VOLUME UPSTREAM(2* NA

____ ___ __ _....... _ __ _ __ __ (ULEG) _ _ _ _ _ _ _

700 EXAMINATION VOLUME DOWNSTREAM

__ ___ __ __ __ __ __ _ (2Id LEG) NA 70 XMNTOCOEAGA OUEUPSTREAM DOWNSTREAMDOVERAGEE10 CLOKWSTEA COVERAGE 50 COUNTER CLOCKWISE COVERAGE 50

___ ___ ___ ___ ___ ___ TOTAL PERCENT 50 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 21 of 35 Figure 4b4 (Page 1 of 3)

Report No: UT-12-061 Summary # Si. R1.11.880 Dominion° Pg. 5 of 5 Prepared by: W. Thomas ,

Date; 5/18/20:12 Weld Number 1-02 Weld Width .,9' Thickness .572" Weld Length 21"

. .. ., . .. . I .. . . , .. . .I . .. . , . .. .* ... ., . . .. I .. .. , . . . . I . . . . , . . . .

I 2 1 2 FLOW 1-02 CL WELDOLET

/ ELBOW

.191" IITX .95" WIDTH .18 SQ. IN. REQUIRED UPSTANO DNST SIDE" SEXAMINED 100% REURDVOWUME UPST SIDE

,.j EXAMINED 0.01 SQ. IN. BEST EFFORT DNST AX DIRECTION

.01 1.18 =.055 X 100 = 5.5% BEST EFFORTAX DIRECTION DNSTSIDE.

NO EXAM DNST SIDE CtRC DIRECTION Examination Volume Dimensions - Height .191" Length 21" Width 1.9"

_....... Coverage Summary

_______Required Scans (each. has a,weighing factor of 100 for complete coverage)

ANGLE U~pSt-Ax UpSt-Clrc DnSt-AxDntCr

) odeCovrag reerstothemaxmumperentge ofdtreuiedera~atg e o votlume50 that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume pastthe weld centerline that Is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

6'~i

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 22 of 35 Figure 4b4 (Page 2 of 3)

Report No: UT-12-060 Summary # Si. R1.11.882 Dominion° Pg. 5 of 5 Prepared by: W. Thomas Date: 5/18/'2012 Weld Number 1-04 Weld Width ,9" Thickness .570' Weld Length 21" S2 1 1 +/-0 2 i

FLOW a.

ELBOW VALVE

,1B' HTX .O5"WIOTH =.18&LO INREcQUIREDOVOLUMEUPST ANDDNST" OE

• **m<.E 10=% OF "ER*OEQJRVOWMEOWSTIOE

"* EXAMINED .02 SQ. IN.BEST EFFCRT UPST SIOE/*( tSRBTICN

....02/.10 = 0.11 X100 = 11% BEST EFFORT UPSraDtEA(DlREOT1ON NOEXAM UP&I CIRC DIRECTION Examination Volume Dimensions - Height .19" Length 21" Width 1.9"

_____Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage)

ANGLE U pSt-Ax, UpSt-Circ DnSt-Ax DnSt-Clrc 45,/60 I 100% I 0%

70 100%

60L *11% I Code Coverage Total I 50%

100+-100+i0+11=211/4=53 Best Effort Coverage (Max 25%) Total ... 3%

Notes:

1) Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examiniatlon procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that Is examined in the axial beam direction with an Appendix VIii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 23 of 35 Figure 4b4 (Page 3 of 3)

Report No: UT-13-126

• Donainion" Summary # $1.R1.11.879 Pg. 6 of 6 oe lwed Prepared by: W. Thomas ***.- 11 Witnessed Date: 11/9/2013 7933 Weld Number 1-01BC Weld Width 1L.50" HSB GS Thickness 1.85" Weld Length 30.5" 2 1 0 1 2

'5

'U C

I

'U

/5 ~5Sf2.INROCSJJROOVOtUMSDSSlOE IN. I3SCDL'XDIR.

.361.~ ~S47XiSO'441%

/

N

• NO E~tAMOSAX DIR 5;.3%

Examination Volume Dimensions Height 0.62" Leng1th 30.5" Width 2.4" J

_______Coverage Sum mary Required Scans (each has' a weighin~g factor of 100 for complete coverage)

ANGLE ' UpSt-Ax U pSt-C:irc DnSt-Ax DnSt-Clrc,.

45/60 100% I 100% 0II 6OL *94.7%

Code Coverage Total j 50%

100*100.,+,0,+94.7=294.7/44=3.7 , , 'Best: Effort.Covera~ge (Max 25%) Total I23.7%

Notes:

1) Code Coverage refers to the maximum percent~age of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 24 of 35 Figure 4b5 (Page 1 of 3)

Report No: UT-43-124

• Dominion" Summary # S1.R1,11.930 Prepared by: W. Thomas Reiee Date: 11/8/2013 t* Witnesso Weld Width 1.60" * ///

Weld Number 1-01BC Thickness 1.85" Weld Length 30.5" 7933

.. a . ,, r , . .

45 a

Ki~8 I~.

______________ i~\

j~a~uai~n~UME 05 805 /

SQ ~N.D5805MtSR.

Q~assrss~Faftr" .55I.~8 1iI4?K1C8=~4.7%

SNO EKAM4 OSAXDIR53%

Examination Volume Dimensions - Height 0.62" Lenath 30.5" Width 2.4" Coverage Summary Required Scans (each has a wei~ghing factor of 1(00 for complete coverage)

,ANGLE ,.,UpSt-Ax UpSt-Circ DnSt-Ax .... DnSt-Circ 45/60 -- 100% I 100% ..... 0%

60L *94.7%

,,,,,Code Coverage Total [,50%

100*100+0+94.7=294.7/4=73.7 Best Effort Coverage (Max 25%) Total J 23.7%

Notes:

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 25 of 35 Figure 4b5 (Page 2 of 3)

Report No: UT-13-127 Summary #f$1.R1.11.931

~DomIni@n Pg. 5 of6 Prepared by: W. Thomas *~',,6-Date: 11/9/2013_

Weld Number 1-02 Weld Widt th 0.8" Thickness 0.552' Weld Leng**th 21' FLOW CL 1-02

,i z i _

0.1 84-rrx 0.025"DhIDI = 0.110 So, INREQUIRED VOLUME EACH SIDE OFWELW

• ,'FFFFFFFF*.,EXAMINED 100% OFTHE REQUIRED EXAM VOLUME US SIDE EXAMINED 0.01 00. IN.DS SlOE AX DIRECTION BEST EFFORT

"- BEST EFFORT= .01/ .17 =0,052 X 10016.0%

• ~NO EXAM OS SIDE AXDIRECTION = 94,1%

Examination Volume Dimensions - Height 0.184" Length 21" Width 1.8" Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage),

ANGLE U~pSt-Ax UpSt-Clrc DnSt-Ax DnSt-Circ

.60L Code Coverage Total 50%

1OD+100+0+5.9=205.9/4=51.5 ...*Best Effort Coverage (Max 25%) Total 1.5%

Notes: ii ii i=

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined In the axial beam direction with an Appendix Viil demonstrated procedure for single sided coverage.

Reviewed 7933 HSB GS

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 26 of 35 Figure 4b5 (Page 3 of 3)

Supplemental Report i 'I ' . , '

Report No.:" 'Ur-07-045 Page: 2 of 2 Examiner: Coburn, Timothy M Level: I...I Reviewer.

Date: It- 3-0o7 Examiner: N/A Level: N/A site Review: z -,} Date //0* D Other:. N/A .Level: N/A ANII Review:_____________ Date '

Comments:

Comments:

Weld Number: 1-03A Nora. Thickness: 0.562" Weld Length: 20.8" Flow Weld Width: 1.25' Box Dimenslons: H =0.19", L =2.25" cjI-Valve - - --- -.-... "- 2" / Elbow.

US exam box = .019"x 1.125" =0(.214 in, Examined (0.19' x 0.33")!* 2 0.031 in2.

0.031 / 0.214 =14,5%

14.5%/S scans =4.83%

-- Coverage Summary Angie. Required Scans (ea~ch scan has aweighing factor of 100 for complete coverage)

U ~t-Ax UpSt - W UPSt"CCW DnSt- Ax DnSt - CW DnSt-OCCW

• 45/60 0% "- 0% 0% 100%' 100% 100%

60 RL . 14.5%

Code Coverage Total 50)%

• Best Effort Coverage (Max 50%) Total 4.83%

Notes:

1. Code Coverage refers to the maximurn percentage of the required examination volume that is effebtively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with" an Appendix VIII demonstrated p~rocedure for single sided coveragqe.,

Mddlionrl - Soppieern~el Reports

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 27 of 35 Figure 4c1 (Page 1 of 2)

Report No: UT-09-059 Summary # S1.R.1,11.521 SDominion" Pg. 4 of 4 Prepared By: W.L. Thomas  %- SiIh~o7 Date: 5/1/2009 Weld Number 2-09 Weld Thickness .562" Weld Length 20" Weld Width 1.o" FLOW PIPE NR NN

• • .* AEA EXAMINO U.s QieSQ 1N058.

-,, AJ*-EXAMtNSDBESr EPIORTO.OI SO. INQ-*

OF NO ME'(PM1OTN .S.

,'ed*-~AI 0c1eSQ. NC-ES B*;T EFFORT AI*JAI OOIE I*QURB* ARED.S. NOT TO SCALE 100+ l00+5+0=20514=51%

Examination Volume Dimensions - Height .187" Length 20" Width 2"

____._._C~overage ,Summary Required Scans (each has a weighing factor of 100 for~complete coverage)

ANGLE I UpSt-Ax U~pSt-Circ DnSt-Ax DnSt-Circ'

""45 100% 0%

60 100% 3 60RL 5%

Code CoverageTotal _ 50

, ~Best Effort Coverage (Max 25%) Total I *1 Notes:

1) Code Coverage refers to the maximum percentage of the required examination ..

volume that Is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examinatin volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage. .

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 28 of 35 Figure 4c1 (Page 2 of 2)

Report No: UT-09-060 Summary #SI.R1.1 1.522 SDominionr Pg. 4 of 4 Prepared By: W.L Thomas -

Date: 511/2009 Weld Number 2-10 Weld Thickness .562" Weld Length 20" Weld Width 1.0" PLOW

-_...=,.__ .

1,L]

PiPEVL-V

.01" NR

/, .AIEA6XA.MtEDUSE9SQ FFORT0,OSQ. IC

,'* A :AFN.IrEDtJe[NArEION IOSQ.018, INd-ES BEST 6FORr AREAl c:oca rUREQIDARe-ADS. NOT TO SCALE O.O1/O,9=S5%.

100+ 100+5+0=205/4--51%

Examination Volume Dimensions - Height .187" Length 20" Width 2"

_______Coverage Summary Required, Scans (each has a weighi~ng, factor of 100 for complete coverage)

SANGLE UpSt-Ax Upst-Circ .... Dnst-Ax 'DnSt-Circ 45 100% 0%

60 100% .... .

6ORL 5%

Code Coverag* Total J 50%

........ Best Effort Cove~rage (Max 25%) Total' 1%

Notes:

Code Coverage

1) volume the maximum refers to examined the qualffledofexamination with percentage examination the requiredprocedure.

tttat is effectively

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstr~ated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 29 of 35 Figure 4c2 (Page 1 of 2)

Report No: UT-13-1_36 Summary # $1.R1.16.532 Pg. 5 of 5 Prepared by: W. Thomas ** -*-

Date: 11/8/2013 K. . . . . . . ..... . ..

Weld Number 1-06 Weld Width 0.5"I Thickness 0.386" Weld Length 40.5" 0

1 12 ____.1 FLOW HCSB GS 1-06.-' CL PiPE \ "'"-*..! VALVE 0.129" HTXO0.75" WI]DTH =0.097 SQ. IN. X 40.5" LENGTH = 3.93 CU. IN.

REQUIRED VOLUME EACH SIDE OF WELD =3.93 CUBIC INCHES 3" LIMITATION FOR ALL SCANS OS SIDE OF WELD

• _,::_. ., EXAMINED 37.5" OF THE REQUIRED 40.75' LENGTH

... 37.51 40.5= 0.926 X 100 = 92.8% DS SIDE AX AND CIRC DIR.

!*'.;';*'.z'.EXAMI NED .05 SQ. IN. X37.5" LENGTH = 1.875 CU. IN.

BEST EFFORT = 1.875 CU. IN. 1,8751/ 3.93 = 0.477 X 100 = 47.7%

"*'T;*KT:* NO EXAM US SIDE AX DIRECTION = 52.3%

Examination Volume Dimensions - Height 0.129" Length 40.5" Width 1.5"

________Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage)

ANGLE UpSt-Ax UpSt-Circ DnSt-Ax DnSt-Circ 45/60 I 0% 92.6% I 92.6%

70 *47.7%

Code Coverage Total I 46.3%

92.6+92.6+0+47.7=232.9/4=58.2 *Best Effort Coverage (Max 25%) TotalI 11.9%

Notes:

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverag~e.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 30 of 35 Figure 4c2 (Page 2 of 2)

SDomh~,io-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11448-WMKS-1101A5 Mark Number: 1-03 ANGLE SCAN AREA SCAN SIDE SCAN %

45 XMIAIN OUEUPSTREAM ,

45° EXAINATIONVOLUME(1st ILEG)I, 450 XAMIATIN VOUMEUP STREAM 45 EAMNAIO VLUE(2* LEG) NA 40DOWNSTREAM 0 4 EXAMINATION VOLUME (jst LEG) ______

450 XAMIATIN VOUMEDOWNSTREAM 4__EXANTIOVOUM (2'* LEG) NA 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50I 600 EXAMINATION VOLUME UPSTRLEAMI0 600 EXAMINATION VOLUME U2PSTREOMN 600 EXAMINATION VOLUME DOWSTRLEAM 60° EXAMINATION VOLUME DOWNSTREAM (2 0d LEG) NA UPSTREAM*

700 EXAMINATION VOLUME ( 1 5t LEG) _______

'700 EXAMINATION VOLUME DOWNSTRLEAM)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCK WISE COVERAGE 50 COUNTER CLOCKWISE COVERAGE 50 TOTAL PERCENT 50 %

• 450 exam coverage encompassed by the 600 and 70*exam used for procedure only and not for coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 31 of 35 Figure 4c3 (Page 1 of 1)

)Dominion-

• STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UME BY SCAN DIRECTION Drawing Number: 11448-WMKS-1106A4 Mark Number: 5-AF ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME UPSTRLEAM 450 EXAMINATION VOLUME ( 211d LEG) _______

450 XAMIATIN VOUMEDOWNSTREAM 450 EXAMINATION VOLUME (1fldLEG) _______

450 EXAMINATION VOLUME CWLG 450 EXAMINATION VOLUME CCW 600 EXAMINATION VOLUME UPTRAM10 UPSTREAM 600 EXAMINATION VOLUME (! st LEG) 100 DOWSTREAM 600 EXAMINATION VOLUME (2"d LEG) NA 600 EXAMINATION VOLUME DOWNSTREAM (Ind LEG).

N0______

700 EXAMINATION VOLUME UPWSTREAM (2"t LEG). _______

NA 700 EXAMINATION VOLUME DOWNTRLEAM 70°EXAINTIOVOUM (Ist LEG) _______

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TOTAL PERCENT 50 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 32 of 35 (Figure 4c4)

(Page 1 of 2)

SDominin-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11448-WMKS-1106A7 Mark Number: 1-13 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EAMINAION VLUMEUPSTREAM*

450° EXAMINATION VOLUME ( 1sAM NEA 45 EAINTONVLUE( 2 nd LEG) NA______

450 DOWNSTREAM*

4 EXAMINATION VOLUME (IlaLEG) 450 EXAMINATION VOLUME DOWNSTREAM N

______( 20d LEG) N 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 UPSTREAM10 600 EXAMINATION VOLUME (1St LEG)10 600 EXAMINAT[ON VOLUME UP"STLEAM NA 600 EAMINAION VLUMEDOWNSTREAM 60°EXAINTIOVOUM (10 LEG)0 600 EXAMINATION VOLUME DOWNSTREAM N

__ __ __ __ __ __ __ __ __ __ __ (2'* LEG) N 700 EXAMINATION VOLUME UPST LEAM NA 700 EXAMINATION VOLUME DOWNTRLEAM NA UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50

_________________________ TOTAL PERCENT 50 %

• 60* axial scan encompassed the 450 axial scan. 700 was used to interrogate far side of weld only and not for coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 33 of 35 (Figure 4c4)

(Page 2 of 2)

) Dominloinr STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11 448-WMKS-11I06A7 Mark Numbe: 1-15 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME UPISTRLEAM 450 ~UPSTREAM N 4 EXAMINATION VOLUME (2'* LEG) N 450 EXAMINATION VOLUME (1Ist LEO) ______

450 ~DOWNSTREAM N 4°EXAMINATION VOLUME (2 0d LEG) ____A__

450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 600 EXAMINATION VOLUME UPSREA 100) 600 EXAMINATION VOLUME U2PSTREAM NA 600 EXAMINATION VOLUME DOWNSTRLEAM 0 600 EXAMINATION VOLUME DOWNSTREGM NA 700 EXAMINATION VOLUME U(SREA LE DOWNSTREAM*

700 EXAMINATION VOLUME (1St LEG)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCK WISE COVERAGE 50 COUNTER CLOCKWISE COVERAGE 50 TOTAL PERCENT 50 %

• 450 scan was encompassed by the 60* and no more coverage could be obtained by the 70*

than was obtained by the 600.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 34 of 35 Figure 4c5)

(Page 1 of 2)

Report No: UT 050 Summary # SI.R1.16.780

• Dominion- Pg. 4 of 4 Prepared By: W.L. Thomas *.z_---

Date: 11109/2010 Weld Number 3-02 Weld Thickness 0.375" Weld Length I11" Weld Width 0.40"

.5

.1l

, . . . . I. .. . , . . . .I .. . . , .. . .I .. . . * .. . .I .. . . , .. . . !.. . .,

2 i 0 t 2 3 FLDW 3.02

,375" NR TOTAL REcIJRED tUMEuUS5IDE= 008 Q IN W**

.. EAMNB (103.*). IN Bas1"EF'F(3r'rUSo*E AAL DIRIEGnTON

.031 .03" .ST5XiC0 ,=3T.M*,

"* '-,F/*NO5C3INAftlAN(:.033mN,

.051 .W-&SN.*2 n 2**

Examination Volume Dimensions - Height 1.4"

.ov5rag e ngth1m"ardt Coverage Summary IANGLE I UpSt-Ax UpSt-Circ DnSt-AxDn-ir 45/60 . 0% 100% 100%

70 *37.5%

Code Coverage Total F50%

100+1-00+0+37.5=237.5/400=.59x1 O00=59%

• Best Effort Coverage (Max 25%) Total 9%

Notes: 1) code coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 35 of 35 Figure 4c5)

(Page 2 of 2)

Report No: UT- 10 -039 Summary#S1 .R1 .16.184

• )Donainion- Pg,.4 of 4 Prepared By: W.L, Thomas Date: 1110/01 Weld Number 3-03 Weld Thlickness 0.420" Weld Length 11" Weld Width 0.45"

,,],,,,Ii I. . . i . . . . .$ . . , I 1. . . .. .

'3 2 1 0 1 2 S R.OV Ci FL.ANG6

.410' ~

.041.1 =,4 XIOG"4O%

'* NO!XAMINA'1ON FcI 0108 IN OSlD4*LDIR.

Examination Volume Dimensions - Height .13"T' Length 11" Width i.45" Cav~rnaA ~ummarv Required Scans (each has a weighing factor of 100 for complete coverage)

'ANGLE

-45160 Up 100%t-Ax , .... UpSt-Cir 100% ' DnSt-Ax

.. n-lr

...0 100+100+40+0=240/40()=.60x1 00=60% ... *Best Effort coverage (Max 25%) Total 10%

Notes

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix ViIII demonstrated procedure for single sided coveragle.

Serial No.15-446 Docket No. 50-280 Attachment 2 Relief Request LMT-R02, Category R-A, Risk Informed Piping Welds on Carbon Steel Piping Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 1 of 10 Relief Request # LMT-R02 Risk Informed Pipe Welds Carbon Steel Relief Requested in Accordance with 10 CFR 50.55 a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class 2 and Non-class Examination Category: R-A, Risk Informed Piping Examinations Item Numbers: Ri1.11, Elements Subject to Thermal Fatigue Component Identification: Refer to Specific Table R02 Material: Refer to Specific Table R02

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. App~licable Code Requirement The examination requirements for piping welds for the Surry Power Station Unit I (SPS1) fourth 10-year inspection interval were governed by the Risk Informed (RI)

Inservice Inspection (ISI) Program as approved by NRC letter dated December 16, 1998. The SPS1 fourth interval RI ISI Program is a full scope program covering ASME Section Xl Class 1, 2, and 3 components.

The pipe welds addressed by the RI ISI Program are assigned to a specific segment. The pipe segment definition includes the following considerations: 1) system, 2) pipe size, 3) flow junctions, 4) pipe failure consequence, and 5) isolation points for pipe breaks. The number of welds per segment varies. Examination is mandatory for some welds in a segment regardless of whether limited coverage will be attained. Other welds are sample selections, and an alternative weld may be chosen to replace the sample weld if the alternative weld could provide greater examination coverage. Although not required by the RI ISI Program, additional welds on the segment may be examined, in addition to the number of welds required by the risk informed analysis, to provide supplemental information for the segment.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 2 of 10 The welds discussed in this section were selected for volumetric (ultrasonic) examination by the RI 1SI Program as assigned item number RI.11 for thermal fatigue.

Neither the approved relief request nor the NRC Safety Evaluation for the RI ISI Program addressed an alternative for limited examination coverage. Therefore, the rules for ASME Section XI shall apply when limitations are encountered due to the design, geometry and materials of construction of the component. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%

volumetric examination coverage requirements for the subject austenitic welds due to the geometric configurations which limit the volumetric coverage that can be obtained.

The subject welds were examined with a manual UT technique using pulse echo UT instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section Xl, Appendix VIII as implemented by the Performance Demonstration Initiative (PDI). No alternative techniques or advanced technologies were considered capable of obtaining complete coverage of the examination volume.

Segment MS-004 Requirements for the RI 1SI Program are to credit the augmented examinations performed on this segment plus two additional Risk Informed selections. This was completed with limited coverage obtained on weld 2-28 as shown in Table R02.

Welds 2-11 and 2-26 were UT examined to meet the augmented examination requirement and also received surface examinations. An indication was identified during the UT exam on weld 2-26 that was determined to be due to geometry and therefore not a flaw. All of the full circumferential pipe welds were inspected on segment MS-004 as there were no other available selections.

Segment MS-007

• Requirements for the RI ISI Program are to credit the augmented examinations performed on this segment plus two additional Risk Informed selections. This was completed with limited coverage obtained on weld 2-31 as shown in Table R02.

Weld 2-29 was examined to meet the augmented examination requirement and also

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 3 of 10 received a surface examination. No indications were discovered during these examinations. All of the full circumferential pipe welds were inspected on segment MS-007 as there were no other available selections.

Segment MS-008 Requirements for the RI 1SI Program are to credit the augmented examinations performed on this segment plus two additional Risk Informed selections. This was completed with limited coverage obtained on weld 4-31 as shown in Table R02.

Weld 4-29 was examined to meet the augmented examination requirement and also received a surface examination. No indications were discovered during these examinations. All of the full circumferential pipe welds were inspected on segment MS-008 as there were no other available selections.

Segment FW-012 This segment is monitored by the Flow Accelerated Corrosion (FAC) Program which requires UT examination for wall thinning, and an Augmented Inspection Program for high energy lines that requires volumetric and surface examinations. For a postulated secondary failure mechanism due to thermal fatigue, weld 1-22 was added as a risk informed examination. Weld 1-22 was examined with limited coverage as shown in Table R02. Welds 1-23, 1-25 and 1-26 on this segment were examined per the Augmented Inspection Program thus receiving volumetric and surface examinations. The FAC Program is actively maintained and updated and thoroughly monitors the piping condition in this area, and the High Energy Line Augmented Inspection Program provides additional monitoring by weld volumetric and surface examinations. No flaws were found during these examinations.

Segment FW-016 This segment is monitored by the FAC Program which requires UT examination for wall thinning, and an Augmented Inspection Program for high energy lines that requires volumetric and surface examinations. For a postulated secondary failure mechanism due to thermal fatigue, weld 3-19 was added as a risk informed examination. Weld 3-19 received limited coverage as shown in Table R02. No flaws were~ found during these examinations. The FAC Program is actively maintained and updated and thoroughly monitors the piping condition in this area.

The High Energy Line Augmented Inspection Program provides additional surveillance through weld volumetric and surface examinations.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 4 of 10 TABLE R02 Risk Informed Pipe Welds, Carbon Steel Drawing /Line# IID I System / Class Pipe Pipe Weld Coverage Limitation I Fig. No. I Risk Informed Material Dia, Thickness Achieved Results Pg. No.

Segment 11448-WMKS-0103A2- 600 lb Single-sided, I I 30-SH P-I / 2-28 AASd 30" 0.7"7%pipe to valve 4e1 Main Steam / 2 AS t .7"7%1 Segment MS-004 NRI 11448-WMKS-0103A2- 600 lb Single-sided, I I 30-SH P-I / 2-31 AASd 30" 0.4"7%pipe to valve 4e1 Main Steam / 2 AS t .4"7%2 Segment MS-007 NRI 11448-WMKS-0103A2- 600 lb Single-sided, 2 I 30-SHP-2 / 4-3130pietvae 4e Main Steam I Non Class ASA Std 3" 0.940" 81.92% piet3av e Segment MS-008 NRI 1 1448-WMKS-1018A3 / Single-sided, 14-WFPD-17 / 1-22 600 lb 140.36.5pietvae 42 Feedwater / Non Class ASA Std 141.3 35 iet av e Segment FW-012 NRI I11448-WMKS-1018A3 / Single-sided, 14-WFPD-9 / 3-19 600 lb 14" 0.920" 86.67% valve to pipe 4e2 Feedwater / 2 ASA Std 2 Segment FW-016 NRI

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option is considered impractical and could impact plant equipment in a detrimental manner.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 5 of 10

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques at the time the examination was performed. Additionally, these components are monitored for through wall leakage either by the ASME Xl System Pressure Test Program required by Section Xl, Table IWC-2500-1 Category C-H for Class 2 components or a visual examination performed weekly as required by the Surry Augmented Inspection Program for high energy lines.

None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. There are no known failures on this type of weld at SPSI. Any indications were recorded and dispositioned as geometric or construction related. No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results, the visual examinations routinely performed to detect through wall leakage and the fact that additional welds were examined to supplement the limited coverage, it is reasonable to conclude that service induced degradation would be detected.

Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

Dominion requests relief in accordance with 10 CER 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for SPS1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 6 of 10 Figure 4el (Page 1 of 3) i~Dominion-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11 448-WMKS-01 03A2-1 Mark Number: 2-28 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM EXAMNATIN VOUME(1s't LEG)

UPSTREAM 450 EXAMINATION VOLUME ( 2 nd LEG) 45° XAMIATIN VOUMEDOWNSTREAM 450 XAMIATIN VOUME(ist LEG) 450 XAM[ATIN VOUMEDOWNSTREAM 45 oEXAMNATIN VOUME( 2fld LEG) 450 EXAMINATION VOLUME CW 100 450 EXAMINATION VOLUME CCW 100 600 EXAMINATION VOLUME UPSTRLEAM 0 UPSTREAM 600 EXAMINATION VOLUME (2nd LEG)

DOWNSTREAM 600 EXAMINATION VOLUME (i st LEG) 94 600 EAMINAION VLUMEDOWNSTREAM N 60°_____ EXMNTO OUE( 2 ndl LEG) N 70 70__EAMNATONVOUM EAMNAIO VLUEUPSTREAM (I st LEG) NA 700EXMIATIN 70__EAMNATONVOUM OLMEDOWNSTREAM (i st LEG) NA UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 94 CLOCKWISE COVERAGE 100 COUNTERCLOCKWISE COVERAGE 100 TOTAL PERCENT 74 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 7 of 10

-igure 4e1

• age 2 of 3) i*'Dominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UME B Y SCAN DIRECTION Drawing Number: 11 448-WMKS-01 03A2-1 Mark Number: 2-31 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM 45 oEXAMNATIN VOUME(I1st LEG)

UPSTREAM 450o EXAMINATION VOLUME ( 2 5d LEG)

DOWNSTREAM 450o EXAMINATION VOLUME (1St LEG) 450 XAMIATIN VOUMEDOWNSTREAM 45° XAMIATIN VOUME( 2 nd LEG) 450 EXAMINATION VOLUME CW 100 450 EXAMINATION VOLUME CCW 100 60______ 600 EAMINAION VLUMEUPSTREAM10 EXAM____NATION_____VOLUME____ (I s LEG) 100_______

UPSTREAM 600 EXAMINATION VOLUME ( 25d LEG)

DOWNSTREAM 600o EXAMINATION VOLUME (i st LEG) 0 DOWNSTREAM NA 600 EXAMINATION VOLUME ( 2sd LEG)

UPSTREAM 700 EXAMINATION VOLUME (i st LEG)

DOWNSTREAM 700 EXAMINATION VOLUME (I1stLEG)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 100 COUNTERCLOCKWISE COVERAGE 100 TOTAL PERCENT 75 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 8 of 10 Figure 4e1 (Page 3 of 3)

/u Dominion-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UME B Y SCAN DIRECTION Drawing Number: 11 448-WMKS-01 03A2-2 Mark Number: 4-31 ANGLE SCAN AREA SCAN SIDE SCAN %

450o EXAMINATION VOLUME UPISTRLEAM 450o EXAMINATION VOLUME UPSTREAM

( 2 nd LEG) 450o EXAMINATION VOLUME DOWNSTREAM (I1stLEG) 450o EXAMINATION VOLUME (2DOWSTEAM 450o EXAMINATION VOLUME CW 10 0 450o EXAMINATION VOLUME CCW 100 600o EXAMINATION VOLUME UPSTRLEAM UPSTREAM 600 EXAMINATION VOLUME (2 nd LEG)

DOWNSTREAM 600 EXAMINATION VOLUME (IsT LEG) 600 XAMIATIN VOUMEDOWNSTREAM 700 EXAMINATION VOLUME UPTRAM10 700o EXAMINATION VOLUME DOWNSTRLEAM 27.7 UPSTREAM COVERAGE DOWNSTREAM COVERAGE CLOCKWISE COVERAGE COUNTERCLOCKWISE COVERAGE TOTAL PERCENT 81.92 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 9 of 10 Figure 4e2 (Page 1 of 2)

STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 1 1448-WM KS- 1018A3 Mark Number: 1-22 ANGLE SCAN AREA SCAN SIDE SCAN %

UPSTREAM 450 EXAMINATION VOLUME (l~t LEG) _______

UPSTREAM 450 EXAMINATION VOLUME (2 nd LEG) ________

DOWNSTREAM 450 EXAMINATION VOLUME (1st LEG) _______

450 EXAMINATION VOLUME (2DOWSTEAM 450 EXAMINATION VOLUME CW 450 EXAMINATION VOLUME CCW 600 XAMIATIN VOUMEUPSTREAM 60_EXAINTIOVOUM (lSt LEG) 100 UPSTREAM 600 EXAMINATION VOLUME ( 2 nd LEG) NA DOWNSTREAM 600 EXAMINATION VOLUME (1st LEG) 0 DOWNSTREAM NA 600 EXAMINATION VOLUME ( 2 nd LEG) 70 EAMNAIO VLUEUP STREAM NA 70°_XAMNATINVLUM (1St LEG) 70_EXAINTIOVOUM 70 EAMNAIO VLUEDOWNSTREAM (ist LEG) 80.7 UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TO TALPER CENT 63.5 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 10 of 10 Figure 4e2 (Page 2 of 2)

LIMITATION COVERAGES for WELD #3-19 due to UPSTREAM VALVE to PIPE CONFIGURATION.

Weld Number: 3-19 Weld Length: 44" Weld Width: 1.5" Box Dimensions: H =0.25", L = 2.5" r-______w _

• ~js Valve F--l ***t m

-ffl Pipe Circ Exam:

DS exam box length = 1.25' Examined 0.75" 0.75 11.25 = 60%

coverage Summary Angiered Scans (each scan has a weig~hing factor'of 100 for complete coeae Anle Upt-Ax .UpSt -CW UpSt -CCW OnSt-Ax DnSt-iCW 1DnSt-CCW 45/60o70o 100ooo____ _____ _ 100%

Code Coverage Total 86.67%

Best Effort coverage (Max 50%) Total NA Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that Is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket Nos. 50-280 Attachment 3 Relief Request LMT-R03, Category R-A, Risk Informed Dissimiliar Metal Welds on Steam Generator Nozzle to Safe-Ends Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 1 of 8 Relief Request LMT-R03 Risk Informed Dissimilar Metal Pipe Welds Relief Requested in Accordance with 10 CFR 50.55 a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class I Examination Category: R-A, Risk Informed Piping Examinations Item Numbers: RI1.11, Elements Subject to Thermal Fatigue Component Identification: Refer to Table Material: Steam Generator Side: Carbon Steel SA-216 with Stainless Steel Buttering Safe End Side: Cast Stainless Steel

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. ApplIicable Code Requirement The examination requirements for piping welds for the Surry Power Station Unit I (SPS1) fourth 10-year inservice inspection interval were governed by the Risk Informed (RI) Inservice Inspection (ISI) Program as approved by NRC letter dated December 16, 1998. The SPS1 fourth interval RI I31 Program is a full scope program covering ASME Section XI Class 1, 2, and 3 components.

The two welds discussed in this relief, 1-05DM and 1-06DM, are part of Risk Segments that were determined to be low safety significant (LSS). During the submittal and review process of the fourth interval RI ISI Program, Dominion agreed to inspect these dissimilar metal welds for defense-in-depth.

These welds were selected for ultrasonic (UT) volumetric examination by the RI ISI Program due to the assigned item number: RI1.11 for thermal fatigue.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 2 of 8 Neither the approved relief request nor the NRC Safety Evaluation for the RI ISI Program addressed an alternative for limited examination coverage. Therefore, the rules for ASME Section Xl shall apply when limitations are encountered due to the design, geometry and materials of construction of the component. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%

volumetric examination coverage requirements for the subject austenitic welds due to geometric configurations that limit the volumetric coverage that can be obtained.

The subject welds were examined with a manual UT technique using pulse echo UT instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section XI, Appendix Ill.

The required examination volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative techniques or advanced technologies were considered feasible and/or capable of obtaining complete coverage of the examination volume.

Welds 1-05 and 1-06 are the hot and cold leg, respectively, dissimilar metal nozzle to safe-end welds on "C" steam generator (S/G). The carbon steel nozzles were buttered with stainless steel to assist the welding process to the stainless steel pipe.

Since the "A" and "B" S/G nozzle to safe-end welds are similarly configured, these alternative welds would also not have provided acceptable examination coverage.

The UT scans recorded intermittent indications 360 degrees on the 1-05DM weld.

The recordable indications (RI) were investigated and determined to be reflectors due to geometry, thickness, and contour and therefore not indicative of a flaw.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 3 of 8 TABLE R03 Risk Informed Dissimilar Metal Welds Drawing /Line#I/ IDI/Pp ed Cvrg iiainFg o System I Class / Pipe Material Pp ed Cvrg iiainFg o Risk Informed Segment Dia. Thickness Achieved I Results Pg. No.

S/G side: SA-216 I11448-WM KS-O102AZ-Gr. WCC with SS bteigSafe-end 1/I29-RC-7 / 1-05DM / RCS pipe: SA-351 29.5" 2.95" (1) 63% to nozzle R03 Reactor Coolant/I1 1-2 Segment RC-006 Safe End Side: RI Cast SS SIG side: SA-216 Gr. WCC with SS I11448-WMKS-010O2AZ- bteigSafe-end 1 / 31-RC-8 / 1-06DM RCS pipe: SA-351 31 2.4() 6% tonzl 0 Reactor Coolant /I 3-4 Segment RC-009 Safe End Side: NRI Cast SS (1) Actual measured thickness obtained from NDE records not provided in this relief request; this value differs from the nominal value shown in the referenced figure.

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option to rebuild components is considered impractical and would cause unnecessary radiation exposure. Furthermore, plant equipment could be impacted in a detrimental manner.

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques at the time the examinations were performed. Additionally, all components are monitored for through wall leakage as part of the ASME Xl System Pressure Test Program and receive visual (vr[-2) examination as required by Section Xl, Table IWB-2500-1, Category B-P for Class I components.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 4 of 8 None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. There are no known failures on this type of dissimilar metal weld at Surry Power Station.

Any indications were recorded and dispositioned as geometric or construction related. No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results and the routinely performed visual (VT-2) examinations, it is reasonable to conclude that service induced degradation would have been detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds. Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for SPS1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 5 of 8 Figure R03 (Page 1 of 4)

Report No: UT~-'1 -038 Summary # SI, Rtl 11340 Dominiour Pg, 5 of 7 PrepF~red fly: WL. Thlomas ,>--f Date: 1V,03/2010 Weld NumbEr 1-O5OM Wrfd Thk~iiess We~d Lengith Weld *Ndth NOTE: SEE ATTACXHEO COVERAGE PLOT 77T.7 + 79 ÷ 0 -"255If4QO =,3*:X100]=e3 Examination Volume Dimensions - Height G5 it 5.7*

Iov S Lemngth Coverane Summary Required Scans (each has a weighirnq factor of 100 fo*r comp1etv coverare:)

ANGLE 35145 t UpSt-Ax 77%

.pgt-Clr* ..................1n.SI-*Ax_

1% 79% I% OnStoCirc t

......... .. Code C*erageTotal~ 3 Best Effort Coverage (Max 25%) Totel NJA Notes: "1) Code Coverage refers to the maximum percerntage of the required exae, lnation volume that is effectively ex~amined with (te qualified examination procedure.

Z) Best *Erfoit Coverage refers to the required examination volume past the wald centerline that is examined in the axial beam direc~ion with an Appeiidi VIII

.... demOnsiraed rocdure for sirgle sided coaver . .........

Supplemental Report Pane: 8 of 7 Stimmar Na1.: S1t.RIlA1.340 EXO drier: tevel; il.PDI Revie~ at: Date: a Examineri Mulrtiaad, Ryan L o ci: il-PDI Site i~ view: i(o~e,+ly;tsi 4 4~Jlwia.. Date:

Othnrz WA - L 'I: N/A ANtI Review: - Date' 1 1 t r

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Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 7 of 8 Figure R03 (Page 3 of 4)

.feport No; UT-lO --039 Summnary # 1.RI,1!34I mb.- Pg. 4 ofl 5 Prepared By: WI., Thomnas ,*r 1-OGDM Weld Thickness W~el Length Wekd Width 2,2' NOTE: SEE ATTACHED COVER~AGE PLOT Examination Volume Dimensions Heighi:- 1i" Length I1656" Wkilrh 5..55*

________ Coverage ummry,

• GL U pSt-A*x Upst-Circ DnSt=Ax DnSt-Circ 35/45 72% 0% ........ .80% .. ..... 96%

Cotie Co}vera~e T la 62%

Notes: 1) Code Coverage refers to the maximum percentage of tile required examirwtioa

2) (les't Effort Coverage refiers to tile required examination volume past tne wveld *.,'r.j~

cent.erine that is: examined in the axial beam direction with* an Appendix VIII de=monstraed proc~edure ior sing* sded co*verage,

.... 9/j0

Supplemental Report Rep=t !'o*: UT-I10-039

~miniC~t Page: 5 or 5 Summary *,: SI.R1 '11 341 Leel: tI-PDIt Re~lewe~: Date: !,',z~*

2-m~ner: Mulrhead, Ryan iti. C.. =* Level: !I-PDP Da4(:Ld/S Site Rev~w: ~-+/-i~d.,V1~S ~ H~frJ4-~A Other* NiA Level: tfA AN I Re C+rnn tsz* i 1 .

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Serial No.15-446 Docket Nos. 50-280 Attachment 4 Relief Request LMT-PO1, Category C-F-I and C-F-2, Preservice Weld Examinations Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 1 of 7 Relief Request # LMT - P01 ASME Xl Preservice Pipe Welds Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class 2 Examination Category: C-F-I, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping Item Numbers: C5.21, Circumferential Weld, Piping Welds >1/5 in..

Nominal Wall Thickness for Piping _>NPS 2 and _<NPS 4 C5.61, Circumferential Weld, Piping Welds >1/5 in.

Nominal Wall Thickness for Piping _>NPS 2 and _<NPS 4 Component Identification: Refer to Specific Table Material: Refer to Specific Table

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. Applicable Code Requirement

Required Method: Surface and Volumetric The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

10 CFR 50.55a(b)(2)(xv)(A), requires the following examination coverage criteria when applying Supplement 2 to Appendix VIII:

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 2 of 7 (1) Piping must be examined in two axial directions. When examination in the circumferential direction is required, the circumferential examination must be performed in two directions provided access is available.

(2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.

10 CFR 50.55a(b)(2)(xvi)(B) requires that 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-sided examinations.

To demonstrate equivalency to two-sided examinations, the demonstration must be performed in accordance with the requirements of Appendix VIII as modified by 10 CFR 50.55a(b)(2)(xvi)(g) and §50.55a(b)(2)(xv)(A).

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the volumetric examination coverage requirements for the subject welds due to geometric configurations which limit the volumetric coverage that can be obtained.

When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A), proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B), and full coverage credit may not be claimed. There are currently no Performance Demonstration Initiative (PDI) qualified single-side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds.

Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to U.S. nuclear applications.

However, PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single-sided examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single-side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology.

The subject welds were examined with a manual ultrasonic (UT) technique using pulse echo UT instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section Xl, Appendix VIII, as

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 3 of 7 implemented by the Performance Demonstration Initiative (PDI). No alternative welds were considered since these are preservice examinations for each specific weld that was reconstructed.

Weld 2-AW-B This is a stainless steel ASME Xl Category C-F-i weld. This weld also received a final liquid penetrant (surface) examination and a radiography examination before return to service. An indication was noted during the UT scan and was determined to be root geometry, due to construction and not a flaw.

Weld O-34A This is a carbon steel ASME Xl Category C-F-2 weld. This weld also received a liquid penetrant (surface) examination on the final weld before return to service. No recordable indications (NRI) were noted during the exams.

Weld 0-1A This is a carbon steel ASME Xl Category C-F-2 weld. This weld also received a liquid penetrant (surface) examination on the final weld before return to service. No indications were noted during the exams.

TABLE P01 - Preservice Examinations Drawing I Line# I ID/ Pipe Pipe Weld Coverage Limitation / Fig. No. I System I Class Material Dia. Thickness Achieved Results Pg. No.

314-CWMKS-A-10B5 Type 304 45.5% Single-sided,

/ 3CH-Sailes

/2-A-B/ 3 0.0"pipe to valve P01 Chemical and Volume Sanes 3 0506.4% 1 Control / 2 Steel Bs fotR Bs fotR 11448-WM KS- 600Sl Single-sided, 01A-/6-AD1Standard 6" 0.48" 88.3% flange to elbow P01 I 0-34A / 2 Carbon Feedwater / 2 SelNRI 600 lb 11448-WMKS- ASA Single-sided, 0118G1-1 /6-WAPD-2 Standard 6" 0.50" 88.3% flange to pipe P01

/I0-1A/ Cabo Feedwater / 2 Steeln NRI

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 4 of 7

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option to rebuild components is considered impractical and would cause unnecessary radiation exposure. Furthermore, plant equipment could be impacted in a detrimental manner.

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques. With the incorporation of the PDI for Supplement 2, demonstration for best effort coverage was made for single-sided examination from the accessible side of austenitic weld 2-AW-B. Additionally, the components are monitored for through wall leakage as part of the ASME XI System Pressure Test Program and receive visual (VTI-2) examination periodically as required by Section XI, IWC-2500-1 Category C-H for Class 2 components.

None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. Any indications were recorded and dispositioned as geometric or construction related.

No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results, the routinely performed visual (VTI-2) examinations, and the additional examinations for surface (liquid penetrant) and, in the case of the 2-AW-B weld, volumetric exam (radiography), it is reasonable to conclude that no flaws exist in the new welds.

These proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for Surry Power Station Unit 1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 5 of 7 Figure P01 (Page 1 of 3)

Weld Number: 2-AW-B Weld Length: 11" Weld Width: 0.5" Box Dimensions: H = 0.15", L= 1.5" Flow Obstruction: Branch connection centered at TDC, 0.5" from weld toe, obstructed axial exams for a length of 3".

Examined 8" of 11" = 73%

Pipe Valve Best Effort Coverage:

Os exam box = 0.15" x 0.7'5" = 0.113 in2 Examined (0.15 x 0.25) + (0.15 x 0.4)/2 = 0.06 in2 0.06/10.113 = 53%

53% (8" of 11") = 38.5%

38.5% /I6scans=6.4%

______Coverage Summary Angle Angle-60 45/60 73%

Requ*ired UpSt -Ax

_____{100%

Scans 1

UpSt - CW UpSt - CCW weighing (each scan

_____j 10.0%

has a DnSt - factor 0%

Ax ofD~nSt100 -for 0%

CW complete DnStcoverage.

- CCW 0%

70 38,5%__1______i Code Coverage Total 45.5%

Best Effort Coverage (Max 50%) Total 6.4%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerdine that is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 6 of 7 Figure P01 (Page 2 of 3)

Weld Number:. 0-34A Weld Length: 21" Weld Width: 0.7" Box Dimensions: H =0.15", L = 1.7" Flange *jElbow Nte: 45° axial probe included in sketch to Ciro exam coverage: demonstrate 100% axial coverage from DS side, US Exam Box: 0.15" x 0.85" = 0.128 in 2 US Circ Exam: 0.15" x 0.55" = 0.083 in2 0.083/0.128=65%

_______Coverage Summary Angle Required Scans (each scan has a weighing factor of 100 for complete coverage)

Age UpSt.- Ax UpS't - CW UPSt - CCW DnSt - Ax DnSt - CW DnSt - COW 45 100% 65% 65% 100% 100% 100%

Code Coverage Total 88.3%

............. Best Effort Coverage (Max 50%) Total NA Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 7 of 7 Figure P01 (Page 3 of 3)

Weld Number; 0-1A Weld Length: 21" Weld Width: 0.7" Box Dimensions: H = 0.15", L =1.7" Flow 3' Circ exam coverage:

OS Exam Box: 0.15" x 0.85" = 0.128 in2, DS Circ Exam: 0.15" x 0.55" =0.083 in2 PsI' 0.083 / 0.128 =65%

Notej."45° axial probe included in sketch to demonstrate 100% axial coverage from OS side.

S~Coverage Summary Angle -Required* Scans (each scan has aweiching factor of 10f cm plete coverage) 45 UpSt - Ax UpSt - OW UpSt - COW JDnSt - Ax DnSt - CW DnSt.-COW 100% 65% 65% 100%, 100% 100%

Code Coverage Total 88.3%

Best Effort Coverage (Max 50%) Total NA Notes:

1.. Code Coverage refers to the maximum percentage olthe required examination volumeI that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Attachment 5 Relief Request LMT-C01 Examination Category B-B, Pressurizer Shell to Head Circumferential And Longitudinal Welds Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 1 of 11 Relief Request LMT-C01 Pressurizer Shell-to-Head Circumferential and Longitudinal Welds Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected Weld No.: 1-07 Drawing: 1 1448-WMKS-RC-E-2 ASME Class: 1 ASME Category: B-B ASME Item: B2.11

Description:

Pressurizer Shell to Head Circumferential Weld Weld No.: 1-15 Drawing: I11448-WMKS-RC-E-2 ASME Class: 1 ASME Category: B-B ASME Item: B2.12

Description:

Pressurizer Shell to Head Longitudinal Weld

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. Applicable Code Requirement

The 1989 Edition of ASME Section Xl Table IWB-2500-1, examination category B-B, item B2.11, requires volumetric examination of essentially 100% of the circumferential shell to head welds.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 2 of 11 Table IWB-2500-l category B-B, item B2.12, of the 1989 Edition requires volumetric examination of one foot on the longitudinal weld that intersects the selected circumferential shell to head weld.

4. Impracticality of Conplijance The pressurizer is covered with an insulation support ring (Figure 1). The insulation support ring is six (6) inches wide where examination interference is encountered for weld 1-07. As seen in Figure 1, this insulation support ring and a power operated relief valve support prevent complete volumetric coverage of both the upper circumferential head weld 1-07 and the intersecting longitudinal weld 1-15.

5. Burden Caused by Compliance Total removal of the support ring at the mechanical connections is considered impractical due to the extreme high dose rates in the pressurizer area. Total radiation dose to remove the interfering support and perform the examination was estimated to be 15.13 man-rem. This includes expended dose necessary for the various crafts involved including mechanical maintenance, insulators, rigging crews and Non-destructive Examination (NDE) personnel. Partial removal of the support ring could allow some increased coverage; however, the actual increase would be very small in relation to the entire weld length. This is not considered a practical option when considering consequential disturbance of interconnected cross supports and the welded connections to safety and power operation relief valve supports.

Removal of the mechanical connections or forced spreading apart of components would create a risk of misalignment and possibly warp the structure. Furthermore, civil engineering proposed that cutting the support could be necessary for removal; thus, destroying the support ring.

6. Proposed Alternative and Basis for Use Examination of pressurizer shell welds 1-07 and 1-15 was performed during the third inservice inspection interval as documented in Dominion letter dated July 14, 2005 (Serial No.05-277). The average total examination coverage of all scan directions for welds 1-07 and 1-15 is 46% and 31%, respectively.

Examination of pressurizer shell welds 1-07 and 1-15 was reattempted during the fourth inservice inspection interval. The obstructions were verified as shown on the inspection reports provided in page 1 of Figure 001. The examiners referenced the previous limitations from the third interval. The documentation of these limitations is provided in Figures 001 for reference.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 3 of 11 No additional ultrasonic examination techniques would provide meaningful additional data on this cladded material for the examination volume not attained. The pressurizer receives a visual (VT-2) examination every refueling outage as required by Section Xl, Table IWB-2500-1, Category B-P for Class I components. Any effort to achieve greater coverage would be impractical creating risk of component damage or destruction and excessive personnel dose exposure.

Based on the volumetric coverage that was obtained with acceptable results and the routinely performed visual (VT-2) examinations, it is reasonable to conclude that service induced degradation would have been detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds. Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for Surry Power Station Unit 1, which began October 14, 2003 and ended October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 4 of 11 iN$ULAtION .~UFP~T ~

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$Sfz*e/tlwnhqt2r Thl-nokes*Daeler 4,375! 7,75' 1 ti~l~e'n:, See previous; rprot1 UTRf U C'H 851 RT5501A; IeTSSQGIB Strlia!:m 1028 F*nleh The': 1I300

£xarhaltoil Surf-ce: Insald* Outaide *] Surface Co dtions Ground Inlush Lo Location: Zero Datum Point Wo lo~cetlon: Weld Cetr Lte* O*couplant: Soundaafa Balclh No: 1:2120 Terop. Tool Mf'g. AMVEC Serial No*: 100 BOGY Surac Temp.; 72.3 °F oC)

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Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 6 of 11 Figure C01l (Page 2 of 7)

Corrected calculation performed in 2005.

Added to report by Dan Jensen. (3 Pages) 9 ohd~ -

PERCENT VOLUME BY SCAN DIRECTION DRA WING NUMBER ! I 548-WMK&RC.-,E4 MARK NUMBER 1-07 ANLE. ......... SCAN AREA, DIRECTION "SCAN %"

45° WELD & BASE METAL 0 68%

..... 45° WEBLD & BASE METAL ' 2 .... 82%

600 WELD & BASB METAL 2 92%

450 WELD)&BASBEMETAL 5 15%

60° WELD & BASE METAL 5 20%

'45° WIELD '&'BASE METAL 7 ... 35%"

6o00 WELD &BASE METAL, 7 35%

....... 450 WELD &BASB METAL 8 35%

600 WELD & BASE METAL 8 35%

___ ___ __ OTAL P'ERCENT _ .... 46%

CO0MMENTS: .....

All Areas were scannaed with the maximum extent possible from both sides of the weld and on the weld with 00, 450 and 600 transducers for the 2, 5, 7 and 8 scans.

DATE DanielL Jensed/

ICorrected calculation performed in 2005.I

~Added to report by Dan Jensen. (3 Pages)

II448-VMKS-RC-E--2 1-07 (Ho~ched *re~s represen-* no exo.Nn~tlon cover'age)

ITEDFOR 2%.OF WELD LE*NG'H 1'I IN*'TRUMEt4TATXON. NOZZLE.UZ4ITE]D FOR 0.7% OF WELD" LEGTH "0)"

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Code; ASMtE iS99 EW2000 Addenida G*'t./'tem; B-B,rB2.t2 Lacation." PZ.R 47 DrawlrK.J No,: 1I44li-WM KS-RC:E-2 Dfs.PI;* t~or*; LONG SHELL TO HEAD WELD

$ystu ID: RC Cowponan: ID: !!44a-WlMKS-RC-E-2' 1-I5 SlzeLeng~h:  ?.,O' 1Z*9; Thickrness.'Oameter 4.375 / 7,75" U~miiations: Sce prevtous roport # UTR.NO 851 fSxa~t Time; 1028 F~nish imec 130}5 FExamiati*,n SUrfa'-e: liisida [] Outs3de [,J Surf-=oe Cond~iiin: Groundi Plsh La Lcf.*ion: Zaro Datum Point Wo Locslkon: Weld Center Line CoUpi~nt; Sountdsaife Batch No.: 12120

-o'-n Temp. Tooi IfM-: AMEC Serial Na.:" IC64SGCY Sir*fSC6 Temp.; 72.3 *F Cjal. Re~pot No.." QAL-13-028, CAL-13-029. CAL-13-030 o(0 C-,o CD ScInigd 1 31 31 36

• 36 Se0, Preavious report:#UTRNO 851 P 6res iaerLon0 scam Weld RTS.*06 *'Je*o T -o'G'V";';J*.-* ****" T ¢ (*

Peneif Of Cvoerage Obtahv~e =-96: No .Rewicvwcd Pnr*-ious D~am: Yes~

z 0)0 0 WI VesselJ Exsd,atfirtn 03)

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 10 of 11 Figure C01 (Page 6 of 7)

/"Dominion-PERtCENT VOLUME BY SCAN DIRECTION Drawing Number: I 144R-W'*¥*IKS.RC-f-2 Mark Nur!b.r: . I-!5 SCAN j SCAN SCAN PERCENT

.ANGLE j DTRECTION .AR1..A ................... AMINED

-- f*0 ............... Wel1d & B~ase Mcmta 10%

6t)* 2 ... Weld & Base Me*al 75%

45* .... .. Weld & Base Metal ........ 36%

,60,....... 5 Weld & Ba.*o Memta 57 64S' 7 Weld &fls*._.(*_ .. ............... 10%

45* 7 Wed* &/.B*s Mei~i 10%A 60* 8 W eld &Jls t 1.f.a1 ....... .... .  %.

C2ommnt~as: AMt area* were se~ined with tihe maximum exsmt posible .from bo*th sides of the ,*vk1 whh th* 0*, 45nd AVEIRAGE PERCENYT EXAMPNED 31! %

May I 5. 2003 DOMIIO'N, VIIArNI,\ POWERS, LEVEL li[ *DATE j~y*

HS~-CT AMI~NI! Fi~V1~T~VS

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• i*'.'VIRGINIA ELECTRIC AND POWER COMPANY

-(q , RICHMOND, VIRGINIA 23261 October 9, 201510CR55a U.S. Nuclear Regulatory Commission Serial No.15-446 Attention: Document Control Desk SPS-LIC/CGL RI Washington, DC 20555 Docket No. 50-280 License No. DPR-32 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 ASME SECTION Xl INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONS PERFORMED IN THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL Virginia Electric and Power Company (Dominion) performed inservice inspection (ISI) examinations at Surry Power Station Unit I for the fourth 10-year ISI interval, which began on October 14, 2003 and ended on October 13, 2014. A one-year extension was applied to the end date of the fourth interval as allowed by ASME Section XI, IWA-2430(d). [

Reference:

Dominion letter Serial No.13-639 dated December 9, 2013 and NRC approval dated May 28, 2014]. Examinations of certain components conducted during the fourth interval received less than the required examination coverage.

Pursuant to 10 CFR 50.55a(g)(5)(iii), Dominion requests relief for limited examinations on the basis that the required examination coverage was impractical due to physical obstructions and limitations imposed by design, geometry and materials of construction of the subject components. Attachments 1 through 5 contain the specific relief requests and the basis for each request. These relief requests have been reviewed and approved by the station's Facility Safety Review Committee.

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

Si nce rely, Mark D. Sartain Vice President - Nuclear Engineering Commitments made in this letter: None

.a Serial No.15-446

• ', Docket No. 50-280 t* Relief Requests for Fourth Interval Limited Coverage Examinations Page 2 of 2 Attachments:

1. Relief Request LMT-R01, Category R-A, Risk Informed Piping Welds on Stainless Steel Piping

2. Relief Request LMT-R02, Category R-A, Risk Informed Piping Welds on Carbon Steel Piping

3. Relief Request LMT-R03, Category R-A, Risk Informed Dissimiliar Metal Welds on Steam Generator Nozzle to Safe-Ends

4. Relief Request LMT-P01, Category C-F-I and C-F-2, Preservice Weld Examinations

5. Relief Request LMT-C01, Category B-B, Pressurizer Shell to Head Circumferential and Longitudinal Welds 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 Ms. K. R. Cotton-Gross, NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Dr. V. Sreenivas, NRC Project Manager - North Anna 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

,I Serial No.15-446 Docket Nos. 50-280

'I Attachment I Relief Request LMT-RO1, Category R-A, Risk Informed Piping Welds on Stainless Steel Piping Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

• Serial No.15-446

~Docket No. 50-280

,* Relief Request LMT-R01 Attachment 1, Page 1 of 35 Relief Request LMT-R0I Risk Informed Pipe Welds Stainless Steel: Non-Alloy 600182/182 Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class 1 and 2 Examination Category: R-A, Risk Informed Piping Examinations Item Numbers: RI .11, Elements Subject to Thermal Fatigue RI1.16, Elements Subject to lntergranular Stress Corrosion Cracking Component Identification: Refer to Specific Table Material: Refer to Specific Table

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. Applicable Code Requirement

The examination requirements for piping welds for the Surry Power Station Unit 1 (SPS1) fourth 10-year inservice inspection interval were governed by the Risk Informed (RI) Inservice Inspection (ISI) Program as approved by NRC letter dated December 16, 1998. The SPSI fourth interval RI ISI Program is a full scope program covering ASME Section Xl Class 1, 2, and 3 components.

The pipe welds addressed by the RI ISI Program are assigned to a specific segment. The pipe segment definition includes the following considerations: 1) system, 2) pipe size, 3) flow junctions, 4) pipe failure consequence, and 5) isolation points for pipe breaks. The number of welds per segment varies. Examination is mandatory for some welds in a segment regardless of whether limited coverage will be attained. Other welds are sample selections, and an alternative weld may be chosen to replace the sample weld if the alternative weld could provide greater

,9 Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 2 of 35 examination coverage. Although not required by the RI 1SI Program, additional welds on the segment may be examined, in addition to the number of welds required by the risk informed analysis, to provide supplemental information for the segment.

The welds discussed in this section were selected for volumetric examination by the RI ISI Program due to the assigned item numbers: R1.11 for thermal fatigue or RI1.16 for intergranular stress corrosion cracking.

Neither the approved relief request nor the NRC Safety Evaluation for the RI ISI Program addressed an alternative for limited examination coverage. Therefore, the rules for ASME Section Xl shall apply when limitations are encountered due to the design, geometry and materials of construction of the component. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

10 CER 50.55a(b)(2)(xv)(A) requires the following examination coverage criteria when applying Supplement 2 to Appendix VIII:

(1) Piping must be examined in two axial directions. When examination in the circumferential direction is required, the circumferential examination must be performed in two directions provided access is available.

(2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full .coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.

10 CFR 50.55a(b)(2)(xvi)(B) requires that 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-sided examinations.

To demonstrate equivalency to two-sided examinations, the demonstration must be performed in accordance with the requirements of Appendix VIII as modified by 10 CFR 50.55a(b)(2)(xvi)(B) and §50.55a(b)(2)(xv)(A).

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%

volumetric examination coverage requirements for the subject austenitic welds due to the geometric configurations which limit the volumetric coverage that can be obtained.

When the examination area is limited to one side of an austenitic weld, examination

• Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 3 of 35 coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B). Therefore, full coverage credit may not be claimed.

The subject welds were examined with a manual ultrasonic (UT) technique using pulse echo ultrasonic instruments and search units to achieve the maximum practical examination coverage. Personnel, equipment and procedures were qualified in accordance with ASME Section Xl, Appendix VIII as implemented by the Performance Demonstration Initiative (PDI).

There are currently no PDI qualified single-sided examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to U.S. nuclear applications.

PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single-sided examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single-side qualification to demonstrate that the examiners' qualification and the subsequent weld examination is based on application of the best available technology.

In some of the earlier UT examinations performed in the first period of the fourth interval at SPS1 (October 14, 2003 - October 13, 2006), reporting "Best Effort" coverage when encountering single-sided limitations on austenitic steel material was not routine practice. Refracted longitudinal (RL) wave was typically used to investigate the far side of the weld to the greatest extent possible if the thickness of the pipe was greater than 0.5 inches. For piping 0.5 inches in thickness or less, a 70 degree examination angle is used to interrogate the far side of the weld. Any indications seen with the RL or the additional angle used would have been noted and investigated.

The required examination volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative techniques or advanced technologies were considered feasible and/or capable of obtaining complete coverage of the examination volume.

a. The 1-12 welds are the reactor coolant pump (RCP) to pipe welds for the three RCPs. Details are provided in Table 4a. The 1-12 welds fall within High Safety Significance (HSS) RI segments RC-010, RC-O011, RC-012 for Loops A, B and C, respectively, with a postulated failure mechanism of thermal fatigue. For each of the three segments, one sample weld (1-12) is required. Only one alternate weld exists on each of the individual segments, weld 1-13, which is a pipe to motor operated valve weld. The UT scanning area would also be restricted to one side

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 4 of 35 of weld 1-13 due to the pipe to valve configuration and would provide approximately 50% coverage similar to the 1-12 weld coverage. Due to the excessively high dose rates in this area, it is not feasible to attempt examination of the 1-13 welds which would offer, at best, only 50% coverage.

During the earlier years of the first period in the fourth 10-year inspection interval, scan diagrams were not prepared at the time of examination. Data was only recorded in tabular format as shown in Figure 4a of this attachment.

There were no recordable indications (NRI).

TABLE 4a Reactor Coolant Pump to Pipe Welds Drawing / Line# / IDI Weld System I Class Pipe PpDi.Tckes Coverage Limitation I Fig. No. /

Risk Informed Material PpDi.Tckes Achieved Results Pg. No.

Segment (Nominal) 48%

11448-WMKS-O100AZ-1 ASTM 45 and 60 Single-sided, 27.5"-RC-3-2501R /1-12 A-376, 2." .5" degree pipe to pump 4a Reactor Coolant / I Type 2.".5" shear wave I Segment RC-010 316 used, 60 NRI degree RL also used 48%

11448-WMKS-0101AZ-1 ASTM 45 and 60 Single-sided, 27.5"-RC-6-2501 R / 1-12 A-376, 27.5" 2.56" degree pipe to pump 4a Reactor Coolant /I Type shear wave 2 Segment RC-011 316 used, 60 NRI degree RL also used 48%

11448-WMKS-0102AZ-1 ASTM 45 and 60 Single-sided, 27.5"-RC-9-2501 R / 1-12 A-376, 27.5" 2.56" degree pipe to pump 4a Reactor Coolant/I1 Type shear wave 3 Segment RC-012 316 used, 60 NRI degree RL also used

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 5 of 35

b. The pipe welds discussed in this section were examined volumetrically by UT method for thermal fatigue concerns (item R1.11). Pipe weld description, examination and limitation descriptions are provided in Table 4b.

Segment RC- 017 The original requirements for Segment RC-017 of the RI ISI Program specified one mandatory examination, weld 2-08, and one sample weld, 2-03. The mandatory weld 2-08 exam was a single-sided, limited exam due to the piping configuration, valve to a pipe elbow. Full required coverage was achieved on weld 2-03. An additional weld was selected to supplement the limited coverage on weld 2-08. Weld 2-05 on segment RC-017 was also examined to meet full coverage requirements and to provide additional data for the segment. There were no indications noted on any of the examination areas.

Segment RC-018 The original requirements for Segment RC-018 of the RI ISI Program specified one mandatory examination, weld 1-08, and one sample weld, 1-05. The mandatory weld 1-08 exam was a single-sided, limited exam due to piping configuration, valve to a pipe elbow. Full required coverage was achieved on weld 1-05. An additional weld was selected to supplement the limited coverage on weld 1-08. Weld 1-03 was also examined, meeting full coverage requirements. There were no indications noted on any of the examination areas.

Segment ECC-005 Weld 1-09 is a mandatory selection for the RI ISI Program. Weld 1-10 is a sample selection. These are the only two welds on the segment. Weld examinations were limited as shown in Figure 4b2. No alternative weld selection exists. No indications were discovered on these welds.

Segment ECC-007 The two examinations of welds 1-09 and 1-10 on segment ECC-007 were performed in 2006 before the "good practice" of documenting best effort. Both weld examinations were limited as shown in Figure 4b3. An indication was found on weld 1-10. The indication was fully investigated and confirmed to be a construction related, geometric reflector and therefore not a flaw.

Weld 1-09 is a mandatory weld selection. There were no indications on weld 1-09. Weld 1-10 falls into the sampling risk informed region. These are the only two welds on the segment. No alternative weld selection exists.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 A

Attachment 1, Page 6 of 35 Segment R0-042 Two welds required examination on this segment. Weld 1-04 is a mandatory selection. Weld 1-02 is a sample selection. Both examinations were limited as shown in Figure 4b4. Weld 1-01BC on this segment was added as a supplemental examination with limited coverage obtained. No indications were found on any of these examinations.

Segment RC-043 Two welds required examination on this segment. Weld 1-03A is a mandatory selection. Weld 1-02 is a sample selection. Both examinations were limited as shown in Figure 4b5. Weld 1-01BC on this segment was added as a supplemental examination with limited coverage obtained. No indications were found on any of these examinations.

The pipe lines discussed in Section 4b are currently analyzed and inspected by the guidelines of the Materials Reliability Program (MRP-146) for the management of thermal fatigue on normally stagnant non-isolable reactor coolant system branch lines. This Program is part of the Surry Augmented Inspection Program under which select welds and pipe areas receive periodic examination as required by the MRP guidelines. The MRP-146 Program did not exist when the initial RI 1SI Program was developed for SPSI. Therefore, no credit was allocated for the MRP-146 Program.

TABLE 4b Risk Informed Pipe Welds, Stainless Steel, MRP 146 Drawing/ILine# / IDI System I Class Pipe Pipe Weld Coverage Limitation I Results Fig. No. I Risk Informed Material Dia. Thickness Achieved Pg. No.

Segment I11448-WMKS-0122K1 Typ 1 0 igesdd av

/ -C1 -8 Stainless 6" 0.797" to elbow 4bl Reactor Coolant / I Ste10 R Segment RC-017 Best Effort NR I11448-WMKS-0122J1 Type 316 50% Single-sided, valve

/ 6-RC-21 / 1-080.6"telo4b Reacor Colan /1 RatrCoat/1 Stainless Steel 6" 056"telo4b 15.56%

(Nominal) 2 Segment RC-018 Best Effort NRI I11448-WMKS-0122H1 Tye3650% Single-sided, pipe

/ 6-RC-16 / 1-09 Type6316to valve 4b2 Reacor Colan /1 RatrCoat/1 Stainless Steel 6" 052 (Nominal) 3.5%1 Segment ECC-005 Best Effort NRI

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 7 of 35 Drawing I Line# / IDI System I Class Pipe Pipe Weld Coverage Limitation I Results Fg o Risk Informed Maeil Da hcns civdPg. No.

1 1448-WMKS-0122H1 Type 316 50% Single-sided, valve

/6-RC-16 / 1-10 Sanes 6" 0.750" to pipe 4b2 Reactor Coolant / 1 ins 3.5% 2 SteelBetEfr Segment ECC-005 BsEfotNRI 50%

I11448-WMKS-0122J1 Type 316 Examination Single-sided, pipe to

/ 6-RC-21 / 1-09 0.6" promdvalve 4b3 Colan I i Reacor Stainless 6" 052 efre RatrCoat/1 Steel (Nominal) prior to1 Segment ECC-007 practice of NRI recording Best Effort 50%

Single-sided, pipe to 11 448-WMKS-0 122J 1 Tye36Examination valve 6ReatrCoolan/ 1- Stainless 6" 0.562" performed4b RatrCoat/1 Steel (Nominal) prior to Geometric indication 2 Segment ECC-007 practice of occurred during recording original construction Best Effort 1 1448-WM KS-0127J2 50% Single-sided, elbow

/ 6-RC-19 / 1-02 Type 316 6" 0.522" (1) to weldolet 4b4 Reactor Coolant /I Stainless 1% 1 Segment RC-042 Steel Best Effort NRI 1 1448-WMKS-0127J2 Type 316 50% Single-sided, valve

/ 6-RC-19 / 1-04 to elbow 4b4 Reactor Coolant / 1 Stainless 6" 0.735" (1) 3%2 Segment RC-042 Steel Best Effort NRI 1 148-WMS-017J26" pipe to 27.5" cold

/6R-9 -IC Type 316 5%leg branch 4b4 ReactorCoolan / 1-0B Stainless 6" 1.85" connection3 SegmerColnt /C1 Steel (Nominal) 23.7%3 Semn C02Best EffortNR 1 148-WMS-027J350% 6" pipe to 27.5" cold Type-WKS03163 0%leg branch

/ 6-RC-20 / 1-01BC Tye3618"cncto4b RatrCoat/1 Stainless 6" 18"cneto b ReacorColnt /C-0I Steel (Nominal) 23.7% 1 Segmnt R-043Best Effort NRI

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 8 of 35 Drawing I Line# I ID/

System / Class Pipe Pipe Weld Coverage Limitation!/ Results Fig. No. /

Risk Informed Material Dia. Thickness Achieved Pg. No.

Segment 1 1448-WMKS-0127J3 Tye3650% Single-sided, pipe to

/ 6-RC-20 / 1-02 Tye36branch connection 4b5 Reactor Coolant /I Stainless 6" 0.528" (1) 1.5% weld 2 Segment RC-043 SelBest EffortNR 11448-WMKS-0127J3 Type 316 50% Single-sided, valve

/ 6-RC-20 / 1-03A Stils " 0.562" to elbow 4b5 Reactor Coolant/i1 Steel (Nominal) 4.83% 3 Segment RC-043 Best Effort NRI (1) Actual measured thickness obtained from NDE records not provided in this relief request; this value differs from the nominal value shown in the referenced figure.

c. The pipe welds addressed in this section were ultrasonically examined for thermal fatigue (ASME Item R1.11) or intergranular stress corrosion cracking (ASME Item R1.16). Details are provided in Table 4c and in the referenced figures.

Segment EGG-006 Only two welds exist on this segment. Weld 2-09 falls within the mandatory examination region for the RI ISI Program, and weld 2-10 is categorized as a sample selection. The welds were examined ultrasonically for thermal fatigue (ASME Item R1.11). Both welds were examined to the fullest extent possible as detailed in Table 4c and Figure 4c1. No indications were discovered during either examination.

Segments RS-004A, 003A Only one weld exists on each of these segments: piping from the containment sump (wall) to the Outside Recirculation Spray (ORS) Pump suction motor operated valves. Weld 1-06 on segment RS-004A and weld 1-03 on segment RS-003A were examined ultrasonically for intergranular stress corrosion cracking (ASME Item R1.16). Both welds of this configuration for each of the ORS Pumps were examined to the fullest extent possible. No indications were discovered on either weld.

Segment HHI-011 Weld 5-AF is the only weld on this segment of piping from the High Head Safety Injection containment penetration to the first check valve inside containment.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 D

Attachment 1, Page 9 of 35 The weld was ultrasonically inspected for thermal fatigue to the greatest extent possible. There were no indications.

Segments LHI-004A, 003A Only one weld exists on each of these segments, piping from the containment sump (wall) to the Low Head Safety Injection (LHSI) Pump suction motor operated valves. Weld 1-13 on segment LHI-004A and weld 1-15 on segment LHI-003A were examined ultrasonically for intergranular stress corrosion cracking (ASME Item R1.16). Both welds of this configuration for each of the LHSI Pumps were examined to the fullest extent possible. No indications were discovered on either weld.

Segment RH-013 Two welds on this segment required ultrasonic examination for intergranular stress corrosion cracking, welds 3-02 and 3-03. The examinations on both of these welds were limited. The branch connection weld 3-01 BC on this segment was added to supplement the data from the two limited examinations.

Weld 3-01 BC was examined with the liquid penetrant method obtaining full coverage. No meaningful UT coverage could be obtained on branch connection weld 3-01BC. No additional selections exist on this segment. No indications were discovered during any of the examinations.

TABLE 4c Risk Informed Pipe Welds, Stainless Steel Drawing / Line# I ID/

System I Class Pipe Pipe Weld Coverage Limitation / Results Fg o Risk Informed Material Dia. Thickness Achieved Fig. No.I Segment I11448-WMKS-0122K1 Type 316 50% Single-sided, pipe to I 6-SI-48 / 2-09 Stainless 6" 0.562" valve 4cl Safety Injection/I1 Steel (Nominal) 1% 1 Segment ECC-006 Best Effort NRI I11448-WMKS-0122K1 Type 316 50% Single- sided, valve

/6-SI-48 /2-10 Stainless 6" 0.610" (1) 1% topp2c Safety Injection/I1 SteelBetEfr2 Segment ECC-006 BsEfotNRI I11448-WMKS-1101A5 Type 304 46.3% Single- sided, pipe

/12-RS-7/1-06 Stainless 12" 0.510" 11.9% tovlv 1 Recirculation Spray I 2 Steel Best Effort NRI Segment RS-004A

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 10 of 35 Drawing I Line# / ID/

System I Class Pipe Pipe Weld Coverage LitaonIRslsFgNoI RsInomd Material Dia. Thickness Achieved LiiainPRslsFg. No.I Segment 50%

11448-WMKS-1101A5 Examination Single-sided, valve

/ 12-RS-8 / 1-03 Type 304 performed to elbow 4c2 Recirculation Spray / 2 Stils 2 .1"prior to 2 SgetR-0A Steel practice of NRI Segmnt R003Arecording Best Effort 50%

1 1448-WMKS-1 106A4 Examination Single-sided, pipe to I 3-SI-70 / 5-AF Type 304 performed valve 4c3 SftIneto/2 Stainless 3" 0.520" prior to 1 HI-11practice Steel of NRI Segmet 1recording HHI01 Best Effort 50%

1 1448-WMKS-1 106A7 Tye34Examination Single-sided, elbow

/ 12-SI-I / 1-13 Tye34performed to valve 4c4 SaeyIjcin/2 Stainless 12" 0.490" prior to 1 Segment LHI-004A Selpractice of NRI recording Best Effort 50%

11448-WMKS-1106A7 Tye34Examination Single-sided, pipe to

/ 12-SI-2 / 1-15 Tye34performed valve 4c4 Stainless 12" 0.487" prior to2 Safety Injection / 2 Steel2 Segment LHI-003A practice of NRI recording Best Effort 11448-WMKS-0122A1 5% Snl-iebac

/ 3-RH-13 / 3-02 Type 304 5%Snl-iebac Residual Heat Stainless 3" 0.375" connection to pipe 4c5 Removal / 2 Steel (Nominal) 9% 1 Segment RH-013 Best Effort NRI 11448-WMKS-0122A1 I 3-RH-13 / 3-03 Type 304 50% Single-sided, pipe to Residual Heat Stainless 3" 0.420" flange 4c5 Removal / 2 Steel (Nominal) 10% 2 Segment RH-013 Best Effort NRI (1) Actual measured thickness obtained from NDE records not provided in this relief request; this value differs from the nominal value shown in the referenced figure.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 11 of 35

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option to rebuild components is considered impractical and would cause unnecessary radiation exposure. Furthermore, plant equipment could be impacted in a detrimental manner.

6. proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques. With the incorporation of the PDI for Supplement 2, demonstration for best effort coverage was made for single-sided examination from the accessible side of the weld. Additionally, these components are monitored for through wall leakage as part of the ASME Xl System Pressure Test Program and receive visual (VT-2) examination as required by Section Xl, Table IWB-2500-1, Category B-P for Class 1 components and IWC-2500-1 Category C-H for Class 2 components.

None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. There are no known failures of the welds discussed in this section at SPS1. Any indications were recorded and dispositioned as geometric or construction related.

No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results, the visual (VT-2) examinations performed routinely and the fact that additional welds were examined to supplement the requirements, it is reasonable to conclude that service induced degradation would have been detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds. Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inservice inspection interval for SPS1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 12 of 35 Figure 4a (Page 1 of 3)

/ Dominion' STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 1 1448-WMKS-0100AZ-1 Mark Number 1-12 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME USRA (1STLEG) _ _ _ _ _ _ _

450 EXAMINATION VOLUME ( 2 nd LEG) _______

450 EXAMINATION VOLUMEW(STRLEG)AM _____

450 EXAMINATION VOLUME DWSRA

____________ ~~~(

2n LEG) _________

450 EXAMINATION VOLUME (2w 50G 450 EXAMINATION VOLUME CCW 50 600 EXAMINATION VOLUME UPSTREA UPSTREAM 600 EXAMINATION VOLUME (ind LEG) 0 DOPSTREAM 600 EXAMINATION VOLUME (2ST LEG) 92 600 EXAMINATION VOLUME DOWNTRLEAM9 UPWSTREAM 700 EXAMINATION VOLUME (1ST LEG) _______

DOWSTREAM 700 EXAMINATION VOLUME (S E) ______

UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 92 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TO TAL PER CENT 48 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 13 of 35 Figure 4a (Page 2 of 3)

S~Dominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 1 1448-WMKS-0101AZ-1 Mark Number 1-12 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM 450o EXAMINATION VOLUME (1nt LEG) 450 EXAMINATION VOLUME (2st LEG) 450 EXAMINATION VOLUME DOWSTRLEAM 450 EXAMINATION VOLUME (2W' 50G 450 EXAMINATION VOLUME CCW 50 UPSTREAM 600 EXAMINATION VOLUME (1s* LEG) 0 UPSTREAM 600 EXAMINATION VOLUME ( 2 nd LEG) 0 DOWNSTREAM 600 EXAMINATION VOLUME (1st LEG) 92 DOWNSTREAM 600 EXAMINATION VOLUME ( 2fld LEG)

UPSTREAM 700 EXAMINATION VOLUME (1st LEG) 7Q0 7°EXAMINATION VOLUME DOWNSTREAM (1st LEG)

UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 92 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TO TAL PERCENT 48 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 14 of 35 Figure 4a (Page 3 of 3)

SDominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 11 448-WMKS-010O2AZ-1 Mark Number 1-12 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM 45° XAMIATIN VOUME(1st LEG)

UPSTREAM 450 EXAMINATION VOLUME ( 2fld LEG)

DOWNSTREAM 450 EXAMINATION VOLUME (1st LEG) 450 XAMIATIN VOUMEDOWNSTREAM 45_____ EXMNTO OUE( 2fld LEG) 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 600o EXAMINATION VOLUME UPSTRLEAM UPSTREAM 600 EXAMINATION VOLUME (2fld LEG) 0 DOWNSTREAM 600 EXAMINATION VOLUME (1 st LEG) 92 600 EXAMINATION VOLUME (2DOWSTEAM UPSTREAM 700 EXAMINATION VOLUME (1st LEG) _______

7Q0 EXAMINATION VOLUME (1st LEG) _______

UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 92 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TOTAL PERCENT 48 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 15 of 35 Figure 4bl (Page 1 of 2)

Weld Number 2-08 Weld Width 0.75" Weld Length 21 .625" 2I l , 1 2 I I, i .... I.. I.,. I ....

. . . . I I I r I I J. " . . . . . . . . . . . . . . . . . . .

FLOW 2 CL 45 VALVE ELBOW 0.188" HT X.875"' WIDTH =0.165 SQ. IN REQUIRED VOLUME UPSTAND DNST SIDE EXAMINED 100% DNST AX AND C1RC DIRECTION EXAMINED 0.07 SQ IN,UPST AX DIRECTION 0,071.165 = 0.42 X 100 = 42% BEST EFFORT UPST AX DIRECTION NO EXAM CIRO DIRECTION UPST SIDE Examination Volume Dimensions:- Heloht: 0.188" Length: 21.625" Width 1.75" Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage)

ANGLE UpSt-Ax UpSt-Circ DnSt-Ax DnSt-Circ 45 _________0% ________ 100%

60 _________ ________100%

60L *42% __________,________.________, ___

Code Coverage Total I 50%

100+1 00+0+42=2421400=60

• Best Effort Coverage (Max 25%) Total 10%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 16 of 35 Figure 4b1 (Page 2 of 2)

Weld Number: 1-08 Weld Length: 20.8" Weld Width: 0.6" Flow Box Dimensions: H =0.22", L = 1.5" Valve-Best Effort Coverage:

UpSt Exam Area = 0.22" x 0.75" =0.165 in2 Examined (0.22 x 0.15) + (0.22 x 0.4)/2 =0.077 in2 0.077 10.165 = 46.67%

46.67% 13 UpSt Scans = 15.56%

_______Coverage Summary Required Scans (each scan has a weighing factor of 100 for complete coverage)

Angle UpSt - Ax UpSt - OW UpSt - CCW DnSt Ax- DnSt. - W DnSt -. CCW 45160 0% 0% 0% 100% 100% 100%

60 RL 46.67% __________ __________ ______

Code Coverage Total 50%

Best Effort.Coverage (Max 50%) Total . 15.56%/,

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 17 of 35 Figure 4b2 (Page 1 of 2)

Weld Number: 1-09 Weld Length: 21" Weld Width: 0,9" Flow Box Dimensions: H = 0.19", L= 1.9" Pipe Best Effort Coverage:

DnSt Exam Area =0.19" x 0.95" =0.181 in2 Examined (0.15 x 0.25)/2 = 0.019 in2 0.019 /0.181 = 10,5%

10.5% 13 DnSt Scans =3.5%

Reqire Sans(eah Canhsv e iaghingmfactry o 0 o oplt oeae Angle U~pSt -Ax UpSt -CW .UpSt-CCW -- DnSt -Ax DnSt -CW DnSt -CCW 60 100% 100% 100% 0% 0% 0%

60RL ______ ______ 10,5% _______

Code Coverage Total 50%

Best Effort Coverage (Max 50%) Total 3.5%

Notes:.

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix Viii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 18 of 35 Figure 4b2 (Page 2 of 2)

Weld Number: 1-10 Weld Length: 20.8" Weld Width: 0,9"' FRow Box Dimensions: H= 0.19", L =1.9" Valve r--

Best Effort Coverage:

DnSt Exam Area = 0.19" x 0.95" = 20.181 in2 Examined (0.15x 0.25)/2 = 0.019in 0.019 10.181= 10.5%

10.5% 1 3 DnSt Scans =3.5%

Coverage Summary Angle Required Scans (each scan has a weighing factor of 100 for comn lete coverage)

UpSt -Ax UpSt -CW UpSt -CCW DnSt -Ax DnSt- CW DnSt- CCW 45 /60 0% 0% 0% 100% 100% 100%

60RL 10.5% ________________ ____________

Code Coverage Total 50%./

,j...... ... . Best Effort Coverage (Max 50%) Total 3.5%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 19 of 35 Figure 4b3 (Page 1 of 2)

Dominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number 1 1448-WMKS-0122J1 Mark Number 1-09 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME UlSTRLEAM NA 450 EXAMINATION VOLUME UPST LEA) NA 450 ~DOWNSTREAM N 4°EXAMINATION VOLUME ( 15t LEG) N

,450 EXAMINATION VOLUME DOWNSTREAM NA 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 600 EXAMINATION VOLUME UP STREAM NA 600 EXAMINATION VOLUME UPSTR EAM NA 600 EAMINAION VLUMEDOWNSTREAM N

___0__ EXMNTO OUE(I st LEG) N DOWNSTREAM 600 EXAMINATION VOLUME ( 2 rndLEG) NA 70° EXAMINATION VOLUME UPSTRLEAM 100 700 EXAMINATION VOLUME DOWNSTREAM)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50

________________________ TOTAL-PERCENT 50 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 20 of 35 Figure 4b3 (Page 2 of 2)

STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOLUME BY SCAN DIRECTION Drawing Number I11448-WMKS-01 22J1 Mark Number 1-10 ANGLE SCAN AREA SCAN SIDE SCAN %

45 EAMNAIO VLUEUPSTREAM NA 4__EXAINTIOVOUM (Ist LEG) 45° XMNTINVLM UPSTREAM N EXAMINATION VOLUME (2DOWSTEA) NA 450 EXMNTO OUEDOWNSTREAM N 40EXAMINATION VOLUME C1 50LG)N 450 XAMNATON OLUEDOWNSTE0 600 EXAMINATION VOLUME (Is! LEG) N 60EXAMINATION VOLUME CWTRA 50 60EXAMINATION VOLUME DOWNSRA 100 600 EXAMINATION VOLUME DOWNTREAM NA 700 EXAMINATION VOLUME UPSTREAM(2* NA

____ ___ __ _....... _ __ _ __ __ (ULEG) _ _ _ _ _ _ _

700 EXAMINATION VOLUME DOWNSTREAM

__ ___ __ __ __ __ __ _ (2Id LEG) NA 70 XMNTOCOEAGA OUEUPSTREAM DOWNSTREAMDOVERAGEE10 CLOKWSTEA COVERAGE 50 COUNTER CLOCKWISE COVERAGE 50

___ ___ ___ ___ ___ ___ TOTAL PERCENT 50 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 21 of 35 Figure 4b4 (Page 1 of 3)

Report No: UT-12-061 Summary # Si. R1.11.880 Dominion° Pg. 5 of 5 Prepared by: W. Thomas ,

Date; 5/18/20:12 Weld Number 1-02 Weld Width .,9' Thickness .572" Weld Length 21"

. .. ., . .. . I .. . . , .. . .I . .. . , . .. .* ... ., . . .. I .. .. , . . . . I . . . . , . . . .

I 2 1 2 FLOW 1-02 CL WELDOLET

/ ELBOW

.191" IITX .95" WIDTH .18 SQ. IN. REQUIRED UPSTANO DNST SIDE" SEXAMINED 100% REURDVOWUME UPST SIDE

,.j EXAMINED 0.01 SQ. IN. BEST EFFORT DNST AX DIRECTION

.01 1.18 =.055 X 100 = 5.5% BEST EFFORTAX DIRECTION DNSTSIDE.

NO EXAM DNST SIDE CtRC DIRECTION Examination Volume Dimensions - Height .191" Length 21" Width 1.9"

_....... Coverage Summary

_______Required Scans (each. has a,weighing factor of 100 for complete coverage)

ANGLE U~pSt-Ax UpSt-Clrc DnSt-AxDntCr

) odeCovrag reerstothemaxmumperentge ofdtreuiedera~atg e o votlume50 that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume pastthe weld centerline that Is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

6'~i

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 22 of 35 Figure 4b4 (Page 2 of 3)

Report No: UT-12-060 Summary # Si. R1.11.882 Dominion° Pg. 5 of 5 Prepared by: W. Thomas Date: 5/18/'2012 Weld Number 1-04 Weld Width ,9" Thickness .570' Weld Length 21" S2 1 1 +/-0 2 i

FLOW a.

ELBOW VALVE

,1B' HTX .O5"WIOTH =.18&LO INREcQUIREDOVOLUMEUPST ANDDNST" OE

• **m<.E 10=% OF "ER*OEQJRVOWMEOWSTIOE

"* EXAMINED .02 SQ. IN.BEST EFFCRT UPST SIOE/*( tSRBTICN

....02/.10 = 0.11 X100 = 11% BEST EFFORT UPSraDtEA(DlREOT1ON NOEXAM UP&I CIRC DIRECTION Examination Volume Dimensions - Height .19" Length 21" Width 1.9"

_____Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage)

ANGLE U pSt-Ax, UpSt-Circ DnSt-Ax DnSt-Clrc 45,/60 I 100% I 0%

70 100%

60L *11% I Code Coverage Total I 50%

100+-100+i0+11=211/4=53 Best Effort Coverage (Max 25%) Total ... 3%

Notes:

1) Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examiniatlon procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that Is examined in the axial beam direction with an Appendix VIii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 23 of 35 Figure 4b4 (Page 3 of 3)

Report No: UT-13-126

• Donainion" Summary # $1.R1.11.879 Pg. 6 of 6 oe lwed Prepared by: W. Thomas ***.- 11 Witnessed Date: 11/9/2013 7933 Weld Number 1-01BC Weld Width 1L.50" HSB GS Thickness 1.85" Weld Length 30.5" 2 1 0 1 2

'5

'U C

I

'U

/5 ~5Sf2.INROCSJJROOVOtUMSDSSlOE IN. I3SCDL'XDIR.

.361.~ ~S47XiSO'441%

/

N

• NO E~tAMOSAX DIR 5;.3%

Examination Volume Dimensions Height 0.62" Leng1th 30.5" Width 2.4" J

_______Coverage Sum mary Required Scans (each has' a weighin~g factor of 100 for complete coverage)

ANGLE ' UpSt-Ax U pSt-C:irc DnSt-Ax DnSt-Clrc,.

45/60 100% I 100% 0II 6OL *94.7%

Code Coverage Total j 50%

100*100.,+,0,+94.7=294.7/44=3.7 , , 'Best: Effort.Covera~ge (Max 25%) Total I23.7%

Notes:

1) Code Coverage refers to the maximum percent~age of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 24 of 35 Figure 4b5 (Page 1 of 3)

Report No: UT-43-124

• Dominion" Summary # S1.R1,11.930 Prepared by: W. Thomas Reiee Date: 11/8/2013 t* Witnesso Weld Width 1.60" * ///

Weld Number 1-01BC Thickness 1.85" Weld Length 30.5" 7933

.. a . ,, r , . .

45 a

Ki~8 I~.

______________ i~\

j~a~uai~n~UME 05 805 /

SQ ~N.D5805MtSR.

Q~assrss~Faftr" .55I.~8 1iI4?K1C8=~4.7%

SNO EKAM4 OSAXDIR53%

Examination Volume Dimensions - Height 0.62" Lenath 30.5" Width 2.4" Coverage Summary Required Scans (each has a wei~ghing factor of 1(00 for complete coverage)

,ANGLE ,.,UpSt-Ax UpSt-Circ DnSt-Ax .... DnSt-Circ 45/60 -- 100% I 100% ..... 0%

60L *94.7%

,,,,,Code Coverage Total [,50%

100*100+0+94.7=294.7/4=73.7 Best Effort Coverage (Max 25%) Total J 23.7%

Notes:

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 25 of 35 Figure 4b5 (Page 2 of 3)

Report No: UT-13-127 Summary #f$1.R1.11.931

~DomIni@n Pg. 5 of6 Prepared by: W. Thomas *~',,6-Date: 11/9/2013_

Weld Number 1-02 Weld Widt th 0.8" Thickness 0.552' Weld Leng**th 21' FLOW CL 1-02

,i z i _

0.1 84-rrx 0.025"DhIDI = 0.110 So, INREQUIRED VOLUME EACH SIDE OFWELW

• ,'FFFFFFFF*.,EXAMINED 100% OFTHE REQUIRED EXAM VOLUME US SIDE EXAMINED 0.01 00. IN.DS SlOE AX DIRECTION BEST EFFORT

"- BEST EFFORT= .01/ .17 =0,052 X 10016.0%

• ~NO EXAM OS SIDE AXDIRECTION = 94,1%

Examination Volume Dimensions - Height 0.184" Length 21" Width 1.8" Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage),

ANGLE U~pSt-Ax UpSt-Clrc DnSt-Ax DnSt-Circ

.60L Code Coverage Total 50%

1OD+100+0+5.9=205.9/4=51.5 ...*Best Effort Coverage (Max 25%) Total 1.5%

Notes: ii ii i=

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined In the axial beam direction with an Appendix Viil demonstrated procedure for single sided coverage.

Reviewed 7933 HSB GS

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 26 of 35 Figure 4b5 (Page 3 of 3)

Supplemental Report i 'I ' . , '

Report No.:" 'Ur-07-045 Page: 2 of 2 Examiner: Coburn, Timothy M Level: I...I Reviewer.

Date: It- 3-0o7 Examiner: N/A Level: N/A site Review: z -,} Date //0* D Other:. N/A .Level: N/A ANII Review:_____________ Date '

Comments:

Comments:

Weld Number: 1-03A Nora. Thickness: 0.562" Weld Length: 20.8" Flow Weld Width: 1.25' Box Dimenslons: H =0.19", L =2.25" cjI-Valve - - --- -.-... "- 2" / Elbow.

US exam box = .019"x 1.125" =0(.214 in, Examined (0.19' x 0.33")!* 2 0.031 in2.

0.031 / 0.214 =14,5%

14.5%/S scans =4.83%

-- Coverage Summary Angie. Required Scans (ea~ch scan has aweighing factor of 100 for complete coverage)

U ~t-Ax UpSt - W UPSt"CCW DnSt- Ax DnSt - CW DnSt-OCCW

• 45/60 0% "- 0% 0% 100%' 100% 100%

60 RL . 14.5%

Code Coverage Total 50)%

• Best Effort Coverage (Max 50%) Total 4.83%

Notes:

1. Code Coverage refers to the maximurn percentage of the required examination volume that is effebtively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with" an Appendix VIII demonstrated p~rocedure for single sided coveragqe.,

Mddlionrl - Soppieern~el Reports

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 27 of 35 Figure 4c1 (Page 1 of 2)

Report No: UT-09-059 Summary # S1.R.1,11.521 SDominion" Pg. 4 of 4 Prepared By: W.L. Thomas  %- SiIh~o7 Date: 5/1/2009 Weld Number 2-09 Weld Thickness .562" Weld Length 20" Weld Width 1.o" FLOW PIPE NR NN

• • .* AEA EXAMINO U.s QieSQ 1N058.

-,, AJ*-EXAMtNSDBESr EPIORTO.OI SO. INQ-*

OF NO ME'(PM1OTN .S.

,'ed*-~AI 0c1eSQ. NC-ES B*;T EFFORT AI*JAI OOIE I*QURB* ARED.S. NOT TO SCALE 100+ l00+5+0=20514=51%

Examination Volume Dimensions - Height .187" Length 20" Width 2"

____._._C~overage ,Summary Required Scans (each has a weighing factor of 100 for~complete coverage)

ANGLE I UpSt-Ax U~pSt-Circ DnSt-Ax DnSt-Circ'

""45 100% 0%

60 100% 3 60RL 5%

Code CoverageTotal _ 50

, ~Best Effort Coverage (Max 25%) Total I *1 Notes:

1) Code Coverage refers to the maximum percentage of the required examination ..

volume that Is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examinatin volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage. .

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 28 of 35 Figure 4c1 (Page 2 of 2)

Report No: UT-09-060 Summary #SI.R1.1 1.522 SDominionr Pg. 4 of 4 Prepared By: W.L Thomas -

Date: 511/2009 Weld Number 2-10 Weld Thickness .562" Weld Length 20" Weld Width 1.0" PLOW

-_...=,.__ .

1,L]

PiPEVL-V

.01" NR

/, .AIEA6XA.MtEDUSE9SQ FFORT0,OSQ. IC

,'* A :AFN.IrEDtJe[NArEION IOSQ.018, INd-ES BEST 6FORr AREAl c:oca rUREQIDARe-ADS. NOT TO SCALE O.O1/O,9=S5%.

100+ 100+5+0=205/4--51%

Examination Volume Dimensions - Height .187" Length 20" Width 2"

_______Coverage Summary Required, Scans (each has a weighi~ng, factor of 100 for complete coverage)

SANGLE UpSt-Ax Upst-Circ .... Dnst-Ax 'DnSt-Circ 45 100% 0%

60 100% .... .

6ORL 5%

Code Coverag* Total J 50%

........ Best Effort Cove~rage (Max 25%) Total' 1%

Notes:

Code Coverage

1) volume the maximum refers to examined the qualffledofexamination with percentage examination the requiredprocedure.

tttat is effectively

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstr~ated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 29 of 35 Figure 4c2 (Page 1 of 2)

Report No: UT-13-1_36 Summary # $1.R1.16.532 Pg. 5 of 5 Prepared by: W. Thomas ** -*-

Date: 11/8/2013 K. . . . . . . ..... . ..

Weld Number 1-06 Weld Width 0.5"I Thickness 0.386" Weld Length 40.5" 0

1 12 ____.1 FLOW HCSB GS 1-06.-' CL PiPE \ "'"-*..! VALVE 0.129" HTXO0.75" WI]DTH =0.097 SQ. IN. X 40.5" LENGTH = 3.93 CU. IN.

REQUIRED VOLUME EACH SIDE OF WELD =3.93 CUBIC INCHES 3" LIMITATION FOR ALL SCANS OS SIDE OF WELD

• _,::_. ., EXAMINED 37.5" OF THE REQUIRED 40.75' LENGTH

... 37.51 40.5= 0.926 X 100 = 92.8% DS SIDE AX AND CIRC DIR.

!*'.;';*'.z'.EXAMI NED .05 SQ. IN. X37.5" LENGTH = 1.875 CU. IN.

BEST EFFORT = 1.875 CU. IN. 1,8751/ 3.93 = 0.477 X 100 = 47.7%

"*'T;*KT:* NO EXAM US SIDE AX DIRECTION = 52.3%

Examination Volume Dimensions - Height 0.129" Length 40.5" Width 1.5"

________Coverage Summary Required Scans (each has a weighing factor of 100 for complete coverage)

ANGLE UpSt-Ax UpSt-Circ DnSt-Ax DnSt-Circ 45/60 I 0% 92.6% I 92.6%

70 *47.7%

Code Coverage Total I 46.3%

92.6+92.6+0+47.7=232.9/4=58.2 *Best Effort Coverage (Max 25%) TotalI 11.9%

Notes:

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverag~e.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 30 of 35 Figure 4c2 (Page 2 of 2)

SDomh~,io-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11448-WMKS-1101A5 Mark Number: 1-03 ANGLE SCAN AREA SCAN SIDE SCAN %

45 XMIAIN OUEUPSTREAM ,

45° EXAINATIONVOLUME(1st ILEG)I, 450 XAMIATIN VOUMEUP STREAM 45 EAMNAIO VLUE(2* LEG) NA 40DOWNSTREAM 0 4 EXAMINATION VOLUME (jst LEG) ______

450 XAMIATIN VOUMEDOWNSTREAM 4__EXANTIOVOUM (2'* LEG) NA 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50I 600 EXAMINATION VOLUME UPSTRLEAMI0 600 EXAMINATION VOLUME U2PSTREOMN 600 EXAMINATION VOLUME DOWSTRLEAM 60° EXAMINATION VOLUME DOWNSTREAM (2 0d LEG) NA UPSTREAM*

700 EXAMINATION VOLUME ( 1 5t LEG) _______

'700 EXAMINATION VOLUME DOWNSTRLEAM)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCK WISE COVERAGE 50 COUNTER CLOCKWISE COVERAGE 50 TOTAL PERCENT 50 %

• 450 exam coverage encompassed by the 600 and 70*exam used for procedure only and not for coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 31 of 35 Figure 4c3 (Page 1 of 1)

)Dominion-

• STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UME BY SCAN DIRECTION Drawing Number: 11448-WMKS-1106A4 Mark Number: 5-AF ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME UPSTRLEAM 450 EXAMINATION VOLUME ( 211d LEG) _______

450 XAMIATIN VOUMEDOWNSTREAM 450 EXAMINATION VOLUME (1fldLEG) _______

450 EXAMINATION VOLUME CWLG 450 EXAMINATION VOLUME CCW 600 EXAMINATION VOLUME UPTRAM10 UPSTREAM 600 EXAMINATION VOLUME (! st LEG) 100 DOWSTREAM 600 EXAMINATION VOLUME (2"d LEG) NA 600 EXAMINATION VOLUME DOWNSTREAM (Ind LEG).

N0______

700 EXAMINATION VOLUME UPWSTREAM (2"t LEG). _______

NA 700 EXAMINATION VOLUME DOWNTRLEAM 70°EXAINTIOVOUM (Ist LEG) _______

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TOTAL PERCENT 50 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 32 of 35 (Figure 4c4)

(Page 1 of 2)

SDominin-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11448-WMKS-1106A7 Mark Number: 1-13 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EAMINAION VLUMEUPSTREAM*

450° EXAMINATION VOLUME ( 1sAM NEA 45 EAINTONVLUE( 2 nd LEG) NA______

450 DOWNSTREAM*

4 EXAMINATION VOLUME (IlaLEG) 450 EXAMINATION VOLUME DOWNSTREAM N

______( 20d LEG) N 450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 UPSTREAM10 600 EXAMINATION VOLUME (1St LEG)10 600 EXAMINAT[ON VOLUME UP"STLEAM NA 600 EAMINAION VLUMEDOWNSTREAM 60°EXAINTIOVOUM (10 LEG)0 600 EXAMINATION VOLUME DOWNSTREAM N

__ __ __ __ __ __ __ __ __ __ __ (2'* LEG) N 700 EXAMINATION VOLUME UPST LEAM NA 700 EXAMINATION VOLUME DOWNTRLEAM NA UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50

_________________________ TOTAL PERCENT 50 %

• 60* axial scan encompassed the 450 axial scan. 700 was used to interrogate far side of weld only and not for coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 33 of 35 (Figure 4c4)

(Page 2 of 2)

) Dominloinr STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11 448-WMKS-11I06A7 Mark Numbe: 1-15 ANGLE SCAN AREA SCAN SIDE SCAN %

450 EXAMINATION VOLUME UPISTRLEAM 450 ~UPSTREAM N 4 EXAMINATION VOLUME (2'* LEG) N 450 EXAMINATION VOLUME (1Ist LEO) ______

450 ~DOWNSTREAM N 4°EXAMINATION VOLUME (2 0d LEG) ____A__

450 EXAMINATION VOLUME CW 50 450 EXAMINATION VOLUME CCW 50 600 EXAMINATION VOLUME UPSREA 100) 600 EXAMINATION VOLUME U2PSTREAM NA 600 EXAMINATION VOLUME DOWNSTRLEAM 0 600 EXAMINATION VOLUME DOWNSTREGM NA 700 EXAMINATION VOLUME U(SREA LE DOWNSTREAM*

700 EXAMINATION VOLUME (1St LEG)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCK WISE COVERAGE 50 COUNTER CLOCKWISE COVERAGE 50 TOTAL PERCENT 50 %

• 450 scan was encompassed by the 60* and no more coverage could be obtained by the 70*

than was obtained by the 600.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 34 of 35 Figure 4c5)

(Page 1 of 2)

Report No: UT 050 Summary # SI.R1.16.780

• Dominion- Pg. 4 of 4 Prepared By: W.L. Thomas *.z_---

Date: 11109/2010 Weld Number 3-02 Weld Thickness 0.375" Weld Length I11" Weld Width 0.40"

.5

.1l

, . . . . I. .. . , . . . .I .. . . , .. . .I .. . . * .. . .I .. . . , .. . . !.. . .,

2 i 0 t 2 3 FLDW 3.02

,375" NR TOTAL REcIJRED tUMEuUS5IDE= 008 Q IN W**

.. EAMNB (103.*). IN Bas1"EF'F(3r'rUSo*E AAL DIRIEGnTON

.031 .03" .ST5XiC0 ,=3T.M*,

"* '-,F/*NO5C3INAftlAN(:.033mN,

.051 .W-&SN.*2 n 2**

Examination Volume Dimensions - Height 1.4"

.ov5rag e ngth1m"ardt Coverage Summary IANGLE I UpSt-Ax UpSt-Circ DnSt-AxDn-ir 45/60 . 0% 100% 100%

70 *37.5%

Code Coverage Total F50%

100+1-00+0+37.5=237.5/400=.59x1 O00=59%

• Best Effort Coverage (Max 25%) Total 9%

Notes: 1) code coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R01 Attachment 1, Page 35 of 35 Figure 4c5)

(Page 2 of 2)

Report No: UT- 10 -039 Summary#S1 .R1 .16.184

• )Donainion- Pg,.4 of 4 Prepared By: W.L, Thomas Date: 1110/01 Weld Number 3-03 Weld Thlickness 0.420" Weld Length 11" Weld Width 0.45"

,,],,,,Ii I. . . i . . . . .$ . . , I 1. . . .. .

'3 2 1 0 1 2 S R.OV Ci FL.ANG6

.410' ~

.041.1 =,4 XIOG"4O%

'* NO!XAMINA'1ON FcI 0108 IN OSlD4*LDIR.

Examination Volume Dimensions - Height .13"T' Length 11" Width i.45" Cav~rnaA ~ummarv Required Scans (each has a weighing factor of 100 for complete coverage)

'ANGLE

-45160 Up 100%t-Ax , .... UpSt-Cir 100% ' DnSt-Ax

.. n-lr

...0 100+100+40+0=240/40()=.60x1 00=60% ... *Best Effort coverage (Max 25%) Total 10%

Notes

1) Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2) Best Effort Coverage refers to the required examination volume past the weld centerline that is examined in the axial beam direction with an Appendix ViIII demonstrated procedure for single sided coveragle.

Serial No.15-446 Docket No. 50-280 Attachment 2 Relief Request LMT-R02, Category R-A, Risk Informed Piping Welds on Carbon Steel Piping Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 1 of 10 Relief Request # LMT-R02 Risk Informed Pipe Welds Carbon Steel Relief Requested in Accordance with 10 CFR 50.55 a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class 2 and Non-class Examination Category: R-A, Risk Informed Piping Examinations Item Numbers: Ri1.11, Elements Subject to Thermal Fatigue Component Identification: Refer to Specific Table R02 Material: Refer to Specific Table R02

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. App~licable Code Requirement The examination requirements for piping welds for the Surry Power Station Unit I (SPS1) fourth 10-year inspection interval were governed by the Risk Informed (RI)

Inservice Inspection (ISI) Program as approved by NRC letter dated December 16, 1998. The SPS1 fourth interval RI ISI Program is a full scope program covering ASME Section Xl Class 1, 2, and 3 components.

The pipe welds addressed by the RI ISI Program are assigned to a specific segment. The pipe segment definition includes the following considerations: 1) system, 2) pipe size, 3) flow junctions, 4) pipe failure consequence, and 5) isolation points for pipe breaks. The number of welds per segment varies. Examination is mandatory for some welds in a segment regardless of whether limited coverage will be attained. Other welds are sample selections, and an alternative weld may be chosen to replace the sample weld if the alternative weld could provide greater examination coverage. Although not required by the RI ISI Program, additional welds on the segment may be examined, in addition to the number of welds required by the risk informed analysis, to provide supplemental information for the segment.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 2 of 10 The welds discussed in this section were selected for volumetric (ultrasonic) examination by the RI 1SI Program as assigned item number RI.11 for thermal fatigue.

Neither the approved relief request nor the NRC Safety Evaluation for the RI ISI Program addressed an alternative for limited examination coverage. Therefore, the rules for ASME Section XI shall apply when limitations are encountered due to the design, geometry and materials of construction of the component. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%

volumetric examination coverage requirements for the subject austenitic welds due to the geometric configurations which limit the volumetric coverage that can be obtained.

The subject welds were examined with a manual UT technique using pulse echo UT instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section Xl, Appendix VIII as implemented by the Performance Demonstration Initiative (PDI). No alternative techniques or advanced technologies were considered capable of obtaining complete coverage of the examination volume.

Segment MS-004 Requirements for the RI 1SI Program are to credit the augmented examinations performed on this segment plus two additional Risk Informed selections. This was completed with limited coverage obtained on weld 2-28 as shown in Table R02.

Welds 2-11 and 2-26 were UT examined to meet the augmented examination requirement and also received surface examinations. An indication was identified during the UT exam on weld 2-26 that was determined to be due to geometry and therefore not a flaw. All of the full circumferential pipe welds were inspected on segment MS-004 as there were no other available selections.

Segment MS-007

• Requirements for the RI ISI Program are to credit the augmented examinations performed on this segment plus two additional Risk Informed selections. This was completed with limited coverage obtained on weld 2-31 as shown in Table R02.

Weld 2-29 was examined to meet the augmented examination requirement and also

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 3 of 10 received a surface examination. No indications were discovered during these examinations. All of the full circumferential pipe welds were inspected on segment MS-007 as there were no other available selections.

Segment MS-008 Requirements for the RI 1SI Program are to credit the augmented examinations performed on this segment plus two additional Risk Informed selections. This was completed with limited coverage obtained on weld 4-31 as shown in Table R02.

Weld 4-29 was examined to meet the augmented examination requirement and also received a surface examination. No indications were discovered during these examinations. All of the full circumferential pipe welds were inspected on segment MS-008 as there were no other available selections.

Segment FW-012 This segment is monitored by the Flow Accelerated Corrosion (FAC) Program which requires UT examination for wall thinning, and an Augmented Inspection Program for high energy lines that requires volumetric and surface examinations. For a postulated secondary failure mechanism due to thermal fatigue, weld 1-22 was added as a risk informed examination. Weld 1-22 was examined with limited coverage as shown in Table R02. Welds 1-23, 1-25 and 1-26 on this segment were examined per the Augmented Inspection Program thus receiving volumetric and surface examinations. The FAC Program is actively maintained and updated and thoroughly monitors the piping condition in this area, and the High Energy Line Augmented Inspection Program provides additional monitoring by weld volumetric and surface examinations. No flaws were found during these examinations.

Segment FW-016 This segment is monitored by the FAC Program which requires UT examination for wall thinning, and an Augmented Inspection Program for high energy lines that requires volumetric and surface examinations. For a postulated secondary failure mechanism due to thermal fatigue, weld 3-19 was added as a risk informed examination. Weld 3-19 received limited coverage as shown in Table R02. No flaws were~ found during these examinations. The FAC Program is actively maintained and updated and thoroughly monitors the piping condition in this area.

The High Energy Line Augmented Inspection Program provides additional surveillance through weld volumetric and surface examinations.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 4 of 10 TABLE R02 Risk Informed Pipe Welds, Carbon Steel Drawing /Line# IID I System / Class Pipe Pipe Weld Coverage Limitation I Fig. No. I Risk Informed Material Dia, Thickness Achieved Results Pg. No.

Segment 11448-WMKS-0103A2- 600 lb Single-sided, I I 30-SH P-I / 2-28 AASd 30" 0.7"7%pipe to valve 4e1 Main Steam / 2 AS t .7"7%1 Segment MS-004 NRI 11448-WMKS-0103A2- 600 lb Single-sided, I I 30-SH P-I / 2-31 AASd 30" 0.4"7%pipe to valve 4e1 Main Steam / 2 AS t .4"7%2 Segment MS-007 NRI 11448-WMKS-0103A2- 600 lb Single-sided, 2 I 30-SHP-2 / 4-3130pietvae 4e Main Steam I Non Class ASA Std 3" 0.940" 81.92% piet3av e Segment MS-008 NRI 1 1448-WMKS-1018A3 / Single-sided, 14-WFPD-17 / 1-22 600 lb 140.36.5pietvae 42 Feedwater / Non Class ASA Std 141.3 35 iet av e Segment FW-012 NRI I11448-WMKS-1018A3 / Single-sided, 14-WFPD-9 / 3-19 600 lb 14" 0.920" 86.67% valve to pipe 4e2 Feedwater / 2 ASA Std 2 Segment FW-016 NRI

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option is considered impractical and could impact plant equipment in a detrimental manner.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 5 of 10

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques at the time the examination was performed. Additionally, these components are monitored for through wall leakage either by the ASME Xl System Pressure Test Program required by Section Xl, Table IWC-2500-1 Category C-H for Class 2 components or a visual examination performed weekly as required by the Surry Augmented Inspection Program for high energy lines.

None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. There are no known failures on this type of weld at SPSI. Any indications were recorded and dispositioned as geometric or construction related. No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results, the visual examinations routinely performed to detect through wall leakage and the fact that additional welds were examined to supplement the limited coverage, it is reasonable to conclude that service induced degradation would be detected.

Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

Dominion requests relief in accordance with 10 CER 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for SPS1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 6 of 10 Figure 4el (Page 1 of 3) i~Dominion-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 11 448-WMKS-01 03A2-1 Mark Number: 2-28 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM EXAMNATIN VOUME(1s't LEG)

UPSTREAM 450 EXAMINATION VOLUME ( 2 nd LEG) 45° XAMIATIN VOUMEDOWNSTREAM 450 XAMIATIN VOUME(ist LEG) 450 XAM[ATIN VOUMEDOWNSTREAM 45 oEXAMNATIN VOUME( 2fld LEG) 450 EXAMINATION VOLUME CW 100 450 EXAMINATION VOLUME CCW 100 600 EXAMINATION VOLUME UPSTRLEAM 0 UPSTREAM 600 EXAMINATION VOLUME (2nd LEG)

DOWNSTREAM 600 EXAMINATION VOLUME (i st LEG) 94 600 EAMINAION VLUMEDOWNSTREAM N 60°_____ EXMNTO OUE( 2 ndl LEG) N 70 70__EAMNATONVOUM EAMNAIO VLUEUPSTREAM (I st LEG) NA 700EXMIATIN 70__EAMNATONVOUM OLMEDOWNSTREAM (i st LEG) NA UPSTREAM COVERAGE 0 DOWNSTREAM COVERAGE 94 CLOCKWISE COVERAGE 100 COUNTERCLOCKWISE COVERAGE 100 TOTAL PERCENT 74 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 7 of 10

-igure 4e1

• age 2 of 3) i*'Dominion" STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UME B Y SCAN DIRECTION Drawing Number: 11 448-WMKS-01 03A2-1 Mark Number: 2-31 ANGLE SCAN AREA SCAN SIDE SCAN %

450 XAMIATIN VOUMEUPSTREAM 45 oEXAMNATIN VOUME(I1st LEG)

UPSTREAM 450o EXAMINATION VOLUME ( 2 5d LEG)

DOWNSTREAM 450o EXAMINATION VOLUME (1St LEG) 450 XAMIATIN VOUMEDOWNSTREAM 45° XAMIATIN VOUME( 2 nd LEG) 450 EXAMINATION VOLUME CW 100 450 EXAMINATION VOLUME CCW 100 60______ 600 EAMINAION VLUMEUPSTREAM10 EXAM____NATION_____VOLUME____ (I s LEG) 100_______

UPSTREAM 600 EXAMINATION VOLUME ( 25d LEG)

DOWNSTREAM 600o EXAMINATION VOLUME (i st LEG) 0 DOWNSTREAM NA 600 EXAMINATION VOLUME ( 2sd LEG)

UPSTREAM 700 EXAMINATION VOLUME (i st LEG)

DOWNSTREAM 700 EXAMINATION VOLUME (I1stLEG)

UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 100 COUNTERCLOCKWISE COVERAGE 100 TOTAL PERCENT 75 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 8 of 10 Figure 4e1 (Page 3 of 3)

/u Dominion-STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UME B Y SCAN DIRECTION Drawing Number: 11 448-WMKS-01 03A2-2 Mark Number: 4-31 ANGLE SCAN AREA SCAN SIDE SCAN %

450o EXAMINATION VOLUME UPISTRLEAM 450o EXAMINATION VOLUME UPSTREAM

( 2 nd LEG) 450o EXAMINATION VOLUME DOWNSTREAM (I1stLEG) 450o EXAMINATION VOLUME (2DOWSTEAM 450o EXAMINATION VOLUME CW 10 0 450o EXAMINATION VOLUME CCW 100 600o EXAMINATION VOLUME UPSTRLEAM UPSTREAM 600 EXAMINATION VOLUME (2 nd LEG)

DOWNSTREAM 600 EXAMINATION VOLUME (IsT LEG) 600 XAMIATIN VOUMEDOWNSTREAM 700 EXAMINATION VOLUME UPTRAM10 700o EXAMINATION VOLUME DOWNSTRLEAM 27.7 UPSTREAM COVERAGE DOWNSTREAM COVERAGE CLOCKWISE COVERAGE COUNTERCLOCKWISE COVERAGE TOTAL PERCENT 81.92 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 9 of 10 Figure 4e2 (Page 1 of 2)

STAINLESS STEEL PIPE, SINGLE SIDED PERCENT VOL UMEBY SCAN DIRECTION Drawing Number: 1 1448-WM KS- 1018A3 Mark Number: 1-22 ANGLE SCAN AREA SCAN SIDE SCAN %

UPSTREAM 450 EXAMINATION VOLUME (l~t LEG) _______

UPSTREAM 450 EXAMINATION VOLUME (2 nd LEG) ________

DOWNSTREAM 450 EXAMINATION VOLUME (1st LEG) _______

450 EXAMINATION VOLUME (2DOWSTEAM 450 EXAMINATION VOLUME CW 450 EXAMINATION VOLUME CCW 600 XAMIATIN VOUMEUPSTREAM 60_EXAINTIOVOUM (lSt LEG) 100 UPSTREAM 600 EXAMINATION VOLUME ( 2 nd LEG) NA DOWNSTREAM 600 EXAMINATION VOLUME (1st LEG) 0 DOWNSTREAM NA 600 EXAMINATION VOLUME ( 2 nd LEG) 70 EAMNAIO VLUEUP STREAM NA 70°_XAMNATINVLUM (1St LEG) 70_EXAINTIOVOUM 70 EAMNAIO VLUEDOWNSTREAM (ist LEG) 80.7 UPSTREAM COVERAGE 100 DOWNSTREAM COVERAGE 0 CLOCKWISE COVERAGE 50 COUNTERCLOCKWISE COVERAGE 50 TO TALPER CENT 63.5 %

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R02 Attachment 2, Page 10 of 10 Figure 4e2 (Page 2 of 2)

LIMITATION COVERAGES for WELD #3-19 due to UPSTREAM VALVE to PIPE CONFIGURATION.

Weld Number: 3-19 Weld Length: 44" Weld Width: 1.5" Box Dimensions: H =0.25", L = 2.5" r-______w _

• ~js Valve F--l ***t m

-ffl Pipe Circ Exam:

DS exam box length = 1.25' Examined 0.75" 0.75 11.25 = 60%

coverage Summary Angiered Scans (each scan has a weig~hing factor'of 100 for complete coeae Anle Upt-Ax .UpSt -CW UpSt -CCW OnSt-Ax DnSt-iCW 1DnSt-CCW 45/60o70o 100ooo____ _____ _ 100%

Code Coverage Total 86.67%

Best Effort coverage (Max 50%) Total NA Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that Is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket Nos. 50-280 Attachment 3 Relief Request LMT-R03, Category R-A, Risk Informed Dissimiliar Metal Welds on Steam Generator Nozzle to Safe-Ends Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 1 of 8 Relief Request LMT-R03 Risk Informed Dissimilar Metal Pipe Welds Relief Requested in Accordance with 10 CFR 50.55 a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class I Examination Category: R-A, Risk Informed Piping Examinations Item Numbers: RI1.11, Elements Subject to Thermal Fatigue Component Identification: Refer to Table Material: Steam Generator Side: Carbon Steel SA-216 with Stainless Steel Buttering Safe End Side: Cast Stainless Steel

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. ApplIicable Code Requirement The examination requirements for piping welds for the Surry Power Station Unit I (SPS1) fourth 10-year inservice inspection interval were governed by the Risk Informed (RI) Inservice Inspection (ISI) Program as approved by NRC letter dated December 16, 1998. The SPS1 fourth interval RI I31 Program is a full scope program covering ASME Section XI Class 1, 2, and 3 components.

The two welds discussed in this relief, 1-05DM and 1-06DM, are part of Risk Segments that were determined to be low safety significant (LSS). During the submittal and review process of the fourth interval RI ISI Program, Dominion agreed to inspect these dissimilar metal welds for defense-in-depth.

These welds were selected for ultrasonic (UT) volumetric examination by the RI ISI Program due to the assigned item number: RI1.11 for thermal fatigue.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 2 of 8 Neither the approved relief request nor the NRC Safety Evaluation for the RI ISI Program addressed an alternative for limited examination coverage. Therefore, the rules for ASME Section Xl shall apply when limitations are encountered due to the design, geometry and materials of construction of the component. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%

volumetric examination coverage requirements for the subject austenitic welds due to geometric configurations that limit the volumetric coverage that can be obtained.

The subject welds were examined with a manual UT technique using pulse echo UT instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section XI, Appendix Ill.

The required examination volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative techniques or advanced technologies were considered feasible and/or capable of obtaining complete coverage of the examination volume.

Welds 1-05 and 1-06 are the hot and cold leg, respectively, dissimilar metal nozzle to safe-end welds on "C" steam generator (S/G). The carbon steel nozzles were buttered with stainless steel to assist the welding process to the stainless steel pipe.

Since the "A" and "B" S/G nozzle to safe-end welds are similarly configured, these alternative welds would also not have provided acceptable examination coverage.

The UT scans recorded intermittent indications 360 degrees on the 1-05DM weld.

The recordable indications (RI) were investigated and determined to be reflectors due to geometry, thickness, and contour and therefore not indicative of a flaw.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 3 of 8 TABLE R03 Risk Informed Dissimilar Metal Welds Drawing /Line#I/ IDI/Pp ed Cvrg iiainFg o System I Class / Pipe Material Pp ed Cvrg iiainFg o Risk Informed Segment Dia. Thickness Achieved I Results Pg. No.

S/G side: SA-216 I11448-WM KS-O102AZ-Gr. WCC with SS bteigSafe-end 1/I29-RC-7 / 1-05DM / RCS pipe: SA-351 29.5" 2.95" (1) 63% to nozzle R03 Reactor Coolant/I1 1-2 Segment RC-006 Safe End Side: RI Cast SS SIG side: SA-216 Gr. WCC with SS I11448-WMKS-010O2AZ- bteigSafe-end 1 / 31-RC-8 / 1-06DM RCS pipe: SA-351 31 2.4() 6% tonzl 0 Reactor Coolant /I 3-4 Segment RC-009 Safe End Side: NRI Cast SS (1) Actual measured thickness obtained from NDE records not provided in this relief request; this value differs from the nominal value shown in the referenced figure.

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option to rebuild components is considered impractical and would cause unnecessary radiation exposure. Furthermore, plant equipment could be impacted in a detrimental manner.

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques at the time the examinations were performed. Additionally, all components are monitored for through wall leakage as part of the ASME Xl System Pressure Test Program and receive visual (vr[-2) examination as required by Section Xl, Table IWB-2500-1, Category B-P for Class I components.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 4 of 8 None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. There are no known failures on this type of dissimilar metal weld at Surry Power Station.

Any indications were recorded and dispositioned as geometric or construction related. No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results and the routinely performed visual (VT-2) examinations, it is reasonable to conclude that service induced degradation would have been detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds. Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for SPS1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 5 of 8 Figure R03 (Page 1 of 4)

Report No: UT~-'1 -038 Summary # SI, Rtl 11340 Dominiour Pg, 5 of 7 PrepF~red fly: WL. Thlomas ,>--f Date: 1V,03/2010 Weld NumbEr 1-O5OM Wrfd Thk~iiess We~d Lengith Weld *Ndth NOTE: SEE ATTACXHEO COVERAGE PLOT 77T.7 + 79 ÷ 0 -"255If4QO =,3*:X100]=e3 Examination Volume Dimensions - Height G5 it 5.7*

Iov S Lemngth Coverane Summary Required Scans (each has a weighirnq factor of 100 fo*r comp1etv coverare:)

ANGLE 35145 t UpSt-Ax 77%

.pgt-Clr* ..................1n.SI-*Ax_

1% 79% I% OnStoCirc t

......... .. Code C*erageTotal~ 3 Best Effort Coverage (Max 25%) Totel NJA Notes: "1) Code Coverage refers to the maximum percerntage of the required exae, lnation volume that is effectively ex~amined with (te qualified examination procedure.

Z) Best *Erfoit Coverage refers to the required examination volume past the wald centerline that is examined in the axial beam direc~ion with an Appeiidi VIII

.... demOnsiraed rocdure for sirgle sided coaver . .........

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Serial No.15-446 Docket No. 50-280 Relief Request LMT-R03 Attachment 3, Page 7 of 8 Figure R03 (Page 3 of 4)

.feport No; UT-lO --039 Summnary # 1.RI,1!34I mb.- Pg. 4 ofl 5 Prepared By: WI., Thomnas ,*r 1-OGDM Weld Thickness W~el Length Wekd Width 2,2' NOTE: SEE ATTACHED COVER~AGE PLOT Examination Volume Dimensions Heighi:- 1i" Length I1656" Wkilrh 5..55*

________ Coverage ummry,

• GL U pSt-A*x Upst-Circ DnSt=Ax DnSt-Circ 35/45 72% 0% ........ .80% .. ..... 96%

Cotie Co}vera~e T la 62%

Notes: 1) Code Coverage refers to the maximum percentage of tile required examirwtioa

2) (les't Effort Coverage refiers to tile required examination volume past tne wveld *.,'r.j~

cent.erine that is: examined in the axial beam direction with* an Appendix VIII de=monstraed proc~edure ior sing* sded co*verage,

.... 9/j0

Supplemental Report Rep=t !'o*: UT-I10-039

~miniC~t Page: 5 or 5 Summary *,: SI.R1 '11 341 Leel: tI-PDIt Re~lewe~: Date: !,',z~*

2-m~ner: Mulrhead, Ryan iti. C.. =* Level: !I-PDP Da4(:Ld/S Site Rev~w: ~-+/-i~d.,V1~S ~ H~frJ4-~A Other* NiA Level: tfA AN I Re C+rnn tsz* i 1 .

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Serial No.15-446 Docket Nos. 50-280 Attachment 4 Relief Request LMT-PO1, Category C-F-I and C-F-2, Preservice Weld Examinations Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 1 of 7 Relief Request # LMT - P01 ASME Xl Preservice Pipe Welds Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected ASME Code Class: Code Class 2 Examination Category: C-F-I, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping Item Numbers: C5.21, Circumferential Weld, Piping Welds >1/5 in..

Nominal Wall Thickness for Piping _>NPS 2 and _<NPS 4 C5.61, Circumferential Weld, Piping Welds >1/5 in.

Nominal Wall Thickness for Piping _>NPS 2 and _<NPS 4 Component Identification: Refer to Specific Table Material: Refer to Specific Table

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. Applicable Code Requirement

Required Method: Surface and Volumetric The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

10 CFR 50.55a(b)(2)(xv)(A), requires the following examination coverage criteria when applying Supplement 2 to Appendix VIII:

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 2 of 7 (1) Piping must be examined in two axial directions. When examination in the circumferential direction is required, the circumferential examination must be performed in two directions provided access is available.

(2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld.

10 CFR 50.55a(b)(2)(xvi)(B) requires that 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-sided examinations.

To demonstrate equivalency to two-sided examinations, the demonstration must be performed in accordance with the requirements of Appendix VIII as modified by 10 CFR 50.55a(b)(2)(xvi)(g) and §50.55a(b)(2)(xv)(A).

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the volumetric examination coverage requirements for the subject welds due to geometric configurations which limit the volumetric coverage that can be obtained.

When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A), proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B), and full coverage credit may not be claimed. There are currently no Performance Demonstration Initiative (PDI) qualified single-side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds.

Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to U.S. nuclear applications.

However, PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single-sided examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single-side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology.

The subject welds were examined with a manual ultrasonic (UT) technique using pulse echo UT instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section Xl, Appendix VIII, as

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 3 of 7 implemented by the Performance Demonstration Initiative (PDI). No alternative welds were considered since these are preservice examinations for each specific weld that was reconstructed.

Weld 2-AW-B This is a stainless steel ASME Xl Category C-F-i weld. This weld also received a final liquid penetrant (surface) examination and a radiography examination before return to service. An indication was noted during the UT scan and was determined to be root geometry, due to construction and not a flaw.

Weld O-34A This is a carbon steel ASME Xl Category C-F-2 weld. This weld also received a liquid penetrant (surface) examination on the final weld before return to service. No recordable indications (NRI) were noted during the exams.

Weld 0-1A This is a carbon steel ASME Xl Category C-F-2 weld. This weld also received a liquid penetrant (surface) examination on the final weld before return to service. No indications were noted during the exams.

TABLE P01 - Preservice Examinations Drawing I Line# I ID/ Pipe Pipe Weld Coverage Limitation / Fig. No. I System I Class Material Dia. Thickness Achieved Results Pg. No.

314-CWMKS-A-10B5 Type 304 45.5% Single-sided,

/ 3CH-Sailes

/2-A-B/ 3 0.0"pipe to valve P01 Chemical and Volume Sanes 3 0506.4% 1 Control / 2 Steel Bs fotR Bs fotR 11448-WM KS- 600Sl Single-sided, 01A-/6-AD1Standard 6" 0.48" 88.3% flange to elbow P01 I 0-34A / 2 Carbon Feedwater / 2 SelNRI 600 lb 11448-WMKS- ASA Single-sided, 0118G1-1 /6-WAPD-2 Standard 6" 0.50" 88.3% flange to pipe P01

/I0-1A/ Cabo Feedwater / 2 Steeln NRI

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 4 of 7

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow full examination from both sides of the weld. This option to rebuild components is considered impractical and would cause unnecessary radiation exposure. Furthermore, plant equipment could be impacted in a detrimental manner.

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical utilizing the best available techniques. With the incorporation of the PDI for Supplement 2, demonstration for best effort coverage was made for single-sided examination from the accessible side of austenitic weld 2-AW-B. Additionally, the components are monitored for through wall leakage as part of the ASME XI System Pressure Test Program and receive visual (VTI-2) examination periodically as required by Section XI, IWC-2500-1 Category C-H for Class 2 components.

None of the pipe or weld material is constructed with Alloy 600/82/182 materials; therefore, there are no primary stress corrosion cracking (PWSCC) concerns. Any indications were recorded and dispositioned as geometric or construction related.

No flaws were found during these examinations.

Based on the volumetric coverage that was obtained with acceptable results, the routinely performed visual (VTI-2) examinations, and the additional examinations for surface (liquid penetrant) and, in the case of the 2-AW-B weld, volumetric exam (radiography), it is reasonable to conclude that no flaws exist in the new welds.

These proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for Surry Power Station Unit 1, which began October 14, 2003 and ended on October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 5 of 7 Figure P01 (Page 1 of 3)

Weld Number: 2-AW-B Weld Length: 11" Weld Width: 0.5" Box Dimensions: H = 0.15", L= 1.5" Flow Obstruction: Branch connection centered at TDC, 0.5" from weld toe, obstructed axial exams for a length of 3".

Examined 8" of 11" = 73%

Pipe Valve Best Effort Coverage:

Os exam box = 0.15" x 0.7'5" = 0.113 in2 Examined (0.15 x 0.25) + (0.15 x 0.4)/2 = 0.06 in2 0.06/10.113 = 53%

53% (8" of 11") = 38.5%

38.5% /I6scans=6.4%

______Coverage Summary Angle Angle-60 45/60 73%

Requ*ired UpSt -Ax

_____{100%

Scans 1

UpSt - CW UpSt - CCW weighing (each scan

_____j 10.0%

has a DnSt - factor 0%

Ax ofD~nSt100 -for 0%

CW complete DnStcoverage.

- CCW 0%

70 38,5%__1______i Code Coverage Total 45.5%

Best Effort Coverage (Max 50%) Total 6.4%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerdine that is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 6 of 7 Figure P01 (Page 2 of 3)

Weld Number:. 0-34A Weld Length: 21" Weld Width: 0.7" Box Dimensions: H =0.15", L = 1.7" Flange *jElbow Nte: 45° axial probe included in sketch to Ciro exam coverage: demonstrate 100% axial coverage from DS side, US Exam Box: 0.15" x 0.85" = 0.128 in 2 US Circ Exam: 0.15" x 0.55" = 0.083 in2 0.083/0.128=65%

_______Coverage Summary Angle Required Scans (each scan has a weighing factor of 100 for complete coverage)

Age UpSt.- Ax UpS't - CW UPSt - CCW DnSt - Ax DnSt - CW DnSt - COW 45 100% 65% 65% 100% 100% 100%

Code Coverage Total 88.3%

............. Best Effort Coverage (Max 50%) Total NA Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that Is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-P01 Attachment 4, Page 7 of 7 Figure P01 (Page 3 of 3)

Weld Number; 0-1A Weld Length: 21" Weld Width: 0.7" Box Dimensions: H = 0.15", L =1.7" Flow 3' Circ exam coverage:

OS Exam Box: 0.15" x 0.85" = 0.128 in2, DS Circ Exam: 0.15" x 0.55" =0.083 in2 PsI' 0.083 / 0.128 =65%

Notej."45° axial probe included in sketch to demonstrate 100% axial coverage from OS side.

S~Coverage Summary Angle -Required* Scans (each scan has aweiching factor of 10f cm plete coverage) 45 UpSt - Ax UpSt - OW UpSt - COW JDnSt - Ax DnSt - CW DnSt.-COW 100% 65% 65% 100%, 100% 100%

Code Coverage Total 88.3%

Best Effort Coverage (Max 50%) Total NA Notes:

1.. Code Coverage refers to the maximum percentage olthe required examination volumeI that is effectively examined with the qualified examination procedure.

2. Best Effort Coverage refers to the required examination volume past the weld centerline that is examined with an Appendix VIii demonstrated procedure for single sided coverage.

Serial No.15-446 Docket No. 50-280 Attachment 5 Relief Request LMT-C01 Examination Category B-B, Pressurizer Shell to Head Circumferential And Longitudinal Welds Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 1 of 11 Relief Request LMT-C01 Pressurizer Shell-to-Head Circumferential and Longitudinal Welds Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected Weld No.: 1-07 Drawing: 1 1448-WMKS-RC-E-2 ASME Class: 1 ASME Category: B-B ASME Item: B2.11

Description:

Pressurizer Shell to Head Circumferential Weld Weld No.: 1-15 Drawing: I11448-WMKS-RC-E-2 ASME Class: 1 ASME Category: B-B ASME Item: B2.12

Description:

Pressurizer Shell to Head Longitudinal Weld

2. Applicable Code Edition and Addenda

1998 Edition with 2000 Addenda of ASME Section Xl

3. Applicable Code Requirement

The 1989 Edition of ASME Section Xl Table IWB-2500-1, examination category B-B, item B2.11, requires volumetric examination of essentially 100% of the circumferential shell to head welds.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 2 of 11 Table IWB-2500-l category B-B, item B2.12, of the 1989 Edition requires volumetric examination of one foot on the longitudinal weld that intersects the selected circumferential shell to head weld.

4. Impracticality of Conplijance The pressurizer is covered with an insulation support ring (Figure 1). The insulation support ring is six (6) inches wide where examination interference is encountered for weld 1-07. As seen in Figure 1, this insulation support ring and a power operated relief valve support prevent complete volumetric coverage of both the upper circumferential head weld 1-07 and the intersecting longitudinal weld 1-15.

5. Burden Caused by Compliance Total removal of the support ring at the mechanical connections is considered impractical due to the extreme high dose rates in the pressurizer area. Total radiation dose to remove the interfering support and perform the examination was estimated to be 15.13 man-rem. This includes expended dose necessary for the various crafts involved including mechanical maintenance, insulators, rigging crews and Non-destructive Examination (NDE) personnel. Partial removal of the support ring could allow some increased coverage; however, the actual increase would be very small in relation to the entire weld length. This is not considered a practical option when considering consequential disturbance of interconnected cross supports and the welded connections to safety and power operation relief valve supports.

Removal of the mechanical connections or forced spreading apart of components would create a risk of misalignment and possibly warp the structure. Furthermore, civil engineering proposed that cutting the support could be necessary for removal; thus, destroying the support ring.

6. Proposed Alternative and Basis for Use Examination of pressurizer shell welds 1-07 and 1-15 was performed during the third inservice inspection interval as documented in Dominion letter dated July 14, 2005 (Serial No.05-277). The average total examination coverage of all scan directions for welds 1-07 and 1-15 is 46% and 31%, respectively.

Examination of pressurizer shell welds 1-07 and 1-15 was reattempted during the fourth inservice inspection interval. The obstructions were verified as shown on the inspection reports provided in page 1 of Figure 001. The examiners referenced the previous limitations from the third interval. The documentation of these limitations is provided in Figures 001 for reference.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 3 of 11 No additional ultrasonic examination techniques would provide meaningful additional data on this cladded material for the examination volume not attained. The pressurizer receives a visual (VT-2) examination every refueling outage as required by Section Xl, Table IWB-2500-1, Category B-P for Class I components. Any effort to achieve greater coverage would be impractical creating risk of component damage or destruction and excessive personnel dose exposure.

Based on the volumetric coverage that was obtained with acceptable results and the routinely performed visual (VT-2) examinations, it is reasonable to conclude that service induced degradation would have been detected. Therefore, these proposed alternatives provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds. Dominion requests relief in accordance with 10 CFR 50.55a(g)(5)(iii).

7. Duration of Proposed Alternative This proposed alternative is requested to meet requirements for the fourth ten-year inspection interval for Surry Power Station Unit 1, which began October 14, 2003 and ended October 13, 2014.

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 4 of 11 iN$ULAtION .~UFP~T ~

~r

~

+/- ' PR:u RI1E,. 4$1JLATIIO~

LIT Vessel Examination P*-edwtr: ER-AA.NIDE.UT-702 Out*g No,: S1R25 Sunumary No.: S1.82,I.,001 Prncedure Re'j.: 4 Rcpirt No.: UT.i3-I11 Workeo~pe: IS! Wo*K Order No,: 3B81033270$INIDFR134038 Code; AS/IAE 1958 EW2000 Addenda Ca~tdlm: 8B-1B2A1 tocl*,on: PZR 47 Drawing No.: Z1448.WMKS.-RG-E-2 De*-cripfiorr O*RC SHELL TO HIEADl WELD Compoenwnt 20: 1 1440-W!MtlS.RtC-E.2 t 1-07 3'0t 392

$Sfz*e/tlwnhqt2r Thl-nokes*Daeler 4,375! 7,75' 1 ti~l~e'n:, See previous; rprot1 UTRf U C'H 851 RT5501A; IeTSSQGIB Strlia!:m 1028 F*nleh The': 1I300

£xarhaltoil Surf-ce: Insald* Outaide *] Surface Co dtions Ground Inlush Lo Location: Zero Datum Point Wo lo~cetlon: Weld Cetr Lte* O*couplant: Soundaafa Balclh No: 1:2120 Terop. Tool Mf'g. AMVEC Serial No*: 100 BOGY Surac Temp.; 72.3 °F oC)

"-40 CaL Repoxt No.: CAL.13.023 CAL-13-023, CAL-1I3-030 ndcatio-*s: Ye 3 lean* svateI O -SScnCseaJ:

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,See preViousceportUTRNO for Irihotions antdco 1381 =a e ' v* O o b -t o r-r$'*_er-fldl A-*J d[O C, OC>

CDo Percent Cf Corea~ge Obiolnodi '19Ai: No0 Reviewed Previ4ous, Daa: Yes O:iT' 0 C.

0 n c urve~eI EeuuL~etien .-- H.-

0 0 ,

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 6 of 11 Figure C01l (Page 2 of 7)

Corrected calculation performed in 2005.

Added to report by Dan Jensen. (3 Pages) 9 ohd~ -

PERCENT VOLUME BY SCAN DIRECTION DRA WING NUMBER ! I 548-WMK&RC.-,E4 MARK NUMBER 1-07 ANLE. ......... SCAN AREA, DIRECTION "SCAN %"

45° WELD & BASE METAL 0 68%

..... 45° WEBLD & BASE METAL ' 2 .... 82%

600 WELD & BASB METAL 2 92%

450 WELD)&BASBEMETAL 5 15%

60° WELD & BASE METAL 5 20%

'45° WIELD '&'BASE METAL 7 ... 35%"

6o00 WELD &BASE METAL, 7 35%

....... 450 WELD &BASB METAL 8 35%

600 WELD & BASE METAL 8 35%

___ ___ __ OTAL P'ERCENT _ .... 46%

CO0MMENTS: .....

All Areas were scannaed with the maximum extent possible from both sides of the weld and on the weld with 00, 450 and 600 transducers for the 2, 5, 7 and 8 scans.

DATE DanielL Jensed/

ICorrected calculation performed in 2005.I

~Added to report by Dan Jensen. (3 Pages)

II448-VMKS-RC-E--2 1-07 (Ho~ched *re~s represen-* no exo.Nn~tlon cover'age)

ITEDFOR 2%.OF WELD LE*NG'H 1'I IN*'TRUMEt4TATXON. NOZZLE.UZ4ITE]D FOR 0.7% OF WELD" LEGTH "0)"

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8 WK-ec-dcluaio efre (PaEs) inL2-0057 jI4 -Co Dan JesHEn.

by:I EdR rpr PREAURI 11448-WMK~-RC--E-E WELD 1-07 PRES~U1~IZER HEA:D TD SHELL VIELU

'0 DATU.H

~A1UI

• 288," '

275.4'

-07 (oC

~~201.9' .

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m z UT Vessel Examination SiteJU*R: Su~rgy i -l Pioaedure: ER-AA-NDE.iTT.702 Outage N'o,: $IR2S Summary No.: 81.BZ.12.002 Procedure Re'.,: 4 Wor*sc~ope, 181 WorR Order No.: $8103327*66{NDER13-035 Page: 1 of  !

Code; ASMtE iS99 EW2000 Addenida G*'t./'tem; B-B,rB2.t2 Lacation." PZ.R 47 DrawlrK.J No,: 1I44li-WM KS-RC:E-2 Dfs.PI;* t~or*; LONG SHELL TO HEAD WELD

$ystu ID: RC Cowponan: ID: !!44a-WlMKS-RC-E-2' 1-I5 SlzeLeng~h:  ?.,O' 1Z*9; Thickrness.'Oameter 4.375 / 7,75" U~miiations: Sce prevtous roport # UTR.NO 851 fSxa~t Time; 1028 F~nish imec 130}5 FExamiati*,n SUrfa'-e: liisida [] Outs3de [,J Surf-=oe Cond~iiin: Groundi Plsh La Lcf.*ion: Zaro Datum Point Wo Locslkon: Weld Center Line CoUpi~nt; Sountdsaife Batch No.: 12120

-o'-n Temp. Tooi IfM-: AMEC Serial Na.:" IC64SGCY Sir*fSC6 Temp.; 72.3 *F Cjal. Re~pot No.." QAL-13-028, CAL-13-029. CAL-13-030 o(0 C-,o CD ScInigd 1 31 31 36

• 36 Se0, Preavious report:#UTRNO 851 P 6res iaerLon0 scam Weld RTS.*06 *'Je*o T -o'G'V";';J*.-* ****" T ¢ (*

Peneif Of Cvoerage Obtahv~e =-96: No .Rewicvwcd Pnr*-ious D~am: Yes~

z 0)0 0 WI VesselJ Exsd,atfirtn 03)

Serial No.15-446 Docket No. 50-280 Relief Request LMT-C01 Attachment 5, Page 10 of 11 Figure C01 (Page 6 of 7)

/"Dominion-PERtCENT VOLUME BY SCAN DIRECTION Drawing Number: I 144R-W'*¥*IKS.RC-f-2 Mark Nur!b.r: . I-!5 SCAN j SCAN SCAN PERCENT

.ANGLE j DTRECTION .AR1..A ................... AMINED

-- f*0 ............... Wel1d & B~ase Mcmta 10%

6t)* 2 ... Weld & Base Me*al 75%

45* .... .. Weld & Base Metal ........ 36%

,60,....... 5 Weld & Ba.*o Memta 57 64S' 7 Weld &fls*._.(*_ .. ............... 10%

45* 7 Wed* &/.B*s Mei~i 10%A 60* 8 W eld &Jls t 1.f.a1 ....... .... .  %.

C2ommnt~as: AMt area* were se~ined with tihe maximum exsmt posible .from bo*th sides of the ,*vk1 whh th* 0*, 45nd AVEIRAGE PERCENYT EXAMPNED 31! %

May I 5. 2003 DOMIIO'N, VIIArNI,\ POWERS, LEVEL li[ *DATE j~y*

HS~-CT AMI~NI! Fi~V1~T~VS

.t

• II1448-*/MKS-RC-E-2 1-15 Pressur~izer, Lang Sean \eed (Hatched clreas represen+/- no exaina-tion coverage) 4a3q2 Sq, In. Exr.* Vah~f~e 182.I Sq. In..*o't exrilned I S7~ ~oi*~e (1)

"(0 2lD)

HSB-CT ANI/ANtI REVIE*WS.--

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