SBK-L-11132, Submittal of Third Ten-Year Interval Inservice Inspection and Second Ten-Year Containment Inservice Inspection Program

Submittal of Third Ten-Year Interval Inservice Inspection and Second Ten-Year Containment Inservice Inspection Program

ML11180A079
Person / Time
Site:	Seabrook
Issue date:	06/22/2011
From:	Freeman P NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-11132
Download: ML11180A079 (105)

Text

NEXTeraM EN ERGY0-mQ, June 22, 2011 10 CFR 50.55a(g)(4)(ii)

Docket No. 50-443 SBK-L-1 1132 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Seabrook Station Third Ten-Year Interval Inservice Inspection and Second Ten-Year Containment Inservice Inspection Program As required by paragraph IWA-1400(c) of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, NextEra Energy Seabrook, LLC (NextEra) hereby submits the Third Ten-Year Interval Inservice Inspection and Second Ten-Year Containment Inservice Inspection Program. This interval commenced on August 19, 2010 and concludes on August 18, 2020.

NextEra is providing this program in the attachment to this letter for information only. NRC approval is not being requested.

Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.

Sincerely, NextEra Energy Seabrook, LLC Paul 0. Freeman Site Vice President NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-11132 / Page 2

Attachment:

NextEra Energy Seabrook Third Ten-Year Interval Inservice Inspection and Second Ten-Year Containment Inservice Inspection Program cc: NRC Region I Administrator G. E. Miller, NRC Project Manager W. J. Raymond, NRC Senior Resident Inspector Mr. Christopher M. Pope, Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

ATTACHMENT TO SBK-L-11132 RMD Controlled Copy F SEABROOK STATION REFERENCE MANUAL Inservice Inspection Reference Approvals ISI Program Owner .. .. Date: s Engineering Manager - Programs Date: 3*

Engineering Director Date: 3/~ s/u SIIR Manual Owner:

Rev. 13 K. A. Whitney

INSERVICE INSPECTION REFERENCE (SIIR)

TABLE OF CONTENTS CONTENT PAGE CHAPTER 1: INTRODUCTION

1.0 INTRODUCTION

1-1.1 1.1 General 1-1.1 1.2 Responsibilities 1-1.2 1.3 Applicable Editions and Addenda to ASME Section XI 1-1.2 1.4 Historical ISI and CISI Program Information 1-1.2 1.5 Program Scope and Exclusions 1-1.3 1.6 Component Classifications and Boundaries 1-1.3 1.7 Technical Specification Commitments 1-1.4 1.8 Updated Final Safety Analysis Report (UFSAR) Commitments 1-1.4 1.9 Quality Assurance Program Commitments 1-1.4 1.10 ASME Section XI Code Case Commitments 1-1.4 1.11 ASME Section XI Interpretations 1-1.8 1.12 Relief Requests and Alternative Requests 1-1.8 1.12.1 Alternative Requests for Non Approved Code Cases 1-1.8 1.12.2 Relief Requests for Hardship or Unusual Difficulty 1-1.8 1.12.3 Relief Requests for Impractical Requirements 1-1.8 1.12.4 Format 1-1.9 1.13 Inspection Interval, Periods, and Outages 1-1.10 1.13.1 Inspection Program B 1-1.10 1.14 Program References 1-1.11 1.15 Examination Procedures 1-1.11 Page I SIIR Rev. 13

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TABLE OF CONTENTS CONTENT PAGE 1.16 Personnel Qualification and Certification 1-1.11 1.17 Authorized Nuclear Inservice Inspector 1-1.11 1.18 Records and Reports 1-1.12 1.1 8.1 General 1-1.12 1.18.2 Owner's Reports for Inservice Inspection and Repair/Replacement Activities 1-1.12 1.18.3 Records Retention 1-1.12 1.19 Code of Federal Regulations - Limitations, Modifications and Augmented Examination Requirements 1-1.12 2.0

SUMMARY

OF CHANGES 1-2.1 CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.0 ASME CLASS I EXEMPTIONS AND REQUIREMENTS 2-1.1 1.1 Class 1 Component Exemptions 2-1.1 1.2 Examination Category B-A Requirements 2-1.2 1.3 Examination Category B-B Requirements 2-1.2 1.4 Examination Category B-D, Inspection Program B Requirements 2-1.3 1.5 Examination Category B-F Requirements 2-1.3 1.6 Examination Category B-G-1 Requirements 2-1.4 1.7 Examination Category B-G-2 Requirements 2-1.4 1.8 Examination Category B-J Requirements 2-1.5 1.9 Examination Category B-K Requirements 2-1.5 1.10 Examination Category B-L-2 Requirements 2-1.6 1.11 Examination Category B-M-2 Requirements 2-1.6 1.12 Examination Category B-N-i Requirements 2-1.6 1.13 Examination Category B-N-2 Requirements 2-1.6 1.14 Examination Category B-N-3 Requirements 2-1.7 Page 2 SIIR Rev. 13

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TABLE OF CONTENTS CONTENT PAGE 1.15 Examination Category B-O Requirements 2-1.7 1.16 Examination Category B-P Requirements 2-1.7 2.0 ASME CLASS 2 EXEMPTIONS AND REQUIREMENTS 2-2.1 2.1 Class 2 Component Exemptions 2-2.1 2.2 Examination Category C-A Requirements 2-2.3 2.3 Examination Category C-B Requirements 2-2.3 2.4 Examination Category C-C Requirements 2-2.4 2.5 Examination Category C-F-I Requirements 2-2.4 2.6 Examination Category C-F-2 Requirements 2-2.5 2.7 Examination Category C-H Requirements 2-2.5 3.0 ASME CLASS 3 EXEMPTIONS AND REQUIREMENTS 2-3.1 3.1 Class 3 Component Exemptions 2-3.1 3.2 Examination Category D-A Requirements 2-3.1 3.3 Examination Category D-B Requirements 2-3.1 4.0 ASME CLASS 1, 2 and 3 COMPONENT SUPPORT EXEMPTIONS AND REQUIREMENTS 2-4.1 4.1 ASME CLASS 1., 2, 3 and MC Component Support Exemptions 2-4.1 4.2 ASME CLASS 1, 2 and 3 Component Support Selections 2-4.1 4.3 Examination Category F-A Requirements 2-4.1 5.0 ASME CLASS 1, 2 and 3 ACCEPTANCE STANDARDS 2-5.1 5.1 ASME Class 1 Acceptance Standards 2-5.1 5.2 ASME Class 2 Acceptance Standards 2-5.2 5.3 ASME Class 3 Acceptance Standards 2-5.2 5.4 ASME Class 1, 2, 3 and MC Component Support Acceptance Standards 2-5.2 Page 3 SIIR Rev. 13

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TABLE OF CONTENTS CONTENT PAGE 6.0 IMPLEMENTATION OF ASME SECTION XI, APPENDIX VIII 2-6.1 6.1 Program Basis 2-6.1 6.2 Effective Code 2-6.1 6.3 Implementation Schedule 2-6.1 6.4 Performance Demonstration Program 2-6.2 6.5 Performance Demonstration Program Administrator 2-6.2 6.6 Single Sided Access for Austenitic Welds 2-6.4 6.7 Responsibilities 2-6.4 7.0 AUGMENTED EXAMINATIONS 2-7.1 7.1 Reactor Coolant Pump Flywheels 2-7.1 7.2 Reactor Coolant System Piping 2-7.1 7.3 Reactor Vessel Head 2-7.2 7.4 Alloy 600 Mitigation 2-7.2 8.0 TABLES 2-8.1 Table 2.1 Class 1, 2, 3 Component and Component Support ISI Examination Summary 2-8.2 Table 2.2 Seabrook Augmented Examination Summary 2-8.10 Table 2.3 Seabrook System Pressure Testing Summary 2-8.11 Table 2.4 ASME Class 1, 2, and 3 System Classifications 2-8.12 Table 2.5 Weld and Component Isometric Drawings 2-8.15 Table 2.6 Vessel, Pump, and Valve Groupings 2-8.18 Table 2.7 Ultrasonic Calibration Block Standards 2-8.20 9.0

SUMMARY

OF CHANGES 2-9.1 Page 4 SIIR Rev. 13

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TABLE OF CONTENTS CONTENT PAGE CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN 1.0 ASME SUBSECTION IWE EXEMPTIONS AND REQUIREMENTS 3-1.1 1.1 Subsection IWE Component Exemptions 3-1.1 1.2 Examination Category E-A Requirements 3-1.1 1.3 Examination Category E-C Requirements 3-1.2 2.0 ASME SUBSECTION IWL EXEMPTIONS AND REQUIREMENTS 3-2.1 2.1 Subsection IWL Component Exemptions 3-2.1 2.2 Examination Category L-A Requirements 3-2.1 3.0 ASME CLASS MC AND CLASS CC COMPONENT ACCEPTANCE STANDARDS 3-3.1 3.1 ASME Class MC Acceptance Standards 3-3.1 3.2 ASME Class CC Acceptance Standards 3-3.1 4.0 TABLES 3-4.1 Table 4.1 Seabrook Subsection IWE and Subsection IWL Component Examination Summary 3-4.3 Table 4.2 Seabrook Class MC, Subsection IWE Inspection Areas 3-4.5 Table 4.3 Seabrook Class CC, Subsection IWL Inspection Areas 3-4.9 5.0

SUMMARY

OF CHANGES 3-5.1 APPENDICES Appendix A Relief and Alternative Requests A-i Page 5 SIIR Rev. 13

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LIST OF EFFECTIVE PAGES PAGE REV. PAGE REV.

Cover 13 TOC 1 -5 13 LOEP 13 1-1.1 thru 1-1.15 13 1-2.1 13 2-1.1 thru 2-1.7 13 2-2.1 thru 2-2.5 13 2-3.1 13 2-4.1 13 2-5.1 and 2-5.2 13 2-6.1 thru 2-6.4 13 2-7.1 and 2-7.2 13 2-8.1 thru 2-8.20 13 2-9.1 13 3-1.1 and 3-1.2 13 3-2.1 13 3-3.1 13 3-4.1 thru 3-4.10 13 3-5.1 13 A-I thru A-21 13 Page I SIIR Rev. 13

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CHAPTER 1: INTRODUCTION

1.0 INTRODUCTION

1.1 General This document establishes the Inservice Inspection Program Plan for the third ten-year Inservice Inspection (ISI) interval and the second ten-year Containment Inservice Inspection (CISI) interval for component surfaces, welds, supports, bolting, pump casings, valve bodies, and reactor vessel internals at Seabrook Station, Unit 1.

The Class 1, 2, 3, CC and MC systems, components, component supports, parts and items subject to examination have been identified as set forth in the 2004 Edition of Section XI of the ASME Boiler and Pressure Vessel Code, within the limitations and modifications specified by the Code of Federal Regulations (CFR) in 10 CFR 50.55a(b)(2). Tables 2.1 and 2.4 of Chapter 2 and Table 4.1 of Chapter 3 summarize the systems, components, component supports, parts and items subject to and selected for examination as required by ASME Section XI. NextEra Energy Seabrook (Seabrook) implementation of the limitations and modifications in 10 CFR 50.55a(b)(2) is addressed in Section 1.19.

During the second ten-year interval, an alternative to ASME Section XI requirements for ISI of ASME Class 1 piping, Categories B-F and B-J was implemented. This Risk-Informed Inservice Inspection (RI-ISI) Program was developed in accordance with EPRI Topical Report 112657 Rev. B-A. The RI-ISI application was also consistent with ASME Code Case N-578. NRC approval was granted on February 7, 2002.

The third interval ISI Program does not currently address examination requirements that will result from the implementation of risk-informed technology for the third inspection interval.

Seabrook is presently developing a RI-ISI program for examination of ASME Class 1 and Class 2 components. The third interval program will be submitted to the NRC, as a relief request, for approval prior to implementation.

This document also includes inservice augmented examinations required by Seabrook regulatory commitments, 10 CFR 50.55a(g)(6)(ii), industry initiatives and plant original equipment manufacturer (OEM) (e.g. Westinghouse) technical publications. The augmented inservice examinations applicable to Seabrook Station Unit I are identified in Section 7.0 of Chapter 2 and summarized in Table 2.3 of Chapter 2.

Where an examination or test required by ASME Section XI has been determined to be impractical or an alternative has been proposed, the basis for this determination has been documented and submitted to the NRC for approval as a request for relief (or a request for alternative) as permitted per 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), 10 CFR 50.55a(g)(5)(iii),

10 CFR 50.55a(g)(5)(iv) and 10 CFR 50.55a(g)(6)(i). Relief Requests and Alternative Requests are summarized in a table in section 1.12.4 and the full text of these documents is included in Appendix A.

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CHAPTER 1: INTRODUCTION 1.2 Responsibilities Seabrook, as Owner, has overall responsibility for the conduct of the Inservice Inspection Program to assure compliance with ASME Section XI, including IWA-1400, entitled "Owner's Responsibilities". Engineering has the responsibility for the Inservice Inspection Program, including preparation, revisions, implementation, scheduling, examinations, repairs, and replacements. Engineering also has the responsibility for the preparation, issuance, and revision of the NonDestructive Examination (NDE) procedures and is further responsible for personnel qualification and certifications for this program.

1.3 Applicable Editions and Addenda to ASME Section XI 1.3.1 The Code of Federal Regulations in 10 CFR 50.55a(g)(4)(ii) requires the ISI Program for the Third 10-Year ISI Interval and the Second 10-Year CISI Interval to comply with the ASME Section XI Edition and Addenda, Division 1, approved for use in 10 CFR 50.55a(b)(2) 12 months prior to the start of the interval. The ISI and CISI Intervals began at midnight on August 19, 2010. The ASME Section XI Edition and Addenda that was approved for use 12 months prior to August 19, 2010 was the 2004 Edition.

Accordingly, this version of ASME Section XI forms the basis for the Third 10-Year ISI Interval and the Second 10-Year CISI Interval.

13.2 As required by 10 CFR 50.55a(b)(2)(xxiv), Seabrook will not implement Appendix VIII, the supplements to Appendix VIII and Appendix I, Article 1-3000 of the 2004 Edition of Section XI. The use of these requirements is prohibited by 10 CFR 50.55a(b)(2)(xxiv). Seabrook shall implement requirements specified in the 2001 Edition of ASME Section XI. Seabrook implementation of ASME Section XI, Appendix VIII is included in Chapter 2, Section 6.0.

1o3.3 As permitted by paragraph 10 CFR 50.55a(g)(4)(iv), Seabrook may elect to meet the requirements set forth in editions and addenda of ASME Section XI which become effective subsequent to the 2004 Edition of ASME Section XI. NRC approval is required prior to implementing these later editions or addenda (Reference NRC Regulatory Issue Summary RIS-2004-12). Editions and Addenda of ASME Section XI or ASME Code Cases that are adopted will be identified in the appropriate sections of this inspection program. It is the intent of Seabrook to apply appropriate revisions of ASME Section XI, with NRC approval, which improve the overall quality of Seabrook's inspection program. Those changes that are applied will be identified in this Section of the SIIR.

1.4 Historical ISI and CISI Program Information 1.4.1 ASME Section XI Preservice examinations and tests were performed in accordance with the 1977 Edition with the Summer 1978 Addenda, except for the preservice examinations of ASME Class 2 piping welds, which were performed in accordance with the 1974 Edition with the Summer 1975 Addenda.

1.4.2 The first 10-Year ISI Interval began on August 19, 1990 and ended on August 18, 2000. The applicable ASME Section XI Code of Record was the 1983 Edition with the Summer 1983 Addenda.

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CHAPTER 1: INTRODUCTION 1.4.3 The first 10-Year CISI Interval began on August 19, 2000 and ended on August 18, 2010. The applicable ASME Section XI Code of Record was the 1995 Edition with the 1996 Addenda. As required by 10 CFR 50.55a(g)(6)(ii)(B)(1), Seabrook implemented the first period Subsection IWE examinations by September 9, 2001, and these examinations served as the Preservice examinations. As required by 10 CFR 50.55a(g)(6)(ii)(B)(2), Seabrook implemented the required Subsection IWL examinations (based on the number of years of commercial operation) by September 9, 2001, and these examinations served as the Preservice examinations.

1.4.4 The second 10-Year ISI Interval began on August 19, 2000 and ended on August 18, 2010. The applicable ASME Section XI Code of Record was the 1995 Edition with the 1996 Addenda.

1.5 Program Scope and Exclusions The scope of this ISI Program includes Class 1 components and component supports, Class 2 components and component supports, Class 3 components and component supports, including all associated areas and surfaces as required by ASME Section XI, and the augmented inservice inspection requirements specified in Chapter 2, Section 7.0. In addition, this ISI Program includes Class MC components and component supports and Class CC components.

The following Seabrook Programs are specifically excluded from the scope of this program:

• Snubber Program 0 Containment Pressure Test Program

• Pump and Valve Test Program 0 Repair and Replacement Program 1.6 Component Classifications and Boundaries ASME Class I systems and components have been classified for inservice inspection using the guidance specified in 10 CFR 50.2, Definitions. Classification of Class 2 and 3 systems and components are specified in Regulatory Guide 1.26, Rev. 3 (Quality Group B and C). Specific code classifications and associated boundaries are depicted on the plant Piping and Instrument Drawings (P&IDs) listed in Table 2.5 of Chapter 2. Typically, systems and components on the P&IDs, which are designated as Safety Class 1, 2, and 3 also correspond to ASME Class 1, 2, and 3, respectively.

The classification of Seabrook primary containment components as Class MC or Class CC for the application of ASME Section XI requirements is based on "Containment Boundary Bases Document", document FP59252, Revision 1. Although the primary containment was originally constructed to several Construction Codes, all of the pressure-retaining portions of the containment are to be considered either Class MC or Class CC and hence are subject to inspection in accordance with ASME Section XI, Subsection IWE or Subsection IWL, respectively. (Reference SECY-96-080, Attachment 6, Part II, NRC response to Public Comment 2.1) 1-1.3 SIIR Rev. 13

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CHAPTER 1: INTRODUCTION 1.7 Technical Specification Commitments The Technical Specification commitments for the scope of this program are addressed in the following sections:

Section Subject 3.4.10 Structural Integrity of ASME Code Class 1, 2, and 3 Components 4.0.5 Surveillance Requirements for Inservice Inspection 4.4.10 Reactor Coolant Pump Flywheel Inspection 6.7 Procedures and Programs 1.8 Updated Final Safety Analysis Report (UFSAR) Commitments The UFSAR commitments for the scope of this program are addressed in the following sections:

Section Subjec 1.8 Conformance to NRC Regulatory Guides 5.2.4 Inservice Inspection of the Reactor Coolant Pressure Boundary 6.6 Inservice Inspection of Class 2 and 3 Components 6.6.8 Augmented Inservice Inspection Requirements 1.9 Quality Assurance Program Commitments The operational Quality Assurance Program is defined in the FPL Quality Assurance Topical Report (QATR).

1.10 ASME Section XI Code Case Commitments ASME Section XI Code Cases clarify the intent of the code or provide alternatives to Section XI code requirements. The NRC approves usage of Code Cases and documents provisions to specific Code Case requirements in Regulatory Guide 1.147. The application of Code Cases are further governed by ASME Section XI Paragraph IWA-2440. Code Cases not authorized for use in accordance with Regulatory Guide 1.147, are not implemented unless specifically approved by the NRC in the form of a Relief Request or written correspondence. The following ASME Section XI Code Cases have been incorporated into this manual.

Code Case No. Title N-460 Alternative Examination Coverage for Class I and Class 2 Welds 1-1.4 SIIR Rev. 13

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CHAPTER 1: INTRODUCTION N-504-4 Alternative Rules for Repair of Class 1, 2 and 3 Austenitic Stainless Steel Piping Note: The provisions of Section XI, Nonmandatory Appendix Q, "Weld Overlay Repair of Class 1, 2, and 3 Austenitic Stainless Steel Piping Weldments," must also be met. In addition, the following conditions shall be met: (a) the total laminar flaw area shall not exceed 10% of the weld surface area, and no linear dimension of the laminar flaw area shall exceed the greater of 3 inches or 10% of the pipe circumference; (b) the finished overlay surface shall be 250 micro-in (6.3 micrometers) root mean square or smoother; (c) the surface flatness shall be adequate for ultrasonic examination; and (d) radiography shall not be used to detect planar flaws under or masked by laminar flaws.

N-513-3 Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Note: The repair or replacement activity temporarily deferred under the provisions of this Code Case shall be performed during the next scheduled outage.

N-517-1 Quality Assurance Program Requirements for Owners N-526 Alternate Requirements for Successive Inspections of Class 1 and 2 Vessels N-528-1 Purchase, Exchange, or Transfer of Material Between Nuclear Plant Sites Note: The requirements of 10 CFR Part 21 are to be applied to the nuclear plant site supplying the material as well as to the nuclear plant site receiving the material that has been purchased, exchanged, or transferred between sites.

N-532-4 Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000 N-552 Alternative Methods - Qualification of Nozzle Inside Radius Section from the Outside Surface Note: To achieve consistency with the 10 CFR 50.55a rule change published September 22, 1999 (64 FR 51370), incorporating Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," to Section XI, add the following to the specimen requirements:

"At least 50 percent of the flaws in the demonstration test set must be cracks and the maximum misorientation must be demonstrated with cracks. Flaws in nozzles with bore diameters equal to or less than 4 inches may be notches."

Add to detection criteria, "The number of false calls must not exceed three."

N-566-2 Corrective Action for Leakage Identified at Bolted Connections N-586-1 Alternative Additional Examination Requirements for Class 1, 2, and 3 Piping, Components, and Supports 1-1.5 SIIR Rev. 13

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CHAPTER 1: INTRODUCTION N-593 Alternative Examination Requirements for Steam Generator Nozzle to Vessel Welds Note: Essentially 100 percent (not less than 90 percent) of the examination volume A-B-C-D-E-F-G-H must be inspected.

N-600 Transfer of Welder, Welding Operator, Brazer, and Brazing Operator Qualifications Between Owners N-613-1 Ultrasonic Examination of Penetration Nozzles in Vessels, Examination Category B-D, Item Nos. B3.10 and B3.90, Reactor Nozzle-to-Vessel Welds, Figs. IWB-2500-7(a), (b), and (c)

N-624 Successive Inspections N-638-4 Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique Note: (1) Demonstration for ultrasonic examination of the repaired volume is required using representative samples which contain construction type flaws.

(2) The provisions of 3(e)(2) or 3(e)(3) may only be used when it is impractical to use the interpass temperature measurement methods described in 3(e)(1), such as in situations where the weldment area is inaccessible (e.g., internal bore welding) or when there are extenuating radiological conditions.

N-639 Alternative Calibration Block Material Note: Chemical ranges of the calibration block may vary from the materials specification if(1) it is within the chemical range of the component specification to be inspected, and (2) the phase and grain shape are maintained in the same ranges produced by the thermal process required by the specification.

N-641 Alternative Pressure-Temperature Relationship and Low Temperature Overpressure Protection System Requirements N-648-1 Alternative Requirements for Inner Radius Examination of Class 1 Reactor Vessel Nozzles Note: In place of a UT examination, licensees may perform a visual examination with enhanced magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria of Table IWB-3512-1 with limiting assumptions on the flaw aspect ratio. The provisions of Table IWB-2500-1, Examination Category B-D, continue to apply except that, in place of examination volumes, the surfaces to be examined are the external surfaces shown in the figures applicable to this table, (the external surface is from point M to point N in the figure).

N-649 Alternative Requirements for IWE-5240 Visual Examination N-651 Ferritic and Dissimilar Metal Welding Using SMAW Temper Bead Technique Without Removing the Weld Bead Crown for the First Layer 1-1.6 SIIR Rev. 13

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CHAPTER 1: INTRODUCTION N-661-1 Alternative Requirements for Wall Thickness Restoration of Classes 2 and 3 Carbon Steel Piping for Raw Water Service Note: (1) If the cause of the degradation has not been determined, the repair is only acceptable until the next refueling outage.

(2) When through-wall repairs are made by welding on surfaces that are wet or exposed to water, the weld overlay repair is only acceptable until the next refueling outage.

N-663 Alternative Requirements for Classes I and 2 Surface Examinations N-665 Alternative Requirements for Beam Angle Measurements Using Refracted Longitudinal Wave Search Units N-666 Weld Overlay of Class 1, 2, and 3 Socket Welded Connections N-683 Method for Determining the Maximum Allowable False Calls When Performing Single-Sided Access Performance Demonstrations in Accordance With Appendix VIII, Supplements 4 and 6 N-686-1 Lighting Requirements for Surface Examinations N-695 Qualification Requirements for Dissimilar Metal Piping Welds N-696 Qualification Requirements for Appendix VIII Piping Examinations Conducted From the Inside Surface N-705 Evaluation Criteria for Temporary Acceptance of Degradation in Moderate Energy Class 2 or 3 Vessels and Tanks N-706-1 Alternative Examination Requirements of Table IWB-2500-1 and Table IWC-2500-1 for PWR Stainless Steel Residual and Regenerative Heat Exchangers N-712 Class I Socket Weld Examinations N-722 Additional Examinations for PWR Pressure Retaining Welds in Class 1 Components Fabricated With Alloy 600/192/1192 N-729-1 Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds N-731 Alternative Class 1 System Leakage Test Pressure Requirements N-733 Mitigation of Flaws in NPS 2 (DN 50) and Smaller Nozzles and Nozzle Partial Penetration Welds in Vessels and Piping by Use of a Mechanical Connection Modification N-735 Successive Inspection of Class 1 and 2 Piping Welds N-753 Vision Tests 1-1.7 SIIR Rev. 13

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CHAPTER 1: INTRODUCTION 1.11 ASME Section XI Interpretations ASME Section XI Interpretations are written replies to inquiries concerning the interpretation of technical aspects of the Code.

ASME Section XI Interpretations are not endorsed by the NRC, and as such, must be applied judiciously. NRC Inspection Manual Part 9900, Technical Guidance, ASME Boiler and Pressure Vessel Code, Sections III & XI, dated 11/12/96, states in part "ASME Code Interpretations are not incorporated into the Code Of Federal Regulations and therefore, the NRC is not bound by these interpretations." Interpretations that provide helpful clarification of ASME Section XI requirements may be included in the Program Plan for information and consistency.

1.12 Relief Requests and Alternative Requests Alternatives or deviations from ASME Section XI code requirements are permitted per 10 CFR 50.55a(a)(3)(i), (ii), 10 CFR 50.55a(g)(5)(iii), (iv), and 10 CFR 50.55a(g)(6)(i), but only if they have been previously approved by the NRC. These deviations and alternatives are documented in the form of a Relief Request or Alternative Request, which provides a description, basis, and proposed alternative for the request. The Relief Requests and Alternative Requests are listed in Table 1.12-1 below and include the current NRC approval status. Full text versions are contained in Appendix A.

1.12.1 Alternative Requests for Non Approved Code Cases If it is determined that it would be beneficial to utilize non approved Code Cases (those not approved for use in Regulatory Guide 1.147) which provide alternative requirements to the inspection requirements of ASME Section XI or other alternative inspection requirements, Seabrook will prepare an Alternative Request in accordance with 10 CFR 50.55a(a)(3)(i). ASME publishes Code Cases which explain the intent of Code rules or provide for alternative requirements under special circumstances.

Section 1.10 of this document describes the use of approved Code Cases.

1.12.2 Relief Requests for Hardship or Unusual Difficulty During ISI, there are cases where compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. An example of this is encountering significant radiation exposure during the performance of an examination. If such circumstances are identified, relief requests will be filed in accordance with 10 CFR 50.55a(a)(3)(ii) 1.12.3 Relief Requests for Impractical Requirements During Inservice Inspection, there are cases where component configuration and/or interferences prohibit coverage of the code required volume or surfaces. In each case where such limitations have been encountered, the details are documented in a relief request. If additional conditions are encountered where the inspection requirements of ASME Section XI as documented in this program manual cannot be met, relief requests will be filed in accordance with 10 CFR 50.55a(g)(5)(iii).

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CHAPTER 1: INTRODUCTION 1.12.4 Format Seabrook Interval 3 Relief Requests and Alternative Requests will be numbered in accordance with the format 31R-XX and 3AR-XX, respectively, where XX is a sequential number. Each Relief Request and Alternative Request will be formatted in accordance with the Nuclear Energy Institute (NEI) document "Standard Format for Requests Pursuant to 10 CFR 50.55", Revision 1, dated June 7, 2004.

Approval Status Relief Request Subject NRC Status 31R-1, Rev.0 Examination Category B-A and B-D, Not Approved' Reactor Vessel Welds 31R-2, Rev.0 Examination Category B-B and B-D, Not Approved' Pressurizer and Steam Generator Welds 31R-3, Rev.0 Examination Category C-B, Steam Generator Not Approved' MS Outlet Nozzle Inside Radius Section 31R-4, Rev.0 Pressurizer Seismic Supports Not Approved' 3IR-5, Rev.0 Use of PDI Ultrasonic Techniques on the Not Approved' RPV Flange-to-Shell Weld 31R-16, Rev.0 Use an Alternative to the Depth Sizing Approved TAC No.

Requirement (Supplement 10) on RPV ME3623 Nozzles From the ID Alternative Request Subject NRC Status None Relief Request submittal to NRC in 2011 is intended to provide sufficient review and approval time to meet the scheduled Fall 2012 refueling outage.

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CHAPTER 1: INTRODUCTION 1.13 Inspection Interval, Periods, and Outages The 3 d ISI interval will follow ASME Section XI Inspection Program B as provided in Paragraph IWA-2432 and discussed below in Paragraph 1.13.1. The interval is divided into three successive inspection periods as determined by calendar years of plant service. The first, second, and third inspection periods are three (3), four (4), and three (3) years in length respectively, as required by Section XI, Tables IWB-2412-1, IWC-2412-1, IWD-2412-1, IWE-2412-1 and IWF-2410-2 and shown in the table below. Inspection Periods are further divided into refueling outages. The start and end dates for the scheduled three inspection periods occur at midnight on the dates as indicated. The scheduled period dates are tentative and subject to change.

Period Start End 1 8-19-10 8-18-13 2 8-19-13 8-18-17 3 8-19-17 8-18-20 1.13.1 Inspection Program B Unless specific examination deferrals are permitted, examination percentages for each examination category meet the inspection period requirements per Inspection Program B in accordance with ASME Section XI, Tables IWB-2412-1, IWC-2412-1, IWD-2412-1, IWE-2412-1 and IWF-2410-2 as follows:

Period Minimum Exams Required Maximum Exams Credited 1 16% 50%

2 50%' 75%

3 100% 100%

If the first period completion percentage for any examination category exceeds 34%, at least 16% of the required examinations shall be performed in the second period.

Inspection Program B is not applicable to the Subsection IWL examinations of Class CC Concrete Components. Class CC Components are examined on a 5 year frequency in accordance with IWL-2400.

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CHAPTER 1: INTRODUCTION 1.14 Program References The administrative controls for the Inservice Inspection Program are addressed in the following Document Title MA 6.1 Implementation Procedure for Inservice Inspection of Class 1, 2, and 3 Components and Primary Containment Structures MA 6.2 ASME Section XI Repair and Replacement Program ES1807.030 Nondestructive Examination (NDE) Certification Program ES 1802.006 Disposition of Inservice Inspection Anomalies MNPR Manuals and Procedures Administration Manual NARC Regulatory Compliance Manual (Reporting Defects, Noncompliances, Preparation of Relief Requests, etc.)

NARM Records Management Manual STMM Seabrook Team Management Manual (Plans, Programs, Procedures, etc.)

EE-07-035 Risk Informed Inservice Inspection of Class 2 Main Steam and Feedwater Break Exclusion Region 1.15 Examination Procedures The inservice inspection program examination requirements are performed and controlled through the use of both Seabrook and vendor NDE procedures. Seabrook procedures are prepared, qualified, issued, implemented, and controlled by Engineering and are maintained as Engineering Department Procedures. Vendor NDE procedures are reviewed, qualified, and approved for use by Seabrook prior to implementation.

1.16 Personnel Qualification and Certification Personnel performing ASME Section XI NDE examinations are qualified and certified in accordance with ANSI/ASNT CP-189, Standard for Qualification and Certification of Non-destructive Testing Personnel (1995) as required by IWA-2300 and modified by the requirements of Section XI, Division I and 10 CFR 50.55a. Qualification and certification of personnel performing examinations for augmented requirements specified in Section 7.0 of Chapter 2 are in accordance with the requirements of each as stipulated. Implementation and control of the qualification and certification activities are within the jurisdiction of Engineering.

1.17 Authorized Nuclear Inservice Inspector The duties of the Authorized Nuclear Inservice Inspector (ANII) are assigned by Section XI to verify that the responsibilities of the Owner and all mandatory requirements are met as specified in IWA-2110. It is the duty of the Inspector, among others, to perform a detailed review of this ISI Program and subsequent revisions, to verify that the required examinations are being properly performed and recorded.

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CHAPTER 1: INTRODUCTION 1.18 Records and Reports 1.18.1 General Records and reports of ISI activities are developed and maintained in accordance with ASME Section XI, 1WA-6000, and should include as applicable, program plans, schedules, examination procedures, examination results, final reports, equipment/personnel certifications, documentation of corrective actions, etc.

1.18.2 Owner's Reports for Inservice Inspection and Repair/Replacement Activities An Owner's Report for Inservice Inspections, Form NIS-1 or Form OAR-I (Code Case N-532-4), will be prepared, certified by the Owner, and verified and signed by the ANII upon completion each refueling outage and submitted within 90 days to the enforcement and regulatory authorities in accordance with IWA-6200.

1.18.3 Records Retention All records associated with ISI and repair/replacement activities will be retained for the duration of the facility operating license in accordance with the Quality Assurance Topical Report (QATR).

1.19 Code of Federal Regulations - Limitations. Modifications and Augmented Examination Requirements The following mandatory and optional Code of Federal Regulations Limitations, Modifications and Augmented Examination Requirements are being implemented during ISI Interval 3 and CISI Interval 2 at Seabrook. These Limitations, Modifications and Augmented Examination Requirements are included in 10 CFR 50.55a published on January 1, 2010.

1.19.1 As required by 10 CFR 50.55a(b)(2)(viii), Seabrook will examine the concrete containment in accordance with 10 CFR 50.55a(b)(2)(viii)(E) and 10 CFR 50.55a(b)(2)(viii)(F). Implementation of these modifications is included in Chapter 3, Section 2.0.

Note: 10 CFR 50.55a(b)(2)(viii)(G) does not apply to Seabrook because the containment structure is not post-tensioned.

1.19.2 As required by 10 CFR 50.55a(b)(2)(ix), Seabrook will examine the metal containment and the liner of the concrete containment in accordance with IOCFR50.55a(b)(2)(ix)(A), IOCFR50.55a(b)(2)(ix)(B) and 10CFR50.55a(b)(2)(ix)(F) through 10 CFR 50.55a(b)(2)(ix)(I). Implementation of these modifications is included in Chapter 3, Section 1.0.

1.19.3 As required by 10 CFR 50.55a(b)(2)(x), Seabrook will apply ASME NQA-1 and 10CFR50 Appendix B quality assurance requirements to the inservice inspection program. Implementation of these requirements is included in the Quality Assurance Topical Report (QATR).

1.19.4 As required by 10 CFR 50.55a(b)(2)(xii), Seabrook will not perform underwater welding on irradiated material per IWA-4660 requirements. Implementation of this limitation is addressed in Seabrook Administrative Procedure MA 6.2.

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CHAPTER 1: INTRODUCTION 1.19.5 As allowed by 10 CFR 50.55a(b)(2)(xiv), for Appendix VIII Qualified Personnel, Seabrook will implement the annual practice requirements in VII-4240 of ASME Section XI, Appendix VII in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training (when deemed appropriate). When utilizing this option, the annual practice requirements will be performed on material or welds that contain cracks, or by analyzing prerecorded data from material or welds that contain cracks. All training will be completed no earlier than 6 months prior to performing ultrasonic examinations. The implementation of ASME Section XI, Appendix VIII requirements is addressed in Chapter 2, Section 6.0 of this document.

1.19.6 As allowed by 10 CFR 50.55a(b)(2)(xv), Seabrook will implement the optional Appendix VIII specimen set and qualification provisions in paragraphs (b)(2)(xv)(A) to (b)(2)(xv)(M). The implementation of ASME Section XI, Appendix VIII requirements is addressed in Chapter 2, Section 6.0 of this document.

Note that the alternative requirements of Code Case N-695 will be utilized in lieu of those in Appendix VIII, Supplement 10. In addition, the alternative requirements of Code Case N-696 will be utilized in lieu of those in Appendix VIII, Supplements 2, 3 and 10.

1.19.7 As required by 10 CFR 50.55a(b)(2)(xvi)(A) and 10 CFR 50.55a(b)(2)(xvi)(B),

Seabrook examinations performed from one side of a ferritic vessel weld and Seabrook examinations performed from one side of a ferritic or stainless steel pipe will be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations in accordance with ASMIE Section XI, Appendix VIII and 10CFR50.55a(b)(2)(xv) requirements. The implementation of ASME Section XI, Appendix VIII requirements is addressed in Chapter 2, Section 6.0 of this document.

1.19.8 As required by 10 CFR 50.55a(b)(2)(xviii)(A), Level I and II nondestructive examination personnel at Seabrook will be recertified on a 3-year interval in lieu of the 5-year interval specified in IWA-2314(a) and IWA-2314(b) of the 2004 Edition of ASME Section XI. The certification of nondestructive examination personnel is addressed in procedure ES 1807.030.

1.19.9 As required by 10 CFR 50.55a(b)(2)(xviii)(B), paragraph IWA-2316 of the 2004 Edition of ASME Section XI will only be used to qualify personnel that observe for leakage during system leakage and hydrostatic tests conducted in accordance with IWA-521 1(a) and (b). The qualification and certification of nondestructive examination personnel is addressed in procedure ES 1807.030.

1.19.10 As required by 10 CFR 50.55a(b)(2)(xviii)(C), when qualifying visual examination personnel for VT-3 visual examinations under paragraph IWA-2317 of the 2004 Edition, the proficiency of the training will be demonstrated by administering an initial qualification examination and administering subsequent examinations on a 3-year interval. The qualification and certification of nondestructive examination personnel is addressed in procedure ES 1807.030.

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

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CHAPTER 1: INTRODUCTION 1.19.12 As required by 10 CFR 50.55a(b)(2)(xx)(B), the NDE provision in IWA-4540(a)(2) of the 2002 Addenda of ASME Section XI will be applied when performing system leakage tests after repair and replacement activities performed by welding or brazing on a pressure retaining boundary using the 2004 Edition of ASME Section XI. Repair Replacement activities are addressed in Seabrook Administrative Procedure MA 6.2.

1.19.13 As required by 10 CFR 50.55a(b)(2)(xxi)(A), the provisions of Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels, Items Nos.

B3.120 and B3.140 of Inspection Program B in the 1998 Edition will be applied by Seabrook. As allowed by 10 CFR 50.55a (b)(2)(xxi)(A), a visual examination with enhanced magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1, 2004 Edition, with a limiting assumption on the flaw aspect ratio (i.e., a/I = 0.5), may be performed by Seabrook in place of an ultrasonic examination. Examination of Category B-D components is addressed in Chapter 2, Section 1.4 of this document.

1.19.14 As required by 10 CFR 50.55a(b)(2)(xxiii), Seabrook will not implement the provision in IWA-4461.4.2 eliminating mechanical processing of thermally cut surfaces. The use of this provision is prohibited by 10 CFR 50.55a(b)(2)(xxiii). Repair Replacement activities are addressed in Seabrook Administrative Procedure MA 6.2.

1.19.15 As required by 10 CFR 50.55a(b)(2)(xxiv), Seabrook will not implement Appendix VIII, the supplements to Appendix VIII and Appendix I, Article 1-3000 in the 2002 Addenda through the 2004 Edition. The use of these requirements is prohibited by 10 CFR 50.55a(b)(2)(xxiv). In lieu of these requirements, Seabrook will implement the rules in the 2001 Edition of ASME Section XI. The implementation of ASME Section XI, Appendix VIII requirements is addressed in Chapter 2, Section 6.0 of this document 1.19.16 As required by 10 CFR 50.55a(b)(2)(xxv), Seabrook will not implement the requirements of IWA-4340 for the mitigation of defects by modification. The use of this provision is prohibited by 10 CFR 50.55a (b)(2)(xxv). Repair Replacement activities are addressed in Seabrook Administrative Procedure MA 6.2.

1.19.17 As required by 10 CFR 50.55a(b)(2)(xxvi), Seabrook will apply the repair and replacement activity provisions in IWA-4540(c) of the 1998 Edition of ASME Section XI for pressure testing of Class 1, 2, and 3 mechanical joints. Repair Replacement activities are addressed in Seabrook Administrative Procedure MA 6.2.

1.19.18 As required by 10 CFR 50.55a(b)(2)(xxvii), insulation will be removed from 17-4 PH or 410 stainless steel studs or bolts aged at a temperature below 11 00'F, from those having a Rockwell Method C hardness value above 30, and from A-2196 stainless steel studs or bolts preloaded to 100,000 pounds per square inch or higher when performing visual examinations in accordance with IWA-5242. Insulation removal during ASME Section XI Pressure Testing is addressed in procedure ES 1807.025.

1.19.19 As allowed by 10 CFR 50.55a(b)(3)(v), the examination and testing of snubbers, including the examination of non-integral attachment hardware will be performed per the 2004 Edition of the OM Code, Subsection ISTD in lieu of the examination and testing requirements for snubbers in ASME Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b). Snubber examination and testing is addressed in procedure EX 1805.01.

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CHAPTER 1: INTRODUCTION 1.19.20 As required by 10 CFR 50.55a(g)(6)(ii)(D), Seabrook will implement the augmented examination requirements in ASME Code Case N-729-1. Augmented examinations are addressed in Chapter 2, Section 7.0 of this document.

1.19.21 As required by 10 CFR 50.55a(g)(6)(ii)(E), Seabrook will implement the augmented examination requirements in ASME Code Case N-722. Augmented examinations are addressed in Chapter 2, Section 7.0 of this document.

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CHAPTER 1: INTRODUCTION 2.0

SUMMARY

OF CHANGES Revision 13:

This revision reflects the updated ISI Program Plan and Schedule for the 3rd 10-Yr. Interval in accordance with ASME Section XI, 2004 Edition as modified by 10 CFR 50.55a requirements.

In addition to updating the requirements included in former revisions of SIIR, this document now includes the requirements for Containment Inservice Inspection (CISI) per Section XI, Subsections IWE and IWL for the 2 nd 10-Year Interval; previously these requirements were included in document FP 59253, Primary Containment Inservice Inspection Plan, which addressed the Is` 10-Year Interval for CISI.

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.0 ASME CLASS 1 EXEMPTIONS AND REQUIREMENTS ASME Class 1 component exemptions and applicable examination category requirements are summarized below with the corresponding relief requests, code cases, and augmented requirements referenced.

1.1 Class 1 Component Exemptions The following componentsI or portions of components are exempted from the volumetric and surface examination requirements of IWB-2500, in accordance with IWB-1220:

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

(b)(1) components and piping segments of NPS I and smaller, except for steam generator tubing; (2) components and piping segments which have one inlet and one outlet, both of which are NPS 1 and smaller; (3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS I pipe.

(c) reactor vessel head connections and associated piping, NPS 2 and smaller, made inaccessible by control rod drive penetrations.

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

Footnotes:

1The exemptions from examination in IWC-1220 may be applied to those components permitted to be Class 2 in lieu of Class 1 by the regulatory authority having jurisdiction at the plant site.

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

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.2 Examination Category B-A Requirements Examination Category B-A requires the reactor pressure vessel, shell, head, shell to flange, and head to flange welds be examined as noted below. The incorporated relief requests are referenced as applicable.

Item No Items Required to be Examined Method Reference BI.11 All Reactor Vessel Circumferential Shell Welds Volumetric 31R-1 B 1. 12 All Reactor Vessel Longitudinal Shell Welds Volumetric B 1.21 Accessible Length of All Reactor Vessel Volumetric 31R-1 Circumferential Head Welds B1.22 Accessible Length of All Reactor Vessel Volumetric Meridional Head Welds B1.30 All of the Reactor Vessel Shell to Flange Weld Volumetric 31R-5 B 1.40 All of the Reactor Vessel Head to Flange Weld Volumetric 31R-1 and Surface 1.3 Examination Category B-B Requirements Examination Category B-B requires the Pressurizer circumferential shell to head weld at both ends, 1 foot of one longitudinal weld per head intersecting the Pressurizer shell to head welds, and one Steam Generator tubesheet-to-head weld be examined as noted below. The incorporated relief requests are referenced as applicable.

Item No, Items Required to be Examined Method Reference B2.11 Pressurizer Circumferential Shell to Head Volumetric 31R-2 Welds B2.12 Pressurizer Longitudinal Weld Per Head Volumetric B2.40 Steam Generator Tubesheet-to-Head Weld Volumetric 31R-2 2-1.2 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (STIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.4 Examination Category B-D, Inspection Program B Requirements Examination Category B-D requires the Reactor Pressure Vessel full penetration nozzle to vessel welds and the nozzle inside radius sections be examined as noted below. Examination Category B-D also requires the Pressurizer and Steam Generator full penetration nozzle to vessel welds be examined as noted below. The examination of the Pressurizer and Steam Generator nozzle inside radius sections is required per 10 CFR 50.55a(b)(2)(xxi)(A) and must be performed in accordance with the 1998 Edition of ASME Section XI. A visual examination with magnification that has a resolution sensitivity to detect a 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1, 2004 Edition, with a limiting assumption on the flaw aspect ratio (i.e., a/1=0.5), may be performed instead of an ultrasonic examination.

The incorporated relief requests and Code Cases are referenced as applicable..

Item No. Items Required to be Examined Method Reference B3.90 All Reactor Vessel Nozzle to Vessel Welds Volumetric 31R-1, 31R-16 N-613-1 B3.100 All Reactor Vessel Nozzle Inside Radius Sections Volumetric N-648-1 B3.l 10 All Pressurizer Nozzle to Vessel Welds Volumetric 31R-2 B3.120 All Pressurizer Nozzle Inside Radius Sections Volumetric B3.130 All Steam Generator Nozzle to Vessel Welds Volumetric 31R-2 B3.140 All Steam Generator Nozzle Inside Radius Volumetric Sections 1.5 Examination Category B-F Requirements Examination Category B-F requires pressure retaining dissimilar metal welds in vessel nozzles be examined as indicated below.

Item No. Items Required to be Examined Method Reference B5.10 All Reactor Vessel Nozzle-to-Safe End Butt Volumetric Welds (NPS 4 or Larger) and Surface B5.70 All Steam Generator Nozzle-to-Safe End Butt Volumetric Welds (NPS 4 or Larger) and Surface 2-1.3 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.6 Examination Category B-G-1 Requirements Examination Category B-G-1 requires pressure retaining bolting larger that 2 inch for the Reactor Vessel and Class 1 pumps to be examined as indicated below.

Item No. Items Required to be Examined Method Reference B6.10 All Reactor Vessel Closure Head Nuts VT-I (Greater Than 2" Diameter)

B6.20 All Reactor Vessel Closure Head Studs in Place or Volumetric When Removed (Greater Than 2" Diameter) Or Surface B6.40 All Reactor Vessel Threads in Flange Volumetric (Greater Than 2" Diameter)

B6.50 All Reactor Vessel Closure Washers and Bushings VT-I (Greater Than 2" Diameter)

B6.180 All Pump Bolts and Studs (Greater Than 2" Volumetric Diameter) for Pumps Selected Under Category B-L-2 or Surface B6.190 Pump Flange Surface When Connection is VT-I Disassembled (For Bolting Greater Than 2" Diameter) for Pumps Selected Under Category B-L-2 1.7 Examination Category B-G-2 Requirements Examination Category B-G-2 requires pressure retaining bolting 2 inch and less on the Pressurizer, Steam Generators, piping, pump casings, and valve bodies, to be examined as indicated below.

Item No. Items Required to be Examined Method Reference B7.20 All Pressurizer Bolts, Studs, and Nuts VT-I (2" Diameter and Less)

B7.30 All Steam Generator Bolts, Studs, and Nuts for VT-I B-B Steam Generator Selected for Examination (2" Diameter and Less)

B7.50 Bolts, Studs, and Nuts for Piping VT-1 (2" Diameter and Less)

B7.60 Bolts, Studs, and Nuts for all B-L-2 Pump Casings VT-I Selected for Examination (2" Diameter and Less)

B7.70 Bolts, Studs, and Nuts for all B-M-2 Valve Bodies VT-I Selected for Examination (2" Diameter and Less) 2-1.4 SIIR Rev. 13

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.8 Examination Category B-J Requirements Examination Category B-J requires pressure retaining bolting larger that 2 inch for the Reactor Vessel and Class 1 pumps to be examined as indicated below.

Item No. Items Required to be Examined Method Reference B9.11 Circumferential Piping Welds (NPS 4 or Larger) Volumetric and Surface B9.21 Circumferential Piping Welds Other Than PWR Surface High Pressure Safety Injection Systems (< 4 NPS)

B9.22 Circumferential Piping Welds of PWR High Volumetric Pressure Safety Injection Systems (< 4 NPS)

B9.31 Branch Pipe Connection Welds Volumetric and Surface B9.32 Branch Pipe Connection Welds (< 4 NPS) Surface B9.40 Socket Welds Surface 1.9 Examination Category B-K Requirements Examination Category B-K requires welded attachments for vessels, piping, pumps, and valves to be examined as indicated below.

Item No[ Items Required to be Examined Method Reference B 10.10 Each Vessel Welded Attachment and One Vessel Surface Welded Attachment of One Vessel Per Each Multiple Vessel Group Associated with Component Supports 2-1.5 SIIR Rev. 13

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.10 Examination Category B-L-2 Requirements Examination Category B-L-2 requires pump casing internal surfaces to be examined as indicated below. See Table 2.6 for identification of the pump groups.

Item No, Items Required to be Examined Method Reference B112.20 One Pump Casing Internal Surface per Group When VT-3 Disassembled for Maintenance, Repair or Volumetric Examination 1.11 Examination Category B-M-2 Requirements Examination Category B-M-2 requires valve body internal surfaces to be examined as indicated below. See Table 2.6 for identification of the valve groups.

Item No[ Items Required to be Examined Method Reference B12.50 One Valve Body Internal Surface per Group VT-3 Exceeding NPS 4 When Disassembled for Maintenance, Repair or Volumetric Examination 1.12 Examination Category B-N-1 Requirements Examination Category B-N-I requires examination of the Reactor Vessel accessible interior areas after removal of the components each inspection period during a normal refueling outage as indicated below.

Item No. Items Required to be Examined Method Reference B13.10 Reactor Vessel Accessible Interior Areas Above and VT-3 Below the Core after Removal of Components During Normal Refueling Outages 1.13 Examination Category B-N-2 Requirements Examination Category B-N-2 requires examination of the Reactor Vessel accessible interior attachment welds beyond the beltline region as indicated below.

Item No, Items Required to be Examined B 13.60 Reactor Vessel Accessible Interior Attachment Welds Beyond the Beltline Region 2-1.6 SIIR Rev. 13

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 1.14 Examination Category B-N-3 Requirements Examination Category B-N-3 requires examination of the Reactor Vessel accessible core support structure surfaces as indicated below.

Item No, Items Required to be Examined Method Reference B 13.70 Reactor Vessel Accessible Core Support Structure VT-3 Surfaces 1.15 Examination Category B-O Requirements Examination Category B-O requires examination of the pressure retaining welds in the Reactor Vessel control rod drive and in-core instrument housings as indicated below.

Item No, Items Required to be Examined Method Reference B 14.20 10% of the Reactor Vessel Peripheral Control Rod Volumetric Drive Housing Welds or Surface 1.16 Examination Category B-P Requirements Examination Category B-P requires examination of Class 1 pressure retaining components as indicated below.

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 2.0 ASME CLASS 2 EXEMPTIONS AND REQUIREMENTS ASME Class 2 component exemptions and applicable examination category requirements are summarized below with the corresponding relief requests, code cases, and augmented requirements referenced.

2.1 Class 2 Component Exemptions The following components within RHR, ECC, and CHR Systems or portions of systems' are exempted from the volumetric and surface examination requirements of IWC-2500, in accordance with IWC-1221 and IWC-1223:

(a) For systems, except high pressure safety injection systems in pressurized water reactor plants [IWC- 1221]:

(1) components and piping segments NPS 4 and smaller (2) components and piping segments which have one inlet and one outlet, both of which are NPS4 and smaller [utilized for Seabrook Excess Letdown Heat Exchanger, E-3 and Letdown Heat Exchanger, E-4 (Tube Side)]

(3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4 pipe. [utilized for Seabrook Regenerative Heat Exchanger, E-2]

(b) For high pressure safety injection systems in pressurized water reactor plants [IWC-1221]:

(1) components and piping segments NPS 11/2 and smaller (2) components and piping segments which have one inlet and one outlet, both of which are NPS I '/2and smaller (3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS I V2 pipe.

(c) Vessels, piping, pumps, valves, other components, and component connections of any size in statically pressurized, passive (i.e. no pumps) safety injection system of pressurized water reactor plants [IWC-1221].

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

[IWC-1221].

(e) Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe [IWC-1223].

The following components within systems or portions of systems other than RHR, ECC, and CHR Systems' are exempted from the volumetric and surface examination requirements of IWC-2500, in accordance with IWC-1222 and IWC-1223:

(a) For systems, except auxiliary feedwater systems in pressurized water reactor plants [IWC-1222]:

(1) components and piping segments NPS 4 and smaller (2) components and piping segments which have one inlet and one outlet, both of which are NPS 4 and smaller 2-2.1 SIMR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN (3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS 4 pipe.

(b) For auxiliary feedwater systems in pressurized water reactor plants [IWC-1222]:

(1) components and piping segments NPS 11/2 and smaller (2) components and piping segments which have one inlet and one outlet, both of which are NPS 1'/2and smaller (3) components 2 and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD of NPS I '1/2pipe.

(c) Vessels, piping, pumps, valves, other components, and component connections of any size in systems or portions of systems that operate (when the system function is required) at a pressure equal to or less than 275 psig and at a temperature equal to or less than 200'F

[IWC-1222].

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

[IWC-1222].

(e) Welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe [IWC-1223].

Footnotes:

1 RHR, ECC, and CHR systems are the Residual Heat Removal, Emergency Core Cooling, and' Containment Heat Removal Systems, respectively.

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

3 Statically pressurized, passive safety injection systems of pressurized water reactor plants are typically called: (a) accumulator tank and associated system, (b) safety injection tank and associated system, (c) core flooding tank and associated system In addition to the exemptions of IWC-1221, IWC-1222 and IWC-1223, Class 2 piping may be exempted from periodic system pressure (per Category C-H and IWC-5000) in accordance with IWA-51 10(c):

Piping that penetrates a containment vessel is exempt from the periodic system pressure test when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of this Division.

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 2.2 Examination Category C-A Requirements Examination Category C-A requires examination of the pressure retaining shell circumferential welds, head circumferential welds and the tubesheet-to-shell welds in Class 2 pressure vessels as indicated below. See Table 2.6 for identification of the vessel groups. The incorporated Code Cases are referenced as applicable.

Item No Items Required to be Examined Method Reference C1.10 Pressure Vessel Shell Circumferential Welds Volumetric N-706-1 (One Vessel per Group)

Cl1.20 Pressure Vessel Head Circumferential Welds Volumetric N-706-1 (One Vessel per Group)

C1.30 Pressure Vessel Tube Sheet-to-Shell Welds Volumetric (One Vessel per Group) 2.3 Examination Category C-B Requirements Examination Category C-B requires examination of the pressure retaining nozzles in vessels as indicated below. See Table 2.6 for identification of the vessel groups. The incorporated Code Cases or Relief Requests are referenced as applicable.

Item No, Items Required to be Examined Method Reference C2.21 All Vessel Nozzle to Shell (or Head) Welds in Volumetric Vessels > Y2 "Thickness Without Reinforcing Plate and at Terminal Ends in C-F Selected Piping Runs (One Surface Vessel per Group)

C2.22 All Vessel Nozzle Inside Radius Sections in Vessels Volumetric 31R-3

> 1/2/2 "Thickness Without Reinforcing Plate at Terminal Ends in C-F Selected Piping Runs' (One Vessel per Group)

C2.31 All Vessel Nozzle to Shell Welds in Vessels > /2" Surface N-706-1 Thickness With Reinforcing Plate at Terminal Ends in C-F Selected Piping Runs (One Vessel per Group)

C2.33 All Vessel Nozzle to Shell (or Head) Welds in VT-2 Vessels >1/2/"Thickness With Reinforcing Plate at Terminal Ends in C-F Selected Piping Runs When Inside of Vessel is Inaccessible (One Vessel per I Group)

Footnotes:

I Applies to nozzles greater than NPS 12 per Figure IWC-2500-4 2-2.3 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 2.4 Examination Category C-C Requirements Examination Category C-C requires welded attachments for vessels, piping, pumps, and valves to be examined as indicated below.

Item No Items Required to be Examined Method Reference C3.10 Each Vessel Welded Attachment (Only One Surface Vessel Welded Attachment within a Multiple Vessel Group Associated with the Vessel Component Supports)

C3.20 10% of the Piping Welded Attachments Surface Associated with Component Supports Selected for Examination 2.5 Examination Category C-F-1 Requirements Examination Category C-F-1 requires examination of pressure retaining welds in austenitic stainless steel or high alloy piping as indicated below.

Item No Items Required to be Examined Method Reference C5.11 Circumferential Welds in Piping _>% in. Nominal Volumetric Wall Thickness for Piping > NPS 4 and Surface C5.21 Circumferential Welds in Piping > 1/5 in. Nominal Volumetric Wall Thickness for Piping > NPS 2 and < NPS 4 and Surface C5.30 Socket Welds Surface C5.41 Circumferential Welds in Pipe Branch Surface Connections of Branch Piping > NPS 2 2-2.4 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 2.6 Examination Category C-F-2 Requirements Examination Category C-F-2 requires examination of pressure retaining welds in carbon steel or low alloy steel piping. Welds within this Code Category are included in the Risk Informed Break Exclusion Region (RI-BER) analysis (Ref. EE-07-035). ASME Code requirements for this category are met by performing > 7.5% of the population and performing both volumetric and surface examination.

Item No, Items Required to be Examined Method Reference RI-BER Circumferential Welds in Piping Volumetric Engineering and Surface Evaluation EE-07-035 2.7 Examination Category C-H Requirements Examination Category C-H requires examination of Class 2 pressure retaining components as indicated below.

2-2.5 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 3.0 ASME CLASS 3 EXEMPTIONS AND REQUIREMENTS ASME Class 3 component exemptions and applicable examination category requirements are summarized below with the corresponding relief requests, code cases, and augmented requirements referenced.

3.1 Class 3 Component Exemptions The following components or parts of components are exempted from the VT-I visual examination requirements of IWD-2500, in accordance with IWD-1220(a) through (e):

(a) components and piping segments NPS 4 (DN 100) and smaller (b) components and piping segments which have one inlet and one outlet, both of which are NPS 4 (DN100) and smaller (c) components' and piping segments which have multiple inlets or multiple outlets whose cumulative pipe cross-sectional area does not exceed the cross-sectional area defined by the OD ofNPS 4 (DN 100) pipe.

(d) components that operate at a pressure of 275 psig (1900 kPa) or less and at a temperature of 200'F (95°C) or less in systems (or portions of systems) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling; (e) welds or portions of welds that are inaccessible due to being encased in concrete, buried underground, located inside a penetration, or encapsulated by guard pipe.

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

3.2 Examination Category D-A Requirements Examination Category D-A requires examination of welded attachments most subject to corrosion and associated with component supports for vessels, piping, pumps, and valves as indicated below.

Item No, Items Required to be Examined Method Reference D11.10 10% of the Welded Attachments Most Subject to VT- I D I.20 Corrosion Associated with Component Supports D1.30 D1.40 3.3 Examination Category D-B Requirements Examination Category D-B requires system leakage tests of all pressure retaining components as indicated below. The system leakage tests shall be conducted once each inspection period.

Item No. Items Required to be Examined Method Reference D2. l0 Pressure Retaining Components-System VT-2 Leakage Test 2-3.1 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SUIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 4.0 ASME CLASS 1, 2,3, and MC COMPONENT SUPPORT EXEMPTIONS AND REQUIREMENTS ASME Class 1, 2, 3, and MC component support exemptions and applicable examination category requirements are summarized below. Note that the term "component support" includes both supports for components such as vessels, pumps, etc., and supports for piping, which are treated separately for selection purposes as discussed below in Paragraph 4.2. Also note that the Seabrook Station design does not include any Class MC component supports.

4.1 ASME Class 1, 2, 3, and MC Component Support Exemptions Supports exempt from the examination requirements of IWF-2000 are those connected to piping and other items exempted from volumetric, surface, or VT-I or VT-3 visual examination by IWB-1220, IWC-1220, IWD-1220, and IWE-1220. In addition, portions of supports that are inaccessible by being encased in concrete, buried underground, or encapsulated by guard pipe are also exempt from the examination requirements of IWF-2000, in accordance with IWF-1230.

4.2 ASME Class 1, 2, and 3 Component Support Selections The supports to be selected for examination are those not exempted by IWF-1230; the selection shall be in accordance with IWF-2510 and Table IWF-2500-1.

4.3 Examination Category F-A Requirements Examination Category F-A requires Class 1, 2, and 3 piping supports and supports of Class 1, 2, 3 and MC components to be examined as follows Item No. Items Required to be Examined Method Reference FI.10 25% of the Class I Supports for the VT-3 nonexempt Class I piping F1.20 15% of the Class 2 Supports for the VT-3 nonexempt Class 2 piping F 1.30 10% of the Class 3 Supports for the VT-3 nonexempt Class 3 piping F1.40 100% of the Class 1, 2, 3, and MC VT-3 31R-4 Supports (other than piping) for the components being examined Note: Snubbers and their attachments (bolting, pins, and clamps) are examined and tested under a separate program in accordance with the Technical Requirements Manual. Welded attachments associated with snubbers and other supports are examined in accordance with Examination Categories B-K, C-C, and D-A.

2-4.1 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 5.0 ASME CLASS 1, 2, AND 3 ACCEPTANCE STANDARDS 5.1 ASME Class 1 Acceptance Standards The following acceptance standards are applicable to Class 1 Components:

Exam Examination Area Acceptance Category Standards B-A Pressure Retaining Welds in Reactor Vessel IWB-3510 B-B Pressure Retaining Welds in Vessels Other Than Reactor IWB-3510 Vessels B-D Full Penetration Welded Nozzles in Vessels IWB-3512 B-F Pressure Retaining Dissimilar Metal Welds in Vessel IWB-3514 Nozzles B-G-I Pressure Retaining Bolting, Greater Than 2" in Diameter IWB-3515 IWB-3517 B-G-2 Pressure Retaining Bolting, 2 in. and Less in Diameter IWB-3517 B-J Pressure Retaining Welds in Piping IWB-3514 B-K Welded Attachments for Vessels, Piping, Pumps, and IWB-3516 Valves B-L-2 Pump Casings IWB-3519 B-M-2 Valve Bodies IWB-3519 B-N-i Interior of Reactor Vessel IWB-3520 B-N-2 Welded Core Support Structures and Interior Attachments IWB-3520 to Reactor Vessels B-N-3 Removable Core Support Structures IWB-3520 B-O Pressure Retaining Welds in Control Rod Housings IWB-3523 B-P All Pressure Retaining Components IWB-3522 2-5.1 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 5.2 ASME Class 2 Acceptance Standards The following acceptance standards are applicable to Class 2 Components:

Exam Examination Area Acceptance Category Standards C-A Pressure Retaining Welds in Pressure Vessels IWC-3510 C-B Pressure Retaining Nozzle Welds in Vessels IWC-3511 C-C Welded Attachments for Vessels, Piping, Pumps, and IWC-3512 Valves C-F-1 Pressure Retaining Welds in Austenitic Stainless Steel or IWC-3514 High Alloy Piping C-F-2 Pressure Retaining Welds in Carbon Steel or Low Alloy IWC-3514 Steel Piping C-H All Pressure Retaining Components IWC-3516 5.3 ASME Class 3 Acceptance Standards The following acceptance standards are applicable to Class 3 Components:

Exam Examination Area Acceptance Category Standards D-A Welded Attachments for Vessels, Piping, Pumps, and IWD-3000 Valves D-B All Pressure Retaining Components IWD-3000 5.4 ASME Class 1, 2, 3 and MC Component Support Acceptance Standards The following acceptance standards are applicable to Class 1, 2, 3 and MC Component Supports:

2-5.2 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 6.0 IMPLEMENTATION OF ASME SECTION XI, APPENDIX VIII 6.1 Program Basis 10 CFR 50.55a, as amended and published in the Federal Register on September 22, 1999, Volume 64, Number 183 requiring expedited implementation of Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems". The effective date for the expedited implementation was November 22, 1999.

6.2 Effective Code Seabrook shall implement Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems" in accordance with ASME Section XI, 2001 Edition for the 3 rd Inspection Interval at Seabrook Station 1.

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

SUPPLEMENT QUALIFICATION REQUIREMENTS IMPLEMENTATION DATE I Evaluating Electronic Characteristics of May 22, 2000 Ultrasonic Systems 2 Wrought Austenitic Piping Welds May 22, 2000 3 Ferritic Piping Welds May 22, 2000 4 Clad/Base Metal Interface of Reactor Vessel November 22, 2000 5 Nozzle Inside Radius Section November 22, 2002 6 Reactor Vessel Welds Other Than Clad/Base November 22, 2000 Metal Interface 7 Nozzle-to-Vessel Welds November 22, 2002 8 Bolts and Studs May 22, 2000 9 Cast Austenitic Piping (In Course of N/A Preparation) 10 Dissimilar Metal Welds November 22, 2002 11 Full Structural Overlaid Wrought Austenitic November 22, 2001 Piping Welds 12 Coordinated Implementation of Selected November 22, 2002 Aspects of Supplements 2, 3, 10 and 11 13 Coordinated Implementation of Selected November 22, 2002 Aspects of Supplements 4, 5, 6 and 7 14 Supplement 14: Qualification Requirements for November 22, 2002 Coordinated Implementation of Supplements 10, 2, and 3 for Piping Examinations Performed from the Inside Surface 2-6.1 SIUR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 6.4 Performance Demonstration Program Seabrook will utilize personnel qualified through the Performance Demonstration Initiative (PDI) Program. PDI is an organization comprised of all the US nuclear utilities formed to provide an efficient, cost effective and technically sound implementation of Appendix VIII performance demonstration requirements.

6.5 Performance Demonstration Program Administrator Seabrook will utilize the EPRI NDE Center as the Performance Demonstration Administrator.

Supplement 1: Evaluating Electronic Characteristics of Ultrasonic Systems This Supplement defines the steps necessary to interchange the pulsars and/or receivers in an ultrasonic examination system without the need for requalification. The PDI Program does not support this activity, but PDI will supply Seabrook with technical guidance as required on a case-by-case basis.

Supplement 2: Qualification Requirements for Wrought Austenitic Piping Welds The PDI Program is in full compliance with Supplement 2 as modified by 10 CFR 50.55a for examinations conducted from outside the piping. The PDI Program does not address examinations conducted from inside the pipe except for RPV nozzle-to-pipe and nozzle-to-safe end welds. These examinations are included in Supplement 14, which is described later.

Welds containing corrosion-resistant cladding (CRC) that is part of the pressure-retaining boundary, such as that typically applied to mitigate cracking are excluded. A recent Code inquiry indicates that these welds should be examined in accordance with Appendix III until qualification requirements are developed.

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

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

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

The PDI Program is in full compliance with Code Case N-552 as modified by Regulatory Guide 1.147 for examinations conducted from outside the reactor vessel. Code Case N-552 is applicable to both the nozzle inside radius region and the inner portion (15%) of nozzle-to-shell welds when scanning for flaws oriented transverse to the weld. Code Case N-552 requires that all nozzles be modeled, including the inner portion of the nozzle-to-vessel weld, and introduces maximum metal path and maximum misorientation angles as new essential variables that must be qualified. Code Case N-552 is identified as an acceptable alternative in Regulatory Guide 1.147 and is identified in the SIIR. Nozzle modeling will be the responsibility of Seabrook.

2-6.2 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Supplement 6: Qualification Requirements for Reactor Vessel Welds Other Than Clad/Base Metal Interface The PDI Program is in full compliance with Supplement 6 as modified by 10 CFR 50.55a. In addition, the PDI Program considers that demonstrations conducted on clad vessel specimens in accordance with Supplement 4 exceed the requirements of Supplement 6 and may be used for examination of the inner 10% of unclad components without a relief request.

Demonstrations performed on unclad vessel specimens, however, may not be used for the examination of clad vessels.

Supplement 7: Qualification Requirements for Nozzle-to-Vessel Welds The PDI Program is in full compliance with Supplement 7 as modified by 10 CFR 50.55a.

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

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

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

Supplement 10: Qualification Requirements for Dissimilar Metal Piping Welds The PDI Program is not in compliance with Supplement 10. PDI qualifications are conducted in accordance with Code Case N-695. This Code Case is identified in RG 1.147, as acceptable and is included in the SIIR.

Supplement 11: Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds The PDI Program is in compliance with Supplement 11.

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

2-6.3 SUIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Supplement 13: Requirements for Coordinated Implementation of Selected Aspects of Supplements 4, 5, 6, and 7 The PDI Program does not support this Supplement. Supplements 4, 5, 6, and 7 qualifications are performed on an individual basis.

Supplement 14: Qualification Requirements for Coordinated Implementation of Supplements 10, 2, and 3 for Piping Examinations Performed from the Inside Surface Supplement 14 is functionally applicable only to PWR vessels. It is a new Supplement established by the PDI Program for a coordinated implementation of the qualifications required for the typical examinations performed from the ID of PWR nozzles. Supplement 14 uses the more technically stringent Supplement 10 qualification as a base and then incorporates a limited number of Supplement 2 and Supplement 3 samples. Qualification requirements for examination conducted from the inside surface are conducted in accordance with Code Case N-696. A relief request will be required if the examination procedure is incapable of depth sizing flaws to an accuracy of 0.125 root mean square (RMS).

6.6 Single Sided Access for Austenitic Welds 10 CFR 50.55a, requires that if access is available, the weld shall be scanned in each of the four directions (parallel and perpendicular to the weld) where required. Coverage credit may be taken for single sided exams on ferritic piping. However, for austenitic piping, a procedure must be qualified with flaws on the inaccessible side of the weld. There are currently no qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to US nuclear applications.

The PDI Program conforms to 10 CFR 50.55a regarding single side access for piping. PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology.

When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiency demonstrations do not comply with 10CFR50.55a(b)(2)(xvi)(B) and full coverage credit may not be claimed.

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

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

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

6.7 Responsibilities The ISI Program Owner is responsible for implementing the Appendix VIII program.

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

2-6.4 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 7.0 AUGMENTED EXAMINATIONS 7.1 Reactor Coolant Pump Flywheels The Seabrook Reactor Coolant Pump Flywheels will be examined in accordance with Seabrook Technical Specification 3/4 4.4.10, which requires the following examinations:

Each reactor coolant pump flywheel shall be inspected at least once every 10 years. This inspection shall be by either of the following examinations:

a) An in-place examination, utilizing ultrasonic testing, over the volume from the inner bore of the flywheel to the circle of one-half the outer radius; or b) A surface examination, utilizing magnetic particle testing and/or penetrant testing, of the exposed surfaces of the disassembled flywheel.

7.2 Reactor Coolant System Piping The Seabrook RCS Hot Leg Piping will be examined in accordance with Code Case N-722 as required by 10CFR50.55a(g)(6)(ii)(E). In addition, any remaining examinations of the RCS Hot Leg Piping required by MRP-139 will be performed.

Item No. Items Required to be Examined Method Reference B 15.80 RPV bottom-mounted instrument penetrations, Visual, VE examination of all penetrations every other refueling outage B15.90 RPV Hot leg nozzle-to-pipe connections, Visual, VE examination of all connections every refueling outage B 15.95 RPV Cold leg nozzle-to-pipe connections, Visual, VE examination of all connections once per interval B 15.120 Steam Generator Bottom channel head drain tube Visual, VE penetration, VE of all penetrations once per interval 2-7.1 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 7.3 Reactor Vessel Head The Seabrook Reactor Vessel Top Head will be examined in accordance with Code Case N-729-1 as required by 10CFR50.55a(g)(6)(ii)(D). The following examinations will be performed:

Item No. Items Required to be Examined Method Reference B4.10 Head with UNS N06600 nozzles and UNS N06082 Visual, VE Note 1 or UNS WS6182 partial penetration welds each I refueling outage.

B4.20 UNS N06600 nozzles and UNS N06082 or UNS Volumetric W86182 partial-penetration welds in head. and Surface Examination of all nozzles, every 8 calendar years or before Reinspection Years (RIY) = 2.25, whichever is less. _ _

Note 1: If the Effective Degradation Years (EDY) < 8 and no flaws unacceptable for continued service under -3130 or -3140 have been detected, the reexamination frequency may be extended to every third refueling outage or 5 calendar years, whichever is less, provided an IWA-2212 VT-2 visual examination of the head is performed under the insulation through multiple access points in outages that the VE is not completed. This IWA-2212 VT-2 visual examination may be performed with the reactor vessel depressurized.

7.4 Alloy 600 Mitigation The Seabrook Pressurizer Full Structural Weld Overlays (Over Alloy 600 Nozzle-to-Pipe Welds) will be examined as follows:

Item No. Items Required to be Examined Method Reference N/A Pressurizer Full Structural Weld Overlays Over A600 Volumetric Nozzle-to-Pipe Welds. Two nozzles once per interval.

2-7.2 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 8.0 TABLES Table 2.1 Class 1, 2, 3 Component and Component Support ISI Examination Summary Table 2.2 Augmented Examination Summary Table 2.3 Pressure Test Summary Table 2.4 Class 1, 2, and 3 Program Systems Table 2.5 Weld and Component Isometric Drawings Table 2.6 Vessel, Pump, and Valve Groupings Table 2.7 Ultrasonic Calibration Block Standard 2-8.1 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

The following definitions are provided for Table 2. 1, Seabrook Class 1, 2, 3 Component and Component Support ISI Examination Summary:

1. Each applicable Examination Category and Item Number is listed. For example, when an Item Number is not listed, this indicates there are no applicable non-exempt components at Seabrook.

2. No. of Components is the total number of Seabrook components (or parts of components) within the Code Item Number.

3. No. of Exams is the total number of examinations that will be performed during the ten year interval. Examination scheduling will be in accordance with IWB-2412, IWC-2412, IWD-2412, and IWF-2412 unless it is modified by a Code Case or approved Relief Request.

4. Examination Method(s) listed are those shown in Tables IWB-2500-1, IWC-2500-1, IWD-2500-1 and IWF-2500-1,. unless they are modified by a Code Case or approved Relief Request.

5. Relief Request(s) listed are all applicable Relief Requests and Alternative Requests for the noted Code Item Number.

TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request(s)

Shell Welds B 1.11 Circumferential 3 3 Volumetric 31R-1 B-A B I. 12 Longitudinal 9 9 Volumetric Pressure Head Welds Retaining Welds B 1.21 Circumferential 2 2 Volumetric 31R-1 in Reactor Vessel B 1.22 Meridional 8 8 Volumetric B 1.30 Shell-to-Flange Weld 1 1 Volumetric 31R-5 B 1.40 Head-to-Flange Weld I 1 Surface and Volumetric 31R-1 2-8.2 SIIR Rev. 13

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CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Cateory Number Components Examined Components Exams Request(s)

Pressurizer Shell to Head Welds B2. 11 Circumferential 2 2 Volumetric 13-1 Pressure B2.12 Longitudinal 2 2 Volumetric Retaining Welds in Vessels Other Than Reactor Vessels Steam Generator (Primary Side) Head Welds B2.40 Tubesheet to Head Weld 4 1 Volumetric 31R-2 Reactor Vessel B3.90 Nozzle-to-Vessel Welds 8 8 Volumetric 31R-1 B3.100 Nozzle Inside Radius Section 8 8 Volumetric B-D Full Penetration Pressurizer Welded Nozzles B3.110 Nozzle-to-Vessel Welds 6 6 Volumetric 3IR-2 in Vessels, Inspection B3.120 Nozzle Inside Radius Section 6 6 Volumetric Program B Steam Generator (Primary Side)

B3.130 Nozzle-to-Vessel Welds 8 8 Volumetric B3.140 Nozzle Inside Radius Section 8 8 Volumetric 2-8.3 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request(s)

Reactor Vessel B-F B5.10 NPS 4 or Larger, Nozzle-to-Safe End Butt Surface and Volumetric Pressure Welds Retaining Dissimilar Metal Welds in Vessel Steam Generator Nozzles B5.70 NPS 4 or Larger, Nozzle-to-Safe End Butt 8 8 Surface and Volumetric Welds Reactor Vessel B6.10 Closure Head Nuts 54 54 Visual, VT- I B6.20 Closure Studs 54 54 Surface and Volumetric B-G-I B6.40 Threads In Flange 54 54 Volumetric Pressure B6.50 Closure Washers, Bushings 54 54 Visual, VT-I Retaining Bolting Greater Than 2 Pumps inch In Diameter B6.180 Bolts and Studs 96 24 Surface and Volumetric B6.190 Flange Surface, when connection is 4 1 Visual, VT-1 disassembled 2-8.4 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request(s)

Pressurizer B7.20 Bolts, Studs, and Nuts 1 I Visual, VT-I Steam Generator B-G-2 Pressure B7.30 Bolts, Studs, and Nuts 16 4 Visual, VT-I Retaining Bolting Pivin 2 inch and Less B7.50 Bolts, Studs, and Nuts 5 5 Visual, VT-I In Diameter Pumps B7.60 Bolts, Studs, and Nuts 4 1 Visual, VT-I Valves B7.70 Bolts, Studs, and Nuts 48 6 Visual, VT-I NPS 4 or Larger B9.1 I Circumferential Welds 388 100 Surface and Volumetric Less Than NPS 4 B9.21 Circumferential Welds Other Than PWR 235 60 Surface B-J High Pressure Safety Injection Systems Pressure Retaining Welds B9.22 Circumferential Welds of PWR High To be To be Volumetric in Piping Pressure Safety Injection Systems populated populated Branch Pipe Connection Welds B9.31 NPS 4 or Larger I1 3 Surface and Volumetric B9.32 Less Than NPS 4 30 8 Surface B9.40 Socket Welds 68 17 Surface 2-8.5 SUIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request(s)

B-K Wele Pressure Vessels Attachments for B 10. 10 Welded Attachments 5 1 Surface Class I Vessels, Piping, Pumps, and Valves B-L-2 Pumps Pump Casings B 12.20 Pump Casing 4 1 Visual, VT-3 B-M-2 Valves Valve Body B 12.50 Valves, Exceeding NPS 4, Valve Internal 33 6 Visual, VT-3 Surfaces B-N-I B 13.10 Vessel Interior 1 1 Visual, VT-3 Interior of Reactor Vessel B-N-2 Reactor Vessel (PWR)

Welded Core Support B 13.60 Interior Attachments Beyond Beltline Region 6 6 Visual, VT-3 Structures and Interior Attachments to Reactor Vessels B-N-3 Reactor Vessel Removable Core B 13.70 Core Support Structure 1 Visual, VT-3 Support Structures 2-8.6 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request(s)

B-O Reactor Vessel (PWR)

Pressure B 14.20 Welds in CRD Housing 11 2 Surface and Volumetric Retaining Welds in Control Rod Housings C-A C 1.10 Shell Circumferential Welds 14 4 Volumetric N-706-1 Pressure Visual, VT-2 RHR HX RHR HX Retaining Welds C1.20 Head Circumferential Welds 6 2 Volumetric in Pressure C 1.30 Tubesheet-to-Shell Weld 6 2 Volumetric Vessels Nozzles Without Reinforcing Plate in Vessels > 1/2/2 in. Nominal Thickness C2.21 Nozzle-to Shell (Nozzle to Head or Nozzle to 12 4 Surface and Volumetric C-B Nozzle) Weld Pressure C2.22 Nozzle Inside Radius Section 8 1 Volumetric 31R-3 Retaining Nozzle Welds Nozzles With Reinforcing Plate in Vessels >

in Vessels / in. Nominal Thickness C2.33 Nozzle-to-Shell (Nozzle to Head or Nozzle to 4 4 Visual, VT-2 N-706-1 Nozzle) Welds When Inside of Vessel is RHIR HX Inaccessible 2-8.7 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request s C-C Welded Pressure Vessels Attachments for C3.10 Welded Attachments 2 1 Surface Class 2 Vessels, Piping Piping. Pumps, C3.20 Welded Attachments 33 4 Surface and Valves Piping Welds > 3/8" NWT and > NPS 4" C5.11 Circumferential Welds 795 60 Surface and Volumetric C-F-I Piping Welds > 1/5" NWT and > NPS 2" Pressure and < NPS 4, Retaining Welds in Austenitic C5.21 Circumferential Welds 762 58 Surface and Volumetric Stainless Steel or High Alloy C5.30 Socket Welds 273 22 Surface Piping Pipe Branch Connections of Branch Piping

> NPS 2 C5.41 Circumferential Welds 14 1 Surface 2-8.8 SUIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.1 SEABROOK CLASS 1, 2,3 COMPONENT AND COMPONENT SUPPORT ISI EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request(s C-F-2 Risk Informed Break Exclusion (RI-BER)

Pressure Pipin Retaining Welds N/A Circumferential Welds 457 42 Surface and Volumetric Engineering in Carbon or Low Evaluation Alloy Piping EE-07-035 D-A Pressure Vessels Welded D1.10 Welded Attachments 2 1 Visual, VT-1 Attachments For Vessels, Piping, Pi13111 Pumps, and D1.20 Welded Attachments 90 10 Visual, VT-I Valves F 1.10 Class I Piping Supports 253 65 Visual, VT-3 F-A F 1.20 Class 2 Piping Supports 798 122 Visual, VT-3 Supports F 1.30 Class 3 Piping Supports 90 10 Visual, VT-3 F 1.40 Supports Other Than Piping Supports 29 11 Visual, VT-3 31R-4 2-8.9 SIMR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.2 SEABROOK AUGMENTED EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of Components No. of Number of Examination Relief Category Number Examined Components Exams Method(s) Request(s)

USNRC RG 1.14 Reactor Coolant Pump Flywheels 4 4 UT and Surface Regulatory Guide Note (a) 1.14 ASME B 15.80 RPV Bottom-Mounted Instrument Penetrations 58 58 Visual, VE Code Case B 15.90 RPV Hot Leg Nozzle-to-Pipe Connections 4 4 Visual, VE N-722 B 15.95 RPV Cold Leg Nozzle-to-Pipe Connections 4 4 Visual, VE Reactor B 15.120 SG Bottom Channel Head Drain Tube Penetration 4 4 Visual, VE Coolant System Piping ASME B4.10 Head with UNS N06600 nozzles and UNS N06082 79 79 Visual, VE Code Case or UNS WS6182 partial penetration welds N-729-1 B4.20 UNS N06600 nozzles and UNS N06082 or UNS 79 79 Surface and Volumetric Reactor W86182 partial-penetration welds in head Vessel Head Alloy 600 N/A Pressurizer Full Structural Weld Overlays Over 6 2 Volumetric Mitigation A600 Nozzle-to-Pipe Welds (Notes b & c)

Notes:

a) Examination of Reactor Coolant Pump Flywheels is in accordance with Technical Specification 3/4 4.4.10 b) Six (6) Pressurizer structural weld overlays examined in OR14, Spring 2011.

c) Examination of Pressurizer structural weld overlays approved per NRC SER dated May 1, 2008 (TAC No. MD5933). Also reference Engineering Evaluation EE-07-020.

2-8.10 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.3 SEABROOK SYSTEM PRESSURE TESTING

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) 1 Relief Categor Number Components Examined lComponentsa Exams Re uest(s)

B-P B 15.10 Pressure Retaining Components 2 1 Visual, VT-2 All Class I Pressure Retaining Componentsb C-H C7. 10 Pressure Retaining Components 17 17 Visual, VT-2 All Class 2 Pressure Retaining Componentsc D-B D2.10 Pressure Retaining Components 13 13 Visual, VT-2 All Class 3 Pressure Retaining Components' Notes:

a) No. of Components in this table corresponds to the number of procedures or PM tasks.

b) B-P pressure test performed at the conclusion of each refueling outage.

c) Pressure tests performed each ISI Period.

2-8.11 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.4 ASME CLASS 1, 2, AND 3 SYSTEM CLASSIFICATION CLASSIFICATION OF COMPONENTS P& ID NUMBER P& ID TITLE CLASS 1 CLASS 2 CLASS 3 I-CBS-D20233 Containment Spray System X X I-CC-D20205 Primary Component Cooling Loop A Detail X 1-CC-D20206 Primary Component Cooling Loop A Detail X I-CC-D20207 Primary Component Cooling Loop A Detail X X I-CC-D20209 Primary Component Cooling Loop A Detail X X I-CC-D2021 I Primary Component Cooling Loop "B" Detail X 1-CC-D20212 Primary Component Cooling Loop "B" Detail X 1-CC-D20213 Primary Component Cooling Loop "B" Detail X X I-CGC-D20612 Combustible Gas Control System X X I-CS-D20722 Chemical & Volume Control Sys Heat Exchangers Detail X X X 1-CS-D20723 Chemical & Volume Control Sys Purification X X 1-CS-D20724 Chemical & Volume Control Sys Letdown Degasifier X 1-CS-D20725 Chemical & Volume Control Charging System X X I-CS-D20726 Chemical & Volume Control Sys Seal Water X X 1-CS-D20727 Chemical & Volume Control System Thermal Regeneration X X 1-CS-D20728 Chemical & Volume Control System Thermal Regeneration X I-CS-D20729 Chemical & Volume Control Sys Boric Acid X X I-DG-D20458 Diesel Generator Lube Oil System Train A X I-DG-D20459 Diesel Generator Fuel Oil System Train A X I-DG-D20460 Diesel Generator Starting Air System Train A X I-DG-D20461 Diesel Generator Cooling Water System Train A X I-DG-D20462 Diesel Generator Intake & Crankcase Vacuum System Train A X I-DG-D20463 Diesel Generator Lube Oil System Train B X I-DG-D20464 Diesel Generator Fuel Oil System Train B X I-DG-D20465 Diesel Generator Starting Air System Train B X I-DG-D20466 Diesel Generator Cooling Water System Train B X I-DG-D20467 Diesel Generator Intake & Crankcase Vacuum System Train B X I-FW-D20686 Feedwater System X X I-FW-D20688 Emergency Feedwater System X I-MS-D20580 Main Steam System Main Steam Headers X 2-8.12 SLIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN TABLE 2.4 ASME CLASS 1, 2, AND 3 SYSTEM CLASSIFICATION CLASSIFICATION OF COMPONENTS P& ID NUMBER P& ID TITLE CLASS I I CLASS 2 [ CLASS 3 I-MS-D20581 Main Steam System Main Steam Headers X 1-MS-D20582 Main Steam System Emergency Feedwater Pump Supply X X I-MS-D20583 Main Steam System Manifold & H.P. Turbine Piping X I-MS-D20587 Main Steam System Main Steam Drains X I-NG-D20135 Nitrogen Gas X 1-NG-D20136 Nitrogen Gas X I-RC-D20841 Reactor Coolant System Loop No. 1 X X I-RC-D20842 Reactor Coolant System Loop No. 2 X X 1-RC-D20843 Reactor Coolant System Loop No. 3 X X 1-RC-D20844 Reactor Coolant System Loop No. 4 X X I-RC-D20845 Reactor Coolant System Reactor Vessel X X I-RC-D20846 Reactor Coolant System Pressurizer X X I-RH-D20662 Residual Heat Removal Sys Train A X X X I-RH-D20663 Residual Heat Removal Sys Train B Cross-Tie X X X Reactor Make-Up Water System X1 X 1-RMW-D20360 I-SA-D20652 Service Air System Misc. Buildings X1 I-SB-D20626 Steam Generator Blowdown X I-SF-D20482 Spent Fuel Pool Cooling and Clean-Up System X I-SF-D20484 Spent Fuel Pool Cooling and Clean-Up System X X I-SI-D20446 Safety Injection System Intermediate Head Injection System X X I-SI-D20447 Safety Injection System High Head Injection System X X I-SI-D20450 Safety Injection System Low Head Injection (Accumulators) Detail X X 1-SS-D20518 Sample System Nuclear Normal Operation X I-SS-D20519 Sample System Nuclear Sample Panel CP-166A X X I-SS-D20520 Sample System Nuclear-Post Accident X1 I-SW-D20794 Service Water System Nuclear X 1-SW-D20795 Service Water System Nuclear X I-SW-D20796 Service Water System Nuclear X I-VG-D20780 Vent Gas System Xl I-WLD-D20218 Waste Processing Liquid Drains Reactor Coolant System X1 I-WLD-D20219 Waste Processing Liquid Drains Containment Building Sumps X1 I-WLD-D20221 Waste Processing Liquid Drains RHR Equipment Valves 1 & 2 Xl I-WLD-D20222 Waste Processing Liquid Drains Primary Auxiliary Bldg X1 2-8.13 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Notes:

1. Exempt Class 2 Containment Boundary Components only. Components are also exempt from system pressure testing per IWA-5110(c).

2-8.14 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Table 2.5 Weld and Component Isometric Drawings (Sheet I of 3)

Drawing Title I-NHY-2022991SI Main Steam Atmospheric Relief Piping 1-NHY-2023001SI Main Steam Atmospheric Relief Piping 1-NHY-2023011SI Main Steam Line No. 4000 i-NHY-2023021SI Main Steam Line No. 4001 I-NHY-202303ISI Main Steam Line No. 4002 I-NHY-2023041SI Main Steam Line No. 4003 I-NHY-2023961SI Feedwater Line No. 4606 I-NHY-2023971SI Feedwater Line No. 4607 I-NHY-202398ISI Feedwater Line No. 4608 I-NHY-2023991SI Feedwater Line No. 4609 I-NHY-2024451SI Main Steam Safety Valve Discharge 1-NHY-650000 Excess Letdown Heat Exchanger CS-E-3 1-NHY-650001 Residual Heat Removal Heat Exchanger RH-E-9A I-NHY-6500021SI Residual Heat Removal Heat Exchanger RH-E-9B 1-NHY-650003 Regenerative Heat Exchanger I-CS-E-2 I-NHY-650004 Reactor Coolant Pumps RC-P- IA-D 1-NHY-6500051SI Reactor Coolant Pump Flywheel I-NHY-6500061SI Pressurizer RC-E- 10 I-NHY-6500071SI Reactor Vessel RC-E-I I-NHY-6500081SI Reactor Vessel RC-E-I 1-NHY-650009 Reactor Vessel RC-E-1 I-NHY-650010 Reactor Vessel RC-E-1 I-NHY-65001 II1S Steam Generator RC-E-II A (typ.)

I-NHY-6500121SI Steam Generator RC-E-I IA & 1 B I-NHY-6500131SI Steam Generator RC-E-1 IC & 1ID I-NHY-8000131SI RC System Line No. 13 I-NHY-800015ISI RC System Line No. 15 1-NHY-8000181SI RC System Line No. 18 I-NHY-8000211SI RC System Line No. 21 I-NHY-8000301SI RC System Line No. 30 I-NHY-8000331SI RC System Line No. 33 I-NHY-8000441SI RC System Line No. 44 1-NHY-8000451SI RC System Line No. 45 I-NHY-8000481SI RC System Line No. 48 I-NHY-8000491SI RC System Line No. 49 I-NHY-8000581SI RC System Line No. 58 I-NHY-8000591SI RC System Line No. 59 I-NHY-8000621SI RC System Line No. 62 I-NHY-8000741SI RC System Line No. 74 I-NHY-8000751SI RC System Line No. 75 1-NHY-8000761SI RC System Line No. 76 I-NHY-8000801SI RC System Line No. 80 I-NHY-800093151 RC System Line No. 93 I-NHY-8000941SI RC System Line No. 94 I-NHY-8000961S5 RC System Line No. 96 I-NHY-8000971SI RC System Line No. 97 I-NHY-8000981SI RC System Line No. 98 2-8.15 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Table 2.5 Weld and Component Isometric Drawings (Sheet 2 of 3)

Drawing Title I-NHY-80015 I SI RH System Line No. 151 i-NHY-8001521SI RH System Line No. 152 I-NHY-8001551SI RH System Line No. 155 I-NHY-8001571SI RH System Line No. 157 1-NHY-8001581SI RI System Line No. 158 1-NHY-8001591SI RH System Line No. 159 1-NHY-800160ISI RH System Line No. 160 I-NHY-8001611SI RH System Line No. 161 1-NH Y-8001621SI RH System Line No. 162 I-NHY-8001631SI RH System Line No. 163 1-NHY-8001671SI RH System Line No. 167 1-NHY-8001781S1 RH System Line No. 178 1-NHY-800179ISI RH System Line No. 179 I-NHY-8001801SI RH System Line No. 180 1-NHY-800201 1SI SI System Line No. 201 1-NHY-8002021SI ST System Line No. 202 I-NHY-8002031SI SI System Line No. 203 I-NHY-8002041SI SI System Line No. 204 I-NHY-8002501SI SI System Line No. 250 1-NHY-8002511SI ST System Line No. 251 1-NHY-8002561SI SI System Line No. 256 I-NHY-8002571SI S1 System Line No. 257 I-NHY-8002581SI S1 System Line No. 258 I-NHY-8002591SI SI System Line No. 259 1-NHY-8002601SI SI System Line No. 260 I-NHY-8002611SI SI System Line No. 261 I-NHY-8002701SI SI System Line No. 270 1-NHY-8002721SI S1 System Line No. 272 1-NHY-800273ISI ST System Line No. 273 I-NHY-8002741SI SI System Line No. 274 I-NHY-8002751SI ST System Line No. 275 1-NHY-8003241SI CS System Line No. 324 I-NHY-8003251SI CS System Line No. 325 I-NHY-8003261SI CS System Line No. 326 1-NHY-8003271SI CS System Line No. 327 I-NHY-8003281SI CS System Line No. 328 I-NHY-8003291SI CS System Line No. 329 I-NHY-8003301SI CS System Line No. 330 I-NHY-800331 ISI CS System Line No. 331 1-NHY-8003551SI CS System Line No. 355 1-NHY-8003571SI CS System Line No. 357 I-NHY-8003581SI CS System Line No. 358 I-NHY-8003621SI CS System Line No. 362 1-NHY-800363ISI CS System Line No. 363 I-NHY-8003641SI CS System Line No. 364 I-NHY-8003651SI CS System Line No. 365 I-NHY-8003661SI CS System Line No. 366 2-8.16 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Table 2.5 Weld and Component Isometric Drawings (Sheet 3 of 3)

Drawing Title I-NHY-8003671SI CS System Line No. 367 I-NHY-8003681SI CS System Line No. 368 1-NHY-8003691SI CS System Line No. 369 I-NHY-8003701SI CS System Line No. 370 I-NHY-8003711SI CS System Line No. 371 I-NHY-8003741SI CS System Line No. 374 1-NHY-8003751SI CS System Line No. 375 1-NHY-8003771SI CS System Line No. 377 1-NHY-8003531SI CS System Line No. 353 1-NHY-8004731S1 CS System Line No. 473 1-NHY-8012011SI CBS System Line No. 1201 I -NHY-8012021S1 CBS System Line No. 1202 I-NHY-8012071SI CBS System Line No. 1207 I-NHY-8012081SI CBS System Line No. 1208 I -NHY-8012091S1 CBS System Line No. 1209 I-NHY-8012101SI CBS System Line No. 1210 1-NHY-80121 lISI CBS System Line No. 1211 I-NHY-8012121SI CBS System Line No. 1212 I-NHY-8012131SI CBS System Line No. 1213 I-NHY-8012141SI CBS System Line No. 1214 I-NHY-8012151SI CBS System Line No. 1215 i-NHY-8012161SI CBS System Line No. 1216 I-NHY-8040001SI MS System Line No. 4000 I-NHY-804001ISI MS System Line No. 4001 I-NHY-8040021SI MS System Line No. 4002 1-NHY-8040031SI MS System Line No. 4003 I -NHY-8046061SI FW System Line No. 4606 I-NHY-8046071Ii FW System Line No. 4607 I-NHY-8046081SI FW System Line No. 4608 i-NHY-8046091SI FW System Line No. 4609 I-NHY-8055541SI Reactor Coolant Loop Weld ID I-NHY-8055551SI Reactor Coolant Loop Weld Table I-NHY-8600001SI RH Line No. 155 Weld Table 1-NHY-860001 ISI RH Line No. 158 Weld Table I-NHY-8600021S1 RH Line No. 48 Weld Table I-NHY-860003ISI CS Line No. 369 Weld Table 2-8.17 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Table 2.6 Vessel, Pump and Valve Groupings (Sheet I of 2)

Class 1 Vessel Grouping Steam Generators (Primary Side)

RC E-1 IA RC E-11B RC E-11C RC E-I ID Class 2 Vessel Grouping Steam Generators RC E-11A RC E-I 1B RC E-I IC RC E-1 ID Residual Heat Removal Heat Exchangers RH E-9A RH E-9B Containment Building Spray Heat Exchangers CBS-E-16A CBS-E-1 6B Class 1 Pump Grouping Reactor Coolant Pumps RC RC-P- I A RC RC-P- 1B RC RC-P- IC RC RC-P-1D 2-8.18 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Table 2.6 Vessel, Pump and Valve Groupings (Sheet 2 of 2)

Class 1 Valve Grouping Group No. Manufacturer System Valve No. Description I Westinghouse Reactor Coolant RC-V-22 12" Gate Valve RC-V-23 RC-V-87 RC-V-88 2 Crosby Reactor Coolant RC-V-I115 6" Relief Valve RC-V-116 RC-V-117 3 Westinghouse Residual Heat RH-V-15 6" Check Valve Removal RH-V-29 RH-V-30 RH-V-31 RH-V-52 RH-V-53 RH-V-50 8" Check Valve RH-V-51 4 Westinghouse Residual Heat RH-V-59 6" Gate Valve Removal RH-V-61 RH-V-63 RH-V-65 S Westinghouse Safety Injection SI-V-3 10" Gate Valve SI-V- 17 SI-V-32 SI-V-47 6 Westinghouse Safety Injection SI-V-5 10" Check Valve SI-V-6 SI-V-20 SI-V-21 SI-V-35 SI-V-36 SI-V-50 SI-V-51 SI-V-82 6" Check Valve SI-V-87 2-8.19 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN Table 2.7 Ultrasonic Calibration Block Standards CalBIfock[D MaterialSpec Description 06-72-0k . .Pressurizer Head-to-Shel I I-RC-MM-427A SA-516 GR.70 Pressurizer Support Sk*iJrIt..............

I1-RC-MM-427B :SA-533 GR.A .Pressurizer Shell & Nozzle I-RC-M1M-42F8ASA-533 GR.A Steam Generator 1-RC-MM-428B i SA-533 GR.B Steam Generator l -RC-MM-430A S-SA-508 . . Steam dGenerator Primary ...

.196-101 JS.A-53 3 GR.B3 ..Reactor. P~ressure V~esseIl

.,196-,160,2. SA-533, GR.B_ Reactor Pressure Vessel j 19.6-1.03 .....................

.9:.,0......................

,.SA-.533 A = 33 G R B ... Reactor GR.B3 .....

P . .a..c....

... e.ss...ss

.. Pressure

.. Vessel..................

196-104 SA-533 GR.B Reactor Pressure Vessel

.196-2.0 . SA-533 GR ...

_i3 .. V iang V.............

iaL .. .

.196-202 6* /

SA-508 IRPV Nozzle *SafeEn 1;a E.......

d1*2 .1.

196-206 !SA-182 F-304 __RPV CRD Mechanism SB-!-CRBSR-HX SA-Y24.0TP.304 Vessel Shell SB-1-RE-R-HX SA-240 TP.304 Vessel Shell____

• SB-10-140-SS SA-376 TP.316 _ Piping Class 1 &Z.

SB-10-40-SS .SA-312 TPi304 [Class 2 Thin Wall SB:.I.0C5C S' S . iping cla-s 1 &....... ....

f§A-234 WPB Piping Class 1&....

SSB-10-XXICS-ý B .!..I,,,4O.r......S.S.. . .S.

. ..... .P...._. ,P t io ,c .Ja .s.s*

SB-12-140-SS .SA-376 TP.3 16 Piping Class 1 & 2 S.B-712-40-SS SA-312 TP.304 LClass 2 Thin Wall .........

,SB- I4-1.60-SS SA-3 76 TP.304 ~Piping Class I & 2

'SB-14-40-SS

• SB.-!6.-..J 0.0:CS ]....A SA-358,Tp.304.

-.!..06..GIR 3...B . ... ipiin22CThin

.Class Wall2?.

lass...!... ....... ....... ......

SB-16-STD-SS ISA-358 TP.304 :Class 2 Thin Wall SB-18-100-CS

. SA-0I6 GR.BB Piping. Class1 &..

.*...... 2.. ..... ....... 7..

.SB-18-XXI-CS Q SA-105 , Pioinj*,Class 1 &2 SB-3-160-SS ,_SA-376 TP.316 Class 2 Thin Wall SB-3-40-SS SA-312 TP.304 :Class 2 Thin Wall SB-3-80-SS SA-312 TP.304 Class 2 Thin Wal SB-30-.XI.-CS SA-155 GR.KC70 P..ipi.ng- Class 1 & 2 ......................... .

Piping 1 &2

,SB-30-XX2-CS

-.3.0 3 C ......SA-.106 S.A..I10.... GR.C ..... P.... .j.n . Class C l s .!..&. 2......... . ..... ..... .

,SB-30-YX3-CS iSA-lOS Piping Class I & 2.-

.SB-32-XXI-CS

.......C '...... jSA-155 S . .- GR.KC70 G I ( ] Piping Class

......... .~i

.. I *&........

I... . ..........

2..........

SB

-ii-i6-6--ss SB-32-XX-C~fA15RK7 . T....

,?W4160-S 'SA-376TPR.KC1 --s 1176

.113

.... PiigClassn Piping Cas1&

I & 22... .. .ii..

SB-4-160-SS

,SB-4.0-8.0.SS SA-3 76 .TP.304, SA-312 TP.316 .,Class Piping2Class I & 2.

Thin Wall.

SB-6-160-SS SA-376 TP.316 Piping Class I & 2 SB-6-40-SS SA-312 TP.304 !Class 2 Thin Wall SB..-.-S ......... .... C.L.2..

.... Pr.e.s.s e .z..z.l.s S .r

.SB-R-67-A ..

2_.. S ......

=......

I6.0-SA-0 .A ...50 C S........ .Pe.....

C .2 ......i Pesuie .. ..

..... ... a. N z .!..s..

SSftyRlif e.....  ! ......

..SB.._IR.-2_73.-CS .............

.SA-5.08 .CL.:2-.... .'...P.ce_.su riz~e~r So t.a..yNo...... .. i*7.!R

!SB-IR-32-CS ...... ISA-508 CL 2 Pressurizer Surge Nozzle IR

.,..S.B.. R. -...............

SB-RC-3 ....

iSA-182......

i.. 2 .F.304

. 0*I. .iPipingl {Class !a s lI & & 22 . . '. .. i...[

SB-RC-4 .. Piping Class ! &.2.

PSA-37.6.GR304 SB-RC-5 SA-351 GR.CF8A Piping Class I & 2 SB-RCP-BOLT SA-540 GR-B-24 Reactor Coolant Pump,.Rottot

.$B-RV-STUD -SA-540 GR-B-24 Rieactor-Vessel-Stud .

..S.E-I R-74J-.C.S SA-50.8 CL 2. .S~team Generator Feedwater SB-PDI-304SS Alternative ASME Block s B-IC-D-'I: i6SS ...; ..... Alternative A-ME B 0ock.

SB-pD-56CS , Alternati.e SM E Block. .......

2-8.20 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 2: INSERVICE INSPECTION (ISI) PLAN 9.0

SUMMARY

OF CHANGES Revision 13:

This revision reflects the updated ISI Program Plan and Schedule for the 3 rd 10-Yr. Interval in accordance with ASME Section XI, 2004 Edition as modified by 10 CFR 50.55a requirements.

In addition to updating the requirements included in former revisions of SIIR, this document now includes the requirements for Containment Inservice Inspection (CISI) per Section XI, Subsections IWE and IWL for the 2 nd 10-Year Interval; previously these requirements were included in document FP 59253, Primary Containment Inservice Inspection Plan, which addressed the 1st 10-Year Interval for CISI.

2-9.1 SIIR Rev. 13

INSERVICE INSPECTION REFERENCE (SIIR)

CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN 1.0 ASME SUBSECTION IWE EXEMPTIONS AND REQUIREMENTS ASME Class MC pressure retaining components and their integral attachments, metallic shell and penetration liners of Class CC pressure retaining components and their integral attachments and ASME Class CC component exemptions and applicable examination category requirements are summarized below with the corresponding relief requests, code cases, and augmented requirements referenced.

1.1 Subsection IWE Component Exemptions The following components (or parts of components) are exempted from the examination requirements of IWE-2000:

(a) vessels, parts, and appurtenances outside the boundaries of the containment system as defined in the Design Specifications; (b) embedded or inaccessible portions of containment vessels, parts, and appurtenances that met the requirements of the original Construction Code; (c) portions of containment vessels, parts, and appurtenances that become embedded or inaccessible as a result of vessel repair/replacement activities if the conditions of IWE-1232(a) and (b) and IWE-5220 are met; (d) piping, pumps, and valves that are part of the containment system, or which penetrate or are attached to the containment vessel. These components shall be examined in accordance with the requirements of IWB or IWC, as appropriate to the classification defined by the Design Specifications.

1.2 Examination Category E-A Requirements Examination Category E-A requires examination of containment surfaces.

Item No. Items Required to be Examined Method Reference E .1 I Containment Vessel Pressure Retaining Boundary General Accessible Surface Areas Visual El.1 11B Pressure Retaining Bolting General Visual El.11 C Pressure Retaining Bolting VT-3 Note 1 E 1.30 Moisture Barriers General Visual NOTES:

1) An examination of the pressure-retaining bolted connections in Item El .11 of Table IWE-2500-1 using the VT-3 examination method must be conducted once each interval per 10 CFR 50.55a(b)(2)(ix)(G). Per 10CFR50.55a(b)(2)(ix)(H), containment bolting that is disassembled during scheduled performance of the examinations in Item El .11 of Table IWE-2500-1 must be examined using the VT-3 method.

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN 1.3 Examination Category E-C Requirements Examination Category E-C requires augmented examination of containment surfaces when applicable per IWE-1240.

Item No{ Items Required to be Examined Method Reference E4.11 Visible Surfaces VT-1 INote I E4.12 Surface Area Grid Minimum Wall Thickness Ultrasonic Location Thickness NOTES:

1) VT-I examination required per 10 CFR 50.55a(b)(2)(ix)(G) 3-1.2 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN 2.0 ASME SUBSECTION IWL EXEMPTIONS AND REQUIREMENTS ASME Class CC component exemptions and applicable examination category requirements are summarized below with the corresponding relief requests, code cases, and augmented requirements referenced. The Subsection IWL requirements for post-tensioning systems are not applicable to the Seabrook Station Unit I design.

2.1 'Subsection IWL Component Exemptions The following components (or parts of components) are exempted from the examination requirements of IWE-2000:

(a) tendon end anchorages that are inaccessible, subject to the requirements of IWL-252 1. 1; (b) portions of the concrete surface that are covered by the liner, foundation material, or backfill, or are otherwise obstructed by adjacent structures, components, parts, or appurtenances.

2.2 Examination Category L-A Requirements Examination Category L-A requires examination of concrete containment surfaces.

Item Nol Items Required to be Examined Method Reference L1.1 1 Concrete Surface-All Accessible Surface Areas General Visual LI. 12 Concrete Surface-Suspect Areas Detailed I I_Visual 3-2.1 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN 3.0 ASME CLASS MC AND CLASS CC COMPONENT ACCEPTANCE STANDARDS 3.1 ASME Class MC Acceptance Standards The following acceptance standards are applicable to Class MC Components and metallic shell and penetration liners of Class CC pressure retaining components:

Exam Examination Area Acceptance Category Standards E-A Containment Surfaces IWE-3510 E-C Containment Surfaces Requiring Augmented Examination IWE-3511 3.2 ASME Class CC Acceptance Standards The following acceptance standards are applicable to Class CC Components:

Exam Examination Area Acceptance Category Standards L-A Containment Surfaces IWL-3210 3-3.1 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN 4.0 TABLES Table 4.1 IWE and IWL CISI Examination Summary Table 4.2 Seabrook Class MC, Subsection IWE Inspection Areas Table 4.3 Seabrook Class CC, Subsection IWL Inspection Areas 3-4.1 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN SECTION 4.0 TABLES The following definitions are provided for Table 4.1, Seabrook Subsection IWE and Subsection IWL Component Examination Summary:

1. Each applicable Examination Category and Item Number is listed. For example, when an Item Number is not listed, this indicates there are no applicable components at Seabrook.

2. No. of Components is the total number of Seabrook components (or parts of components) within the Code Item Number.

3. No. of Exams is the total number of examinations that will be performed during the ten year interval. Examination scheduling will be in accordance with IWE-2412 and IWL-2500 unless it is modified by a Code Case or approved Relief Request.

4. Examination Method(s) listed are those shown in Tables IWE-2500-1 and IWL-2500-1, unless they are modified by a Code Case an approved Relief Request or 10 CFR50.55a.

5. Relief Request(s) listed are all applicable Relief Requests and Alternative Requests for the noted Code Item Number.

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN TABLE 4.1 SEABROOK SUBSECTION IWE AND SUBSECTION IWL COMPONENT EXAMINATION

SUMMARY

Examination Item Description of Components Or Parts of No. of Number of Examination Method(s) Relief Category Number Components Examined Components Exams Request(s)

El. I1 Accessible Surface Areas (not including areas 164 492 General Visual embedded in concrete, covered with insulation E-A or wetted surfaces) [Note (a)] _____

Containment ELI11B Pressure Retaining Bolting 16 48 General Visual Surfaces [Notes (b) and (c)]

El. I1C Pressure Retaining Bolting 16 16 Visual, VT-3

[Notes (b) and (c)]

E-C E4.11 Visible Surfaces [Notes (d) through (g)] 9 9 Visual, VT-I Containment Surfaces E4.12 Surface Area Grid, Minimum Wall Thickness 9 9 Ultrasonic Thickness Requiring Location Augmented [Notes (d) and (e)]

Examination L I. 11 Concrete Surface-All Accessible Surface 24 48 General Visual L-A Areas Concrete LI. 12 Concrete Surface-Suspect Areas 0 0 Detailed Visual Notes:

a) See Table IWE-2500-1, Notes 1(a), 1(b), and 1(c) for examination scope.

b) Pressure-retaining bolted connections, including bolts, studs, nuts, bushings, washers, and threads in base material and flange ligaments between fastener holes. Bolted connections need not be disassembled for performance of examinations, and bolting may remain in place under tension. A General Visual examination is required per Table IWE-2500-1.

c) VT-3 examination (and VT-I as applicable) of pressure retaining bolting are requirements of 10CFR50.55a(b)(2)(ix)(G) and (H). The VT-3 examination must be conducted once each interval per 10CFR50.55a(b)(2)(ix)(G). Per 10CFR50.55a(b)(2)(ix)(H1), containment bolted connections that are disassembled during scheduled performance of the examinations in Item El. 11 of Table IWE-2500-1 must be examined using the VT-3 examination method. As an alternative to performing VT-3 examinations of containment bolted connections that are disassembled during the scheduled performance of Item E 1.Ii, VT-3 examinations of containment bolted connections may be conducted whenever containment bolted connections are disassembled for any reason. Note that if flaws or degradation are identified during the performance ofa VT-3 examination, the bolting must be examined in accordance with the VT-I examination method.

d) Containment surface areas requiring augmented examination are those identified in IWE-1240.

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN e) The extent of examination shall be 100% for each inspection period until the areas examined remain essentially unchanged for the next inspection period. Such areas no longer require augmented examination in accordance with IWE-2420(c), and will revert back to Category E-A, Item No E1. 11 or Item No E1.12.

f) VT-I examination of Item Number E4.11 Containment Surface Areas is a requirement of IOCFR50.55a(b)(2)(ix)(G).

g) Number of components reflects Period I status.

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN TABLE 4.2 SEABROOK CLASS MC, SUBSECTION IWE INSPECTION AREAS Sheet 1 of 4 Drawing No. Examination Area Elevation Azimuth Reference Drawings SB-IWE-001 Contaimnent Interior (-)26'0", 0"0" 0- 90o 9673-F-101495 9673-F- 101496 SB-IWE-002 Containment Interior (-)26'0", 0"0" 900 - 1800 9673-F-101495 9673-F- 101496 SB-IWE-003 Containment Interior (-)26'0", 0"0" 180o- 2700 9673-F-101495 9673-F- 101496 SB-IWE-004 Containment Interior (-)26'0", 0"0" 2700- 00 9673-F-101495 9673-F- 101496 SB-IWE-005 Containment Interior 0"0", 30'0" 00.900 9673-F- 1496 9673-F- 101496 SB-IWE-006 Containment Interior 0"0", 30'0" 900- 1800 9673-F-101495 9673-F-101496 SB-IWE-007 Containment Interior 0"0", 3010" 1800_2700 9673-F-101495 9673-F-101496 SB-IWE-008 Containment Interior 0"0", 30'0" 2700- 00 9673-F-101495 9673-F- 101496 Containment Interior 3010", 60'0"00-900 9673-F-101495 SB-IWE-009 9673-F- 101496 Containment Interior 30'0", 60'0" 900- 1800 9673-F-101495 SB-IWE-010 9673-F- 101496 Containment Interior 30'0", 60'0" 1800- 2700 9673-F- 101495 SB-IWE-0 11 9673-F- 101496 SB-IWE-012 Containment Interior 30'0", 60'0" 2700- 00 9673-F-101495

_ _9673-F- 101496 SB-IWE-013 Containment Interior 60-0", 90'0" 00- 90 9673-F-101495 9673-F- 101496 SB-IWE-014 Containment Interior 60'0", 90'0" 900o 1800 9673-F-101495 9673-F- 101496 Containment Interior 60'0", 90'0" 180o_2700 9673-F-101495 SB-IWE-0 15 9673-F- 101496 Containment Interior W0'0", 9010" 2700 00 9673-F-101495 SB-IWE-016 101496 SB-IWE-017 Containment Interior 90'0", 119'0" 0900 9673-F- 101495 9673-F-9673-F- 101496 Containment Interior 90'0", 119'0" 900o 1800 9673-F-101495 SB-IWE-018 9673-F- 101496 Containment Interior 90'0", 119'0" 1800- 2700 9673-F-101495 SB-IWE-019 9673-F-101496 SB-IWE-020 Containment Interior 90'0", 11920" 2700o 9673-F-101495 9673-F- 101496 Containment Interior 119'0", 192'6" 00- 900 9673-F-101495 SB-IWE-021 9673-F- 101496 SB-IWE-022 Containment Interior 119'0"g 192'6" 900 - 1800 9673-F- 101495 I 9673-F-101496 3-4.5 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN TABLE 4.2 SEABROOK CLASS MC, SUBSECTION IWE INSPECTION AREAS Sheet 2 of 4 Drawing No. Examination Area Elevation Azimuth I Reference Drawings 1 SB-IWE-023 Containment Interior 119'0", 192'6" 180'. 2700 9673-F-101495

_ 9673-F- 10_496 SB-IWE-024 Containment Interior 119'0", 192'6" 270o0 o 9673,F 101495 9673-F- 101496 SB-IWE-025 IWE Boundary for Attachments Varies Varies Electrical Penetrations E-I thru E- See Appendix C Seendix 64 Appendix C Electrical Penetrations E-1 thru 8, See SB-IWE-027 11, 14, 16, 18 thru 32, 34, 35, 38 See Appendix C Appendix C thru 43, 45 thru 50, 52 thru 56 SB-IWE-028 Electrical Penetrations E-17, 51 See Appendix C See Appendix C SB-IWE-029 5 02,3 hu3,48 9SeApni peedx 9673-F-10 1496 Mechanical Penetrations X-I thru See Appendix C Seendix 15, 20,21, 35 thru 38, 48, 49 Apni SB-IWE-030 Mechanical Penetrations X- thru See Appendix C Appendix 9763-F-805575 15, 63 thru 66 Apni SB-IWE-031 Penetration X-38 90'0", 119'0" 1100 9763-F-805574 Mechanical Penetrations X- 16 thru See SB-IWE-032 19, 22 thru 34, 39 thru 47, 50, 51, See Appendix C Appendix C 9463-F-101496 52, 57, 58, 59, 63, 64, 65, 66 thru 72 Mechanical Penetrations X-20 thru See Appendix C Seendix 27, 32, 33 Appendix C SB-WE034 Mechanical Penetrations X-35 thru See 9763F805575 SB-IWE-034 37, 40, 43, 47, 48, 49, 52, 57, 77, 78 See Appendix C Appendix C Mechanical Penetrations X-41, 42, See Appendix C Seendix 44, 45, 46, 51, 58,59,69,70 Appendix C Mechanical Penetrations X- 17, 19, See Appendix C Sendix 28 thru 31, 34, 39, 50, 67, 68 Appendix C SB-IWE-037 Mechanical Penetrations X-60, 61 (-)3 1.', 6" 264'379463-F-1496 2730-15' SB-IWE-038 Mechanical Penetrations X-60, 61 (-)3 1', 6" 264'F37" 9 2730- 15 9763-F-805575 SB-IWE-039 Penetration X-62 (-)9'-41/4" 1840-14' 9763-F-101495 SB-IWE-040 Penetration X-62 (-)9'-41/4" 1840- 14' 9763-F-805573 SB-IWE-041 Penetration X-62 (-)9'-41/4" 184°-14' 9763-F-805573 SB-IWE-042 Mechanical Penetrations X-71 , 72 22'-9" 1130-30', 9763-F-805575 1100 SB-IWE-043 Penetrations HVAC-I & HVAC-2 191-3", 13"-6' 2250, 2350 9763-F-101495 SB-IWE-044 Personnel Lock 29'-6" 3150 9763-F-101495 3-4.6 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN TABLE 4.2 SEABROOK CLASS MC, SUBSECTION IWE INSPECTION AREAS Sheet 3 of 4 Drawing No. Examination Area Elevation Azimuth Reference Drawings SB-IWE-045 Personnel Lock 29'-6" 3150 SB-IWE-046 Equipment Hatch 37'-01/2" 1500 9763-F-101496 SB-IWE-047 Equipment Hatch 37'-01/2" 1500 9763-F-101496 SB-IWE-048 Containment Liner Bottom Plate (-)30'-0" Varies 9763-F-101462 SB-IWE-049 Containment Liner Bottom Plate (-)30'-0" Varies SB-IWE-050 Recirculation Sump/Pump Sump (-)30'-0" Varies 9763-F- 10462 Areas SB-IWE-O5 Recirculation Sump/Pump Sump (-)30'-0" Varies 9763-F- 101462 SB-IWE-051_ Areas SB-IWE-052 Reactor Pit (-)30'-0" Varies 9763-F-101462 SB-IWE-053 Attachment Plates Varies Varies SB-IWE-054 Attachment Plates Varies Varies SB-IWE-055 Attachment Plates Varies Varies 9763-F- 101915 SB-IWE-056 Lift Lugs Varies Varies 9763-F-101915 SB-IWE-057 Lift Lugs Varies Varies 9763-F-101915 SB-IWE-058 Lift Lugs Varies Varies 9763-F-101915 SB-IWE-059 Attachment Plates Varies Varies SB-IWE-060 Attachment Plates Varies Varies 9763-F-101915 SB-IWE-061 Duct Supports Varies Varies 9763-F- 101461 SB-IWE-062 Duct Supports Varies Varies 9763-F-101461 SB-IWE-063 Duct Supports Varies Varies 9763-F-101461 SB-IWE-064 Duct Supports Varies Varies 9763-F-101461 SB-IWE-065 Attachment Plates Varies Varies 9763-F-101461 SB-IWE-066 Liner Attachments Varies Varies 9763-F- 101461 SB-IWE-067 Attachment Plates Varies Varies 9763-F-101461 SB-IWE-068 Fixture Supports Varies Varies 9763-F-101499 SB-IWE-069 Conduit Supports Varies Varies 9763-F- 101499 SB-IWE-070 Duct Supports Varies Varies 9763-F-101499 SB-IWE-071 Duct Supports Varies Varies 9763-F- 101499 SB-IWE-072 Attachment Plate Varies Varies 9763-F-101499 SB-IWE-073 Attachment Plate Varies Varies 9763-F-101499 3-4.7 SUIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN TABLE 4.2 SEABROOK CLASS MC, SUBSECTION IWE INSPECTION AREAS Sheet 4 of 4 Drawing No. Examination Area Elevation Azimuth Reference Drawings SB-IWE-074 Attachment Plate Varies Varies 9763-F- 101499 SB-IWE-075 Equipment Hatch Attachment Varies Varies 9763-F- 101499 SB-IWE-076 Attachment Plate Varies Varies 9763-F- 101499 SB-IWE-077 Attachment Plate Varies Varies 9763-F- 101499 SB-IWE-078 Attachment Plate Varies Varies 9763-F- 101499 SB-IWE-079 Attachment Plate Varies Varies 9763-F- 101499 SB-IWE-080 Attachment Plate Varies Varies 9763-F- 101499 3-4.8 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN TABLE 4.3 SEABROOK CLASS CC, SUBSECTION IWL INSPECTION AREAS Sheet 1 of 2 Drawing No. Examination Area Elevation Azimuth Reference Drawings SB-IWL-001 Containment Interior (-)30'0", 0"0"00-900 9673-F-101495 9673-F-101496

(-)30'0"., 0"0" 9800- 2700 9673-F-101496 9673-F- 101495 SB-IWL-002 Containment Interior SB-IWL-003 Containment Interior (-)30'0", 0"0" 1800-200 9673-F-101495 9673-F- 101496 9Q0 9673-F-b 11495 9673-F-0 149 SB-IWL-004 Containment Interior (-)30'0", 0"0" 00-9673-F- 101496 9673-F- 101496 SB-IWL-006 Containment Interior 0"W", 30"0" 2700 2700 9673-F-101495 9673-F-101496 SB-IWL-007 Containment Interior 0910", 300"l 1802700o 9673-F- 101496 9673-F101495 SB-IWL-008 Containment Interior 0"0", 300' 00900 9673-F-101495 9673-F- 101496 9673-F- 101495 SB-IWL-010 Containment Interior 300", 60'0" 900- 1800 9673-F-101495 9673-F-101496 9673-F- 101496 SB-IWL-012 Containment Interior 300", 60'0" 2700100 9673-F-101495 9673-F- 101495 9673-F- 101496 SB-IWL-0 13 Containment Interior 60'0", 90'0" 00-0 9673-F-101495 9673-F- 101496 SB-IWL-014 Containment Interior 60'0', 90-0" 900- 1800 9673-F-101495 9673-F- 101496 SB-IWL-015 Containment Interior 600", 90'0" 1800-2700 9673-F-101495 SB-I WL-011 Containment Interior 90'0", 9673-F-80-1496 9673-F- 101496 SB-IWL-016 Containment Interior 60'0", 90'0" 2700-00 9673-F--10149 9673-F- 101496 9673-F- 10 1496 SB-IWL-0 17 Containment Interior 90,0" 119'0" 00-0 9673-F-101495 SB-IWL-018 Containment Interior 90'0", 119'0" 900- 1800 9673-F-101495 9673-F-101496 9673-F-101495 SB-IWL-020 Containment Interior 90,0", 1190" 2700-00 9673-F-101495 9673-F- 101496 SB-IWL-021 Containment Interior 019'0", 1926" 70 9673-F-10149 SB-IWL-022 Containment Interior H 910", 192'" 9093-180101495 1__ 900 180' 9673-F- 101496 3-4.9 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN TABLE 4.3 SEABROOK CLASS CC, SUBSECTION IWL INSPECTION AREAS Sheet 2 of 2 Drawing No. Examination Area Elevation Azimuth Reference Drawings 9673-F-b!1495 Containment Interior 119'0", 192'6" 1800- 2700 9673-F-101495 SB-IWL-023 9673 10 1496 Containment Interior 119'0", 192'6" 2700-00 9673F101495 SB-IWL-024 9673-F- 101496 SB-IWL-025 Containment Wall Varies 00 - 2400', 9673-F-101435 3000-360 _

SB-IWL-026 Containment Wall Varies 2400- 3000 9673-F-101435 SB-IWL-027 Containment Wall Varies 00 - 3000 9673-F-101416 3-4.10 SIIR Rev. 13

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CHAPTER 3: CONTAINMENT INSERVICE INSPECTION (CISI) PLAN 5.0

SUMMARY

OF CHANGES Revision 13:

This revision reflects the updated Containment Inservice Inspection (CISI) per Section XI, 2004 Edition, Subsections IWE and IWL for the 2nd 10-Year Interval. Previously these requirements were included in document FP 59253, Primary Containment Inservice Inspection Program Plan, which addressed the 1st 10-Year Interval for CISI.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS Appendix A RELIEF AND ALTERNATIVE REQUESTS (See Section 1.12.4 for Relief and Alternative Request approval status)

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 3IR-1. Revision 0 Relief Request in Accordance with 10 CFR 50.55(g)(5)(iii)

--Inservice Inspection Impracticality--

Sheet I of 4 Request For Relief For Reactor Vessel Welds

1. ASME Code Components Affected Code Class: I System: RC Examination Categories: B-A, Pressure Retaining Welds in Reactor Vessel B-D, Full Penetration Welded Nozzles in Vessels ISI Component IDs: See Table 1

2. Applicable Code Edition and Addenda

NextEra Energy Seabrook (Seabrook) is currently in the 3rd 10-Year Inservice Inspection (ISI)

Interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-Year ISI interval is Section XI, 2004 Edition.

3. Applicable Code Requirements:

ASME Section XI, 2004 Edition, Table IWB-2500-1 Category B-A, Pressure Retaining Welds in Reactor Vessel Item No. B 1.11, Circumferential Shell Welds Item No. B 1.21, Circumferential Head Welds Item No. B 1.40, Head-to-Flange Weld Category B-D, Full Penetration Welded Nozzles in Vessels Item No. B3.90, Nozzle-to-Vessel Welds (Reactor Vessel)

Seabrook has adopted ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds. This Code Case provides the alternative requirement when the entire examination volume or area cannot be examined due to interference by another component or part geometry, a reduction in examination coverage on any Class I or Class 2 weld may be accepted provided the reduction in coverage for that weld is less than 10%.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-1, Revision 0 Sheet 2 of 4

4. Impracticality of Compliance Pursuant to 10CFR50.55a(g)(5)(iii), Seabrook has determined that, due to design and geometric configuration, it is impractical to meet the Code required 100% coverage of Section XI or the alternative examination coverage requirements of Code Case N-460 on welds identified in Table 1.

RPV Circumferential Shell Weld Reactor vessel lower head to lower shell circumferential weld, RC RPV 104-141 is situated just below six (6) core support lugs, which are fixed in place. Each core support lug occupies about 20 degrees of space including the attachment weld. This circumferential weld was completely scanned between the core lugs and the accessible areas below the lugs in both the parallel and perpendicular directions to maximize coverage.

RPV Circumferential Head Weld Reactor vessel lower head circumferential weld, RC RPV 102-151 is located in elevation at the periphery of the lower head penetrations. The weld was scanned in numerous individual segments between and around the penetrations. The end effector was guided into position by cameras and scanning parameters were established to maximize coverage.

RPV Head-to-Flange Weld Reactor vessel head-to-flange weld, RC RPV 101-101 has limited coverage due to close proximity of the weld to the reactor vessel head flange. The weld is sufficiently close such that only a one sided ultrasonic examination is possible. The surface examination of this weld is fully achievable.

RPV Nozzle Welds Four reactor vessel nozzle welds listed in Table 1 have limited coverage due to nozzle protrusion on the outlet nozzle-to-shell weld limiting UT scans.

5. Burden Caused by Compliance To achieve Code required examination coverage per ASME Code Case N-460, redesign of the reactor vessel would be required to effect coverage limitations.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-1, Revision 0 Sheet 3 of 4

6. Proposed Alternative And Basis for Use There are no alternate examinations proposed. Volumetric examination of the subject welds will be completed to the maximum extent practical.

In addition to the limited volumetric examinations, welds identified in Table 1 are subject to VT-2 visual examination conducted during the system leakage test each refueling outage as specified in Table IWB-2500-1, Examination Category B-P of the 2004 Edition of ASME Section XI.

Seabrook believes that the volumetric examination coverage achieved and acceptable UT examination results, as well as previous acceptable results of VT-2 visual examinations, provide reasonable assurance of continued structural integrity of these welds, and an acceptable level of quality and safety is maintained.

7. Duration of Proposed Alternative The alternative requirements of this request will be applied for the remaining duration of the current 3rd 10-year ISI interval.

8. Precedents

• Second interval relief request 21R-I Rev. 0 was approved for Seabrook Station by the NRC in a Safety Evaluation Report dated March 21, 2001 (TAC No. MA9902).

• Second interval relief request 21R-10 Rev. 0 was approved for Seabrook Station by the NRC in a Safety Evaluation Report dated March 21, 2001 (TAC No. MA9902).

This relief request combines the two approved relief requests above from the 2 "d10-Year ISI interval.

Limitations associated with the reactor vessel are presented in this one relief request.

Generally, this relief request presents coverage improvements from the previous interval due to improvements in method and technology. One weld, RC RPV 103-101 (upper reactor vessel head) from the previous interval is not included in this relief due to achievement of> 90% coverage.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS Sheet 4 of 4 31R-1, Revision 0 Table 1 Reactor Vessel Welds Code Code CRV Weld Identification Weld Description Cateeory Item Limitation Coverage RC RPV 104-141 Lower head to shell weld B-A BI.Il Six (6) core support lugs located just above weld. 77%

RC RPV 102-151 Lower head circumferential B-A B 1.21 Interference of lower head penetrations 67%

weld RC RPV 101-101 Upper head to flange weld B-A B 1.40 One-sided exam due to CRD Shield. Obstruction due to 50%

lifting lugs.

RC RPV 107-121-A Nozzle to vessel weld B-D B 3.90 Nozzle protrusion on the outlet nozzle-to-shell weld 86%

RC RPV 107-121-D Nozzle to vessel weld B-D B 3.90 Nozzle protrusion on the outlet nozzle-to-shell weld 86%

RC RPV 107-121-lE Nozzle to vessel weld B-D B 3.90 Nozzle protrusion on the outlet nozzle-to-shell weld 86%

RC RPV 107-121-H Nozzle to vessel weld B-D B 3.90 Nozzle protrusion on the outlet nozzle-to-shell weld 86%

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-2. Revision 0 Relief Request in Accordance with 10 CFR 50.55(g)(5)(iii)

--Inservice Inspection Impracticality--

Sheet I of 4 Request for Relief for Pressurizer and Steam Generator Welds

1. ASME Code Components Affected Code Class: 1 System: RC Examination Categories: B-B, Pressure Retaining Welds in Vessels Other Than Reactor Vessels B-D, Full Penetration Welded Nozzles in Vessels ISI Component IDs: See Table 1

2. Applicable Code Edition and Addenda

NextEra Energy Seabrook (Seabrook) is currently in the 3rd 10-Year Inservice Inspection (ISI)

Interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-Year ISI interval is Section XI, 2004 Edition.

3. Applicable Code Requirements:

ASME Section XI, 2004 Edition, Table IWB-2500-1 Category B-B, Pressure Retaining Welds in Vessels Other Than Reactor Vessels Item No. B2.40, Tubesheet-to-Head Weld (Steam Generators)

Category B-D, Full Penetration Welded Nozzles in Vessels Item No. B3.1 10, Nozzle-to-Vessel Welds (Pressurizer)

Seabrook has adopted ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds. This Code Case provides the alternative requirement when the entire examination volume or area cannot be examined due to interference by another component or part geometry, a reduction in examination coverage on any Class I or Class 2 weld may be accepted provided the reduction in coverage for that weld is less than 10%.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 3IR-2. Revision 0 Sheet 2 of 4

4. Impracticality of Compliance Pursuant to I0CFR50.55a(g)(5)(iii), Seabrook has determined that, due to design and geometric configuration, it is impractical to meet the Code required 100% coverage of Section XI or the alternative examination coverage requirements of Code Case N-460 on the welds identified in Table 1.

Steam Generator Tubesheet-to-Head Weld Steam generator tubesheet-to-head weld, RC E-l I A SEAM-1 can not be examined for essentially 100% of the weld length due to design (physical obstruction from four steam generator support pads).

These pads are approximately 18" in length and block access to this weld where the four steam generator supports are located. These obstructions limit the weld examination volume to 80%.

In addition to the limited volumetric examination, the steam generator tubesheet-to-head weld is subject to VT-2 visual examination conducted during the system leakage test each refueling outage as specified in Table IWB-2500-1, Examination Category B-P of the 2004 Edition of ASME Section XM.

Seabrook believes that previous acceptable results of volumetric examination on 80% of the weld examination volume is representative of the entire weld. In addition to the volumetric examination, the acceptable results of volumetric examination of similar Class 2 girth welds on this steam generator, the acceptable results of visual examinations and pressure tests performed each refueling outage provides reasonable assurance of continued structural integrity of this weld, and maintains an acceptable level of quality and safety.

Pressurizer Nozzle Welds Pressurizer nozzle welds listed in Table 1 have limited coverage due to the nozzle to shell geometry.

The transition from the Pressurizer vessel to nozzle is large over a short distance. This causes transducer sound beam propagation angle to change abruptly thereby not fully interrogating the required ASME examination volume. Each nozzle has its own unique fit-up, weld, and finish contour which presents specific individual limitations on examination volume. As listed in Table 1,these limitations result in coverage from 53% to 80% of the total examination volume.

Seabrook believes that the achievable examination volumes are representative of the entirety of each weld. ASME Code Category B-D, Item No. B3.1 10, requires that all Pressurizer nozzle-to-vessel welds be examined volumetrically. Since all of the nozzles require examination, the probability of finding a flaw is increased. Seabrook believes that it is impractical grind these transitions or add weld material to increase examination volume. These techniques could decrease the level of quality and safety in the Pressurizer nozzle welds.

In addition to the limited volumetric examinations, the Pressurizer nozzle to vessel welds are subject to VT-2 visual examination conducted during the system leakage test each refueling outage as specified in Table IWB-2500-1, Examination Category B-P of the 2004 Edition of ASME Section XI.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-2. Revision 0 Sheet 3 of 4 Seabrook believes that previous acceptable results of volumetric examinations of Pressurizer nozzle to vessel welds, acceptable results of visual examinations during pressure tests performed each refueling outage, provides reasonable assurance of continued structural integrity of these welds, and maintains an acceptable level of quality and safety.

5. Burden Caused by Compliance To achieve Code required examination coverage per ASME Code Case N-460 for the steam generator tubesheet-to-head weld, redesign of the four supports would be required to effect coverage limitations.

For the Pressurizer nozzle-to-shell welds, redesign of the nozzles by grinding or adding weld material would be required to effect coverage limitations.

6. Proposed Alternative And Basis for Use There are no alternate examinations proposed. Volumetric examination of the subject welds will be completed to the maximum extent practical.

7. Duration of Proposed Alternative The alternative requirements of this request will be applied for the remaining duration of the current 3rd 10-year ISI interval.

8. Precedents

• Second interval relief request 21R-2 Rev. 0 was approved for Seabrook Station by the NRC in a Safety Evaluation Report dated March 21, 2001 (TAC No. MA9902)

Generally, this relief request presents some coverage improvements from the previous interval due to improvements technology. Three welds from the previous interval are not included in this relief due to achievement of >90% coverage.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS Sheet 4 of 4 31R-2. Revision 0 Table 1 Nozzle and Circumferential Welds Code Code CRV Weld Identification Weld Description Category Item Limitation Coverage RC E-I IA SEAM-I Steam Generator tubesheet- B-B B2.40 Four (4) Steam Generator support pads 80%

to-head weld RC E-10 A-NZ Pressurizer nozzle-to-shell B-A B3.110 Interference of lower head penetrations 71%

weld RC E-10 B-NZ Pressurizer nozzle-to-shell B-A B3.1 10 Nozzle to shell geometry 55%

weld RC E-10 C-NZ Pressurizer nozzle-to-shell B-D B3.1 10 Nozzle to shell geometry 53%

weld RC E-10 D-NZ Pressurizer nozzle-to-shell B-D B3.1 10 Nozzle to shell geometry 77%

weld RC E-10 S-NZ Pressurizer nozzle-to-shell B-D B3. 110 Nozzle to shell geometry 71%

weld RC E-10 SP-NZ Pressurizer nozzle-to-shell B-D B3.110 Nozzle to shell geometry 77%

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-3, Revision 0 Relief Request in Accordance with 10 CFR 50.55(g)(5)(iii)

--Inservice Inspection Impracticality--

Sheet 1 of 2 Request for Relief for Steam Generator Main Steam Outlet Nozzle Inside Radius Section

1. ASME Code Components Affected Code Class: 2 System: RC Examination Categories: C-B, Pressure Retaining Nozzle Welds in Vessels ISI Component ID: RC E-II A 16-IR

2. Applicable Code Edition and Addenda

NextEra Energy Seabrook (Seabrook) is currently in the 3rd 10-Year Inservice Inspection (ISI)

Interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-Year ISI interval is Section XI, 2004 Edition.

3. Applicable Code Requirements:

ASME Section XI, 2004 Edition, Table IWC-2500-1 Category C-B, Pressure Retaining Nozzle Welds in Vessels Item No. C2.22, Nozzle Inside Radius Section ASME Section XI, 2004, Table IWC-2500-1 Category C-B, Item No. C2.22 - Nozzle Inside Radius Section requires that the inner radius sections of all nozzles at terminal ends of piping runs be volumetrically examined.

Note 4 of Table IWC-2500-1, Category C-B states "in the case of multiple vessels of similar design, size, and service (such as steam generators, heat exchangers), the required examinations may be limited to one vessel or distributed among the vessels."

4. Impracticality of Compliance Pursuant to 10CFR50.55a(g)(5)(iii), Seabrook has determined that due to design and geometry, the volumetric examination requirement for nozzle inside radius section of the Steam Generator Main Steam Outlet Nozzle Inner Radius, RC E-1 IA 16-IR as specified in Table IWC-2500-1, Examination Category C-B, Item No. C2.22 is impractical to meet.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-3. Revision 0 Sheet 2 of 2

5. Burden Caused by Compliance The steam generator main steam outlet nozzle is somewhat typical of a dropout nozzle, which is welded to the head; however, it is unlike a forged dropout, which has an inner radius transition. The main steam outlet nozzle contains a flow limiter device within the bore of the nozzle. This device makes a square transition to the nozzle making it ultrasonically impractical to examine. Outlet nozzle replacement with a different design nozzle would be required to comply with this examination requirement. A replacement of this magnitude would be impractical.

6. Proposed Alternative And Basis for Use No alternate examinations of inner radius section RC E-1 1A 16-IR are proposed.

The steam generator main steam outlet nozzle weld (RC E-I IA 16-NZ) receives a volumetric and surface examination as specified in Table IWC-2500-1, Examination Category C-B of the 2004 Edition of ASME Section XI.

Volumetric coverage of this weld is greater than 90%, which is considered full coverage in accordance with Code Case N-460. Code Case N-460 is approved for use in Regulatory Guide 1.147 and included in the Seabrook 3rd Interval ISI Program. Surface examination coverage of this weld is 100%.

In addition, a VT-2 examination associated with the system pressure test is performed on this weld each inspection period as specified in Table IWC-2500-1, Examination Category C-H of the 2004 Edition of ASME Section XI.

The full volumetric examination coverage, the 100% surface examination coverage, and visual examination associated with the system pressure test conducted on the nozzle weld provide reasonable assurance of continued structural integrity.

7. Duration of Proposed Alternative The alternative requirements of this request will be applied for the remaining duration of the current 3rd 10-year ISI interval.

8. Precedents

• Second interval relief request 21R-4 Rev. 0 was approved for Seabrook Station by the NRC in a Safety Evaluation Report dated March 21, 2001 (TAC No. MA9902)

This relief request is essentially the same as 21R-4 approved for the 2 nd 10-Year ISI interval. One difference is the omission of weld CS E-3 C. This weld is on the Excess Letdown Heat Exchanger, which is exempt per the 2004 Edition of ASME Section XI.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-4. Revision 0 Proposed Alternative in Accordance with CFR 50.55a(a)(3)(ii)

--Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety--

Sheet I of 2 Request for Relief for Pressurizer Supports

1. ASME Code Components Affected Code Class: I System: RC Examination Category: F-A Item No: F 1.40, Supports Other Than Piping ISI Component ID: RC E-10 A-LUG Support RC E-10 B-LUG Support RC E-10 C-LUG Support RC E-10 D-LUG Support

2. Applicable Code Edition and Addenda

NextEra Energy Seabrook (Seabrook) is currently in the 3rd 10-Year Inservice Inspection (ISI)

Interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-Year ISI Interval is Section Xl, 2004 Edition.

3. Applicable Code Requirement

ASME Section XI, 2004 Edition, Table IWF-2500-1 Category F-A, Supports Item No. F 1.40, Supports Other Than Piping

4. Reason for Request

Pursuant to I OCFR50.55a(a)(3)(ii), relief is requested from performing the visual examination of the four Pressurizer supports on the basis that meeting the Code requirements present unusual difficulty.

A 15" thick concrete shield wall weighing approximately 85,000 pounds surrounds the Seabrook Pressurizer approximately three quarters of the way around. The clearance between the shield wall and the Pressurizer vessel is approximately 91/2/2". The north end of the cubicle has greater vessel to shield wall clearance, but is where safety valve piping and spray piping run. Ladders or platforms do not exist to make the examination area accessible nor can any ladders be placed due to restrictions by piping, conduit and other attachments.

The subject supports are associated with seismic lugs and are located on the Pressurizer at elevation 23 '-6".

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-4, Revision 0 Sheet 2 of 2 Potential access is gained by climbing a ladder on the outside of the shield wall and entering the cubicle at the top of the Pressurizer at elevation 50'. Safety valve structural steel is used for footing as no platform exists in the cubicle. The Seabrook Safety Department evaluated the lack of normal and emergency access/egress as an unsafe work environment.

Consideration was given to remote visual techniques, but overcoming the nearly 27' distance containing numerous obstacles also presented unusual difficulty.

5. Proposed Alternative and Basis for Use:

No alternate examinations for the Pressurizer supports are proposed.

The unusually difficult normal and emergency access/egress inside this highly restricted enclosure to perform the visual examinations does not provide a compensating increase in quality and safety.

A likely failure mechanism of these supports would involve a transient or seismic activity, which could impose rotational forces on the Pressurizer. Attached lugs that exist between these supports could impart forces on the supports from a transient or seismic event. There has been no documented seismic event or transient affecting the Pressurizer. These attachments are subject to VT-2 visual examination as part of the system leakage test on the Pressurizer vessel conducted each refueling outage as specified in Table IWB-2500-1, Examination Category B-P of the 2004 Edition of ASME Section XI. The VT-2 examination provides evidence that potential damage to the lugs has not breached the pressure boundary of the Pressurizer.

6. Duration of Proposed Alternative The alternative requirements of this request will be applied for the remaining duration of the current 3rd 10-year ISI interval.

7. Precedents

• A similar first interval relief request, IR-12 Rev. 0 was approved for Seabrook Station by the NRC in a letter dated September 3, 2002 (TAC No. MB2561)

" A second interval relief request, 21R-12 Rev. 0 was approved for Seabrook Station by the NRC for the B-K components listed in this relief request in a letter dated March 21, 2001 (TAC No.

MA9902)

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-5, Revision 0 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety-Sheet I of 4 Request for Relief to use PDI Demonstrated Ultrasonic Techniques for the Examination of the Reactor Pressure Vessel Flange-to-Upper Shell Weld

1. ASME Code Components Affected Code Class: I System: RC Examination Categories: B-A Item No.: B1.30, Shell-to-Flange Weld ISI Component ID: RC RPV-101-121

2. Component Detail Drawing:

4,, C0

'-,4 SE ,','A'S f__ 1- , W0° 1"0' '7r' U)

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-5, Revision 0 Sheet 2 of 4

3. Applicable Code Edition and Addenda

NextEra Energy's Seabrook Station (Seabrook) is currently in the 3rd 10-year Inservice Inspection (ISI) interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-year ISI interval is Section XI, 2004 Edition (Reference 1).

4. Applicable Code Requirement

ASME Section XI, 2004 Edition, Appendix I, Article 1-2 100, paragraph (b) requires "Ultrasonic examination of reactor vessel-to-flange welds shall be conducted in accordance with Article 4 of ASME Section V, except that alternative examination beam angles may be used. These examinations shall be further supplemented by Table 1-2000-I ."

5. Reason for Request

Seabrook is performing volumetric examinations of all Reactor Pressure Vessel (RPV) welds during the upcoming ten-year RPV Inservice Inspection (ISI). Seabrook is required to perform the ten-year RPV ISI pursuant to I0CFR50.55a. The Code requires that Ultrasonic (UT) examination of RPV welds, excluding the vessel-to-flange weld, shall be with techniques that have been demonstrated in accordance with AMSE Code Section Xl, Appendix VIII. Further, in accordance with Appendix I, Paragraph 1-21 10(b), "Ultrasonic examination of reactor vessel-to-flange welds, closure head-to-flange welds, and integral attachment welds shall be conducted in accordance with Article 4 of Section V, except that alternative examination beam angles may be used."

Examination from the inside surface provides the best access for examination of the RPV shell-to-flange weld. The flange forging contains both inside and outside surface tapers, the outside taper angle is more than twice the angle of the inside surface taper. While both tapers will interfere with the examination to some degree, the inside surface taper provides the least amount of interference.

Additionally, the outside surface of the RPV is typically inaccessible due to its placement inside the biological-shield wall and the installed insulation. Examination of this weld from the outside surface would require the removal of the installed insulation and access beneath the cavity seal ring. These efforts would result in significant personnel radiation exposure without a compensating increase in the level of quality and safety.

Although the reactor vessel-to-flange weld is specifically excluded from the referenced codes requiring Appendix VIII/PDI qualified techniques, Seabrook believes that performing the reactor vessel-to-flange weld examination with PDI qualified personnel and procedures from the inside surface will provided an acceptable level of quality and safety.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-5, Revision 0 Sheet 3 of 4

6. Proposed Alternative And Basis for Use In lieu of requirements specified in the ASME Code, Section XI, Appendix I, Subarticle 1-2110, Paragraph (b), Seabrook proposes to use procedures, personnel, and equipment qualified to the requirements of ASME Section XI Appendix VIII, Supplements 4 and 6 of the 2004 Edition, as administered by the Electric Power Research Institute's (EPRI) PDI program to conduct the vessel-to-flange weld examination. The RPV examination vendor will perform examinations designed to achieve the maximum coverage possible utilizing PDI qualified procedures and personnel from the inside surface. The proposed alternative represents the best techniques, procedures, and qualifications available to perform UT examinations of RPV welds. The PDI program addresses qualification requirements for each of the supplements that are defined in Appendix VIII of ASME Section XI. The applicable vendor procedure has been qualified in accordance with PDI's implementation of Supplements 4' and 62 of Appendix VIII.

The listed weld is the only circumferential shell weld in the RPV that is not examined with ASME Section XI, Appendix VIII techniques, as mandated in 10 CFR 50.55a. This rule mandates the use of ASME Section XI, Appendix VIII, Supplements 4 and 6 for the conduct of all other RPV weld examinations. Per Appendix I, Article 1-2 100, paragraph (b), ASME Section V, Article 4 techniques shall be used for the listed weld. ASME Section V, Article 4 describes required techniques to be used for UT of welds in ferritic pressure vessels with wall thicknesses greater than 2 inches. The calibration techniques, recording criteria and flaw sizing methods are based upon the use of a distance-amplitude-correction curve (DAC) derived from machined reflectors in a basic calibration block. UT performed in accordance with Section V, Article 4, uses recording thresholds known as percent of DAC for recording and reporting of indications within the examination volume. Indications detected in the exam volume, with amplitudes below these thresholds, are not required to be recorded and/or evaluated. Use of the Appendix VIII qualified techniques would enhance the quality of the examination.

The detection criterion is more conservative and the procedure requires the examiner to evaluate all indications determined to be flaws regardless of their amplitude. The recording thresholds in Section V, Article 4 are generic and do not take into consideration of such factors as flaw orientation, which can influence the amplitude of UT responses.

1'"QUALIFICATION REQUIEMENTS FOR THE CLAD/BASE METAL INTERFACE OF REACTOR VESSEL" 2

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 31R-5, Revision 0 Sheet 4 of 4 EPRI Report NP-6273, "Accuracy of Ultrasonic Flaw Sizing Techniques for Reactor Pressure Vessels," dated March 1989, contains a comparative analysis of sizing accuracy for several different techniques. The results show that UT flaw sizing techniques based on tip diffraction are the most accurate. The proposed alternative Appendix VIII UT qualified detection and sizing methodologies use analysis tools based upon echo dynamics and tip diffraction. This methodology is considered more sensitive and accurate than the Section V, Article 4 processes. Procedures, equipment and personnel qualified via the PDI Appendix VIII, Supplement 4 and 6 programs have been demonstrated to have a high probability of detection and are generally considered superior to the techniques employed during earlier Section V, Article 4 RPV examinations. Accordingly, approval of this alternative examination and evaluation process is requested pursuant to 10 CFR 50.55a (a)(3)(i).

7. Duration of Pronosed Alternative The alternative requirements of this request will be applied for the duration of up to and including the last outage of the current 3rd 10-year ISI interval.

8. Precedents Similar relief requests have been granted to the following plants:

" Second interval relief request 21R- 15 Rev. 0 was approved for Seabrook Station by the NRC in a Safety Evaluation Report dated April 7, 2009 (TAC No. MD9784)

" NRC Safety Evaluation dated October 20, 2004, for Catawba Nuclear Station, Units I and 2; McGuire Nuclear Station, Unit 2, and Oconee Nuclear Station, Unit 3, dated July 14, 2004, "Request for Relief for Use of an Alternate to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, for Reactor Vessel Examinations RR-04-GO-002 (TAC Nos. MC3804, MC3805, MC3807, and MC3810)" (ML420040261)

" NRC Safety Evaluation dated August 2, 2005, for Browns Ferry Units 1, 2 and 3; Sequoyah Nuclear Plant Units 1 and 2; and Watts Bar Nuclear Plant Unit 1, "in-service Inspection Program Relief Request PDI-4 (TAC Nos. MC6232, MC6233, MC6234, MC6235, MC6236, and MC6237)" (ML051730487)

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS Alternative To Inservice Inspection Requirements 31R-16, Revision 0 10 CFR 50.55a REQUEST Proposed Alternative in Accordance with 10 CFR 50.55a(g)(5)(iii)

REQUEST FOR RELIEF TO USE AN ALTERNATIVE TO THE DEPTH SIZING QUALIFICATION REQUIREMENT OF ASME SECTION XI, SUPPLEMENT 10 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE FOR SEABROOK UNIT 1 Sheet I of 4 ASME Code Components Affected Code Class: 1 System: RC Examination Categories: R-A, Risk Informed Inservice Inspection Program ISI Component IDs: See Table I TABLE 1 WELD NUMBERS BY ISI DESIGNATION Item Location Nozzle-to-Safe End Weld Type Weld I RPV "A" Outlet Nozzle @2020 RC RPV-SE-301-121-A Shop 2 RPV "B" Inlet Nozzle, @247' RC RPV-SE-302-121 -B Shop 3 RPV "C" Inlet Nozzle, @293' RC RPV-SE-302-121-C Shop 4 RPV "D" Outlet Nozzle, @3380 RC RPV-SE-301-121-D Shop 5 RPV "E" Outlet Nozzle, @22' RC RPV-SE-301-121-E Shop 6 RPV "F" Inlet Nozzle, @67' RC RPV-SE-302-121-F Shop 7 RPV "G" Inlet Nozzle, @1130 RC RPV-SE-302-121-G Shop 8 RPV "H" Outlet Nozzle, @158' RC RPV-SE-301-121-H Shop A-18 SIIR Rev. 13

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 10 CFR 50.55a REQUEST Proposed Alternative in Accordance with 10 CFR 50.55a(g)(5)(iii)

REQUEST FOR RELIEF TO USE AN ALTERNATIVE TO THE DEPTH SIZING QUALIFICATION REQUIREMENT OF ASME SECTION XI, SUPPLEMENT 10 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE FOR SEABROOK UNIT 1 Sheet 2 of 4

Applicable Code Edition and Addenda

Seabrook Station (Seabrook) is currently in the 3rd 10-year In-service Inspection (ISI) interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-year ISI interval is Section XI, 2004 Edition (Reference 1).

Applicable Code Requirement

The examination of Class I piping welds are required to be performed using procedures, personnel and equipment qualified to the criteria of the applicable ASME Code, Section XI, Appendix VIII, Supplements. The applicable supplement to this relief is 10, "QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS".

Paragraph 3.2, "Sizing Acceptance Criteria," Subparagraph (b) of Supplement 10, states that the "examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS [root mean square] error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125-inch (3.2mm).

Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping Welds, Section XI, Division I ", provides alternative requirements to Appendix VIII, Supplement 10. Paragraph 3.3(c) of Code Case N-695 states, "Examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, do not exceed 0.125-in.

(3 mm)". Code Case N-695 is unconditionally approved for use through Regulatory Guide 1.147, "In-service Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 16.

Impracticality of Compliance Seabrook is performing volumetric examination of the RPV nozzle-to-safe end dissimilar metal (DM) welds from the inside surface during the upcoming ten-year RPV ISI. Seabrook will implement the NRC approved alternative requirements of Code Case N-695 for the qualification of procedures and personnel for examinations performed during the upcoming ten-year RPV ISI.

This relief is being submitted due to the impracticality of meeting the required 0.125- inch RMS value required by Code Case N-695. Code Case N-695 requires that qualified procedures and personnel shall demonstrate a flaw depth sizing error less than or equal to 0.125-inch RMS.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 10 CFR 50.55a REQUEST Proposed Alternative in Accordance with 10 CFR 50.55a(g)(5)(iii)

REQUEST FOR RELIEF TO USE AN ALTERNATIVE TO THE DEPTH SIZING QUALIFICATION REQUIREMENT OF ASME SECTION XI, SUPPLEMENT 10 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE FOR SEABROOK UNIT I Sheet 3 of 4 The nuclear power industry has attempted to qualify personnel and procedures for depth sizing examinations performed from the inside surface of dissimilar metal welds (Supplement 10, Code Case N-695) since November 2002. To date, no personnel or procedure has achieved less than or equal to the ASME Code required 0.125-inch RMS error. This has been verified by Seabrook in Reference 2.

The inability of examination procedures to achieve the required RMS value is primarily due to a combination of factors such as surface condition, scan access, base materials and the dendritic structure in the welds themselves. Combination of these factors has proven too difficult for procedures and personnel to achieve an RMS value that meet current Code requirements or Code Case N-695.

Burden Caused by Compliance The most recent attempt at achieving 0.125-inch RMS was in early 2008. This attempt, as well as previous attempts, did not achieve the required RMS values for personnel or procedures. The qualification attempts have been substantial. The attempts have involved multiple; vendors, ultrasonic instruments, personnel and flaw depth sizing methodologies, all of which have been incapable of achieving the 0.125-inch RMS value.

The process of qualification for this type of flaw sizing is well established. The cost and effort involved to perform a successful demonstration is quantifiable when a capable technique is available. However, when a capable technique is not available, the costs and effort required for a successful demonstration cannot be easily quantified.

Proposed Alternative And Basis for Use Seabrook proposes using an alternative depth-sizing RMS error value greater than the 0.125-inch RMS error value stated in Code Case N-695 for the examination of welds listed in Table 1 of this relief request.

Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested to use an alternative that will provide an acceptable level of quality and safety.

As an alternative to the required RMS error stated in Code Case N-695 for procedure and personnel depth sizing, Seabrook will add the difference between the required RMS value of 0.125-inch RMS and the actual RMS value achieved by our inspection vendor to the flaw depth as determined during flaw sizing.

The inspection vendor chosen has achieved an RMS of 0.189" for Supplement 10 welds.

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APPENDIX A: RELIEF AND ALTERNATIVE REQUESTS 10 CFR 50.55a REQUEST Proposed Alternative in Accordance with 10 CFR 50.55a(g)(5)(iii)

REQUEST FOR RELIEF TO USE AN ALTERNATIVE TO THE DEPTH SIZING QUALIFICATION REQUIREMENT OF ASME SECTION XI, SUPPLEMENT 10 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE FOR SEABROOK UNIT 1 Sheet 4 of 4 Applying the difference between the required RMS error and the achieved RMS error to the actual flaw size, will ensure a conservative flaw bounding approach and provide an acceptable level of quality and safety.

Duration of Proposed Alternative The alternative requirements of this request will be applied for the remaining duration of the current 3rd 10-year ISI interval.

Precedents Similar relief requests have been granted to the following plants:

" NRC to Southern Nuclear Operating Company Inc. letter, "Joseph M. Farley Nuclear Plant Unit 1, and Vogtle Electric Generating Plant, Units I and 2 - Evaluation of Relief Request ISI-GEN-ALT 02," (TAC Nos. MD 2482, MD2483 and MD2484), dated September 29, 2006, (ML062770359)

" NRC to Exelon Generating Company, LLC letter, "Braidwood Station, Units I and 2 - Relief Request (12R-49) Regarding In-service Inspection Program Alternative Method (TAC Nos. MD5996 and MD5997)," dated November 8, 2007, (ML072760048)

References

1. ASME Code, Section XI, 2004 Edition.

2. EPRI Letter Dated 6/30/08, "Summary of WESDYNE International, LLC Supplements 2 & 10 depth sizing results obtained from the inside surface.

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