ML033630741

Response to NRC Bulletin 2002-02 Reactor Pressure Vessel Head and Vessel Head Penetration Nozzle Inspection Programs

ML033630741
Person / Time
Site:	Summer
Issue date:	12/23/2003
From:	Byrne S South Carolina Electric & Gas Co
To:	Cotton K Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-02-002, RC-03-0254
Download: ML033630741 (17)

Text

Stephen A. Byrne Senior Vice President, Nuclear Operations 803.345.4622 December 23, 2003 A SCANA COMPANY RC-03-0254 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Ms. K. R. Cotton

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 RESPONSE TO NRC BULLETIN 2002-02 REACTOR PRESSURE VESSEL HEAD AND VESSEL HEAD PENETRATION NOZZLE INSPECTION PROGRAMS

Reference:

1. S. A. Byrne (SCE&G) letter to Document Control Desk (NRC),

RC-02-0160, (30 day after start-up) Response to NRC Bulletin 2002-02, September 12, 2002

2. K. R. Cotton (NRC) letter to S. A. Byrne (SCE&G), Virgil C. Summer Nuclear Station, Unit No. 1 - Response to NRC Bulletin 2002-02, "Reactor Pressure Vessel Head and Vessel Head penetration Nozzle Inspection Programs" (TAC No. MB5928), December 23, 2002

3. NRC, February 11, 2003 Order Establishing Interim inspection Requirements for Reactor Vessel Heads at Pressurized Water Reactors (EA-03-009)

4. S. A. Byrne (SCE&G) letter to Document Control Desk (NRC),

RC-03-0048, Response to NRC Order, February 28, 2003 The U. S. Nuclear Regulatory Commission (NRC) issued NRC Bulletin 2002-02 to require that pressurized water reactor (PWR) utilities to provide information related to their reactor pressure vessel (RPV) head and vessel head penetration (VHP) nozzle inspection programs.

The information was to include a summary discussion of inspection program plans to supplement their required visual inspections with non-visual non-destructive examination (NDE) methods, or justification for reliance on visual examinations as the primary method to detect degradation.

SCE&G I Virgil C Summer Nuclear Station

• P. 0. Box 88

• Jenkinsville, South Carolina 29065.T (803) 345.5209.www.scana.com

Document Control Desk 0-C-02-2640 RC-03-0254 Page 2 of 3 South Carolina Electric & Gas (SCE&G) Company provided the required response through Reference 1 on September 12, 2002. In this response, SCE&G indicated that it would implement the EPRI Material Reliability Program (MRP) Inspection Plan and comply with its requirements beginning with the conduct of a planned bare metal visual (BMV) inspection during RF-14.

SCE&G noted that the MRP Inspection Plan is consistent with the inspection commitments SCE&G made in its responses to Bulletin 2001-01 and Bulletin 2002-01, and is more rigorous.

The NRC stated through Reference 2 on December 23, 2002, that the SCE&G plan to perform a 100-percent BMV inspection during RF-14 would provide reasonable assurance of adequate protection of public health and safety. It was noted that SCE&G was to provide the inspection scope and results within 30 days after plant restart following the inspection of the RPV head and VHP nozzles.

On February 11, 2003, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 3) in accordance with 10 CFR 2.202 that established interim inspection requirements for pressurized water reactor (PWR) vessel heads.

Licensees were required by Section V of the Order to submit an answer in accordance with 10 CFR 2.202 within twenty (20) days of date of the Order.

SCE&G provided the required response through Reference 4 on February 28, 2003. In this response, SCE&G indicated that it would comply with the Order and submit the inspection results within 60 days of plant re-start as required.

As the requirements are the same for both responses, SCE&G acting for itself and as agent for South Carolina Public Service Authority, hereby submits the attached in response to these requirements.

Should you have questions, please call Mr. Ronald B. Clary at (803) 345-4757.

I certify under penalty of perjury that the foregoing is true and correct.

Executed on Stephen A. Byrne JT/SAB/dr Attachments (3)

Document Control Desk 0-C-02-2640 RC-03-0254 Page 3 of 3 c:

N. 0. Lorick N. S. Cams T. G. Eppink (w/o Attac-R. J. White L. A. Reyes K. R. Cotton A. L. Bennett S. C. Lee NRC Resident Inspector K. M. Sutton NSRC RTS (C-02-2640, C File (815.02, 815.07)

DMS (RC-03-0254) iments)

.0447)

Document Control Desk Letter Attachment I 0-C-02-2640 RC-03-0254 Page 1 of 3 30-Day After Re-start from Refueling Outage 14 Response to NRC regarding February 11, 2003 Order and NRC SER issued from VCSNS Refueling Outage 13 (Bulletin 2002-02 "Reactor Pressure Vessel Head and Vessel Head Penetration Nozzle Inspection Programs")

for V. C. Summer Nuclear Station Discussion VCSNS Engineering personnel conducted an evaluation of video inspection performed between the reactor vessel head insulation and the reactor vessel head.

EPRI Report Visual Examination for Leakage of PWR Reactor Head Penetrations on Top of RPV Head", Revision 1 (TR 1006296) was used as guidance for the evaluation. Attachment II contains comments about the as found conditions of each penetration. Control Rod Drive Mechanism (CRDM) penetration numbers are identified on Attachment Ill.

The following are general comments on the vessel head inspection video:

Dirt, Debris, and Miscellaneous Comments

1. Insulation collars on several tubes, which are all not specifically identified, were not fully flush with the bottom of the insulation. This is considered a cosmetic item and no corrective action is needed.

2. There were small amounts of debris (dust, dirt, etc.) adjacent to several of the tubes and on the general area of the vessel head. This debris is small in size and is not considered to be a concern.

Most of this debris had accumulated on the uphill side of the tubes. None of these accumulations are considered large enough to conceal any boric acid deposits. Most of the debris was blown from the area of the CRDMs during the video inspection.

3. In addition to this small debris, a nail, washer, bolt, and lockwasher were blown from the vicinity of the CRDM. These items are also not a concern because they are very small (cannot cause any damage to the head), the area on the top of the head is encapsulated by the insulation, and there is no airflow in this area to move the objects.

4. No signs of pitting or corrosion were noted on any of the tube surfaces or on the surface material of the vessel head.

Boron Deposition Comments A close inspection of 360 degrees of each penetration-to-head interface (annulus) was performed to determine if any boron deposits were present that had a popcom" or "stalagmite" appearance as described in sections 6.2.2 and 6.2.3 of EPRI Report TR 1006296. No boron deposits were found to be originating from the annulus area.

Document Control Desk Letter Attachment I O-C-02-2640 RC-03-0254 Page 2 of 3 Traces of boric acid were noted on several of the tubes. The deposits were very thin films of dried boron that originated from above the reactor vessel head insulation and trickled down the tubes. This trickle was noted on 36 of the 65 tubes (or on the insulation at the top of the tube). The majority of the boron did not make it all the way to the surface of the reactor vessel.

The only areas where it did make it to the vessel head were at tubes 27, 47, 51, 55, and 59. The boron was a thin dry film on the tube and on the vessel head surface. All areas on the vessel head were sampled. CRDM #50 was also sampled because of the thickness and it was not identified in RF-13 because of the nature of the video inspection. Chemical analysis showed that all swipes of the residue on the surface of the vessel head dated to greater than two years (Ref. 19). No corrosion was noted on the head surface. A dry film of boron is not considered to be a corrosion threat to carbon steel materials. Although there is no concern with leaving this thin film of boron on the head surface, all areas identified above were adequately cleaned to the extent practical to assure that there was no adverse impact from the accumulations.

In 2002 after the video inspection, QC inspected the top surface of the reactor vessel head. This inspection was performed from the crane looking down on the vessel head assembly. No signs of boric acid residue were found on the top surface of the head insulation or at the top of the CRDM and conoseal housings. Since all on the samples of boric acid residue was dated to greater than two years, it is likely that the leakage occurred sometime earlier in plant life.

The boron deposits are all consistent with leakage found at relatively low temperatures. Each deposit is a thin film that has uniform thickness, indicating that the leakage was allowed to trickle and dry. This would indicate that the leakage occurred during shutdown conditions where the metal temperatures were relatively low and the boron concentrations were relatively high. In contrast, a leak at higher temperatures would evaporate quickly when contact was made with the hot surfaces, leaving a buildup at that point of contact instead of a uniform film.

Cleaning Results The reactor vessel was adequately cleaned to the extent practical considering the high dose rates in the general area to assure that there was no adverse impact from the Boric Acid residue. The areas cleaned were videoed to show the as left conditions. The cleaning video was reviewed by VCSNS engineering.

Great consideration was given to the dose rates in the vicinity of the head.

In the cleaning plan, CRDMs 27, 47, 50, 51, 55 and 59 were treated with the highest concern because they had the most dried residue and/or were in areas where the dried film went onto the vessel head.

Also, as a result of the cleaning efforts, CRDMs 44, 62, 63, 42, 46, and 58 were cleaned. All of the additional CRDMs that were cleaned are in the vicinity of the CRDMs that were treated with the highest concern. Cleaning was terminated because of high dose concerns. Attachment II contains comments about the as left conditions of the penetrations after the cleaning.

Leakage History Since the boric acid residue sampled dates greater than two years and there are no cases reported since the last vessel head inspection, prior historical reviews for leakage are still valid. Due to head design, the most likely sources of leakage that could have caused the boron deposits are the conoseals, the vessel head vent assembly, and the RVLIS connection.

Document Control Desk Letter Attachment I 0-C-02-2640 RC-03-0254 Page 3 of 3 Conoseal penetrations are identified by housings 47, 49, 51, 59 and 55 on Attachment ll. Leakage has been noted in the past, but not specifically on the conoseal for housing 47. However, the leakage from other conoseals could have run across the top of the insulation and entered through the insulation at a different location.

A historical review for the RVLIS and Reactor Head Vent piping attached to the reactor vessel was performed.

No documented evidence could be found of leakage from the mechanical joints associated with these lines.

In summary, the time and location of the leakage that caused the deposits has not been positively determined; however, it is highly likely that the source of the leakage can be attributed to previous leaks from the instrumentation conoseals.

Material Comments The vessel head is SA 533, Grade B, Class 1 alloy steel and the CRDM housings are Inconel. The primary concern for the leakage onto the vessel head material is boric acid induced corrosion of the metals from the boric acid in the primary coolant that leaked from the RCS. This type of process fluid has the capability, under the right conditions, to be highly corrosive to carbon and certain low alloy steels. The corrosion mechanism of greatest concern due to leakage of borated water is uniform corrosion, or wastage.

Conclusion The video inspection shows no evidence of boric acid leakage from the CRDM penetrations on the Reactor Vessel Head.

The minor boron deposits found on the head have not resulted in any corrosion of the vessel head material. This deposit is not from an active leak and does not pose a future corrosion concern since it was a dry film. The boron residue that was found on the vessel head was cleaned to the extent practical. The debris noted during this inspection is considered very minor. Only some of the debris was cleaned off, but leaving some of the debris on the head surface will pose no concern. There is no indication of any degradation of materials and structural integrity is unaffected.

Document Control Desk Letter Attachment II O-C-02-2640 RC-03-0254 Page 1 of 10 As Found conditions:

CRDM Boric Acid Ins ection Remarks Other Remarks As found As left As found As left 1

Possible evidence of very slight This CRDM was not cleaned and

1. Small amount of debris around During initial inspection, the boron deposit (dried trickle) on the was left as it was found.

the tube.

majority of the debris was blown tube. Deposit was a dried thin film

2. Insulation collar around the away from the circumference of the that originated from above the tube is not fully flush with the CRDM.

insulation and did not reach the insulation.

vessel head.

2 Possible evidence of very slight This CRDM was not cleaned and

1. Small amount of debris around During initial inspection, the boron deposit (dried trickle) on the was left as it was found.

the tube blown away by air majority of the debris was blown tube. Deposit was a dried thin film blower.

away from the circumference of the that originated from above the

2. Insulation collar around the CRDM.

insulation and did not reach the tube is not fully flush with the vessel head.

insulation.

3 Evidence of very slight boron This CRDM was not cleaned and

1. Slight amount of debris.

During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

2. Washer on vessel head next to majority of the debris was blown Deposit was a dried thin film that the tube blown to the side.

away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

4 Evidence of very slight boron This CRDM was not cleaned and No debris noted.

No debris noted.

deposit (dried trickle) on the tube.

was left as it was found.

Deposit was a dried thin film that originated from above the insulation and did not reach the vessel head.

5 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris around During initial inspection, the was left as it was found.

tube.

majority of the debris was blown away from the circumference of the CRDM.

6 No boron deposits were observed.

This CRDM was not cleaned and

1. Small amount of debris around During initial inspection, the was left as it was found.

the tube.

majority of the debris was blown

2. Insulation collar around the away from the circumference of the tube is not fully flush with the CRDM.

insulation.

3. Nail found between this tube and tube 10.

Document Control Desk Letter Attachment II 0-C-02-2640 RC-03-0254 Page 2 of 10 CRDM Boric Acid Ins ection Remarks Other Remarks Asfound As left Asfound As left 7

Possible evidence of very slight This CRDM was not cleaned and No debris noted.

No debris noted.

boron deposit (dried trickle) on the was left as it was found.

tube. Deposit was a dried thin film that originated from above the insulation and did not reach the vessel head.

8 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris around the During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

9 Evidence of very slight boron This CRDM was not cleaned and

1. Small amount of debris around During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

the tube.

majority of the debris was blown Deposit was a dried thin film that

2. Possible piece of steel wool away from the circumference of the originated from above the coming out from the insulation.

CRDM.

insulation and did not reach the vessel head.

10 Evidence of very slight boron This CRDM was not cleaned and

1. Small amount of debris on the During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

uphill side of the tube.

majority of the debris was blown Deposit was a dried thin film that

2. Nail found between this tube away from the circumference of the originated from above the and tube 6.

CRDM.

insulation and did not reach the vessel head.

11 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris.

During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

12 No boron deposits were observed.

This CRDM was not cleaned and

1. Small amount of debris around During initial inspection, the was left as it was found.

the tube.

majority of the debris was blown

2. Piece of steel wool coming out away from the circumference of the between collar and insulation.

CRDM.

Piece of steel wool is coming out between collar and insulation.

Document Control Desk Letter Attachment II O-C-02-2640 RC-03-0254 Page 3 of 10 CRDM Boric Acid Ins ection Remarks Other Remarks Asfound As left Asound As left 13 No boron deposits were observed.

This CRDM was not cleaned and Slight amount of debris on uphill During initial inspection, the was left as it was found.

side of tube.

majority of the debris was blown away from the circumference of the CRDM.

14 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris.

During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

15 Evidence of very slight boron This CRDM was not cleaned and No debris noted.

No debris noted.

deposit (dried trickle) on the tube.

was left as it was found.

Deposit was a dried thin film that originated from above the insulation and did not reach the vessel head.

16 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris on the uphill During initial inspection, the was left as it was found.

side of the tube.

majority of the debris was blown away from the circumference of the CRDM.

17 No boron deposits were observed.

This CRDM was not cleaned and

1. Surface scratch at base of Surface scratch at base of tube.

was left as it was found.

tube.

During initial inspection, the

2. Small amount of debris around majority of the debris was blown tube.

away from the circumference of the CRDM.

18 No boron deposits were observed.

This CRDM was not cleaned and No debris noted.

No debris noted.

was left as it was found.

19 Evidence of very slight boron This CRDM was not cleaned and

1. Small amount of debris on the During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

uphill side of the tube.

majority of the debris was blown Deposit was a dried thin film that

2. Insulation collar around the away from the circumference of the originated from above the tube does not appear to be CRDM. Insulation collar around insulation and did not reach the flush with the insulation.

the tube does not appear to be vessel head.

flush with the insulation.

Document Control Desk Letter Attachment II 0-C-02-2640 RC-03-0254 Page 4 of 10 CRDM Boric Acid Ins Icton Remarks Other Remarks As found As left As found As left 20 No boron deposits were observed.

This CRDM was not cleaned and

1. Small amount of debris around During initial inspection, the was left as it was found.

the tube.

majority of the debris was blown

2. Possible slight scratch on tube away from the circumference of the surface.

CRDM.

Possible slight scratch on tube surface.

21 Evidence of very slight boron This CRDM was not cleaned and

1. Housing appears to have a Housing appears to have a slight deposit (dried trickle) on the tube.

was left as it was found.

slight surface scratch.

surface scratch.

Deposit was a dried thin film that

2. Small amount of debris around During initial inspection, the originated from above the tube.

majority of the debris was blown insulation and did not reach the away from the circumference of the vessel head.

CRDM.

22 No boron deposits were observed.

This CRDM was not cleaned and

1. Small amount of debris/dust Brownish stain on head on the was left as it was found.

around tube.

uphill side of the tube.

2. Brownish stain on head on the During initial inspection, the uphill side of the tube.

majority of the debris was blown away from the circumference of the CRDM.

23 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris around the During initial inspection, the was left as it was found.

tube.

majority of the debris was blown away from the circumference of the CRDM.

24 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris on the uphill During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

side of the tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

25 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris noted on During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

the uphill side of tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

Document Control Desk Letter Attachment II 0-C-02-2640 RC-03-0254 Page 5 of 10 CRDM Boric Acid Ins!ection Remarks Other Remarks As found As left As found As left 26 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris/dust around During initial inspection, the was left as it was found.

tube.

majority of the debris was blown away from the circumference of the CRDM.

27 Small amount of boron deposit There is a thin film or stain that is Small amount of debris noted on During initial inspection, the noted at top of insulation, with dry, nearly transparent. No the uphill side of tube.

majority of the debris was blown trickle down the tube. Thin film on evidence of any degradation of the away from the circumference of the the head between this tube and reactor vessel head surface.

CRDM.

tube 47. The film was dry. No Brownish stain on head on the evidence of any degradation of the uphill side of the tube.

reactor vessel head surface.

28 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris around the During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the

_______vessel head.

29 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris around the During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

30 Evidence of boron deposit on the This CRDM was not cleaned and No debris noted.

No debris noted.

tube. Deposit was a dried film that was left as it was found.

originated from above the insulation and did not reach the vessel head.

31 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris around the During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

Document Control Desk Letter Attachment II 0-C-02-2640 RC-03-0254 Page 6 of 10 CRDM Boric Acid Ins ection Remarks Other Remarks As found As left As found As left 32 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris around the During initial inspection, the was left as it was found.

tube.

majority of the debris was blown away from the circumference of the CRDM.

33 No boron deposits were observed.

This CRDM was not cleaned and

1. No debris noted.

No debris noted.

was left as it was found.

2. Possible small scratches on the Possible small scratches on the tube.

tube.

34 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris around the During initial inspection, the was left as it was found.

tube.

majority of the debris was blown away from the circumference of the CRDM.

35 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris on the uphill During initial inspection, the was left as it was found.

side of the tube.

majority of the debris was blown away from the circumference of the CRDM.

36 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris on the uphill During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

side of the tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

37 Evidence of very slight boron This CRDM was not cleaned and Piece of debris (metal sliver) at During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

base of tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

38 Evidence of very slight boron This CRDM was not cleaned and Small amount of debris on the uphill During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

side of the tube.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

Document Control Desk Letter 1 0-C-02-2640 RC-03-0254 Page 7 of 10 CRDM Boric Acid Ins ection Remarks Other Remarks As found As left As found As left 39 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris around the During initial inspection, the was left as it was found.

tube.

majority of the debris was blown away from the circumference of the CRDM.

40 Evidence of very slight boron This CRDM was not cleaned and

1. Slight amount of debris.

During initial inspection, the deposit (dried trickle) on the tube.

was left as i was found.

2. Lock washer on vessel head majority of the debris was blown Deposit was a dried thin film that next to the tube.

away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

41 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris on the uphill During initial inspection, the was left as it was found.

side of the tube.

majority of the debris was blown away from the circumference of the CRDM.

42 Boron noted at top insulation There is a thin film or stain that is No debris noted.

No debris noted.

around the tube, but no boron dry, nearly transparent. No noted on tube.

evidence of any degradation of the reactor vessel head surface.

43 Evidence of very slight boron This CRDM was not cleaned and Slight amount of debris.

During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the I vessel head.

44 Evidence of very slight boron There is a thin film or stain that is No debris noted.

No debris noted.

deposit (dried trickle) on the tube.

dry, nearly transparent. No Deposit was a dried thin film that evidence of any degradation of the originated from above the reactor vessel head surface.

insulation and did not reach the vessel head.

Document Control Desk Letter Attachment II 0-C-02-2640 RC-03-0254 Page 8 of 10 CRDM Boric Acid Ins ection Remarks Other Remarks Astfound As left Asfound As left 45 Evidence of very slight boron This CRDM was not cleaned and Slight amount of debris.

During initial inspection, the deposit (dried trickle) on the tube.

was left as it was found.

majority of the debris was blown Deposit was a dried thin film that away from the circumference of the originated from above the CRDM.

insulation and did not reach the vessel head.

46 No boron deposits were observed.

There is a thin film or stain that is Dust/debris around tube.

During initial inspection, the majority dry, nearly transparent. No of the debris was blown away from evidence of any degradation of the the circumference of the CRDM.

reactor vessel head surface.

47 Small amount of boron deposit There is a thin film or stain that is No debris noted.

Brownish stain on head on the noted at top of insulation, with dry, nearly transparent. No uphill side of the tube.

trickle down the tube. Thin film on evidence of any degradation of the the head between this tube and reactor vessel head surface.

tube 27. The film was dry, nearly transparent, and uniform in thickness. No evidence of any degradation of the reactor vessel head surface.

48 Evidence of very slight boron This CRDM was not cleaned and No debris noted.

No debris noted.

deposit (dried trickle) on the tube.

was left as it was found.

Deposit was a dried thin film that originated from above the insulation and did not reach the vessel head.

49 No boron deposits were observed.

This CRDM was not cleaned and No debris noted.

No debris noted.

was left as it was found.

50 Evidence of very slight boron There is a thin film or stain that is Small amount of debris around the During initial inspection, the deposit (dried trickle) on the tube.

dry, nearly transparent. No tube.

majority of the debris was blown Deposit was a dried thin film that evidence of any degradation of the away from the circumference of the originated from above the reactor vessel head surface.

CRDM.

insulation and did not reach the vessel head.

51 Small amount of boron deposit There is a thin film or stain that is Small amount of debris around the During initial inspection, the noted at top of insulation, with dry, nearly transparent. No tube.

majority of the debris was blown trickle down the tube. Thin film on evidence of any degradation of the away from the circumference of the the head reactor vessel head surface.

CRDM.

Document Control Desk Letter 1 0-C-02-2640 RC-03-0254 Page 9 of 10 CRDM Boric Acid Ins ection Remarks Other Remarks Asfound As left Asound As left 52 No boron deposits were observed.

This CRDM was not cleaned and Small amount of debris around the During initial inspection, the was left as it was found.

tube.

majority of the debris was blown away from the circumference of the CRDM.

53 No boron deposits were observed.

This CRDM was not cleaned and No debris noted.

No debris noted.

(Conoseal tube) was left as it was found.

54 No boron deposits were observed.

This CRDM was not cleaned and No debris noted.

No debris noted.

was left as it was found.

55 Small amount of boron deposit There is a thin film or stain that is Piece of steel wool in the vicinity of Piece of steel wool in the vicinity of noted at top of insulation, with dry, nearly transparent. No the CRDM.

the CRDM.

trickle down the tube. Thin film on evidence of any degradation of the the head.

reactor vessel head surface.

56 No boron deposits were observed.

This CRDM was not cleaned and No debris was noted.

No debris noted.

was left as it was found.

57 No boron deposits were observed.

This CRDM was not cleaned and No debris was noted.

was left as it was found.

58 Evidence of very slight boron There is a thin film or stain that is No debris noted.

No debris noted.

deposit (dried trickle) on the tube.

dry, nearly transparent. No Deposit was a dried thin film that evidence of any degradation of the originated from above the reactor vessel head surface insulation and did not reach the vessel head.

59 Evidence of very slight boron There is a thin film or stain that is Small amount of debris around the Steel wool near by.

deposit (dried trickle) on the tube.

dry, nearly transparent. No evidence tube. Steel wool nearby.

During initial inspection, the Thin film on the head.

of any degradation of the reactor majority of the debris was blown vessel head surface.

away from the circumference of the CRDM.

60 No boron deposits were observed.

This CRDM was not cleaned and No debris noted.

No debris noted.

was left as it was found.

61 No boron deposits were observed.

This CRDM was not cleaned and No debris noted.

No debris noted.

Iwas left as it was found.

Document Control Desk Letter Attachment II 0-C-02-2640 RC-03-0254 Page 10 of 10 CRDM Boric Acid Ins ection Remarks Other Remarks As found As left As found As left 62 Evidence of very slight boron There is a thin film or stain that is Small amount of debris around the During initial inspection, the deposit (dried trickle) on the tube.

dry, nearly transparent. No tube.

majority of the debris was blown Deposit was a dried thin film that evidence of any degradation of the away from the circumference of the originated from above the reactor vessel head surface.

CRDM.

insulation and did not reach the vessel head.

63 Evidence of very slight boron There is a thin film or stain that is Small amount of debris around the During initial inspection, the majority deposit (dried trickle) on the tube.

dry, nearly transparent. No tube.

of the debris was blown away from Deposit was a dried thin film that evidence of any degradation of the the circumference of the CRDM.

originated from above the reactor vessel head surface.

insulation and did not reach the vessel head.

64 No boron deposits were observed.

This CRDM was not cleaned and No debris was noted.

No debris was noted.

was left as it was found.

65 No boron deposits were observed.

This CRDM was not cleaned and No debris was noted.

No debris was noted.

was left as it was found.

Vent Evidence of very slight boron This was not cleaned and was left Small bolt next to vent piping Small bolt next to vent piping Pipe deposit (dried trickle) on the tube.

as it was found.

penetration.

penetration.

Deposit was a dried thin film that originated from above the insulation and did not reach the vessel head.

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,HOLE NO.'S CTYP.)

VIRGIL C. SUMMER NUCLEAR STATION REACTOR VESSEL HEAD CONTROL ROD DRIVE MECHANISM (CRDM)

PENETRATIONS OUTSIDE VIEW-TOP HEAD