Revision as of 03:39, 6 June 2018

Text

Surry, Unit 1 - 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:	Sartain M D; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	15-446
	Download: ML15293A124 (78)
	v • d • e

ELECTRIC AND POWER COMPANY-(q , RICHMOND, VIRGINIA 23261October 9, 201510CR55aU.S. Nuclear Regulatory Commission Serial No. 15-446Attention: Document Control Desk SPS-LIC/CGL RIWashington, DC 20555 Docket No. 50-280License No. DPR-32VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNIT 1ASME SECTION Xl INSERVICE INSPECTION PROGRAMRELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONSPERFORMED IN THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVALVirginia Electric and Power Company (Dominion) performed inservice inspection (ISI)examinations at Surry Power Station Unit I for the fourth 10-year ISI interval, whichbegan on October 14, 2003 and ended on October 13, 2014. A one-year extension wasapplied 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, 2013and NRC approval dated May 28, 2014]. Examinations of certain componentsconducted during the fourth interval received less than the required examinationcoverage.Pursuant to 10 CFR 50.55a(g)(5)(iii), Dominion requests relief for limited examinationson the basis that the required examination coverage was impractical due to physicalobstructions and limitations imposed by design, geometry and materials of constructionof the subject components. Attachments 1 through 5 contain the specific relief requestsand the basis for each request. These relief requests have been reviewed andapproved by the station's Facility Safety Review Committee.If you have any questions or require additional information, please contactMr. Gary D. Miller at (804) 273-2771.Si nce rely,Mark D. SartainVice President -Nuclear EngineeringCommitments made in this letter: None

.a Serial No. 15-446Docket No. 50-280Relief Requests for Fourth IntervalLimited Coverage ExaminationsPage 2 of 2Attachments:1. Relief Request LMT-R01, Category R-A, Risk Informed Piping Welds on StainlessSteel Piping2. Relief Request LMT-R02, Category R-A, Risk Informed Piping Welds on CarbonSteel Piping3. Relief Request LMT-R03, Category R-A, Risk Informed Dissimiliar Metal Welds onSteam Generator Nozzle to Safe-Ends4. Relief Request LMT-P01, Category C-F-I and C-F-2, Preservice Weld Examinations5. Relief Request LMT-C01, Category B-B, Pressurizer Shell to Head Circumferentialand Longitudinal Weldscc: U.S. Nuclear Regulatory Commission, Region IIMarquis One Tower245 Peachtree Center Avenue NE, Suite 1200Atlanta, Georgia 30303-1257NRC Senior Resident InspectorSurry Power StationMs. K. R. Cotton-Gross, NRC Project Manager -SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852Dr. V. Sreenivas, NRC Project Manager -North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852Mr. R. A. SmithAuthorized Nuclear InspectorSurry Power Station

,ISerial No. 15-446Docket Nos. 50-280'IAttachment IRelief Request LMT-RO1, Category R-A,Risk Informed Piping Welds on Stainless Steel PipingVirginia Electric and Power Company(Dominion)Surry Power Station Unit I

Serial No. 15-446~Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 1 of 35Relief Request LMT-R0IRisk Informed Pipe WeldsStainless Steel: Non-Alloy 600182/182Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)Inservice Inspection Impracticality1. ASME Code Components AffectedASME Code Class: Code Class 1 and 2Examination Category: R-A, Risk Informed Piping ExaminationsItem Numbers: RI .11, Elements Subject to Thermal FatigueRI1.16, Elements Subject to lntergranular StressCorrosion CrackingComponent Identification: Refer to Specific TableMaterial: Refer to Specific Table2. Applicable Code Edition and Addenda1998 Edition with 2000 Addenda of ASME Section Xl3. Applicable Code RequirementThe examination requirements for piping welds for the Surry Power Station Unit 1(SPS1) fourth 10-year inservice inspection interval were governed by the RiskInformed (RI) Inservice Inspection (ISI) Program as approved by NRC letter datedDecember 16, 1998. The SPSI fourth interval RI ISI Program is a full scopeprogram covering ASME Section Xl Class 1, 2, and 3 components.The pipe welds addressed by the RI ISI Program are assigned to a specificsegment. The pipe segment definition includes the following considerations: 1)system, 2) pipe size, 3) flow junctions, 4) pipe failure consequence, and 5) isolationpoints for pipe breaks. The number of welds per segment varies. Examination ismandatory for some welds in a segment regardless of whether limited coverage willbe attained. Other welds are sample selections, and an alternative weld may bechosen to replace the sample weld if the alternative weld could provide greater

,9Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 2 of 35examination coverage. Although not required by the RI 1SI Program, additionalwelds on the segment may be examined, in addition to the number of welds requiredby the risk informed analysis, to provide supplemental information for the segment.The welds discussed in this section were selected for volumetric examination by theRI ISI Program due to the assigned item numbers: R1.11 for thermal fatigue orRI1.16 for intergranular stress corrosion cracking.Neither the approved relief request nor the NRC Safety Evaluation for the RI ISIProgram addressed an alternative for limited examination coverage. Therefore, therules for ASME Section Xl shall apply when limitations are encountered due to thedesign, geometry and materials of construction of the component. The alternativerequirements of ASME Section Xl, Code Case N-460, approved for use inRegulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of theweld provided greater than 90% of the required volume has been examined.10 CER 50.55a(b)(2)(xv)(A) requires the following examination coverage criteriawhen applying Supplement 2 to Appendix VIII:(1) Piping must be examined in two axial directions. When examination in thecircumferential direction is required, the circumferential examination must beperformed in two directions provided access is available.(2) Where examination from both sides is not possible, full coverage credit maybe claimed from a single side for ferritic welds. Where examination from bothsides is not possible on austenitic welds, full .coverage credit from a singleside may be claimed only after completing a successful single-sided AppendixVIII 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 ofa 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 beperformed in accordance with the requirements of Appendix VIII as modified by 10CFR 50.55a(b)(2)(xvi)(B) and §50.55a(b)(2)(xv)(A).4. Impracticality of CompliancePursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%volumetric examination coverage requirements for the subject austenitic welds dueto the geometric configurations which limit the volumetric coverage that can beobtained.When the examination area is limited to one side of an austenitic weld, examination Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 3 of 35coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiencydemonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B). Therefore, fullcoverage credit may not be claimed.The subject welds were examined with a manual ultrasonic (UT) technique usingpulse echo ultrasonic instruments and search units to achieve the maximumpractical examination coverage. Personnel, equipment and procedures werequalified in accordance with ASME Section Xl, Appendix VIII as implemented by thePerformance Demonstration Initiative (PDI).There are currently no PDI qualified single-sided examination procedures thatdemonstrate equivalency to two-sided examination procedures on austenitic pipingwelds. Current technology is not capable of reliably detecting or sizing flaws on thefar side of an austenitic weld for configurations common to U.S. nuclear applications.PDI Performance Demonstration Qualification Summary (PDQS) certificates foraustenitic piping list the limitation that single-sided examination is performed on abest effort basis. The best effort qualification is provided in place of a completesingle-side qualification to demonstrate that the examiners' qualification and thesubsequent weld examination is based on application of the best availabletechnology.In some of the earlier UT examinations performed in the first period of the fourthinterval at SPS1 (October 14, 2003 -October 13, 2006), reporting "Best Effort"coverage when encountering single-sided limitations on austenitic steel material wasnot routine practice. Refracted longitudinal (RL) wave was typically used toinvestigate the far side of the weld to the greatest extent possible if the thickness ofthe pipe was greater than 0.5 inches. For piping 0.5 inches in thickness or less, a70 degree examination angle is used to interrogate the far side of the weld. Anyindications seen with the RL or the additional angle used would have been notedand investigated.The required examination volume of these welds was interrogated ultrasonically tothe maximum extent possible. No alternative techniques or advanced technologieswere considered feasible and/or capable of obtaining complete coverage of theexamination volume.a. The 1-12 welds are the reactor coolant pump (RCP) to pipe welds for the threeRCPs. Details are provided in Table 4a. The 1-12 welds fall within High SafetySignificance (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 ofthe three segments, one sample weld (1-12) is required. Only one alternate weldexists on each of the individual segments, weld 1-13, which is a pipe to motoroperated valve weld. The UT scanning area would also be restricted to one side Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 4 of 35of weld 1-13 due to the pipe to valve configuration and would provideapproximately 50% coverage similar to the 1-12 weld coverage. Due to theexcessively high dose rates in this area, it is not feasible to attempt examinationof 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 onlyrecorded in tabular format as shown in Figure 4a of this attachment.There were no recordable indications (NRI).TABLE 4a Reactor Coolant Pump to Pipe WeldsDrawing / Line# / ID I WeldSystem 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 4aReactor Coolant / I Type 2.".5" shear wave ISegment RC-010 316 used, 60 NRIdegree RLalso used48%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 4aReactor Coolant /I Type shear wave 2Segment RC-011 316 used, 60 NRIdegree RLalso used48%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 4aReactor Coolant/I1 Type shear wave 3Segment RC-012 316 used, 60 NRIdegree RLalso used Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 5 of 35b. The pipe welds discussed in this section were examined volumetrically by UTmethod for thermal fatigue concerns (item R1.11). Pipe weld description,examination and limitation descriptions are provided in Table 4b.Segment RC- 017The original requirements for Segment RC-017 of the RI ISI Program specifiedone mandatory examination, weld 2-08, and one sample weld, 2-03. Themandatory weld 2-08 exam was a single-sided, limited exam due to the pipingconfiguration, valve to a pipe elbow. Full required coverage was achieved onweld 2-03. An additional weld was selected to supplement the limited coverageon weld 2-08. Weld 2-05 on segment RC-017 was also examined to meet fullcoverage requirements and to provide additional data for the segment. Therewere no indications noted on any of the examination areas.Segment RC-018The original requirements for Segment RC-018 of the RI ISI Program specifiedone mandatory examination, weld 1-08, and one sample weld, 1-05. Themandatory weld 1-08 exam was a single-sided, limited exam due to pipingconfiguration, valve to a pipe elbow. Full required coverage was achieved onweld 1-05. An additional weld was selected to supplement the limited coverageon weld 1-08. Weld 1-03 was also examined, meeting full coveragerequirements. There were no indications noted on any of the examination areas.Segment ECC-005Weld 1-09 is a mandatory selection for the RI ISI Program. Weld 1-10 is asample selection. These are the only two welds on the segment. Weldexaminations were limited as shown in Figure 4b2. No alternative weld selectionexists. No indications were discovered on these welds.Segment ECC-007The two examinations of welds 1-09 and 1-10 on segment ECC-007 wereperformed in 2006 before the "good practice" of documenting best effort. Bothweld examinations were limited as shown in Figure 4b3. An indication was foundon weld 1-10. The indication was fully investigated and confirmed to be aconstruction related, geometric reflector and therefore not a flaw.Weld 1-09 is a mandatory weld selection. There were no indications on weld1-09. Weld 1-10 falls into the sampling risk informed region. These are the onlytwo welds on the segment. No alternative weld selection exists.

ASerial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 6 of 35Segment R0-042Two welds required examination on this segment. Weld 1-04 is a mandatoryselection. Weld 1-02 is a sample selection. Both examinations were limited asshown in Figure 4b4. Weld 1-01BC on this segment was added as asupplemental examination with limited coverage obtained. No indications werefound on any of these examinations.Segment RC-043Two welds required examination on this segment. Weld 1-03A is a mandatoryselection. Weld 1-02 is a sample selection. Both examinations were limited asshown in Figure 4b5. Weld 1-01BC on this segment was added as asupplemental examination with limited coverage obtained. No indications werefound on any of these examinations.The pipe lines discussed in Section 4b are currently analyzed and inspected by theguidelines of the Materials Reliability Program (MRP-146) for the management ofthermal fatigue on normally stagnant non-isolable reactor coolant system branchlines. This Program is part of the Surry Augmented Inspection Program under whichselect welds and pipe areas receive periodic examination as required by the MRPguidelines. The MRP-146 Program did not exist when the initial RI 1SI Program wasdeveloped for SPSI. Therefore, no credit was allocated for the MRP-146 Program.TABLE 4b Risk Informed Pipe Welds, Stainless Steel, MRP 146Drawing/ILine# / IDISystem I Class Pipe Pipe Weld Coverage Limitation I Results Fig. No. IRisk Informed Material Dia. Thickness Achieved Pg. No.SegmentI11448-WMKS-0122K1 Typ 1 0 igesdd av/ -C1 -8 Stainless 6" 0.797" to elbow 4blReactor Coolant / I Ste10 RSegment RC-017 Best Effort NRI11448-WMKS-0122J1 Type 316 50% Single-sided, valve/ 6-RC-21 / 1-080.6"telo4bReacor Colan /1 Stainless 6" 056"telo4bRatrCoat/1 Steel (Nominal) 15.56% 2Segment RC-018 Best Effort NRII11448-WMKS-0122H1 Tye3650% Single-sided, pipe/ 6-RC-16 / 1-09 Type6316to valve 4b2Reacor Colan /1 Stainless 6" 052RatrCoat/1 Steel (Nominal) 3.5%1Segment ECC-005 Best Effort NRI Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 7 of 35Drawing I Line# / IDISystem I Class Pipe Pipe Weld Coverage Limitation I Results Fg oRisk 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 4b2Reactor Coolant / 1 ins 3.5% 2SteelBetEfrSegment ECC-005 BsEfotNRI50%I11448-WMKS-0122J1 Type 316 Examination Single-sided, pipe to/ 6-RC-21 / 1-09 0.6" promdvalve 4b3Reacor Colan I i Stainless 6" 052 efreRatrCoat/1 Steel (Nominal) prior to1Segment ECC-007 practice of NRIrecordingBest Effort50%Single-sided, pipe to11 448-WMKS-0 122J 1 Tye36Examination valve6ReatrCoolan / 1- Stainless 6" 0.562" performed4bRatrCoat/1 Steel (Nominal) prior to Geometric indication 2Segment ECC-007 practice of occurred duringrecording original constructionBest Effort1 1448-WM KS-0127J2 50% Single-sided, elbow/ 6-RC-19 / 1-02 Type 316 6" 0.522" (1) to weldolet 4b4Reactor Coolant /I Stainless 1% 1Segment RC-042 Steel Best Effort NRI1 1448-WMKS-0127J2 Type 316 50% Single-sided, valve/ 6-RC-19 / 1-04 to elbow 4b4Reactor Coolant / 1 Stainless 6" 0.735" (1) 3%2Segment RC-042 Steel Best Effort NRI1 148-WMS-017J26" pipe to 27.5" cold/6R-9 -IC Type 316 5%leg branch 4b4ReactorCoolan / 1-0B Stainless 6" 1.85" connection3SegmerColnt /C 1 Steel (Nominal) 23.7%3Semn C02Best EffortNR1 148-WMS-027J350% 6" pipe to 27.5" coldType-WKS03163 0%leg branch/ 6-RC-20 / 1-01BC Tye3618"cncto4bRatrCoat/1 Stainless 6" 18"cneto bReacorColnt /C-0I Steel (Nominal) 23.7% 1Segmnt R-043Best EffortNRI Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 8 of 35Drawing I Line# I ID/System / Class Pipe Pipe Weld Coverage Limitation!/ Results Fig. No. /Risk Informed Material Dia. Thickness Achieved Pg. No.Segment1 1448-WMKS-0127J3 Tye3650% Single-sided, pipe to/ 6-RC-20 / 1-02 Tye36branch connection 4b5Reactor Coolant /I Stainless 6" 0.528" (1) 1.5% weld 2Segment RC-043 SelBest EffortNR11448-WMKS-0127J3 Type 316 50% Single-sided, valve/ 6-RC-20 / 1-03A Stils " 0.562" to elbow 4b5Reactor Coolant/i1 Steel (Nominal) 4.83% 3Segment RC-043 Best Effort NRI(1) Actual measured thickness obtained from NDE records not provided in this relief request; this valuediffers from the nominal value shown in the referenced figure.c. The pipe welds addressed in this section were ultrasonically examined forthermal fatigue (ASME Item R1.11) or intergranular stress corrosion cracking(ASME Item R1.16). Details are provided in Table 4c and in the referencedfigures.Segment EGG-006Only two welds exist on this segment. Weld 2-09 falls within the mandatoryexamination region for the RI ISI Program, and weld 2-10 is categorized as asample selection. The welds were examined ultrasonically for thermal fatigue(ASME Item R1.11). Both welds were examined to the fullest extent possible asdetailed in Table 4c and Figure 4c1. No indications were discovered duringeither examination.Segments RS-004A, 003AOnly one weld exists on each of these segments: piping from the containmentsump (wall) to the Outside Recirculation Spray (ORS) Pump suction motoroperated valves. Weld 1-06 on segment RS-004A and weld 1-03 on segmentRS-003A were examined ultrasonically for intergranular stress corrosion cracking(ASME Item R1.16). Both welds of this configuration for each of the ORS Pumpswere examined to the fullest extent possible. No indications were discovered oneither weld.Segment HHI-011Weld 5-AF is the only weld on this segment of piping from the High Head SafetyInjection containment penetration to the first check valve inside containment.

DSerial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 9 of 35The weld was ultrasonically inspected for thermal fatigue to the greatest extentpossible. There were no indications.Segments LHI-004A, 003AOnly one weld exists on each of these segments, piping from the containmentsump (wall) to the Low Head Safety Injection (LHSI) Pump suction motoroperated valves. Weld 1-13 on segment LHI-004A and weld 1-15 on segmentLHI-003A were examined ultrasonically for intergranular stress corrosioncracking (ASME Item R1.16). Both welds of this configuration for each of theLHSI Pumps were examined to the fullest extent possible. No indications werediscovered on either weld.Segment RH-013Two welds on this segment required ultrasonic examination for intergranularstress corrosion cracking, welds 3-02 and 3-03. The examinations on both ofthese welds were limited. The branch connection weld 3-01 BC on this segmentwas added to supplement the data from the two limited examinations.Weld 3-01 BC was examined with the liquid penetrant method obtaining fullcoverage. No meaningful UT coverage could be obtained on branch connectionweld 3-01BC. No additional selections exist on this segment. No indicationswere discovered during any of the examinations.TABLE 4c Risk Informed Pipe Welds, Stainless SteelDrawing / Line# I ID /System I Class Pipe Pipe Weld Coverage Limitation / Results Fg oRisk Informed Material Dia. Thickness Achieved Fig. No.ISegmentI11448-WMKS-0122K1 Type 316 50% Single-sided, pipe toI 6-SI-48 / 2-09 Stainless 6" 0.562" valve 4clSafety Injection/I1 Steel (Nominal) 1% 1Segment ECC-006 Best Effort NRII11448-WMKS-0122K1 Type 316 50% Single- sided, valve/6-SI-48 /2-10 Stainless 6" 0.610" (1) 1% topp2cSafety Injection/I1 SteelBetEfr2Segment ECC-006 BsEfotNRII11448-WMKS-1101A5 Type 304 46.3% Single- sided, pipe/12-RS-7/1-06 Stainless 12" 0.510" 11.9% tovlv 1Recirculation Spray I 2 Steel Best Effort NRISegment RS-004A Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 10 of 35Drawing I Line# / ID /System I Class Pipe Pipe Weld Coverage LitaonIRslsFgNoIRsInomd Material Dia. Thickness Achieved LiiainPRslsFg. No.ISegment50%11448-WMKS-1101A5 Examination Single-sided, valve/ 12-RS-8 / 1-03 Type 304 performed to elbow 4c2Recirculation Spray / 2 Stils 2 .1"prior to 2SgetR-0A Steel practice of NRISegmnt R003ArecordingBest Effort50%1 1448-WMKS-1 106A4 Examination Single-sided, pipe toI 3-SI-70 / 5-AF Type 304 performed valve 4c3SftIneto/2 Stainless 3" 0.520" prior to 1Steel HI-11practice of NRISegmet HHI01 1recordingBest Effort50%1 1448-WMKS-1 106A7 Tye34Examination Single-sided, elbow/ 12-SI-I / 1-13 Tye34performed to valve 4c4SaeyIjcin/2 Stainless 12" 0.490" prior to 1Segment LHI-004A Selpractice of NRIrecordingBest Effort50%11448-WMKS-1106A7 Tye34Examination Single-sided, pipe to/ 12-SI-2 / 1-15 Tye34performed valve 4c4Stainless 12" 0.487" prior to2Safety Injection / 2 Steel2Segment LHI-003A practice of NRIrecordingBest Effort1 1448-WMKS-0122A1 5% Snl-iebac/ 3-RH-13 / 3-02 Type 304 5%Snl-iebacResidual Heat Stainless 3" 0.375" connection to pipe 4c5Removal / 2 Steel (Nominal) 9% 1Segment RH-013 Best Effort NRI1 1448-WMKS-0122A1I 3-RH-13 / 3-03 Type 304 50% Single-sided, pipe toResidual Heat Stainless 3" 0.420" flange 4c5Removal / 2 Steel (Nominal) 10% 2Segment RH-013 Best Effort NRI(1) Actual measured thickness obtained from NDE records not provideddiffers from the nominal value shown in the referenced figure.in this relief request; this value Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 11 of 355. Burden Caused by ComplianceCompliance with the Code requirements would require extensive modification orreplacement of components with a design that would allow full examination fromboth sides of the weld. This option to rebuild components is considered impracticaland would cause unnecessary radiation exposure. Furthermore, plant equipmentcould be impacted in a detrimental manner.6. proposed Alternative and Basis for UseThe subject welds received a volumetric examination to the maximum extentpractical utilizing the best available techniques. With the incorporation of the PDI forSupplement 2, demonstration for best effort coverage was made for single-sidedexamination from the accessible side of the weld. Additionally, these componentsare monitored for through wall leakage as part of the ASME Xl System PressureTest Program and receive visual (VT-2) examination as required by Section Xl,Table IWB-2500-1, Category B-P for Class 1 components andIWC-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. Thereare no known failures of the welds discussed in this section at SPS1. Anyindications 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, thevisual (VT-2) examinations performed routinely and the fact that additional weldswere examined to supplement the requirements, it is reasonable to conclude thatservice induced degradation would have been detected. Therefore, these proposedalternatives provide an acceptable level of quality and safety by providingreasonable assurance of structural integrity of the subject welds. Dominion requestsrelief in accordance with 10 CFR 50.55a(g)(5)(iii).7. Duration of Proposed AlternativeThis proposed alternative is requested to meet requirements for the fourth ten-yearinservice inspection interval for SPS1, which began October 14, 2003 and ended onOctober 13, 2014.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 12 of 35Figure 4a(Page 1 of 3)/ Dominion'Drawing Number 1 1448-WMKS-0100AZ-1STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONMark Number 1-12ANGLE SCAN AREA SCAN SIDE SCAN %450 EXAMINATION VOLUME USRA(1 ST LEG) _ _ _ _ _ _ _450 EXAMINATION VOLUME (2nd LEG) _______450 EXAMINATION VOLUMEW(STRLEG)AM _____450 EXAMINATION VOLUME DWSRA____________ ~~~(2n LEG) _________450 EXAMINATION VOLUME (2w 50G450 EXAMINATION VOLUME CCW 50600 EXAMINATION VOLUME UPSTREAUPSTREAM600 EXAMINATION VOLUME (ind LEG) 0DOPSTREAM600 EXAMINATION VOLUME (2ST LEG) 92600 EXAMINATION VOLUME DOWNTRLEAM9UPWSTREAM700 EXAMINATION VOLUME (1ST LEG) _______DOWSTREAM700 EXAMINATION VOLUME (S E) ______UPSTREAM COVERAGE 0DOWNSTREAM COVERAGE 92CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50TO TAL PER CENT 48 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 13 of 35S~Dominion"Figure 4a(Page 2 of 3)STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONDrawing Number 1 1448-WMKS-0101AZ-1Mark Number 1-12ANGLE SCAN AREA SCAN SIDE SCAN %450 XAMIATIN VOUMEUPSTREAM450o EXAMINATION VOLUME (1 nt LEG)450 EXAMINATION VOLUME (2st LEG)450 EXAMINATION VOLUME DOWSTRLEAM450 EXAMINATION VOLUME (2W' 50G450 EXAMINATION VOLUME CCW 50UPSTREAM600 EXAMINATION VOLUME (1s* LEG) 0UPSTREAM600 EXAMINATION VOLUME (2nd LEG) 0DOWNSTREAM600 EXAMINATION VOLUME (1 st LEG) 92DOWNSTREAM600 EXAMINATION VOLUME (2fld LEG)UPSTREAM700 EXAMINATION VOLUME (1 st LEG)7Q0 DOWNSTREAM7°EXAMINATION VOLUME (1 st LEG)UPSTREAM COVERAGE 0DOWNSTREAM COVERAGE 92CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50TO TAL PER CENT 48 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 14 of 35Figure 4a(Page 3 of 3)SDominion"STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONMark Number 1-12Drawing Number 11 448-WMKS-010O2AZ-1ANGLE SCAN AREA SCAN SIDE SCAN %450 XAMIATIN VOUMEUPSTREAM45° XAMIATIN VOUME(1st LEG)UPSTREAM450 EXAMINATION VOLUME (2fld LEG)DOWNSTREAM450 EXAMINATION VOLUME (1st LEG)450 XAMIATIN VOUMEDOWNSTREAM45_____ EXMNTO OUE(2fld LEG)450 EXAMINATION VOLUME CW 50450 EXAMINATION VOLUME CCW 50600o EXAMINATION VOLUME UPSTRLEAMUPSTREAM600 EXAMINATION VOLUME (2fld LEG) 0DOWNSTREAM600 EXAMINATION VOLUME (1 st LEG) 92600 EXAMINATION VOLUME (2DOWSTEAMUPSTREAM700 EXAMINATION VOLUME (1 st LEG) _______7Q0 EXAMINATION VOLUME (1st LEG) _______UPSTREAM COVERAGE 0DOWNSTREAM COVERAGE 92CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50TOTAL PERCENT 48 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 15 of 35Figure 4bl(Page 1 of 2)Weld Number2-082I l ,I I,Weld WidthWeld Length1i .... I..0.75"21 .625"2I.,. I ........I I I r I I J. " ...................FLOWCL2-00-VALVE45ELBOW0.188" HT X.875"' WIDTH =0.165 SQ. IN REQUIRED VOLUME UPSTAND DNST SIDEEXAMINED 100% DNST AX AND C1RC DIRECTIONEXAMINED 0.07 SQ IN, UPST AX DIRECTION0,071.165 = 0.42 X 100 = 42% BEST EFFORT UPST AX DIRECTIONNO EXAM CIRO DIRECTION UPST SIDEExamination Volume Dimensions:- Heloht: 0.188" Length: 21.625" Width 1.75"Coverage SummaryRequired Scans (each has a weighing factor of 100 for complete coverage)ANGLE UpSt-Ax UpSt-Circ DnSt-Ax DnSt-Circ45 _________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 thatis effectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerline thatis examined in the axial beam direction with an Appendix VIII demonstrated procedure forsingle sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 16 of 35Figure 4b1(Page 2 of 2)Weld Number: 1-08Weld Length: 20.8"Weld Width: 0.6"Box Dimensions: H =0.22", L = 1.5"Valve-Best Effort Coverage:UpSt Exam Area = 0.22" x 0.75" =0.165 in2Examined (0.22 x 0.15) + (0.22 x 0.4)/2 =0.077 in20.077 1 0.165 = 46.67%46.67% 13 UpSt Scans = 15.56%Flow_______Coverage SummaryRequired Scans (each scan has a weighing factor of 100 for complete coverage)Angle UpSt -Ax UpSt -OW UpSt -CCW DnSt -Ax DnSt. -W DnSt -. CCW45160 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 examinationvolume that is effectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined with an Appendix VIii demonstrated procedure for singlesided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 17 of 35Figure 4b2(Page 1 of 2)Weld Number: 1-09Weld Length: 21"Weld Width: 0,9"Box Dimensions: H = 0.19", L = 1.9"PipeBest Effort Coverage:DnSt Exam Area =0.19" x 0.95" =0.181 in2Examined (0.15 x 0.25)/2 = 0.019 in20.019 /0.181 = 10,5%10.5% 13 DnSt Scans =3.5%FlowReqire Sans(eah Canhsv e iaghingmfactry o 0 o oplt oeaeAngle U~pSt -Ax UpSt -CW .UpSt -CCW --DnSt -Ax DnSt -CW DnSt -CCW60 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 iseffectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerline that isexamined with an Appendix Viii demonstrated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 18 of 35Figure 4b2(Page 2 of 2)Weld Number: 1-10Weld Length: 20.8"Weld Width: 0,9"'Box Dimensions: H= 0.19", L =1.9"Valver--Best Effort Coverage:DnSt Exam Area = 0.19" x 0.95" = 0.181 in2Examined (0.15x 0.25)/2 = 0.019in20.019 10.181= 10.5%10.5% 1 3 DnSt Scans =3.5%FRowCoverage SummaryAngle 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- CCW45 /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 iseffectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerline that isexamined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 19 of 35Figure 4b3(Page 1 of 2)Dominion"STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONMark Number 1-09Drawing Number 1 1448-WMKS-0122J1ANGLE SCAN AREA SCAN SIDE SCAN %450 EXAMINATION VOLUME UlSTRLEAM NA450 EXAMINATION VOLUME UPST LEA) NA450 ~DOWNSTREAM N4°EXAMINATION VOLUME (1 5t LEG) N,450 EXAMINATION VOLUME DOWNSTREAM NA450 EXAMINATION VOLUME CW 50450 EXAMINATION VOLUME CCW 50600 EXAMINATION VOLUME UP STREAM NA600 EXAMINATION VOLUME UPSTR EAM NA600 EAMINAION VLUMEDOWNSTREAM N___0__ EXMNTO OUE(I st LEG) NDOWNSTREAM600 EXAMINATION VOLUME (2rnd LEG) NA70° EXAMINATION VOLUME UPSTRLEAM 100700 EXAMINATION VOLUME DOWNSTREAM)UPSTREAM COVERAGE 100DOWNSTREAM COVERAGE 0CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50________________________ TOTAL-PERCENT 50 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 20 of 35Figure 4b3(Page 2 of 2)Drawing Number I11448-WMKS-01 22J1STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONMark Number 1-10ANGLE SCAN AREA SCAN SIDE SCAN %45 EAMNAIO VLUEUPSTREAM NA4__EXAINTIOVOUM (Ist LEG)45° XMNTINVLM UPSTREAM NEXAMINATION VOLUME (2DOWSTEA) NA450 EXMNTO OUEDOWNSTREAM N40EXAMINATION VOLUME C1 50LG)N450 XAMNATON OLUEDOWNSTE0600 EXAMINATION VOLUME (Is! LEG) N60EXAMINATION VOLUME CWTRA 5060EXAMINATION VOLUME DOWNSRA 100600 EXAMINATION VOLUME DOWNTREAM NA700 EXAMINATION VOLUME UPSTREAM NA__ __ __ _ __ _....... _ __ _ __ __ (ULEG) _ _ _ _ _ _ _700 EXAMINATION VOLUME DOWNSTREAM__ __ __ __ __ __ _ __ __ __ __ __ _ (2Id LEG) NA70 XMNTO OUEUPSTREAM COEAGADOWNSTREAMDOVERAGEE10CLOKWSTEA COVERAGE 50COUNTER CLOCKWISE COVERAGE 50____ ___ ___ ___ ___ ___ ___ ___ ___ ___ TOTAL PERCENT 50 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 21 of 35Figure 4b4(Page 1 of 3), Dominion°Report No: UT-12-061Summary # Si. R1.11.880Pg. 5 of 5Prepared by: W. Thomas ,Date; 5/18/20:12Weld NumberThickness1-02.572"Weld WidthWeld Length.,9'21"I 2 1 2...., ....I ...., ....I ...., ........, ....I ...., ....I ...., ....FLOW1-02WELDOLETCL/ 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 DIRECTIONDNSTSIDE.NO EXAM DNST SIDE CtRC DIRECTIONExamination 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 ofdt e reuiedera~atg o votlume50that is effectively examined with the qualified examination procedure.2) Best Effort Coverage refers to the required examination volume pastthe weldcenterline that Is examined in the axial beam direction with an Appendix VIIIdemonstrated procedure for single sided coverage.6'~i Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 22 of 35Figure 4b4(Page 2 of 3)' Dominion°Report No: UT-12-060Summary # Si. R1.11.882Pg. 5 of 5Prepared by: W. ThomasDate: 5/18/'2012Weld NumberThickness1-04.570'Weld WidthWeld Length,9"21"S2 0 1 21 +/- iFLOWa.ELBOWVALVE,1B' HTX .O5"WIOTH =.18&LO IN REcQUIREDOVOLUMEUPST ANDDNST" OE10=% OF EXAMINED .02 SQ. IN. BEST EFFCRT UPST tSRBTICN....02/.10 = 0.11 X 100 = 11% BEST EFFORT UPSraDtEA(DlREOT1ONNO EXAM UP&I CIRC DIRECTIONExamination Volume Dimensions -Height .19" Length 21" Width 1.9"_____Coverage SummaryRequired Scans (each has a weighing factor of 100 for complete coverage)ANGLE U pSt-Ax, UpSt-Circ DnSt-Ax DnSt-Clrc45,/60 I 100% I 0%70 100%60L *11% ICode 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 volumethat Is effectively examined with the qualified examiniatlon procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that Is examined in the axial beam direction with an Appendix VIiidemonstrated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 23 of 35Figure 4b4(Page 3 of 3)Report No: UT-13-126Summary # $1.R1.11.879Pg. 6 of 6Prepared by: W. Thomas Date: 11/9/2013oe lwed11 Witnessed7933HSB GSWeld NumberThickness1-01BC1.85"Weld WidthWeld Length1L.50"30.5"2 1 0 1 2'5'UC'UIN//5 ~5 Sf2. INROCSJJROOVOtUMSDSSlOEIN. I3SCDL'XDIR..361 .~ ~S47X iSO '441%E~tAM OSAX DIR 5;.3%Examination Volume Dimensions -Height 0.62"Leng1th 30.5" Width 2.4"_______Coverage Sum maryJ 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% 0II6OL *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 volumethat is effectively examined with the qualified examination procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined in the axial beam direction with an Appendix VIIIdemonstrated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 24 of 35Figure 4b5(Page 1 of 3)Report No: UT-43-124Summary # S1.R1,11.930Prepared by: W. Thomas ReieeDate: 11/8/2013 WitnessoWeld Width 1.60" ///Weld Length 30.5" 7933Weld NumberThickness1-01BC1.85".. .a , , r , ..45aKi~8I~.______________ i~ \j~a~uai~n ~UME 05 805 /SQ ~N. D5805MtSR.Q~assrss~Faftr" .55I.~8 1iI4?K1C8=~4.7%SNO EKAM4 OS AX DIR 53%Examination Volume Dimensions -Height0.62"Lenath 30.5" Width 2.4"Coverage SummaryRequired Scans (each has a wei~ghing factor of 1(00 for complete coverage),ANGLE ,.,UpSt-Ax UpSt-Circ DnSt-Ax .... DnSt-Circ45/60 -- 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 volumethat is effectively examined with the qualified examination procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined in the axial beam direction with an Appendix VIIIdemonstrated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 25 of 35Figure 4b5(Page 2 of 3)~DomIni@nReport No: UT-13-127Summary #f $1.R1.11.931Pg. 5 of6Prepared by: W. Thomas Date: 11/9/2013_th 0.8"21'Weld Number 1-02Thickness 0.552'Weld WidtWeld FLOWCL 1-02,i z i _0.1 84-rrx 0.025"DhIDI = 0.110 So, IN REQUIRED VOLUME EACH SIDE OFWELW.,EXAMINED 100% OFTHE REQUIRED EXAM VOLUME US SIDEEXAMINED 0.01 00. IN. DS SlOE AX DIRECTION BEST EFFORT"- BEST EFFORT= .01 / .17 =0,052 X 10016.0%EXAM OS SIDE AX DIRECTION = 94,1%Examination Volume Dimensions -Height 0.184" Length 21" Width 1.8"Coverage SummaryRequired Scans (each has a weighing factor of 100 for complete coverage),ANGLE U~pSt-Ax UpSt-Clrc DnSt-Ax DnSt-Circ.60LCode Coverage Total 50%1OD+100+0+5.9=205.9/4=51.5 ...*Best Effort Coverage (Max 25%) Total 1.5%Notes: i i ii i=1) Code Coverage refers to the maximum percentage of the required examination volumethat is effectively examined with the qualified examination procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined In the axial beam direction with an Appendix Viildemonstrated procedure for single sided coverage.Reviewed7933HSB GS Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 26 of 35Figure 4b5(Page 3 of 3)i 'I ' ., 'Supplemental ReportReport No.:" 'Ur-07-045Page: 2 of 2Comments:Examiner: Coburn, Timothy M Level: I...I Reviewer.Examiner: N/A Level: N/A site Review: z -,}Other:. N/A .Level: N/A ANII Review:_____________Date: It- 3-0o7Date //0 DDate 'Comments:Weld Number: 1-03ANora. Thickness: 0.562"Weld Length: 20.8" FlowWeld 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 2 0 .031 in2.0.031 / 0.214 =14,5%14.5%/S scans =4.83%-- Coverage SummaryAngie. Required Scans (ea~ch scan has a weighing factor of 100 for complete coverage)U ~t-Ax UpSt -W UPSt"CCW DnSt- Ax D nSt -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 volumethat is effebtively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerlinethat is examined with" an Appendix VIII demonstrated p~rocedure for single sidedcoveragqe.,Mddlionrl -Soppieern~el Reports Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 27 of 35Figure 4c1(Page 1 of 2)SDominion"Report No: UT-09-059Summary # S1.R.1,11.521Pg. 4 of 4Prepared By: W.L. Thomas %-Date: 5/1/2009SiIh~o7Weld NumberWeld ThicknessWeld LengthWeld Width2-09.562"20"1.o"FLOWPIPENRNNAEA EXAMINO U.s QieSQ 1N058.-,, EPIORTO.OI SO. OF NO ME'(PM 1OTN .S. 0c1eSQ. NC-ESEFFORT OOIE ARED.S.100+ l00+5+0=20514=51%NOT TO SCALEExamination Volume Dimensions -Height.187" Length 20"Width2"____._._C~overage ,SummaryRequired 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% 360RL 5%Code CoverageTotal _ 50, ~Best Effort Coverage (Max 25%) Total I

1Notes: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 weldcenterline that is examined in the axial beam direction with an Appendix VIIIdemonstrated procedure for single sided coverage. .

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 28 of 35Figure 4c1(Page 2 of 2)SDominionrReport No: UT-09-060Summary #SI.R1.1 1.522Pg. 4 of 4Prepared By: W.L Thomas -Date: 511/2009Weld NumberWeld ThicknessWeld LengthWeld Width2-10.562"20"1.0"PLOW-_...=,._ _ .1,L]PiPEVL-V.01"NR/, .AIEA6XA.MtEDUSE9SQ FFORT0,OSQ. IC,'* A :AF N.IrEDtJe[NArEION IOSQ.018, INd-ESBEST 6FORr AREAl c:oca rUREQIDARe-ADS.O.O1/O,9=S5%.100+ 100+5+0=205/4--51%NOT TO SCALEExamination Volume Dimensions -Height .187" Length 20" Width2"_______Coverage SummaryRequired, Scans (each has a weighi~ng, factor of 100 for complete coverage)SANGLE UpSt-Ax Upst-Circ ....Dnst-Ax 'DnSt-Circ45 100% 0%60 100% .... .6ORL 5%Code Total J 50%........Best Effort Cove~rage (Max 25%) Total' 1 %Notes:1) Code Coverage refers to the maximum percentage of the required examinationvolume tttat is effectively examined with the qualffled examination procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined in the axial beam direction with an Appendix VIIIdemonstr~ated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 29 of 35Figure 4c2(Page 1 of 2)Weld NumberThicknessK ............. ..... _. ...Report No: UT-13-1_36Summary # $1.R1.16.532Pg. 5 of 5Prepared by: W. Thomas Date: 11/8/20131-06 Weld Width0.386" Weld Length0.5"I40.5"1012 ____.1HCSB GSFLOW1-06.-' CLPiPE \ VALVE0.129" 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 INCHES3" 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.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%NO EXAM US SIDE AX DIRECTION = 52.3%Examination Volume Dimensions -Height 0.129" Length40.5"Width 1.5"________Coverage SummaryRequired Scans (each has a weighing factor of 100 for complete coverage)ANGLE UpSt-Ax UpSt-Circ DnSt-Ax DnSt-Circ45/60 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 volumethat is effectively examined with the qualified examination procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined in the axial beam direction with an Appendix VIIIdemonstrated procedure for single sided coverag~e.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 30 of 35Figure 4c2(Page 2 of 2)SDomh~,io-STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME BY SCAN DIRECTIONDrawing Number: 11448-WMKS-1101A5Mark Number: 1-03ANGLE SCAN AREA SCAN SIDE SCAN %45 XMIAIN OUEUPSTREAM ,45° EXAINATIONVOLUME(1st ILEG)I,450 XAMIATIN VOUMEUP STREAM45 EAMNAIO LEG) NA40DOWNSTREAM 04 EXAMINATION VOLUME (jst LEG) ______450 XAMIATIN VOUMEDOWNSTREAM4__EXANTIOVOUM LEG) NA450 EXAMINATION VOLUME CW 50450 EXAMINATION VOLUME CCW 50I600 EXAMINATION VOLUME UPSTRLEAMI0600 EXAMINATION VOLUME U2PSTREOMN600 EXAMINATION VOLUME DOWSTRLEAM60° EXAMINATION VOLUME DOWNSTREAM(20d LEG) NAUPSTREAM*700 EXAMINATION VOLUME (15t LEG) _______'700 EXAMINATION VOLUME DOWNSTRLEAM)UPSTREAM COVERAGE 1 00DOWNSTREAM COVERAGE 0CLOCK WISE COVERAGE 50COUNTER CLOCKWISE COVERAGE 50TOTAL PER CENT 50 %*450 exam coverage encompassed by the 600 and 70* exam used for procedure only and not forcoverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 31 of 35Figure 4c3(Page 1 of 1))Dominion-*STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME BY SCAN DIRECTIONDrawing Number: 11448-WMKS-1106A4Mark Number: 5-AFANGLE SCAN AREA SCAN SIDE SCAN %450 EXAMINATION VOLUME UPSTRLEAM450 EXAMINATION VOLUME (211d LEG) _______450 XAMIATIN VOUMEDOWNSTREAM450 EXAMINATION VOLUME (1fld LEG) _______450 EXAMINATION VOLUME CW LG450 EXAMINATION VOLUME CCW600 EXAMINATION VOLUME UPTRAM10UPSTREAM600 EXAMINATION VOLUME (! st LEG) 100DOWSTREAM600 EXAMINATION VOLUME (2"d LEG) NADOWNSTREAM N600 EXAMINATION VOLUME (Ind LEG). 0______UPWSTREAM NA700 EXAMINATION VOLUME (2"t LEG). _______700 EXAMINATION VOLUME DOWNTRLEAM70°EXAINTIOVOUM (Ist LEG) _______UPSTREAM COVERAGE 100DOWNSTREAM COVERAGE 0CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 5 0TOTAL PERCENT 50 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 32 of 35(Figure 4c4)(Page 1 of 2)SDominin-STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME BY SCAN DIRECTIONDrawing Number: 11448-WMKS-1106A7Mark Number: 1-13ANGLE SCAN AREA SCAN SIDE SCAN %450 EAMINAION VLUMEUPSTREAM*450° EXAMINATION VOLUME ( 1 sAM NEA45 EAINTONVLUE(2nd LEG) NA______450 DOWNSTREAM*4 EXAMINATION VOLUME (Il aLEG)450 EXAMINATION VOLUME DOWNSTREAM N______(20d LEG) N450 EXAMINATION VOLUME CW 50450 EXAMINATION VOLUME CCW 50UPSTREAM10600 EXAMINATION VOLUME (1St LEG)10600 EXAMINAT[ON VOLUME UP"STLEAM NA600 EAMINAION VLUMEDOWNSTREAM60°EXAINTIOVOUM (10 LEG)0600 EXAMINATION VOLUME DOWNSTREAM N___ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ LEG) N700 EXAMINATION VOLUME UPST LEAM NA700 EXAMINATION VOLUME DOWNTRLEAM NAUPSTREAM COVERAGE 100DOWNSTREAM COVERAGE 0CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50_________________________ TOTAL PERCENT 50 %*60* axial scan encompassed the 450 axial scan. 700 was used to interrogate far side of weldonly and not for coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 33 of 35(Figure 4c4)(Page 2 of 2)) DominloinrSTAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME BY SCAN DIRECTIONMark Numbe: 1-15Drawing Number: 11 448-WMKS-11I06A7ANGLE SCAN AREA SCAN SIDE SCAN %450 EXAMINATION VOLUME UPISTRLEAM450 ~UPSTREAM N4 EXAMINATION VOLUME LEG) N450 EXAMINATION VOLUME (1Ist LEO) ______450 ~DOWNSTREAM N4°EXAMINATION VOLUME (20d LEG) ____A__450 EXAMINATION VOLUME CW 50450 EXAMINATION VOLUME CCW 50600 EXAMINATION VOLUME UPSREA 100)600 EXAMINATION VOLUME U2PSTREAM NA600 EXAMINATION VOLUME DOWNSTRLEAM 0600 EXAMINATION VOLUME DOWNSTREGM NA700 EXAMINATION VOLUME U(SREA LEDOWNSTREAM*700 EXAMINATION VOLUME (1St LEG)UPSTREAM COVERAGE 100DOWNSTREAM COVERAGE 0CLOCK WISE COVERAGE 50COUNTER CLOCKWISE COVERAGE 50TOTAL 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. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 34 of 35Figure 4c5)(Page 1 of 2)Report No: UT-10 -050Summary # SI.R1.16.780Pg. 4 of 4Prepared By: W.L. Thomas Date: 11109/2010Weld NumberWeld ThicknessWeld LengthWeld Width3-020.375"I11"0.40".5.1l, ....I ...., ....I ...., ....I ........I ...., ....! ....,2i0t23FLDW3.02,375" NRTOTAL REcIJ RED tUMEu US5IDE= 008 Q IN..EAMNB IN Bas1" EF'F(3r'r AAL DIRIEGnTON.031 .03" .ST5X iC0 .051 n Examination Volume Dimensions -Height.ov5rag e ngth1m"ardt1.4"Coverage SummaryIANGLE I UpSt-Ax UpSt-Circ DnSt-AxDn-ir45/60 .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 examinationvolume that is effectively examined with the qualified examination procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined in the axial beam direction with an Appendix VIIIdemonstrated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 35 of 35Figure 4c5)(Page 2 of 2)Report No: UT- 10 -039Summary#S1 .R1 .16.184Pg,.4 of 4Prepared By: W.L, ThomasDate: 1 110/01Weld NumberWeld ThlicknessWeld LengthWeld Width3-030.420"11"0.45"'3I ...i ....$ ..., I ...1 ...,,],,,,Ii21012SR.OVCiFL.ANG6.410' ~.041.1 =,4 XIOG"4O %NO!XAMINA'1ON FcI 0108 IN Examination Volume Dimensions -Height .13"T' Length 11" Width i.45"Cav~rnaA ~ummarvRequired Scans (each has a weighing factor of 100 for complete coverage)'ANGLE Up t-Ax , ....UpSt-Cir ' .. ... DnSt-Ax n-lr-45160 100% 100% 0100+100+40+0=240/40()=.60x1 00=60% ...Effort coverage (Max 25%) Total 10%;Notes: 1) Code Coverage refers to the maximum percentage of the required examinationvolume that is effectively examined with the qualified examination procedure.2) Best Effort Coverage refers to the required examination volume past the weldcenterline that is examined in the axial beam direction with an Appendix ViIIIdemonstrated procedure for single sided coveragle.

Serial No. 15-446Docket No. 50-280Attachment 2Relief Request LMT-R02, Category R-A,Risk Informed Piping Welds on Carbon Steel PipingVirginia Electric and Power Company(Dominion)Surry Power Station Unit I Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 1 of 10Relief Request # LMT-R02Risk Informed Pipe Welds Carbon SteelRelief Requested in Accordance with 10 CFR 50.55 a(g)(5)(iii)Inservice Inspection Impracticality1. ASME Code Components AffectedASME Code Class: Code Class 2 and Non-classExamination Category: R-A, Risk Informed Piping ExaminationsItem Numbers: Ri1.11, Elements Subject to Thermal FatigueComponent Identification: Refer to Specific Table R02Material: Refer to Specific Table R022. Applicable Code Edition and Addenda1998 Edition with 2000 Addenda of ASME Section Xl3. App~licable Code RequirementThe 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 coveringASME Section Xl Class 1, 2, and 3 components.The pipe welds addressed by the RI ISI Program are assigned to a specificsegment. The pipe segment definition includes the following considerations: 1)system, 2) pipe size, 3) flow junctions, 4) pipe failure consequence, and 5) isolationpoints for pipe breaks. The number of welds per segment varies. Examination ismandatory for some welds in a segment regardless of whether limited coverage willbe attained. Other welds are sample selections, and an alternative weld may bechosen to replace the sample weld if the alternative weld could provide greaterexamination coverage. Although not required by the RI ISI Program, additionalwelds on the segment may be examined, in addition to the number of welds requiredby the risk informed analysis, to provide supplemental information for the segment.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 2 of 10The welds discussed in this section were selected for volumetric (ultrasonic)examination by the RI 1SI Program as assigned item number RI.11 for thermalfatigue.Neither the approved relief request nor the NRC Safety Evaluation for the RI ISIProgram addressed an alternative for limited examination coverage. Therefore, therules for ASME Section XI shall apply when limitations are encountered due to thedesign, geometry and materials of construction of the component. The alternativerequirements of ASME Section Xl, Code Case N-460, approved for use inRegulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of theweld provided greater than 90% of the required volume has been examined.4. Impracticality of CompliancePursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%volumetric examination coverage requirements for the subject austenitic welds dueto the geometric configurations which limit the volumetric coverage that can beobtained.The subject welds were examined with a manual UT technique using pulse echo UTinstruments and search units to achieve the maximum examination coveragepractical. Examinations were performed using personnel, equipment andprocedures qualified in accordance with ASME Section Xl, Appendix VIII asimplemented by the Performance Demonstration Initiative (PDI). No alternativetechniques or advanced technologies were considered capable of obtainingcomplete coverage of the examination volume.Segment MS-004Requirements for the RI 1SI Program are to credit the augmented examinationsperformed on this segment plus two additional Risk Informed selections. This wascompleted 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 examinationrequirement and also received surface examinations. An indication was identifiedduring the UT exam on weld 2-26 that was determined to be due to geometry andtherefore not a flaw. All of the full circumferential pipe welds were inspected onsegment MS-004 as there were no other available selections.Segment MS-007*Requirements for the RI ISI Program are to credit the augmented examinationsperformed on this segment plus two additional Risk Informed selections. This wascompleted 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. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 3 of 10received a surface examination. No indications were discovered during theseexaminations. All of the full circumferential pipe welds were inspected on segmentMS-007 as there were no other available selections.Segment MS-008Requirements for the RI 1SI Program are to credit the augmented examinationsperformed on this segment plus two additional Risk Informed selections. This wascompleted 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 alsoreceived a surface examination. No indications were discovered during theseexaminations. All of the full circumferential pipe welds were inspected on segmentMS-008 as there were no other available selections.Segment FW-012This segment is monitored by the Flow Accelerated Corrosion (FAC) Program whichrequires UT examination for wall thinning, and an Augmented Inspection Programfor high energy lines that requires volumetric and surface examinations. For apostulated secondary failure mechanism due to thermal fatigue, weld 1-22 wasadded as a risk informed examination. Weld 1-22 was examined with limitedcoverage as shown in Table R02. Welds 1-23, 1-25 and 1-26 on this segment wereexamined per the Augmented Inspection Program thus receiving volumetric andsurface examinations. The FAC Program is actively maintained and updated andthoroughly monitors the piping condition in this area, and the High Energy LineAugmented Inspection Program provides additional monitoring by weld volumetricand surface examinations. No flaws were found during these examinations.Segment FW-016This segment is monitored by the FAC Program which requires UT examination forwall thinning, and an Augmented Inspection Program for high energy lines thatrequires volumetric and surface examinations. For a postulated secondary failuremechanism due to thermal fatigue, weld 3-19 was added as a risk informedexamination. Weld 3-19 received limited coverage as shown in Table R02. Noflaws were~ found during these examinations. The FAC Program is activelymaintained and updated and thoroughly monitors the piping condition in this area.The High Energy Line Augmented Inspection Program provides additionalsurveillance through weld volumetric and surface examinations.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 4 of 10TABLE R02 Risk Informed Pipe Welds, Carbon SteelDrawing /Line# IID ISystem / Class Pipe Pipe Weld Coverage Limitation I Fig. No. IRisk Informed Material Dia, Thickness Achieved Results Pg. No.Segment11448-WMKS-0103A2- 600 lb Single-sided,I I 30-SH P-I / 2-28 AASd 30" 0.7"7%pipe to valve 4e1Main Steam / 2 AS t .7"7%1Segment MS-004 NRI11448-WMKS-0103A2- 600 lb Single-sided,I I 30-SH P-I / 2-31 AASd 30" 0.4"7%pipe to valve 4e1Main Steam / 2 AS t .4"7%2Segment MS-007 NRI11448-WMKS-0103A2- 600 lb Single-sided,2 I 30-SHP-2 / 4-3130pietvae 4eMain Steam I Non Class ASA Std 3" 0.940" 81.92% piet3av eSegment MS-008 NRI1 1448-WMKS-1018A3 / Single-sided,14-WFPD-17 / 1-22 600 lb 140.36.5pietvae 42Feedwater / Non Class ASA Std 141.3 35 iet av eSegment FW-012 NRII11448-WMKS-1018A3 / Single-sided,14-WFPD-9 / 3-19 600 lb 14" 0.920" 86.67% valve to pipe 4e2Feedwater / 2 ASA Std 2Segment FW-016 NRI5. Burden Caused by ComplianceCompliance with the Code requirements would require extensive modification orreplacement of components with a design that would allow full examination fromboth sides of the weld. This option is considered impractical and could impact plantequipment in a detrimental manner.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 5 of 106. Proposed Alternative and Basis for UseThe subject welds received a volumetric examination to the maximum extentpractical utilizing the best available techniques at the time the examination wasperformed. Additionally, these components are monitored for through wall leakageeither by the ASME Xl System Pressure Test Program required by Section Xl, TableIWC-2500-1 Category C-H for Class 2 components or a visual examinationperformed weekly as required by the Surry Augmented Inspection Program for highenergy 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. Thereare no known failures on this type of weld at SPSI. Any indications were recordedand dispositioned as geometric or construction related. No flaws were found duringthese examinations.Based on the volumetric coverage that was obtained with acceptable results, thevisual examinations routinely performed to detect through wall leakage and the factthat additional welds were examined to supplement the limited coverage, it isreasonable to conclude that service induced degradation would be detected.Therefore, these proposed alternatives provide an acceptable level of quality andsafety 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 AlternativeThis proposed alternative is requested to meet requirements for the fourth ten-yearinspection interval for SPS1, which began October 14, 2003 and ended on October13, 2014.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 6 of 10Figure 4el(Page 1 of 3)i~Dominion-Drawing Number: 11 448-WMKS-01 03A2-1STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME BY SCAN DIRECTIONMark Number: 2-28ANGLE SCAN AREA SCAN SIDE SCAN %450 XAMIATIN VOUMEUPSTREAMEXAMNATIN VOUME(1s't LEG)UPSTREAM450 EXAMINATION VOLUME (2nd LEG)45° XAMIATIN VOUMEDOWNSTREAM450 XAMIATIN VOUME(ist LEG)450 XAM[ATIN VOUMEDOWNSTREAM45 oEXAMNATIN VOUME(2fld LEG)450 EXAMINATION VOLUME CW 100450 EXAMINATION VOLUME CCW 100600 EXAMINATION VOLUME UPSTRLEAM 0UPSTREAM600 EXAMINATION VOLUME (2nd LEG)DOWNSTREAM600 EXAMINATION VOLUME (i st LEG) 94600 EAMINAION VLUMEDOWNSTREAM N60°_____ EXMNTO OUE(2ndl LEG) N70 EAMNAIO VLUEUPSTREAM NA70__EAMNATONVOUM (I st LEG)700EXMIATIN OLMEDOWNSTREAM NA70__EAMNATONVOUM (i st LEG)UPSTREAM COVERAGE 0DOWNSTREAM COVERAGE 94CLOCKWISE COVERAGE 100COUNTERCLOCKWISE COVERAGE 100TOTAL PERCENT 74 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 7 of 10Drawing Number: 11 448-WMKS-01 03A2-1-igure 4e12 of 3)STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME B Y SCAN DIRECTIONMark Number: 2-31ANGLE SCAN AREA SCAN SIDE SCAN %450 XAMIATIN VOUMEUPSTREAM45 oEXAMNATIN VOUME(I1st LEG)UPSTREAM450o EXAMINATION VOLUME (25d LEG)DOWNSTREAM450o EXAMINATION VOLUME (1St LEG)450 XAMIATIN VOUMEDOWNSTREAM45° XAMIATIN VOUME(2nd LEG)450 EXAMINATION VOLUME CW 100450 EXAMINATION VOLUME CCW 100600 EAMINAION VLUMEUPSTREAM1060______ EXAM____NATION_____VOLUME____ (I s LEG) 100_______UPSTREAM600 EXAMINATION VOLUME (25d LEG)DOWNSTREAM600o EXAMINATION VOLUME (i st LEG) 0DOWNSTREAM NA600 EXAMINATION VOLUME (2sd LEG)UPSTREAM700 EXAMINATION VOLUME (i st LEG)DOWNSTREAM700 EXAMINATION VOLUME (I1st LEG)UPSTREAM COVERAGE 100DOWNSTREAM COVERAGE 0CLOCKWISE COVERAGE 100COUNTERCLOCKWISE COVERAGE 100TOTAL PERCENT 75 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 8 of 10/u Dominion-Figure 4e1(Page 3 of 3)STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME B Y SCAN DIRECTIONDrawing Number: 11 448-WMKS-01 03A2-2Mark Number: 4-31ANGLE SCAN AREA SCAN SIDE SCAN %450o EXAMINATION VOLUME UPISTRLEAMUPSTREAM450o EXAMINATION VOLUME (2nd LEG)DOWNSTREAM450o EXAMINATION VOLUME (I1st LEG)450o EXAMINATION VOLUME (2DOWSTEAM450o EXAMINATION VOLUME CW 10 0450o EXAMINATION VOLUME CCW 1 00600o EXAMINATION VOLUME UPSTRLEAMUPSTREAM600 EXAMINATION VOLUME (2nd LEG)DOWNSTREAM600 EXAMINATION VOLUME (I sT LEG)600 XAMIATIN VOUMEDOWNSTREAM700 EXAMINATION VOLUME UPTRAM10700o EXAMINATION VOLUME DOWNSTRLEAM 27.7UPSTREAM COVERAGEDOWNSTREAM COVERAGECLOCKWISE COVERAGECOUNTERCLOCKWISE COVERAGETOTAL PERCENT 81.92 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 9 of 10Figure 4e2(Page 1 of 2)STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOL UME BY SCAN DIRECTIONDrawing Number:1 1448-WM KS- 1018A3Mark Number: 1-22ANGLE SCAN AREA SCAN SIDE SCAN %UPSTREAM450 EXAMINATION VOLUME (l~t LEG) _______UPSTREAM450 EXAMINATION VOLUME (2nd LEG) ________DOWNSTREAM450 EXAMINATION VOLUME (1st LEG) _______450 EXAMINATION VOLUME (2DOWSTEAM450 EXAMINATION VOLUME CW450 EXAMINATION VOLUME CCW600 XAMIATIN VOUMEUPSTREAM60_EXAINTIOVOUM (lSt LEG) 100UPSTREAM600 EXAMINATION VOLUME (2nd LEG) NADOWNSTREAM600 EXAMINATION VOLUME (1st LEG) 0DOWNSTREAM NA600 EXAMINATION VOLUME (2nd LEG)70 EAMNAIO VLUEUP STREAM NA70°_XAMNATINVLUM (1St LEG)70 EAMNAIO VLUEDOWNSTREAM 80.770_EXAINTIOVOUM (ist LEG)UPSTREAM COVERAGE 100DOWNSTREAM COVERAGE 0CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50TO TALPER CENT 63.5 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R02Attachment 2, Page 10 of 10Figure 4e2(Page 2 of 2)LIMITATION COVERAGES for WELD #3-19 due to UPSTREAM VALVE to PIPE CONFIGURATION.Weld Number: 3-19Weld Length: 44"Weld Width: 1.5"Box Dimensions: H =0.25", L = 2.5" r-______w _Valve F--l m-fflPipeCirc Exam:DS exam box length = 1.25'Examined 0.75"0.75 11.25 = 60%coverage SummaryAngiered Scans (each scan has a weig~hing factor'of 100 for complete coeaeAnle Upt-Ax .UpSt -CW UpSt -CCW OnSt-Ax DnSt-iCW 1DnSt-CCW45/60o70o 100 ooo____ _____ _ 100%Code Coverage Total 86.67%Best Effort coverage (Max 50%) Total NANotes:1. Code Coverage refers to the maximum percentage of the required examination volume thatis effectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerlinethat Is examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No. 15-446Docket Nos. 50-280Attachment 3Relief Request LMT-R03, Category R-A,Risk Informed Dissimiliar Metal Welds onSteam Generator Nozzle to Safe-EndsVirginia Electric and Power Company(Dominion)Surry Power Station Unit I Serial No. 15-446Docket No. 50-280Relief Request LMT-R03Attachment 3, Page 1 of 8Relief Request LMT-R03Risk Informed Dissimilar Metal Pipe WeldsRelief Requested in Accordance with 10 CFR 50.55 a(g)(5)(iii)Inservice Inspection Impracticality1. ASME Code Components AffectedASME Code Class: Code Class IExamination Category: R-A, Risk Informed Piping ExaminationsItem Numbers: RI1.11, Elements Subject to Thermal FatigueComponent Identification: Refer to TableMaterial: Steam Generator Side: Carbon Steel SA-216 withStainless Steel ButteringSafe End Side: Cast Stainless Steel2. Applicable Code Edition and Addenda1998 Edition with 2000 Addenda of ASME Section Xl3. ApplIicable Code RequirementThe examination requirements for piping welds for the Surry Power Station Unit I(SPS1) fourth 10-year inservice inspection interval were governed by the RiskInformed (RI) Inservice Inspection (ISI) Program as approved by NRC letter datedDecember 16, 1998. The SPS1 fourth interval RI I31 Program is a full scopeprogram 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 RiskSegments that were determined to be low safety significant (LSS). During thesubmittal and review process of the fourth interval RI ISI Program, Dominion agreedto inspect these dissimilar metal welds for defense-in-depth.These welds were selected for ultrasonic (UT) volumetric examination by the RI ISIProgram due to the assigned item number: RI1.11 for thermal fatigue.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R03Attachment 3, Page 2 of 8Neither the approved relief request nor the NRC Safety Evaluation for the RI ISIProgram addressed an alternative for limited examination coverage. Therefore, therules for ASME Section Xl shall apply when limitations are encountered due to thedesign, geometry and materials of construction of the component. The alternativerequirements of ASME Section Xl, Code Case N-460, approved for use inRegulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of theweld provided greater than 90% of the required volume has been examined.4. Impracticality of CompliancePursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%volumetric examination coverage requirements for the subject austenitic welds dueto geometric configurations that limit the volumetric coverage that can be obtained.The subject welds were examined with a manual UT technique using pulse echo UTinstruments and search units to achieve the maximum examination coveragepractical. Examinations were performed using personnel, equipment andprocedures qualified in accordance with ASME Section XI, Appendix Ill.The required examination volume of these welds was interrogated ultrasonically tothe maximum extent possible. No alternative techniques or advanced technologieswere considered feasible and/or capable of obtaining complete coverage of theexamination volume.Welds 1-05 and 1-06 are the hot and cold leg, respectively, dissimilar metal nozzleto safe-end welds on "C" steam generator (S/G). The carbon steel nozzles werebuttered 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, thesealternative 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 reflectorsdue to geometry, thickness, and contour and therefore not indicative of a flaw.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R03Attachment 3, Page 3 of 8TABLE R03 Risk Informed Dissimilar Metal WeldsDrawing /Line#I/ IDI/Pp ed Cvrg iiainFg oSystem I Class / Pipe Material Pp ed Cvrg iiainFg oRisk Informed Segment Dia. Thickness Achieved I Results Pg. No.S/G side: SA-216Gr. WCC with SSI11448-WM KS-O102AZ- bteigSafe-end1/I29-RC-7 / 1-05DM / RCS pipe: SA-351 29.5" 2.95" (1) 63% to nozzle R03Reactor Coolant/I1 1-2Segment RC-006 Safe End Side: RICast SSSIG side: SA-216Gr. WCC with SSI11448-WMKS-010O2AZ- bteigSafe-end1 / 31-RC-8 / 1-06DM RCS pipe: SA-351 31 2.4() 6% tonzl 0Reactor Coolant /I 3-4Segment RC-009 Safe End Side: NRICast SS(1) Actual measured thickness obtained from NDE records not provided in this relief request; this valuediffers from the nominal value shown in the referenced figure.5. Burden Caused by ComplianceCompliance with the Code requirements would require extensive modification orreplacement of components with a design that would allow full examination fromboth sides of the weld. This option to rebuild components is considered impracticaland would cause unnecessary radiation exposure. Furthermore, plant equipmentcould be impacted in a detrimental manner.6. Proposed Alternative and Basis for UseThe subject welds received a volumetric examination to the maximum extentpractical utilizing the best available techniques at the time the examinations wereperformed. Additionally, all components are monitored for through wall leakage aspart 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 Icomponents.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R03Attachment 3, Page 4 of 8None of the pipe or weld material is constructed with Alloy 600/82/182 materials;therefore, there are no primary stress corrosion cracking (PWSCC) concerns. Thereare no known failures on this type of dissimilar metal weld at Surry Power Station.Any indications were recorded and dispositioned as geometric or constructionrelated. No flaws were found during these examinations.Based on the volumetric coverage that was obtained with acceptable results and theroutinely performed visual (VT-2) examinations, it is reasonable to conclude thatservice induced degradation would have been detected. Therefore, these proposedalternatives provide an acceptable level of quality and safety by providingreasonable assurance of structural integrity of the subject welds. Dominion requestsrelief in accordance with 10 CFR 50.55a(g)(5)(iii).7. Duration of Proposed AlternativeThis proposed alternative is requested to meet requirements for the fourth ten-yearinspection interval for SPS1, which began October 14, 2003 and ended onOctober 13, 2014.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R03Attachment 3, Page 5 of 8Figure R03(Page 1 of 4)DominiourReport No: UT~-'1 -038Summary # SI, Rtl 11340Pg, 5 of 7PrepF~red fly: WL. Thlomas ,>--fDate: 1V,03/2010Weld NumbErWrfd Thk~iiessWe~d LengithWeld 1-O5OMNOTE: SEE ATTACXHEO COVERAGE PLOT77T .7 + 79 ÷ 0 -" 255If4QO = Examination Volume Dimensions -HeightIov Le S mngth G5 itCoverane SummaryRequired Scans (each has a weighirnq factor of 100 comp1etv coverare:)ANGLE t UpSt-Ax ..................OnStoCirc35145 77% 1% 79% I% t......... ..Code 3Best Effort Coverage (Max 25%) Totel NJANotes: "1) Code Coverage refers to the maximum percerntage of the required exae, lnationvolume that is effectively ex~amined with (te qualified examination procedure.Z) Best Coverage refers to the required examination volume past the waldcenterline that is examined in the axial beam direc~ion with an Appeiidi VIII.... demOnsiraed rocdure for sirgle sided coaver ..........

Supplemental ReportPane: 8 of 7Stimmar Na1.: S1t.RIlA1.340EXO drier:Examineri Mulrtiaad, Ryan LOthnrz WA -tevel; il.PDIo ci: il-PDIL 'I: N/ARevie~ at: Date: aSite i~ view: i(o~e,+ly;tsi44~Jlwia.. Date:ANtI Review: -Date'1 1 trNCZ -~1S ~tch ~ 1 08DM--7//N /N 7 N1'9$; A'X)$.JC /AXJK'S////.5. NOZ -~ .zz1 I SEA ~ r ~ .QSSMNI /N ) 'IillN Q NI / /1141~i.I. ~ 1?ao.s~ *,L IWOJPIfl EllA .flMC tEl IlkICflAUC4IC rk Olta all.,, RAllj Eta MdtEl'tbcv ~sIM1altE. 1ewelExnEtti*flarn" ~fl.XP*1C1kI4 C4CEl~-0"1"h.0e243 EQ 1k It. ltfb.JLtddvnflC ta air903 llXR A-EQ El/tIE CJ03NIrkMrA/a REWIWI EAMIEQIJII3 lk&'312NnArst cvAutta 1416 roe fft EQ 14 iNk 20@N 01k tAllo ="D0AddI "al-S on" entatRr cilazzo1-Serial No. 15-446Docket No. 50-280Relief Request LMT-R03Attachment 3, Page 7 of 8Figure R03(Page 3 of 4)mb.-.feport No; UT-lO --039Summnary # 1.RI,1!34IPg. 4 ofl 5Prepared By: WI., Thomnas Weld ThicknessW~el LengthWekd Width1-OGDM2,2'NOTE: SEE ATTACHED COVER~AGE PLOTExamination Volume Dimensions -Heighi:1i" Length I1656"Wkilrh________ Coverage ummry,U Upst-Circ DnSt=Ax DnSt-Circ35/45 72% 0% ........ .80% .. .....96%Cotie Co}vera~e T la 62%Notes: 1) Code Coverage refers to the maximum percentage of tile required examirwtioa2) (les't Effort Coverage refiers to tile required examination volume past tne wveld cent.erine that is: examined in the axial beam direction an Appendix VIIIde=monstraed proc~edure ior sded .... 9/j0 Supplemental Report~miniC~tRep=t UT-I10-039Page: 5 or 5Summary SI.R1 '11 3412-m~ner: Mulrhead, Ryan iti. C.. NiALeel: tI-PDItLevel: !I-PDPLevel: tfARe~lewe~:Site Rev~w: ~-+/-i~d.,V1~S ~ H~frJ4-~AAN I ReDate: Da4(:Ld/SC+rnn i 1 ..3 3 3* 1i>+ 1' j ,\r2.~ S.N tO I/0 (r zo aio I-5 T2 2.tS , Z X.t4O\! ""0)1o(0/IL r !!"I J1-iI2~SQ N VQL OS~iNr NOfUV E..tIA 0$ll SJ0$l OUSTO AIFTION (0 =:-,o27g-- Uzcoc,2o0f)z01(3Addlho~ -. R'pl'en P~~d Serial No. 15-446Docket Nos. 50-280Attachment 4Relief Request LMT-PO1, Category C-F-I and C-F-2,Preservice Weld ExaminationsVirginia Electric and Power Company(Dominion)Surry Power Station Unit I Serial No. 15-446Docket No. 50-280Relief Request LMT-P01Attachment 4, Page 1 of 7Relief Request # LMT -P01ASME Xl Preservice Pipe WeldsRelief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)Inservice Inspection Impracticality1. ASME Code Components AffectedASME Code Class: Code Class 2Examination Category: C-F-I, Pressure Retaining Welds in Austenitic StainlessSteel or High Alloy PipingC-F-2, Pressure Retaining Welds in Carbon or Low AlloySteel PipingItem Numbers: C5.21, Circumferential Weld, Piping Welds >1/5 in..Nominal Wall Thickness for Piping _> NPS 2 and _< NPS 4C5.61, Circumferential Weld, Piping Welds >1/5 in.Nominal Wall Thickness for Piping _> NPS 2 and _<NPS 4Component Identification: Refer to Specific TableMaterial: Refer to Specific Table2. Applicable Code Edition and Addenda1998 Edition with 2000 Addenda of ASME Section Xl3. Applicable Code RequirementRequired Method: Surface and VolumetricThe alternative requirements of ASME Section Xl, Code Case N-460, approved foruse in Regulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverageof 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 criteriawhen applying Supplement 2 to Appendix VIII:

Serial No. 15-446Docket No. 50-280Relief Request LMT-P01Attachment 4, Page 2 of 7(1) Piping must be examined in two axial directions. When examination in thecircumferential direction is required, the circumferential examination must beperformed in two directions provided access is available.(2) Where examination from both sides is not possible, full coverage credit maybe claimed from a single side for ferritic welds. Where examination from bothsides is not possible on austenitic welds, full coverage credit from a singleside may be claimed only after completing a successful single-sided AppendixVIII 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 ofa 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 beperformed in accordance with the requirements of Appendix VIII as modified by 10CFR 50.55a(b)(2)(xvi)(g) and §50.55a(b)(2)(xv)(A).4. Impracticality of CompliancePursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the volumetricexamination coverage requirements for the subject welds due to geometricconfigurations which limit the volumetric coverage that can be obtained.When the examination area is limited to one side of an austenitic weld, examinationcoverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A), proficiencydemonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B), and full coveragecredit may not be claimed. There are currently no Performance DemonstrationInitiative (PDI) qualified single-side examination procedures that demonstrateequivalency to two-sided examination procedures on austenitic piping welds.Current technology is not capable of reliably detecting or sizing flaws on the far sideof 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 isperformed on a best effort basis. The best effort qualification is provided in place ofa complete single-side qualification to demonstrate that the examiners qualificationand the subsequent weld examination is based on application of the best availabletechnology.The subject welds were examined with a manual ultrasonic (UT) technique usingpulse echo UT instruments and search units to achieve the maximum examinationcoverage practical. Examinations were performed using personnel, equipment andprocedures qualified in accordance with ASME Section Xl, Appendix VIII, as Serial No. 15-446Docket No. 50-280Relief Request LMT-P01Attachment 4, Page 3 of 7implemented by the Performance Demonstration Initiative (PDI). No alternativewelds were considered since these are preservice examinations for each specificweld that was reconstructed.Weld 2-AW-BThis is a stainless steel ASME Xl Category C-F-i weld. This weld also received afinal liquid penetrant (surface) examination and a radiography examination beforereturn to service. An indication was noted during the UT scan and was determinedto be root geometry, due to construction and not a flaw.Weld O-34AThis is a carbon steel ASME Xl Category C-F-2 weld. This weld also received aliquid penetrant (surface) examination on the final weld before return to service. Norecordable indications (NRI) were noted during the exams.Weld 0-1AThis is a carbon steel ASME Xl Category C-F-2 weld. This weld also received aliquid penetrant (surface) examination on the final weld before return to service. Noindications were noted during the exams.TABLE P01 -Preservice ExaminationsDrawing I Line# I ID/ Pipe Pipe Weld Coverage Limitation / Fig. No. ISystem I Class Material Dia. Thickness Achieved Results Pg. No.314-CWMKS -A-10B5 Type 304 45.5% Single-sided,/ 3CH- /2-A-B/ Sailes 3 0.0"pipe to valve P01Chemical and Volume Sanes 3 0506.4% 1Steel Bs fotRControl / 2 Bs fotR11448-WM KS- 600Sl Single-sided,01A-/6-AD1Standard 6" 0.48" 88.3% flange to elbow P01I 0-34A / 2CarbonFeedwater / 2 SelNRI600 lb1 1448-WMKS- ASA Single-sided,0118G1-1 /6-WAPD-2 Standard 6" 0.50" 88.3% flange to pipe P01/I0-1A/ CaboFeedwater / 2 Steeln NRI Serial No. 15-446Docket No. 50-280Relief Request LMT-P01Attachment 4, Page 4 of 75. Burden Caused by ComplianceCompliance with the Code requirements would require extensive modification orreplacement of components with a design that would allow full examination fromboth sides of the weld. This option to rebuild components is considered impracticaland would cause unnecessary radiation exposure. Furthermore, plant equipmentcould be impacted in a detrimental manner.6. Proposed Alternative and Basis for UseThe subject welds received a volumetric examination to the maximum extentpractical utilizing the best available techniques. With the incorporation of the PDI forSupplement 2, demonstration for best effort coverage was made for single-sidedexamination from the accessible side of austenitic weld 2-AW-B. Additionally, thecomponents are monitored for through wall leakage as part of the ASME XI SystemPressure Test Program and receive visual (VTI-2) examination periodically asrequired 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. Anyindications 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, theroutinely performed visual (VTI-2) examinations, and the additional examinations forsurface (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 byproviding 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 AlternativeThis proposed alternative is requested to meet requirements for the fourth ten-yearinspection interval for Surry Power Station Unit 1, which began October 14, 2003and ended on October 13, 2014.

Serial No. 15-446Docket No. 50-280Relief Request LMT-P01Attachment 4, Page 5 of 7Figure P01(Page 1 of 3)Weld Number: 2-AW-BWeld Length: 11"Weld Width: 0.5"Box Dimensions: H = 0.15", L = 1.5"Obstruction: Branch connection centeredat TDC, 0.5" from weld toe, obstructedaxial exams for a length of 3".Examined 8" of 11" = 73%FlowPipeValveBest Effort Coverage:Os exam box = 0.15" x 0.7'5" = 0.113 in2Examined (0.15 x 0.25) + (0.15 x 0.4)/2 = 0.06 in20.06/10.113 = 53%53% (8" of 11") = 38.5%38.5% /I6scans =6.4%______Coverage SummaryAngle .Required Scans (each scan has a weighing factor of 100 for complete coverage.Angle- UpSt -Ax UpSt -CW UpSt -CCW DnSt -Ax D~nSt -CW DnSt -CCW60 73% 1 _____j 0% _____45/60 _____{100% 10.0% _ ____ 0% 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 thatis effectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerdine thatis examined with an Appendix VIII demonstrated procedure for single sided coverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-P01Attachment 4, Page 6 of 7Figure P01(Page 2 of 3)Weld Number:. 0-34AWeld Length: 21"Weld Width: 0.7"Box Dimensions: H = 0.15", L = 1.7"Flange Nte: 45° axial probe included in sketch todemonstrate 100% axial coverage from DSside,Ciro exam coverage:US Exam Box: 0.15" x 0.85" = 0.128 in2US Circ Exam: 0.15" x 0.55" = 0.083 in20.083/0.128=65%_______Coverage SummaryAngle 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 -COW45 100% 65% 65% 100% 100% 100%Code Coverage Total 88.3%...... .......Best Effort Coverage (Max 50%) Total NANotes:1. Code Coverage refers to the maximum percentage of the required examination volumethat Is effectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerlinethat is examined with an Appendix VIII demonstrated procedure for single sidedcoverage.

Serial No. 15-446Docket No. 50-280Relief Request LMT-P01Attachment 4, Page 7 of 7Figure P01(Page 3 of 3)Weld Number; 0-1AWeld Length: 21"Weld Width: 0.7"Box Dimensions: H = 0.15", L =1.7"Circ exam coverage:OS Exam Box: 0.15" x 0.85" = 0.128 in2,DS Circ Exam: 0.15" x 0.55" =0.083 in20.083 / 0.128 =65%Flow3'PsI'Notej." 45° axial probe included insketch to demonstrate 100% axialcoverage from OS side.S~Coverage SummaryAngle -Required* Scans (each scan has aweiching factor of 10f cm plete coverage)____ UpSt -Ax UpSt -OW UpSt -COW JDnSt -Ax DnSt -CW DnSt.- COW45 100% 65% 65% 100%, 100% 100%Code Coverage Total 88.3%Best Effort Coverage (Max 50%) Total NANotes:1.. Code Coverage refers to the maximum percentage olthe required examination volumeIthat is effectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerlinethat is examined with an Appendix VIii demonstrated procedure for single sidedcoverage.

Serial No. 15-446Docket No. 50-280Attachment 5Relief Request LMT-C01Examination Category B-B, Pressurizer Shell to HeadCircumferential And Longitudinal Welds Virginia Electric and Power Company(Dominion)Surry Power Station Unit I Serial No. 15-446Docket No. 50-280Relief Request LMT-C01Attachment 5, Page 1 of 11Relief Request LMT-C01Pressurizer Shell-to-Head Circumferential and Longitudinal WeldsRelief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)Inservice Inspection Impracticality1. ASME Code Components AffectedWeld No.: 1-07Drawing: 1 1448-WMKS-RC-E-2ASME Class: 1ASME Category: B-BASME Item: B2.11Description: Pressurizer Shell to Head Circumferential WeldWeld No.: 1-15Drawing: I11448-WMKS-RC-E-2ASME Class: 1ASME Category: B-BASME Item: B2.12Description: Pressurizer Shell to Head Longitudinal Weld2. Applicable Code Edition and Addenda1998 Edition with 2000 Addenda of ASME Section Xl3. Applicable Code RequirementThe 1989 Edition of ASME Section Xl Table IWB-2500-1, examination categoryB-B, item B2.11, requires volumetric examination of essentially 100% of thecircumferential shell to head welds.

Serial No. 15-446Docket No. 50-280Relief Request LMT-C01Attachment 5, Page 2 of 11Table IWB-2500-l category B-B, item B2.12, of the 1989 Edition requires volumetricexamination of one foot on the longitudinal weld that intersects the selectedcircumferential shell to head weld.4. Impracticality of ConplijanceThe pressurizer is covered with an insulation support ring (Figure 1). The insulationsupport ring is six (6) inches wide where examination interference is encountered forweld 1-07. As seen in Figure 1, this insulation support ring and a power operatedrelief valve support prevent complete volumetric coverage of both the uppercircumferential head weld 1-07 and the intersecting longitudinal weld 1-15.5. Burden Caused by ComplianceTotal removal of the support ring at the mechanical connections is consideredimpractical due to the extreme high dose rates in the pressurizer area. Totalradiation dose to remove the interfering support and perform the examination wasestimated to be 15.13 man-rem. This includes expended dose necessary for thevarious crafts involved including mechanical maintenance, insulators, rigging crewsand Non-destructive Examination (NDE) personnel. Partial removal of the supportring could allow some increased coverage; however, the actual increase would bevery small in relation to the entire weld length. This is not considered a practicaloption when considering consequential disturbance of interconnected cross supportsand the welded connections to safety and power operation relief valve supports.Removal of the mechanical connections or forced spreading apart of componentswould 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 UseExamination of pressurizer shell welds 1-07 and 1-15 was performed during the thirdinservice inspection interval as documented in Dominion letter dated July 14, 2005(Serial No.05-277). The average total examination coverage of all scan directionsfor welds 1-07 and 1-15 is 46% and 31%, respectively.Examination of pressurizer shell welds 1-07 and 1-15 was reattempted during thefourth inservice inspection interval. The obstructions were verified as shown on theinspection reports provided in page 1 of Figure 001. The examiners referenced theprevious limitations from the third interval. The documentation of these limitations isprovided in Figures 001 for reference.

Serial No. 15-446Docket No. 50-280Relief Request LMT-C01Attachment 5, Page 3 of 11No additional ultrasonic examination techniques would provide meaningful additionaldata on this cladded material for the examination volume not attained. Thepressurizer receives a visual (VT-2) examination every refueling outage as requiredby Section Xl, Table IWB-2500-1, Category B-P for Class I components. Any effortto achieve greater coverage would be impractical creating risk of componentdamage or destruction and excessive personnel dose exposure.Based on the volumetric coverage that was obtained with acceptable results and theroutinely performed visual (VT-2) examinations, it is reasonable to conclude thatservice induced degradation would have been detected. Therefore, these proposedalternatives provide an acceptable level of quality and safety by providingreasonable assurance of structural integrity of the subject welds. Dominion requestsrelief in accordance with 10 CFR 50.55a(g)(5)(iii).7. Duration of Proposed AlternativeThis proposed alternative is requested to meet requirements for the fourth ten-yearinspection interval for Surry Power Station Unit 1, which began October 14, 2003and ended October 13, 2014.

Serial No. 15-446Docket No. 50-280Relief Request LMT-C01Attachment 5, Page 4 of 11iN$ULAtION .~UFP~T ~~r~+/-' PR:u RI1E,. 4 $1JLATIIO~

Sunumary No.: S1.82,I.,001Workeo~pe: IS!LIT Vessel ExaminationER-AA.NIDE.UT-702Prncedure Re'j.: 4Wo*K Order No,: 3B81033270$INIDFR134038No,: S1 R25Rcpirt No.: UT.i3-I11Code; AS/IAE 1958 EW2000 Addenda Ca~tdlm: 8B-1B2A1 PZR 47Drawing No.: Z 1448.WMKS.-RG-E-2 SHELL TO HIEADl WELDCompoenwnt 20: 1 1440-W!MtlS.RtC-E.2 t 1-07 3'0t 392 4,375! 7,75'1 ti~l~e'n:, See previous; rprot1 UTRf U C'H 851 RT5501A; IeTSSQGIB Strlia!:m 1028 The': 1I300£xarhaltoil Surf-ce: Outaide Surface Co dtions Ground InlushLo Location: Zero Datum Point W o lo~cetlon: Weld Cetr Soundaafa Balclh No: 1:2120Terop. Tool Mf'g. AMVEC Serial 100 BOGY Surac Temp.; 72.3 °FCaL Repoxt No.: CAL.13.023 CAL-13-023, CAL-1I3-030Ye 3 -SScnCseaJ: svateI O,See preViousceportUTRNO 1381 for Irihotions antd co =a e ' O o b -t o r-r$ d[O C,oC)"-40Percent Cf Corea~ge Obiolnodi '1 9Ai: No0Reviewed Previ4ous, Daa: YesOC>CDoO:iT' 0 C.0 n c.--H.-00,urve~eI EeuuL~etien Serial No. 15-446Docket No. 50-280Relief Request LMT-C01Attachment 5, Page 6 of 11Figure C01 l(Page 2 of 7)Corrected calculation performed in 2005.Added to report by Dan Jensen. (3 Pages)-9ohd~PERCENT VOLUME BY SCAN DIRECTIONDRA WING NUMBER! I 548-WMK&RC.-,E4MARK NUMBER 1-07ANLE. .........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 theweld with 00, 450 and 600 transducers for the 2, 5, 7 and 8 scans.DanielL Jensed/DATE ICorrected calculation performed in 2005.I~Added to report by Dan Jensen. (3 Pages)II448-VMKS-RC-E--2 1-07(Ho~ched no exo.Nn~tlon cover'age)ITED FOR 2%. OF WELD 1'I NOZZLE.UZ4ITE]D FOR 0.7% OF WELD" LEGTH"0)"oO-hC;;DoCD1C',---C-.,-rj- Ct-0)0_CD ZZ* ",! -1 .-o °I--o 0 O0RT55O1B jI4 8 W K -Co -ec-dcluaio efre inL 2-0057PREAURI EdR rpr by:I Dan JesHEn. (PaEs)11448-WMK~-RC--E-E WELD 1-07PRES~U1~IZER HEA:D TD SHELL VIELU'0~A1UIDATU.H* 288," '275.4'~~201.9' ." 164.8" ..= ~126.3' -S 88,5"ItjPn2RT LUU13ATIW4 1W4', c$" L£GI7H!-07(oC.O(D"0)o ID:3-~---:1' n~ZLEI~-S5' AND 2-6.5~ FDUA Th~ ~ VUIp R!IULThAD IN LD~TATJW1 F~ OJX or vrij LaADTU\ -L~' ~RfDf T~ O~ ~IEI~DRESILThNI IN UmT&TmII O~ IN VI1~W~1It(rYI. a SZLm.T, F'4 ULI1WN'YI f'lA IDAD D I.3UTIHRT55O1A m zUT Vessel ExaminationSu~rgy i -lSummary No.: 81.BZ.12.002181Pioaedure: ER-AA-NDE.iTT.702Procedure Re'.,: 4WorR Order No.: Outage N'o,: $IR2SPage: 1 of !Code; ASMtE iS99 EW2000 Addenida B-B, rB2.t2 Lacation." PZ.R 47DrawlrK.J No,: 1I44li-WM KS-RC:E-2 LONG SHELL TO HEAD WELD$ystu ID: RCCowponan: ID: !!44a-WlMKS-RC-E-2' 1-I5 SlzeLeng~h: ?.,O' 1 Thickrness.'Oameter 4.375 / 7,75"U~miiations: Sce prevtous roport # UTR.NO 851 fSxa~t Time; 1028 F~nish imec 130}5SUrfa'-e: liisida [] Outs3de [,J Surf-=oe Cond~iiin: Groundi PlshLa Zaro Datum Point Wo Locslkon: Weld Center Line CoUpi~nt; Sountdsaife Batch No.: 12120Temp. Tooi IfM-: AMEC Serial Na.:" IC64SGCY Temp.; 72.3 Cjal. Re~pot No.." QAL-13-028, CAL-13-029. CAL-13-030ScInigd 1 31 31 36 36 Se0, Preavious report:#UTRNO 851 P 6res iaerLon0 scam Weld -o' T G'V";'; T ¢ -o'-no(0C-,oCDPeneif Of Cvoerage Obtahv~e =- 96: No.Rewicvwcd D~am:Yes~0)0z003)WI VesselJ Exsd,atfirtn Serial No. 15-446Docket No. 50-280Relief Request LMT-C01Attachment 5, Page 10 of 11Figure C01(Page 6 of 7)/"Dominion-PERtCENT VOLUME BY SCAN DIRECTIONDrawing Number: I Mark Nur!b.r:.I-!5SCAN j SCAN SCAN PERCENT.ANGLE j DTRECTION .AR1..A ................... AMINED--...............Wel1d & B~ase Mcmta 10%6t)* 2 ...Weld & Base 75%.... .. Weld & Base Metal ........ 36%,60,....... 5 Weld & Memta 5764S ' 7 Weld & .. ............... 10%45* 7 Mei~i 10%A8 W eld &Jls t 1.f.a1 ....... .... .%.C2ommnt~as: AMt were se~ined with tihe maximum exsmt posible .from sides of the whh 45ndAVEIRAGE PERCENYT EXAMPNED 31! %May I 5. 2003DOMIIO'N, VIIArNI,\ POWERS, LEVEL li[*DATEHS~-CT AMI~NI! Fi~V1~T~VSj~y

.t *1-15Pressur~izer, Lang Sean \eed(Hatched clreas represen+/- no exaina-tion coverage)4a3q2 Sq, In. Vah~f~e182.I Sq. exrilned IS7~ ~oi*~e(1)"(02lD)C r.-o O0 I .-'oco-nHSB-CT ANI/ANtI RT550O ELECTRIC AND POWER COMPANY-(q , RICHMOND, VIRGINIA 23261October 9, 201510CR55aU.S. Nuclear Regulatory Commission Serial No. 15-446Attention: Document Control Desk SPS-LIC/CGL RIWashington, DC 20555 Docket No. 50-280License No. DPR-32VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNIT 1ASME SECTION Xl INSERVICE INSPECTION PROGRAMRELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONSPERFORMED IN THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVALVirginia Electric and Power Company (Dominion) performed inservice inspection (ISI)examinations at Surry Power Station Unit I for the fourth 10-year ISI interval, whichbegan on October 14, 2003 and ended on October 13, 2014. A one-year extension wasapplied 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, 2013and NRC approval dated May 28, 2014]. Examinations of certain componentsconducted during the fourth interval received less than the required examinationcoverage.Pursuant to 10 CFR 50.55a(g)(5)(iii), Dominion requests relief for limited examinationson the basis that the required examination coverage was impractical due to physicalobstructions and limitations imposed by design, geometry and materials of constructionof the subject components. Attachments 1 through 5 contain the specific relief requestsand the basis for each request. These relief requests have been reviewed andapproved by the station's Facility Safety Review Committee.If you have any questions or require additional information, please contactMr. Gary D. Miller at (804) 273-2771.Si nce rely,Mark D. SartainVice President -Nuclear EngineeringCommitments made in this letter: None

.a Serial No. 15-446Docket No. 50-280Relief Requests for Fourth IntervalLimited Coverage ExaminationsPage 2 of 2Attachments:1. Relief Request LMT-R01, Category R-A, Risk Informed Piping Welds on StainlessSteel Piping2. Relief Request LMT-R02, Category R-A, Risk Informed Piping Welds on CarbonSteel Piping3. Relief Request LMT-R03, Category R-A, Risk Informed Dissimiliar Metal Welds onSteam Generator Nozzle to Safe-Ends4. Relief Request LMT-P01, Category C-F-I and C-F-2, Preservice Weld Examinations5. Relief Request LMT-C01, Category B-B, Pressurizer Shell to Head Circumferentialand Longitudinal Weldscc: U.S. Nuclear Regulatory Commission, Region IIMarquis One Tower245 Peachtree Center Avenue NE, Suite 1200Atlanta, Georgia 30303-1257NRC Senior Resident InspectorSurry Power StationMs. K. R. Cotton-Gross, NRC Project Manager -SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852Dr. V. Sreenivas, NRC Project Manager -North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852Mr. R. A. SmithAuthorized Nuclear InspectorSurry Power Station

,ISerial No. 15-446Docket Nos. 50-280'IAttachment IRelief Request LMT-RO1, Category R-A,Risk Informed Piping Welds on Stainless Steel PipingVirginia Electric and Power Company(Dominion)Surry Power Station Unit I

Serial No. 15-446~Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 1 of 35Relief Request LMT-R0IRisk Informed Pipe WeldsStainless Steel: Non-Alloy 600182/182Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii)Inservice Inspection Impracticality1. ASME Code Components AffectedASME Code Class: Code Class 1 and 2Examination Category: R-A, Risk Informed Piping ExaminationsItem Numbers: RI .11, Elements Subject to Thermal FatigueRI1.16, Elements Subject to lntergranular StressCorrosion CrackingComponent Identification: Refer to Specific TableMaterial: Refer to Specific Table2. Applicable Code Edition and Addenda1998 Edition with 2000 Addenda of ASME Section Xl3. Applicable Code RequirementThe examination requirements for piping welds for the Surry Power Station Unit 1(SPS1) fourth 10-year inservice inspection interval were governed by the RiskInformed (RI) Inservice Inspection (ISI) Program as approved by NRC letter datedDecember 16, 1998. The SPSI fourth interval RI ISI Program is a full scopeprogram covering ASME Section Xl Class 1, 2, and 3 components.The pipe welds addressed by the RI ISI Program are assigned to a specificsegment. The pipe segment definition includes the following considerations: 1)system, 2) pipe size, 3) flow junctions, 4) pipe failure consequence, and 5) isolationpoints for pipe breaks. The number of welds per segment varies. Examination ismandatory for some welds in a segment regardless of whether limited coverage willbe attained. Other welds are sample selections, and an alternative weld may bechosen to replace the sample weld if the alternative weld could provide greater

,9Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 2 of 35examination coverage. Although not required by the RI 1SI Program, additionalwelds on the segment may be examined, in addition to the number of welds requiredby the risk informed analysis, to provide supplemental information for the segment.The welds discussed in this section were selected for volumetric examination by theRI ISI Program due to the assigned item numbers: R1.11 for thermal fatigue orRI1.16 for intergranular stress corrosion cracking.Neither the approved relief request nor the NRC Safety Evaluation for the RI ISIProgram addressed an alternative for limited examination coverage. Therefore, therules for ASME Section Xl shall apply when limitations are encountered due to thedesign, geometry and materials of construction of the component. The alternativerequirements of ASME Section Xl, Code Case N-460, approved for use inRegulatory Guide 1.147, Rev.17, allows credit for essentially 100% coverage of theweld provided greater than 90% of the required volume has been examined.10 CER 50.55a(b)(2)(xv)(A) requires the following examination coverage criteriawhen applying Supplement 2 to Appendix VIII:(1) Piping must be examined in two axial directions. When examination in thecircumferential direction is required, the circumferential examination must beperformed in two directions provided access is available.(2) Where examination from both sides is not possible, full coverage credit maybe claimed from a single side for ferritic welds. Where examination from bothsides is not possible on austenitic welds, full .coverage credit from a singleside may be claimed only after completing a successful single-sided AppendixVIII 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 ofa 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 beperformed in accordance with the requirements of Appendix VIII as modified by 10CFR 50.55a(b)(2)(xvi)(B) and §50.55a(b)(2)(xv)(A).4. Impracticality of CompliancePursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100%volumetric examination coverage requirements for the subject austenitic welds dueto the geometric configurations which limit the volumetric coverage that can beobtained.When the examination area is limited to one side of an austenitic weld, examination Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 3 of 35coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiencydemonstrations do not comply with 10 CFR 50.55a(b)(2)(xvi)(B). Therefore, fullcoverage credit may not be claimed.The subject welds were examined with a manual ultrasonic (UT) technique usingpulse echo ultrasonic instruments and search units to achieve the maximumpractical examination coverage. Personnel, equipment and procedures werequalified in accordance with ASME Section Xl, Appendix VIII as implemented by thePerformance Demonstration Initiative (PDI).There are currently no PDI qualified single-sided examination procedures thatdemonstrate equivalency to two-sided examination procedures on austenitic pipingwelds. Current technology is not capable of reliably detecting or sizing flaws on thefar side of an austenitic weld for configurations common to U.S. nuclear applications.PDI Performance Demonstration Qualification Summary (PDQS) certificates foraustenitic piping list the limitation that single-sided examination is performed on abest effort basis. The best effort qualification is provided in place of a completesingle-side qualification to demonstrate that the examiners' qualification and thesubsequent weld examination is based on application of the best availabletechnology.In some of the earlier UT examinations performed in the first period of the fourthinterval at SPS1 (October 14, 2003 -October 13, 2006), reporting "Best Effort"coverage when encountering single-sided limitations on austenitic steel material wasnot routine practice. Refracted longitudinal (RL) wave was typically used toinvestigate the far side of the weld to the greatest extent possible if the thickness ofthe pipe was greater than 0.5 inches. For piping 0.5 inches in thickness or less, a70 degree examination angle is used to interrogate the far side of the weld. Anyindications seen with the RL or the additional angle used would have been notedand investigated.The required examination volume of these welds was interrogated ultrasonically tothe maximum extent possible. No alternative techniques or advanced technologieswere considered feasible and/or capable of obtaining complete coverage of theexamination volume.a. The 1-12 welds are the reactor coolant pump (RCP) to pipe welds for the threeRCPs. Details are provided in Table 4a. The 1-12 welds fall within High SafetySignificance (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 ofthe three segments, one sample weld (1-12) is required. Only one alternate weldexists on each of the individual segments, weld 1-13, which is a pipe to motoroperated valve weld. The UT scanning area would also be restricted to one side Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 4 of 35of weld 1-13 due to the pipe to valve configuration and would provideapproximately 50% coverage similar to the 1-12 weld coverage. Due to theexcessively high dose rates in this area, it is not feasible to attempt examinationof 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 onlyrecorded in tabular format as shown in Figure 4a of this attachment.There were no recordable indications (NRI).TABLE 4a Reactor Coolant Pump to Pipe WeldsDrawing / Line# / ID I WeldSystem 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 4aReactor Coolant / I Type 2.".5" shear wave ISegment RC-010 316 used, 60 NRIdegree RLalso used48%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 4aReactor Coolant /I Type shear wave 2Segment RC-011 316 used, 60 NRIdegree RLalso used48%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 4aReactor Coolant/I1 Type shear wave 3Segment RC-012 316 used, 60 NRIdegree RLalso used Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 5 of 35b. The pipe welds discussed in this section were examined volumetrically by UTmethod for thermal fatigue concerns (item R1.11). Pipe weld description,examination and limitation descriptions are provided in Table 4b.Segment RC- 017The original requirements for Segment RC-017 of the RI ISI Program specifiedone mandatory examination, weld 2-08, and one sample weld, 2-03. Themandatory weld 2-08 exam was a single-sided, limited exam due to the pipingconfiguration, valve to a pipe elbow. Full required coverage was achieved onweld 2-03. An additional weld was selected to supplement the limited coverageon weld 2-08. Weld 2-05 on segment RC-017 was also examined to meet fullcoverage requirements and to provide additional data for the segment. Therewere no indications noted on any of the examination areas.Segment RC-018The original requirements for Segment RC-018 of the RI ISI Program specifiedone mandatory examination, weld 1-08, and one sample weld, 1-05. Themandatory weld 1-08 exam was a single-sided, limited exam due to pipingconfiguration, valve to a pipe elbow. Full required coverage was achieved onweld 1-05. An additional weld was selected to supplement the limited coverageon weld 1-08. Weld 1-03 was also examined, meeting full coveragerequirements. There were no indications noted on any of the examination areas.Segment ECC-005Weld 1-09 is a mandatory selection for the RI ISI Program. Weld 1-10 is asample selection. These are the only two welds on the segment. Weldexaminations were limited as shown in Figure 4b2. No alternative weld selectionexists. No indications were discovered on these welds.Segment ECC-007The two examinations of welds 1-09 and 1-10 on segment ECC-007 wereperformed in 2006 before the "good practice" of documenting best effort. Bothweld examinations were limited as shown in Figure 4b3. An indication was foundon weld 1-10. The indication was fully investigated and confirmed to be aconstruction related, geometric reflector and therefore not a flaw.Weld 1-09 is a mandatory weld selection. There were no indications on weld1-09. Weld 1-10 falls into the sampling risk informed region. These are the onlytwo welds on the segment. No alternative weld selection exists.

ASerial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 6 of 35Segment R0-042Two welds required examination on this segment. Weld 1-04 is a mandatoryselection. Weld 1-02 is a sample selection. Both examinations were limited asshown in Figure 4b4. Weld 1-01BC on this segment was added as asupplemental examination with limited coverage obtained. No indications werefound on any of these examinations.Segment RC-043Two welds required examination on this segment. Weld 1-03A is a mandatoryselection. Weld 1-02 is a sample selection. Both examinations were limited asshown in Figure 4b5. Weld 1-01BC on this segment was added as asupplemental examination with limited coverage obtained. No indications werefound on any of these examinations.The pipe lines discussed in Section 4b are currently analyzed and inspected by theguidelines of the Materials Reliability Program (MRP-146) for the management ofthermal fatigue on normally stagnant non-isolable reactor coolant system branchlines. This Program is part of the Surry Augmented Inspection Program under whichselect welds and pipe areas receive periodic examination as required by the MRPguidelines. The MRP-146 Program did not exist when the initial RI 1SI Program wasdeveloped for SPSI. Therefore, no credit was allocated for the MRP-146 Program.TABLE 4b Risk Informed Pipe Welds, Stainless Steel, MRP 146Drawing/ILine# / IDISystem I Class Pipe Pipe Weld Coverage Limitation I Results Fig. No. IRisk Informed Material Dia. Thickness Achieved Pg. No.SegmentI11448-WMKS-0122K1 Typ 1 0 igesdd av/ -C1 -8 Stainless 6" 0.797" to elbow 4blReactor Coolant / I Ste10 RSegment RC-017 Best Effort NRI11448-WMKS-0122J1 Type 316 50% Single-sided, valve/ 6-RC-21 / 1-080.6"telo4bReacor Colan /1 Stainless 6" 056"telo4bRatrCoat/1 Steel (Nominal) 15.56% 2Segment RC-018 Best Effort NRII11448-WMKS-0122H1 Tye3650% Single-sided, pipe/ 6-RC-16 / 1-09 Type6316to valve 4b2Reacor Colan /1 Stainless 6" 052RatrCoat/1 Steel (Nominal) 3.5%1Segment ECC-005 Best Effort NRI Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 7 of 35Drawing I Line# / IDISystem I Class Pipe Pipe Weld Coverage Limitation I Results Fg oRisk 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 4b2Reactor Coolant / 1 ins 3.5% 2SteelBetEfrSegment ECC-005 BsEfotNRI50%I11448-WMKS-0122J1 Type 316 Examination Single-sided, pipe to/ 6-RC-21 / 1-09 0.6" promdvalve 4b3Reacor Colan I i Stainless 6" 052 efreRatrCoat/1 Steel (Nominal) prior to1Segment ECC-007 practice of NRIrecordingBest Effort50%Single-sided, pipe to11 448-WMKS-0 122J 1 Tye36Examination valve6ReatrCoolan / 1- Stainless 6" 0.562" performed4bRatrCoat/1 Steel (Nominal) prior to Geometric indication 2Segment ECC-007 practice of occurred duringrecording original constructionBest Effort1 1448-WM KS-0127J2 50% Single-sided, elbow/ 6-RC-19 / 1-02 Type 316 6" 0.522" (1) to weldolet 4b4Reactor Coolant /I Stainless 1% 1Segment RC-042 Steel Best Effort NRI1 1448-WMKS-0127J2 Type 316 50% Single-sided, valve/ 6-RC-19 / 1-04 to elbow 4b4Reactor Coolant / 1 Stainless 6" 0.735" (1) 3%2Segment RC-042 Steel Best Effort NRI1 148-WMS-017J26" pipe to 27.5" cold/6R-9 -IC Type 316 5%leg branch 4b4ReactorCoolan / 1-0B Stainless 6" 1.85" connection3SegmerColnt /C 1 Steel (Nominal) 23.7%3Semn C02Best EffortNR1 148-WMS-027J350% 6" pipe to 27.5" coldType-WKS03163 0%leg branch/ 6-RC-20 / 1-01BC Tye3618"cncto4bRatrCoat/1 Stainless 6" 18"cneto bReacorColnt /C-0I Steel (Nominal) 23.7% 1Segmnt R-043Best EffortNRI Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 8 of 35Drawing I Line# I ID/System / Class Pipe Pipe Weld Coverage Limitation!/ Results Fig. No. /Risk Informed Material Dia. Thickness Achieved Pg. No.Segment1 1448-WMKS-0127J3 Tye3650% Single-sided, pipe to/ 6-RC-20 / 1-02 Tye36branch connection 4b5Reactor Coolant /I Stainless 6" 0.528" (1) 1.5% weld 2Segment RC-043 SelBest EffortNR11448-WMKS-0127J3 Type 316 50% Single-sided, valve/ 6-RC-20 / 1-03A Stils " 0.562" to elbow 4b5Reactor Coolant/i1 Steel (Nominal) 4.83% 3Segment RC-043 Best Effort NRI(1) Actual measured thickness obtained from NDE records not provided in this relief request; this valuediffers from the nominal value shown in the referenced figure.c. The pipe welds addressed in this section were ultrasonically examined forthermal fatigue (ASME Item R1.11) or intergranular stress corrosion cracking(ASME Item R1.16). Details are provided in Table 4c and in the referencedfigures.Segment EGG-006Only two welds exist on this segment. Weld 2-09 falls within the mandatoryexamination region for the RI ISI Program, and weld 2-10 is categorized as asample selection. The welds were examined ultrasonically for thermal fatigue(ASME Item R1.11). Both welds were examined to the fullest extent possible asdetailed in Table 4c and Figure 4c1. No indications were discovered duringeither examination.Segments RS-004A, 003AOnly one weld exists on each of these segments: piping from the containmentsump (wall) to the Outside Recirculation Spray (ORS) Pump suction motoroperated valves. Weld 1-06 on segment RS-004A and weld 1-03 on segmentRS-003A were examined ultrasonically for intergranular stress corrosion cracking(ASME Item R1.16). Both welds of this configuration for each of the ORS Pumpswere examined to the fullest extent possible. No indications were discovered oneither weld.Segment HHI-011Weld 5-AF is the only weld on this segment of piping from the High Head SafetyInjection containment penetration to the first check valve inside containment.

DSerial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 9 of 35The weld was ultrasonically inspected for thermal fatigue to the greatest extentpossible. There were no indications.Segments LHI-004A, 003AOnly one weld exists on each of these segments, piping from the containmentsump (wall) to the Low Head Safety Injection (LHSI) Pump suction motoroperated valves. Weld 1-13 on segment LHI-004A and weld 1-15 on segmentLHI-003A were examined ultrasonically for intergranular stress corrosioncracking (ASME Item R1.16). Both welds of this configuration for each of theLHSI Pumps were examined to the fullest extent possible. No indications werediscovered on either weld.Segment RH-013Two welds on this segment required ultrasonic examination for intergranularstress corrosion cracking, welds 3-02 and 3-03. The examinations on both ofthese welds were limited. The branch connection weld 3-01 BC on this segmentwas added to supplement the data from the two limited examinations.Weld 3-01 BC was examined with the liquid penetrant method obtaining fullcoverage. No meaningful UT coverage could be obtained on branch connectionweld 3-01BC. No additional selections exist on this segment. No indicationswere discovered during any of the examinations.TABLE 4c Risk Informed Pipe Welds, Stainless SteelDrawing / Line# I ID /System I Class Pipe Pipe Weld Coverage Limitation / Results Fg oRisk Informed Material Dia. Thickness Achieved Fig. No.ISegmentI11448-WMKS-0122K1 Type 316 50% Single-sided, pipe toI 6-SI-48 / 2-09 Stainless 6" 0.562" valve 4clSafety Injection/I1 Steel (Nominal) 1% 1Segment ECC-006 Best Effort NRII11448-WMKS-0122K1 Type 316 50% Single- sided, valve/6-SI-48 /2-10 Stainless 6" 0.610" (1) 1% topp2cSafety Injection/I1 SteelBetEfr2Segment ECC-006 BsEfotNRII11448-WMKS-1101A5 Type 304 46.3% Single- sided, pipe/12-RS-7/1-06 Stainless 12" 0.510" 11.9% tovlv 1Recirculation Spray I 2 Steel Best Effort NRISegment RS-004A Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 10 of 35Drawing I Line# / ID /System I Class Pipe Pipe Weld Coverage LitaonIRslsFgNoIRsInomd Material Dia. Thickness Achieved LiiainPRslsFg. No.ISegment50%11448-WMKS-1101A5 Examination Single-sided, valve/ 12-RS-8 / 1-03 Type 304 performed to elbow 4c2Recirculation Spray / 2 Stils 2 .1"prior to 2SgetR-0A Steel practice of NRISegmnt R003ArecordingBest Effort50%1 1448-WMKS-1 106A4 Examination Single-sided, pipe toI 3-SI-70 / 5-AF Type 304 performed valve 4c3SftIneto/2 Stainless 3" 0.520" prior to 1Steel HI-11practice of NRISegmet HHI01 1recordingBest Effort50%1 1448-WMKS-1 106A7 Tye34Examination Single-sided, elbow/ 12-SI-I / 1-13 Tye34performed to valve 4c4SaeyIjcin/2 Stainless 12" 0.490" prior to 1Segment LHI-004A Selpractice of NRIrecordingBest Effort50%11448-WMKS-1106A7 Tye34Examination Single-sided, pipe to/ 12-SI-2 / 1-15 Tye34performed valve 4c4Stainless 12" 0.487" prior to2Safety Injection / 2 Steel2Segment LHI-003A practice of NRIrecordingBest Effort1 1448-WMKS-0122A1 5% Snl-iebac/ 3-RH-13 / 3-02 Type 304 5%Snl-iebacResidual Heat Stainless 3" 0.375" connection to pipe 4c5Removal / 2 Steel (Nominal) 9% 1Segment RH-013 Best Effort NRI1 1448-WMKS-0122A1I 3-RH-13 / 3-03 Type 304 50% Single-sided, pipe toResidual Heat Stainless 3" 0.420" flange 4c5Removal / 2 Steel (Nominal) 10% 2Segment RH-013 Best Effort NRI(1) Actual measured thickness obtained from NDE records not provideddiffers from the nominal value shown in the referenced figure.in this relief request; this value Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 11 of 355. Burden Caused by ComplianceCompliance with the Code requirements would require extensive modification orreplacement of components with a design that would allow full examination fromboth sides of the weld. This option to rebuild components is considered impracticaland would cause unnecessary radiation exposure. Furthermore, plant equipmentcould be impacted in a detrimental manner.6. proposed Alternative and Basis for UseThe subject welds received a volumetric examination to the maximum extentpractical utilizing the best available techniques. With the incorporation of the PDI forSupplement 2, demonstration for best effort coverage was made for single-sidedexamination from the accessible side of the weld. Additionally, these componentsare monitored for through wall leakage as part of the ASME Xl System PressureTest Program and receive visual (VT-2) examination as required by Section Xl,Table IWB-2500-1, Category B-P for Class 1 components andIWC-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. Thereare no known failures of the welds discussed in this section at SPS1. Anyindications 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, thevisual (VT-2) examinations performed routinely and the fact that additional weldswere examined to supplement the requirements, it is reasonable to conclude thatservice induced degradation would have been detected. Therefore, these proposedalternatives provide an acceptable level of quality and safety by providingreasonable assurance of structural integrity of the subject welds. Dominion requestsrelief in accordance with 10 CFR 50.55a(g)(5)(iii).7. Duration of Proposed AlternativeThis proposed alternative is requested to meet requirements for the fourth ten-yearinservice inspection interval for SPS1, which began October 14, 2003 and ended onOctober 13, 2014.

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 12 of 35Figure 4a(Page 1 of 3)/ Dominion'Drawing Number 1 1448-WMKS-0100AZ-1STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONMark Number 1-12ANGLE SCAN AREA SCAN SIDE SCAN %450 EXAMINATION VOLUME USRA(1 ST LEG) _ _ _ _ _ _ _450 EXAMINATION VOLUME (2nd LEG) _______450 EXAMINATION VOLUMEW(STRLEG)AM _____450 EXAMINATION VOLUME DWSRA____________ ~~~(2n LEG) _________450 EXAMINATION VOLUME (2w 50G450 EXAMINATION VOLUME CCW 50600 EXAMINATION VOLUME UPSTREAUPSTREAM600 EXAMINATION VOLUME (ind LEG) 0DOPSTREAM600 EXAMINATION VOLUME (2ST LEG) 92600 EXAMINATION VOLUME DOWNTRLEAM9UPWSTREAM700 EXAMINATION VOLUME (1ST LEG) _______DOWSTREAM700 EXAMINATION VOLUME (S E) ______UPSTREAM COVERAGE 0DOWNSTREAM COVERAGE 92CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50TO TAL PER CENT 48 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 13 of 35S~Dominion"Figure 4a(Page 2 of 3)STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONDrawing Number 1 1448-WMKS-0101AZ-1Mark Number 1-12ANGLE SCAN AREA SCAN SIDE SCAN %450 XAMIATIN VOUMEUPSTREAM450o EXAMINATION VOLUME (1 nt LEG)450 EXAMINATION VOLUME (2st LEG)450 EXAMINATION VOLUME DOWSTRLEAM450 EXAMINATION VOLUME (2W' 50G450 EXAMINATION VOLUME CCW 50UPSTREAM600 EXAMINATION VOLUME (1s* LEG) 0UPSTREAM600 EXAMINATION VOLUME (2nd LEG) 0DOWNSTREAM600 EXAMINATION VOLUME (1 st LEG) 92DOWNSTREAM600 EXAMINATION VOLUME (2fld LEG)UPSTREAM700 EXAMINATION VOLUME (1 st LEG)7Q0 DOWNSTREAM7°EXAMINATION VOLUME (1 st LEG)UPSTREAM COVERAGE 0DOWNSTREAM COVERAGE 92CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50TO TAL PER CENT 48 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 14 of 35Figure 4a(Page 3 of 3)SDominion"STAINLESS STEEL PIPE, SINGLE SIDEDPERCENT VOLUME BY SCAN DIRECTIONMark Number 1-12Drawing Number 11 448-WMKS-010O2AZ-1ANGLE SCAN AREA SCAN SIDE SCAN %450 XAMIATIN VOUMEUPSTREAM45° XAMIATIN VOUME(1st LEG)UPSTREAM450 EXAMINATION VOLUME (2fld LEG)DOWNSTREAM450 EXAMINATION VOLUME (1st LEG)450 XAMIATIN VOUMEDOWNSTREAM45_____ EXMNTO OUE(2fld LEG)450 EXAMINATION VOLUME CW 50450 EXAMINATION VOLUME CCW 50600o EXAMINATION VOLUME UPSTRLEAMUPSTREAM600 EXAMINATION VOLUME (2fld LEG) 0DOWNSTREAM600 EXAMINATION VOLUME (1 st LEG) 92600 EXAMINATION VOLUME (2DOWSTEAMUPSTREAM700 EXAMINATION VOLUME (1 st LEG) _______7Q0 EXAMINATION VOLUME (1st LEG) _______UPSTREAM COVERAGE 0DOWNSTREAM COVERAGE 92CLOCKWISE COVERAGE 50COUNTERCLOCKWISE COVERAGE 50TOTAL PERCENT 48 %

Serial No. 15-446Docket No. 50-280Relief Request LMT-R01Attachment 1, Page 15 of 35Figure 4bl(Page 1 of 2)Weld Number2-082I l ,I I,Weld WidthWeld Length1i .... I..0.75"21 .625"2I.,. I ........I I I r I I J. " ...................FLOWCL2-00-VALVE45ELBOW0.188" HT X.875"' WIDTH =0.165 SQ. IN REQUIRED VOLUME UPSTAND DNST SIDEEXAMINED 100% DNST AX AND C1RC DIRECTIONEXAMINED 0.07 SQ IN, UPST AX DIRECTION0,071.165 = 0.42 X 100 = 42% BEST EFFORT UPST AX DIRECTIONNO EXAM CIRO DIRECTION UPST SIDEExamination Volume Dimensions:- Heloht: 0.188" Length: 21.625" Width 1.75"Coverage SummaryRequired Scans (each has a weighing factor of 100 for complete coverage)ANGLE UpSt-Ax UpSt-Circ DnSt-Ax DnSt-Circ45 _________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 thatis effectively examined with the qualified examination procedure.2. Best Effort Coverage refers to the required examination volume past the weld centerline thatis examined in the axial beam direction with an Appendix VIII demonstrated procedure forsingle sided coverage.