JAFP-05-0151, Request for Approval of Relief Request No. RR-39, Implementation of BWRVIP Guidelines in Lieu of ASME Section XI Code Requirements on Reactor Vessel Internals and Components Inspection

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Request for Approval of Relief Request No. RR-39, Implementation of BWRVIP Guidelines in Lieu of ASME Section XI Code Requirements on Reactor Vessel Internals and Components Inspection
ML052900075
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 10/07/2005
From: Ted Sullivan
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-05-0151
Download: ML052900075 (23)
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Text

X s Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP

  • _-' 13 RfrP.O.

Box 110

/l tl,I Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan October 7, 2005 Site Vice President - JAF JAFP-05-0151 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Request for Approval of Relief Request No. RR-39, Implementation of BWRVIP Guidelines in lieu of ASME Section Xl Code Requirements on Reactor Vessel Internals and Components Inspection

Reference:

NRC Letter to Michael Kansler, "Safety Evaluation of Relief Request RI-01, Vermont Yankee Nuclear Power Station (TAC. NO. MC0960), dated September 19, 2005.

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Nuclear Operations, Inc. (ENO) is submitting a relief request (Attachment 1) to implement various Boiling Water Reactor Vessel Internals Program (BWRVIP) Guidelines in lieu of the American Society of Mechanical Engineers (ASME) Section Xi Code Inspection Requirements on reactor vessel internals and components.

The James A. FitzPatrick Nuclear Power Plant (JAFNPP) requests relief from the Inservice Inspection (ISI) Program requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition, No Addenda. The request applies to reactor vessel internals and components, and includes the technical basis for relief on each applicable component, or group of components.

Attachment 2 is a comparison of the ASME Examination Requirements and the BWRVIP Guideline requirements. Attachment 3 is the reactor internals inspection history, including up to the most recent refueling outage (RO16, dated October 2004). Attachment 4 is a list of the applicable components in the Reactor Vessel Internals Inspection Program and the number of welds for these components. Additionally, the ASME Code does not have specific inspection requirements on the steam dryers. Entergy'will be using the guidelines in

_$04 1

BWRVIP-139, UBWRVIP Steam Dryer Inspection and Flaw Evaluation Guidelines" and GE SIL 644, Revision 1 for the steam dryer inspections.

Entergy has concluded that this proposed alternative will ensure that the integrity of the reactor vessel internal components is maintained with an acceptable level of quality and safety.

A similar relief request was approved for Entergy's Vermont Yankee Nuclear Power Station (Reference).

Entergy requests approval of the relief request by August 2006 to support JAF Refueling Outage R17 scheduled for the Fall 2006.

Should you have any questions concerning this letter, please contact Mr. James Costedio, Regulatory Compliance Manager at (315) 349-6358.

There are no new commitments made in this letter.

Very truly yours, N J..--- _- - -

T.A. SULLIVAN Attachments

-I cc:

Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. John Boska, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555-0001 Mr. Peter R. Smith, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Department of Public Service 3 Empire Plaza, 10 th Floor Albany, NY 12223

JAFP-05-0151 Attachment 1 JAMES A. FITZPATRICK NUCLEAR POWER PLANT THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-039 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety-1.0 ASME Code Component(s) Affected Code Class: Class 1 Examination Categories: B-N-1, Interior of Reactor Vessel, and B-N-2, Integrally Welded Core Support Structures and Interior Attachments to Reactor Vessels Item Numbers: B13.10, Vessel Interior B13.20, Interior Attachments within Beltline Region B13.30, Interior Attachments beyond Beltline Region B13.40, Core Support Structure 2.0 Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section Xl Code, 1989 Edition, No Addenda.

3.0 Applicable Code Requirements ASME Section XI requires the examination of components within the Reactor Pressure Vessel.

These examinations are included in Table IWB-2500-1, Examination Categories B-N-1 and B-N-2 and are identified with the following item numbers:

B13.10 Examine accessible areas of the reactor vessel interior each period by the VT-3 method.

813.20 Examine interior attachment welds within the beltline region each interval by the VT-1 method.

813.30 Examine interior attachment welds beyond the beltline region each interval by the VT-3 method.

B13.40 Examine surfaces of the core support structure each interval by the VT-3 method.

These examinations are performed to assess the structural integrity of components within the boiling water reactor pressure vessel.

Page 1 of 8

JAFP-05-0151 Attachment 1 4.0 Reason for Request To conserve radiological person rem and reduce outage duration, while still maintaining an adequate level of quality and safety for the examination of the reactor vessel internals and welds.

5.0 Proposed Alternative In lieu of the requirements of ASME Section Xi, 1989 Edition, the proposed alternative described herein shall be used.

Entergy will examine components within the reactor vessel in accordance with BWRVIP Guideline requirements, unless otherwise noted. The particular guidelines that are applicable to those components are:

  • BWRVIP-25, UBWRVIP Core Plate Inspection and Flaw Evaluation Guidelines'
  • BWRVIP-38, "BWRVIP Shroud Support Inspection and Flaw Evaluation Guideline"
  • BWRVIP-41, "BWRVIP Jet Pump Assembly Inspection and Flaw Evaluation Guidelines"
  • BWRVIP-47-A, 'BWR Lower Plenum Inspection and Flaw Evaluation Guidelines"
  • BWRVIP-48-A, 'Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines"
  • BWRVIP-76, 'BWR Core Shroud Inspection and Flaw Evaluation Guidelines"
  • BWRVIP-1 04, UBWRVIP Evaluation and Recommendations to Address Shroud Support Cracking in BWRs"
  • BWRVIP-138, "BWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines" compares the required ASME Category B-N-1 and B-N-2 examination requirements with the above current BWRVIP Guideline requirements that are applicable to FitzPatrick. Attachment 3 is a summary of JAF's reactor internals inspection history, including results from the last inspections performed during the most recent refuel outage (RO16, October 2004). Attachment 4 identifies the applicable component in the reactor internal inspection program and the total number of welds in each component.

In addition, the requirements of BWRVIP-94, "Program Implementation Guideline", will be followed. BWRVIP-94 states that where guidance in existing BWRVIP documents has been supplemented or revised by subsequent correspondence approved by the BWRVIP Executive Committee, the most current approved guidance will be implemented. Therefore, the attached Table only represents a most current comparison.

Page 2 of 8

JAFP-05-01 51 Attachment 1 6.0 Basis for Use These BWRVIP Guidelines were developed and maintained to provide guidance in the examination of BWR internals and components. These Guidelines have been written to address the safety significant vessel internal components and to examine these components using appropriate methods and re-examination frequencies. The NRC has agreed with the BWRVIP approach in principle and has issued Safety Evaluations for these guidelines (see References). The technical basis for the proposed alternative inspection of each component, or group of components, is discussed in the following paragraphs, by Code Subsections. Each section includes several examples of a component or weld that belong in each Code Subsection.

6.1 B13.10. Reactor Vessel Interior Accessible Areas B-N-1 The ASME Section Xl Code requires a VT-3 inspection of reactor vessel interior surfaces made accessible every three and a third (3 1/3) years during each 10 year interval. This is a non-specific inspection requiring inspection of surfaces made accessible during refueling. The various BWRVIP Inspection and Evaluation guidelines require, as a minimum, a VT-3 inspection of reactor vessel interior components. Additionally, the BWRVIP guidelines require that many component welds and weld heat affected zones in this category be inspected by a VT-1, EVT-1, or UT. The BWRVIP inspection method meets (VT-3) or exceeds (VT-1, EVT-1, or UT) the inspection method requirement specified by the Code.

The Core Spray piping and sparger is used as an example for comparison between the Code and the BWRVIP inspection requirements.

BWR Core Spray Internals Inspection and Flaw Evaluation Guideline (BWRVIP-18-A)

  • The Section Xl Code requires a VT-3 each period (3 1/3 years) of each 10 year interval of the Core Spray internal piping and sparger accessible surfaces.
  • The BWRVIP requires either an EVT-1 of the core spray pipe creviced welds and weld heat affected zones each refuel outage (2 year) along with 25% of the non creviced weld locations on a rotated basis or UT. If UT is performed on the creviced weld locations, then the frequency is every other outage (4 years).

100% of the pipe brackets are inspected by EVT-1 every 4 outages (8 years).

100% of the major Core Spray sparger welds require an EVT-1 inspection every other outage (4 years). 50 % of the other Core Spray sparger welds require a VT-1 inspection every other outage (4 years). 100% of the sparger bracket welds are inspected by VT-1 every 2 outages.

The BWRVIP inspection methods are superior to the Code inspection methods. The BWRVIP specifies EVT-1 and UT inspections to detect small tight cracks before component functionality is challenged. The BWRVIP inspections are directed to component welds and weld heat affected zones, where experience has shown IGSCC cracks will initiate. The BWRVIP specified EVT-1 and UT examination have superior crack detection and characterization capability as compared to the Code VT-3. The inspection of high susceptibility creviced weld locations every outage (visual EVT-1) or every other outage (UT) is superior in crack detection and inspection frequency to the Page 3 of 8

JAFP-05-0151 Attachment 1 VT-3 examination required every period. The sparger bracket inspection method (VT-1) is superior to the code inspection method (VT-3) and inspection intervals are similar. The 25% sampling of non creviced welds ensure all welds are inspected in a 10 year interval.

The BWRVIP inspection requirements for reactor vessel interior accessible areas provide an acceptable level of quality and safety as compared to the Code requirements by providing an equivalent or in most cases superior inspection methods. Additional examples of components in this category are:

  • Control Rod Guide Tube and Fuel Support Castings (BWRVIP-47-A) 6.2 B13.20, Interior Attachments Within the Beftline (B-N-2)

The ASME Code requires a VT-1 inspection of accessible reactor interior surface attachment welds each 10 year interval.

The BWRVIP requires an EVT-1 inspection on the majority of attachment welds in the beltline region in the first 12 years and then 25% during each subsequent 6 years.

The Jet Pump Riser Brace inspection requirements are used as an example for comparison between the Code and the BWRVIP inspection requirements.

Jet Pump Riser Braces (BWRVIP-41 and 48-A)

  • The Code requires a 100% VT-1 inspection of the Jet Pump riser brace-to-reactor vessel wall pad welds each 10 year interval.
  • The BWRVIP requires an EVT-1 inspection of the Jet Pump Beam riser brace-to-reactor vessel wall pad welds the first 12 years and then 25% during each subsequent 6 years.

The Code VT-1 examination is conducted to detect discontinuities and imperfections on the surfaces of components, including such conditions as cracks, wear, corrosion, or erosion. The BWRVIP enhanced VT-1 (EVT-1) is conducted to detect discontinuities and imperfections on the surface of components, including fatigue cracks and very tight cracks characteristic of inter-granular stress corrosion cracking (IGSCC). General wear, corrosion, or erosion, is generally not a concern for stainless steel due to its inherently tough, corrosion resistant material characteristics. However, the process of performing an EVT-1 inspection would detect such degradation mechanisms.

The Code VT-1 visual inspection method requires that a letter character with a height of 0.044 inches can be read at a maximum distance of 2 feet. The BWRVIP EVT-1 is a visual inspection method where the equipment and environmental conditions are such that they can achieve a /2 mil (0.0005 inch) resolution on the inspection surface.

The ASME Code and the BWRVIP have the same flaw evaluation criteria for detected indications. Both criteria measure the observed surface indication and compare them against acceptable flaw sizes determined by ASME Section Xl Code.

Page 4 of 8

JAFP-05-01 51 Attachment 1 The BWRVIP inspection method of interior attachments within the reactor vessel beltline has superior flaw detection capability (0.0005 inches versus 0.044 inches resolution) compared to the Code. The enhanced flaw detection capability of an EVT-1, with a less frequent inspection schedule and the same flaw evaluation criteria, results in the BWRVIP inspection requirement providing the same level of quality and safety to that provided by the ASME Code.

6.3 B13.30 Interior Attachments Beyond the Beltline Region (B-N-2)

The BWRVIP requires as a minimum the same VT-3 inspection method as the Code for interior attachment welds beyond the beltline region and in some cases specifies an enhanced visual inspection technique EVT-1.

As described in Attachment 2, the following components have the same VT-3 method of inspection, the same scope of inspection (accessible welds), the same inspection frequency (each 10 year interval) and ASME Section Xl flaw evaluation criteria. Therefore, the level of quality and safety provided by the BWRVIP requirements are equivalent to that provide by the ASME Code. Examples of component attachment welds in this category are:

  • Surveillance Specimen Upper Holder Brackets (BWRVIP-48-A)

Additionally, there are interior attachment welds outside the beltline region that the BWRVIP requires an EVT-1 inspection instead of the Code required VT-3 inspection. The inspection frequency for EVT-1 is every four refueling outages (8 years) as compared to the Code inspection frequency of 10 years. The Code VT-3 examination is conducted to detect component structural integrity by ensuring components general condition is acceptable. An enhanced EVT-1 is conducted to detect discontinuities and imperfections on the inspection surfaces, including such conditions as tight cracks caused by IGSCC. Therefore, with the EVT-1 inspection method, the same inspection scope (accessible welds), an increased inspection frequency (8 years instead of 10 years) and the same flaw evaluation criteria (Section Xl), the level of quality and safety provided by the BWRVIP criteria is superior than that provided by the Code.

The Core Spray piping bracket-to-vessel attachment weld is used as an example for comparison between the Code and BWRVIP inspection requirements.

Vessel ID Attachment Weld Inspection and Flaw Evaluation (BWRVIP-48)

  • The Code inspection requirement is a VT-3 inspection of each weld every 10 years.
  • The BWRVIP inspection requirement for the Core Spray piping brackets attachment weld is that each weld is inspected every four refueling outages (8 years) with an EVT-1.

Page 5 of 8

JAFP-05-01 51 Attachment 1 The BWRVIP examination method EVT-1 has superior flaw detection and sizing capability, the inspection frequency is greater than the Code requirements and the same flaw evaluation criteria is used. Therefore the BWRVIP inspection criteria will provide a superior level of quality and safety as provided by the Code.

6.4 B13.40 Integrally Welded Core Support Structure-Shroud Support (B-N-2)

The Code requires a VT-3 of accessible surfaces each 10 year interval.

The BWRVIP requires as a minimum the same inspection method VT-3 as the Code for integrally welded Core Support Structures or either an enhanced visual inspection EVT-1 or volumetric examination UT.

As described in Attachment 1, the following component has the same VT-3 method of inspection, the same scope of inspection (accessible surfaces), the same inspection frequency (each 10 year interval) and the same flaw evaluation criteria, with the addition of an enhanced visual EVT-1 examination of the tie-rod locking devices. Therefore, the BWRVIP requirements provide a level of quality and safety equivalent to or superior to that provide by the ASME Code.

An example of a component in this category is:

The BWRVIP may also require either an EVT-1 or UT of core support structures. The core shroud is used as an example for comparison between the Code and BWRVIP inspection requirements.

BWR Core Shroud Inspection and Flaw Evaluation Guideline (BWRVIP-76)

  • The Code requires a VT-3 of accessible surfaces every 10 years.
  • The BWRVIP requires an EVT-1 or UT of each core shroud design reliant weld every 10 years (maximum).

This BWRVIP examination methods (EVT-1 or UT) are superior to the Code required VT-3 for flaw detection and characterization. The BWRVIP inspection frequency is equivalent to or greater than the inspection frequency required by the Code. The superior flaw detection and characterization capability, with an equivalent or greater inspection frequency and the same flaw evaluation criteria, results in the BWRVIP criteria providing a level of quality and safety equivalent to or superior to that provided by the Code requirements.

7.0 Conclusion Pursuant to 10 CFR 50.55a(a)(3)(i), using these BWRVIP guidelines as an alternative to the ASME Section Xl Code requirements provides an acceptable level of quality and safety. In many cases the BWRVIP examination requirements exceed the requirements of ASME Xl by requiring more detailed examination criteria (for example, VT-1 and UT for shroud welds vs.

VT-3). The BWRVIP Guidelines also provides detailed inspection areas and guidance for scope expansion if a defect is detected.

Page 6 of 8

JAFP-05-01 51 Attachment 1 8.0 Duration of Proposed Alternative Entergy proposes to use the alternative for the remaining term of the 3rd Inservice Inspection Interval for James A. FitzPatrick Nuclear Power Plant.

9.0 Precedents A similar relief request was approved for Entergy's Vermont Yankee Nuclear Power Station (Reference NRC SER (TAC No. MC0960), dated September 19, 2005).

10.0 Attachments:

Attachment 2 Comparison of ASME Category B-N-1 and B-N-2 Examination Requirements with BWRVIP Guideline Requirements.

Attachment 3 Reactor Internals Inspection History for James A. FitzPatrick Nuclear Power Plant (Updated through Refuel Outage R016),

dated October2004 (Reference 11.17).

Attachment 4 List of Components in the Reactor Internals Inspection Program and the Number of Welds/Components Page 7 of 8

JAFP-05-01 51 Attachment 1

11. References 11.1 NYPA Letter JPN-97-013, to NRC, dated March 24, 1997, "Core Spray Internals Inspection".

11.2 NRC Letter to BWRVIP, dated July 29, 1997, 'BWR Utility Commitments to the BWRVI P".

11.3 BWRVIP Letters to NRC, dated May 30 and October 30, 1997, 'BWR Utility Commitments to the BWRVIP".

11.4 NRC letter to BWRVIP, dated April 27, 1998, "Final Supplement to the Safety Evaluation of the BWRVIP, BWRVIP-07 Report".

11.5 NRC letter to BWRVIP, dated September 15, 1998, 'Safety Evaluation of the BWRVIP, BWRVIP-06 Report".

11.6 NRC letter to BWRVIP, dated September 29, 1999, 'Final Safety Evaluation of

'BWRVIP, BWR Top Guide Inspection and Flaw Evaluation Guidelines (BWRVIP-26),' EPRI Report TR-1 07285, December 1996".

11.7 NRC letter to BWRVIP, dated September 29, 1999, "Final Safety Evaluation of

'BWRVIP, BWR Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines (BWRVIP-48),' EPRI Report TR-1 08724".

11.8 NRC letter to BWRVIP, dated October 6, 1999, "Staff Reevaluation of Table 1 in the BWRVIP-07 Report".

11.9 NRC letter to BWRVIP, dated October 13, 1999, 'Final Safety Evaluation of

'BWRVIP, BWR Lower Plenum Inspection and Flaw Evaluation Guidelines (BWRVIP-47),' EPRI Report TR-1 08727".

11.10 NRC letter to BWRVIP, dated December 2, 1999, 'Final Safety Evaluation of BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines (BWRVIP-18)".

11.11 NRC letter to BWRVIP, dated December 19, 1999, "Final Safety Evaluation of BWRVIP, 'BWR Core Plate Inspection and Flaw Evaluation Guidelines (BWRVIP-25)' EPRI Report TR-107284, December 1996".

11.12 NRC letter to BWRVIP, dated July 24, 2000, 'Final Safety Evaluation of the

'BWRVIP, BWR Shroud Support Inspection and Flaw Evaluation Guidelines (BWRVIP-38),' EPRI Report TR-1 08823".

11.13 Entergy Letter JAFP-01-0021 to NRC, dated January 26, 2001, "In-Vessel Visual Inspection Summary Report 2000 Refuel Outage (Reload 14/Cycle 15)".

11.14 NRC letter to BWRVIP, dated February 4, 2001, "Final Safety Evaluation of the

'BWRVIP, BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines (BWRVIP-41)".

11.15 NRC letter to BWRVIP, dated August 20, 2001, "Final Safety Evaluation of the

'BWRVIP, Shroud Vertical Weld Inspection and Evaluation Guidelines (BWRVI P-63)".

11.16 Entergy Letter JAFP-02-0251 to NRC, dated December 26, 2002, "In-Vessel Visual Inspections Summary Report 2002 Refuel Outage (Reload 15/Cycle 16)".

11.17 Reactor Internals Inspection History for James A. FitzPatrick Nuclear Power Plant (Updated after RO16), October 2004.

11.18 BWRVIP-27A, "BWRVIP BWR Standby Liquid Control System / Core Plate AP Inspection and Flaw Evaluation Guidelines", EPRI Report 1007279, August 2003.

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JAFP-05-01 51, Attachment 2 Comparison of ASME Category B-N-1 and B-N-2 Examination Requirements with BWRVIP Guideline Requirements t 2)

ASME Item Component ASME Exam ASME ASME Applicable BWRVIP BlRVIP BWRVIP WBRVIP lFrequency No. Table Scope Exam Frequency Document Exam Scope Exam IWB-2500-1 I 1313.10 Reactor Vessel Interior Accessible VT-3 Each period BWRVIP-18-A, 25, 26- In accordance with applicable BWRVIP Document.

(Note I) Areas A, 27-A, 38, 41, 47-A, (Non-specific) 48-A, 76, 104, 138 B 13.20 Interior Attachments Accessible VT-I Each 10-year BWRVIP-48-A Table Riser Brace EVT- 100%

I in first 12 years (with Within Beltlinc - Jet Welds Interval 3-2 Attachment 50% to be inspected inthe first Pump Riser Brace 6 years); 25% during each subsequent 6 years Lower Surveillance BWRVIP-48-A Table Bracket VT-I Each 10-year Interval Specimen Holder Brackets 3-2 Attachment B13.30 Interior Attachments Accessible VT-3 Each 10-year BWRVIP-48-A Table Bracket VT-3 Each 10-year Interval Beyond Beltlinc - Steam Welds Interval 3-2 Attachment Dryer I old-down Brackets Guide Rod Brackets BWRVIP-48-A Table Bracket VT-3 Each 10-year Interval 3-2 Attachment Steam Dryer Support BWRVIP48-A Table Bracket EVT-I Each 10-year Interval Brackets 3-2 Attachment Feedwater Sparger BWRVIP-48-A Table Bracket EVT-1 Each 10-year Interval Brackets 3-2 Attachment Core Spray Piping BWRVIP-48-A Table Bracket EVT-I Every 4 Refueling Cycles Brackets 3-2 Attachment Upper Surveillance BWRVIP-48-A Table Bracket VT-3 Each 10-year Interval Specimen Holder Brackets 3-2 Attachment Shroud Support (Weld BWRVIP-38 Weld 119 EVT-I or Maximum of 6 years for EVT-119) 3.1.3.2, Figure 3-5 UT 1, Maximum of 10 years for

& BWRVIP-104 UT B13.40 Integrally Welded Core Accessible VT-3 Each 10-year BWRVIP-38 Weld 119 EVT-I or Maximum 6 years for EVT- 1, Support Structure- Surfaces Interval 3.1.3.2, 3.2.1, Figures and Gusset UT 10 years for UT Shroud Support 3-5 and 3-6 Attachments

& BWRVIP-104 Shroud BWRVIP-76 3.3 and Vertical and EVT-I or Per Shroud repair Designer 3.4 Top Guide UT Recommendations.

Ring Seg.

Welds BWRVIP-76 Tie-rod EVT-I and JAF has a shroud repair 3.5 and 3.6 Repair VT-3 consisting of ten tie-rods.

Inspection frequency is wvithin 10 years Notes: 1. Per NYPA letter to NRC (JPN-97-013), 'Core Spray Internals Inspection', dated March 24, 1997, JAF informed the NRC of a new commitment to perform Core Spray System piping and spargers inspections inside the reactor vessel in accordance with the BWRVIP-18 guidelines (Reference I 1.1).

2. This table provided only an overview of the requirements. For more details, refer to ASME Section Xl, Table IWB-2500-1, and the appropriate BWRVIP document.

Pane 1 of 1

JAFP-05-0 151 Attachment 3 James A. FitzPatrick Nuclear Power Plant Reactor Internals Inspection History (Updated through ROI 6, October 2004)

Components in Date or Inspection Summary of Inspection Results, Repairs, Replacements, BWRVIP Frequency of Method Used and Re-inspections Scope Inspection Core 1994 to UT, EVT-I 94/95 Outage: Planar flaws on H2, 35" length intermittent present VT-3 For (ID/OD) less than 0.75" depth by UT; two small planar Shroud Shroud Tie Rods flaws on H3, 1.42" length (ID/OD) by UT . A calculated 136" of vertical weld were inspected by EVT-I or UT with no relevant indications.

96 Outage: Crack like indications on H2, 55" length intermittent (OD) by EVT-I. This cracking is being mitigated by the shroud repair from 94/95 outage with 10 tie-rods; vertical crack like indications on SV5A intermittent (OD) totaling 6-3/4" in length out of total 92", and two horizontal 1/2" each (one OD and one ID).

Crack like indications were less than 10% of weld length and are within allowables per BWRVIP-07. Shroud inspections included 25% vertical welds with 50% at beltline areas, and 3 tie-rods. A calculated 286" of vertical welds were inspected. No relevant indications on other welds. Tie-rod assemblies were found acceptable.

Fall 1998 EVT-I Baseline completed per BWRVIP-07 Guidelines (by (RO13) EVT-I) for all vertical welds. 100% of beltline shroud welds inspected in RO-13. Relevant indications found in 5 welds as follows:

  • SV5A OD-There are 6 indications with a combined length of 9.3 inches.
  • SV5B OD-There are 18 indications with a combined indication length of 45.8 inches.
  • SV6A OD-There is I indication that is measured to be I" long.
  • SV6B ID-There is I indication in the weld which is measured to be 0.8 inches long.
  • SH4 Indication-Indication is 3 inches from SV5A ID and is 6 inches long and goes across the SH4 horizontal weld.

No relevant indications noted on other vertical welds.

Page 1 of 9

JAFP-05-01 51 Attachment 3 Fall 2000 EVT-I Re-inspected per BWRVIP-76 Guidelines: Vertical Core Shroud (RO114) Welds SV5A, SV5B, SV6A and SV6B. Relevant (cont.) indications found in these welds are as follows:

  • SV5A OD-There are 7 indications total with a combined indication length of 11.7" vertical and 3.3" circ.
  • SV5B OD-There are 19 indications total with a combined indication length of 50.7" vertical.
  • SV6A OD-There is one vertical indication that is measured to be I" long.
  • SV6B ID-There is one vertical indication in the weld measured to be 1.25" long.
  • SH4 ID-There are 2 vertical indications across SH4 with total combined length of 6.4". The closest indication is 3" from SV5B. This indication is branching out near the bottom portion.

Fall 2002 EVT-I Re-inspected by BWRVIP-76 Guidelines: Vertical (ROI5) Welds SV2B, SV5B, and SV8A; and Radial Ring Welds SV3A and SV3D. Relevant indications were only noted on the SV5B weld, as follows:

  • SV5B ID and OD. There appears to be no discernable changes this outage affecting the cracks length from R014; though one additional indication is noted on the ID CCW side of the weld approximately '2" long. This indication may be associated with indications on the opposite side (OD) at the same location.

Inspected Vertical Welds SV2A, SV8C, SV9A, SV9B Fall 2004 EVT-I and SV9C. No relevant indications noted.

(R016) 4 4 Shroud Support 1992 to UT or EVT-1 92 Outage: Inspected 0 and 180 deg access covers by UT.

present One planar indication detected at 180 deg, which is believed to be inherent to the fabrication process and is not ID connected.

94/95 Outage: Inspected 40" of H9 weld and accessible areas of 10 gusset plates used for tie-rod repair.

96 Outage: Inspected access hole cover at 0 deg. and inspected 36" of H9 weld and gusset plate welds at 3 tie-rod locations. No relevant indications noted.

Fall 1998 EVT-I Baseline completed per BWRVIP-07 and BWRVIP-38 (RO 13) VT-3 guidelines for all shroud repaired tie rods and load transfer gusset plate welds.

  • 7 out of 10 tie rod assemblies inspected (by EVT-I/VT-
3) in Fall 1998. No relevant indications noted.
  • AII load transfer gusset plate welds and 12 inches of H9 weld each side of the gussets were examined by EVT-I.

7 out of 10 gussets inspected in RO13. No relevant indications noted.

Examined by EVT-I the access hole cover at 180 degrees. No relevant indications noted.

Fall 2000/2002 No inspections during R014 and R015 Page 2 of 9

JAFP-05-01 51 Attachment 3 Shroud Support Fall 2004 EVT-I Inspected two shroud support gusset plate welds and 12 (RO 16) inches of H9 top weld each side of the gussets. No (cont.) relevant indications noted.

Core Spray 1987 to VT-3, IEB 80-13 of piping and welds in annulus. One clamp Pipin present MVT-I or repair in 1988 at cracked weld in "B" loop at 190 deg Pig EVT-I below upper elbow piping. Welds were brushed and inspected by EVT-I per BWRVIP-18 in Fall, 1996. No relevant indications found.

Fall 1998 EVT-I, Re-inspected 100% of loop "A" and "B" welds per (RO13) MVT-I BWRVIP-18 Guidelines (by EVT-1). No relevant indications noted, except for a rub-mark near CSA- IO weld.

Support brackets were examined by MVT-1. No recordable indications noted.

Fall 2000 EVT-I Re-inspected all Loop "A" and "B" creviced and T-box-(RO14) to-pipe welds, including repair clamp welds per BWRVIP-18 Guidelines (by EVT-I).

A relevant indication was noted on weld CSB-12. No other relevant indications were noted.

Fall 2002 EVT-I Re-inspected all Loop "A" and "B" creviced and T-box-(RO 15) to-pipe welds; repair clamp at Loop "B" downcomer pipe; and rotating sample of pipe elbow upper/lower welds in Loop "A" at 10 degrees. No relevant indications noted.

Re-inspected the indication noted in R014 on weld CSB-

12. Level Ills assessment is that the indication is now believed to be a scratch.

Re-inspected all Loop "A" and "B" creviced and T-box-Fall 2004 EVT-I to-pipe welds; repair clamp welds at Loop "B" (RO 16) downcomer pipe; and rotating sample of pipe elbow upper/lower welds in Loop "A" at 170 degrees. No relevant indications noted.

Core Spray 1987 to VT-3, IEB 80-13 of sparger and welds. MVT-I and EVT-I Sparger present MVT-I or inspections per BWRVIP-18 in Fall, 1996. An indication Pag EVT-I characterized as weld profile deficiency was recorded on spray nozzle D-28. Historical IVVI data was reviewed and the indication was previously noted and dispositioned as acceptable.

Fall 1998 EVT-I, Re-inspected 100% of sparger piping "A" and "B" welds (RO13) MVT-I per BWRVIP-18 Guidelines (EVT-I/MVT-I) including tee boxes, end caps, drain welds, and support brackets.

No relevant indications noted.

Fall 2000 N/A No inspections during RO14 Page 3 of 9

JAFP-05-0151 Attachment 3 Fall 2002 EVT-I Re-inspected all T-box and end caps to sparger pipe (RO 15) welds at Loops "A", "B", "C", and "D". No relevant Core Spray indications noted.

Sparger SpcoterVT-I Re-inspected Sparger "C" and "D" nozzle welds, and

(*cont.) supporting brackets at "A" and "B". No relevant indications noted.

VT-I Re-inspected all sparger bracket support welds at "C" and Fall 2004 "D". No relevant indications noted.

(RO 16)

Top Guide 1988, 1992 VT-3, and 2 cells inspected in 1988 and in 1992; 4 cells in 1994.

. and 1994/1995 Additional inspections included, alignment wedges, (Rim, etc.) EVT-1 hold down bolts, and rim welds at several locations (EVT-I at rim welds in 94/95). No relevant indications noted.

Fall 1998 N/A No inspections during RO13 Fall 2000 VT-I, and A total of 4 hold down assemblies were examined by VT-(RO14) VT-3 I and 3 alignment pin assemblies by VT-3 per BWRVIP-26 Guidelines. No indications were noted.

Fall 2002 and N/A No inspections in RO15 and R016.

2004 Core Plate 1992 and 1994 VT-3 Inspection at one core plate in 1992. Inspected (Rim, etc.) approximately 25% of hold down bolting in 1994/95. No relevant indications noted.

Fall 1998 VT-3 Inspected 100% of hold down bolting. No relevant (RO13) indications noted.

Fall 2000 VT-3 Inspected core plate plugs at 5 core locations. No relevant (RO 14) indications noted.

Fall 2002 N/A- No inspections during RO15 Fall 2004 VT-3 Inspected a total of 6 core plate plugs (at two locations).

(RO 16) No relevant indications noted.

SLC Fall 2000 EVT-2 Performed Enhanced VT-2 on SLC nozzle-to-safe end weld during RPV System Leakage Test per BWRVIP-27 Guidelines. Test was "Accepted".

Performed Enhanced VT-2 on SLC nozzle-to-safe end Fall 2002/2004 EVT-2 weld during RPV System Leakage Test per BWRVIP-27 (RO15/16) Guidelines. Test was "Accepted".

Page 4 of 9

JAFP-05-0151 Attachment 3

.1. .1. 1 Jet Pump 1987 to1994 VT-I ,VT-3 Inspected all riser brace attachment welds by VT-I. No and UT relevant indications but found debris at some weld Assembly locations. Have replaced all jet pump beams in 1992 because one exhibited indications of cracking by UT exam. Also inspected pump assembly, sensing lines, supports and diffuser to shelf welds, all by visual. No relevant indications but found debris at some weld locations.

Cracking at a Japanese BWR of a Jet Pump riser weld prompted FitzPatrick to review IVVI tapes from previous refueling outages, including 1996 outage.

Viewed accessible areas at two welds by VT-1, and at three welds by VT-3 examination. No cracking was found in the reviewed welds.

Fall 1998 MVT-1, and VT- Inspected by MVT-I 50% of all Jet Pumps (#7 to #16)

(RO 13) 3 for component safety priority H (high) and M (medium),

per BWRVIP-41 Guidelines. No relevant indications noted. Interferences in the annulus region restricted inspection of AD-I and AD-3b welds.

Inspected by VT-3 sensing lines/brackets at same jet pumps (#7 to #16). No relevant indications noted.

Fall 2000 N/A No inspections during R014 Fall 2002 EVT-l, VT-I, Completed inspection of Jet Pumps 5 and 6, and portions (RO 15) and of Jet Pumps 19 and 20, with no relevant indications VT-3 noted. Used inspections guidelines of BWRVIP-41 and

48. There are no MX-I welds on the inlet-mixer, but there are IN4 and MX-2 welds. Interferences in the annulus region (gussets) prevented inspection of the AD-3b welds.

VT-I Inspected Jet Pump Beams at #5, 6, 19 and 20, at locations recommended by BWRVIP-41, and by latest Operating Experience. No relevant indications noted.

Fall 2004 EVT-I Performed "High - priority" riser weld inspections at Jet (RO 16) Pumps #1, 2, 3,4, 17 and 18. No relevant indications noted.

Performed diffuser/adapter assembly weld inspections (Also "High"- priority) at Jet Pumps #17 and 18. No relevant indications noted.

VT-I Performed wedge bearing surface (WD-I) inspections at Jet Pumps # 17 and 18. No relevant indications noted.

Jet Pump 1992 and 94 VT-3 See above.

Diffuser Fall 1998 MVT-I See Jet Pump Assembly (above).

(RO 13)

Page 5 of 9

JAFP-05-01 51 Attachment 3 Fall 2000 N/A No inspections during R014 Jet Pump Fall 2002/2004 EVT-I/VT-1 See Jet Pump Assembly (above).

Diffuser (RO15/16)

(cont.)

CRD Guide 1992 VT-3 Inspected stub tube to vessel and stub tube to housing Tube welds for 9 tubes. No relevant indications.

Fall 1998 N/A No inspections during R013.

Fall 2000 EVT-I and, Inspected accessible surfaces at 3 Guide Tubes per (RO 14) VT-3 BWRVIP-47 Guidelines. Inspected accessible surfaces at 8 Guide Tubes (VT-3). No relevant indications noted.

Fall 2002 EVT-I and VT-3 Inspected accessible surfaces at 4 Guide Tubes per (RO 15) BWRVIP-47 Guidelines. No relevant indications noted.

Fall 2004 NIA No inspections in RO16.

CRD Stub 1992 VT-3 See above.

Tube Fall 1998 N/A No inspections during RO-13.

Fall N/A No inspection requirements per BWRVIP-47 Guidelines.

2000/2002/

2004 In-Core 1992 VT-I No relevant indications.

Housing Fall 1998 N/A No inspections during RO-13.

Fall 2000 thru N/A No inspection requirements per BWRVIP-47 Guidelines.

2004 Dry Tube 1994 VT-I No indications. Replaced all dry tubes in 1987/88.

Fall 1998 N/A No inspections during RO-13.

Fall 2000 VT-I Inspected 4 IRM/SRM In Core Dry Tubes per GE SIL-(RO 14) 409 and GE RICSIL-073 Guidelines. No relevant indications noted.

Fall 2002 VT-I Re-inspected SRM Core Dry Tube 20-17 per GE SIL 409 (RO15) and GE RICSIL-073 Guidelines. No relevant indications noted Fall 2004 N/A No inspections in RO16.

Instrument 1992 VT-I Two inspected in 1992. No relevant indications noted.

Penetrations Fall 1998 N/A No inspections in RO13.

Page 6 of 9

JAFP-05-01 51 Attachment 3 Fall 2000 VT-2 Performed VT-2 ISI System Leakage Exam Test at 6 Instrument (RO 14) instrument nozzles (during RPV System Test) per Penetrations BWRVIP49 Guidelines. Test was conducted to the extent possible with insulation installed and shield doors (cont.) closed. Test was "Accepted".

Fall 2002 and VT-2 Performed a VT-2 leakage test at 6 instrument nozzles 2004 (same as in R014-Fall 2000). Test was "Accepted".

(RO15/16)

Vessel ID 1987 to VT-I, Section Xl inspections ofjet pump riser brace, dryer, present VT-3, feedwater sparger, core spray, and surveillance capsule Brackets EVT-I for core holder brackets, performed once per interval. Last spray inspection was Fall, 96 VT-3, or VT-I if in beltline region. EVT-I for core spray. No relevant indications noted.

Fall 1998 MVT-I Inspected Core Spray Brackets and Jet Pump Riser Brace (RO 13) Attachments per BWRVIP-48 requirements. No relevant indications noted.

Fall 2000 N/A No inspections in RO14 Fall 2002 EVT-I Inspected Jet Pump Riser Brace (at JP #5/6 and # 19/20);

(RO15) and Feedwater Sparger Bracket Attachments (at all 8-locations), per BWRVIP-48 requirements. No relevant indications noted.

Fall 2004 EVT-I Inspected shroud support gusset plate welds to RPV wall (RO16) at two locations, with no relevant indications.

EVT-1, Inspected all four steam dryer support brackets and VT-3 attachment welds to RPV wall, with no relevant indications.

VT-3 Inspected all four steam dryer hold-down brackets and attachment welds to RPV top head, with no relevant indications noted.

Inspected guide rod and bracket to RPV weld at 1800, with no relevant indications noted.

LPCI Coupling I N/A I N/A I Not applicable to this plant.

Page 7 of 9

I JAFP-05-01 51 Attachment 3 Fuel Support Fall 1998 VT-3 Inspected accessible areas at fuel support castings during in-process control rod blade change-out. No relevant Castings (RO 13) indications noted.

Inspected accessible areas at fuel support castings during Fall 2000 VT-3 in-process control rod blade change-out. No relevant indications noted.

(RO14)

Inspected accessible areas at four fuel support castings Fall 2002 VT-3 during in-process control rod blade change-out. No (RO 15) relevant indications noted.

Fall 2004 N/A No inspections in RO16 CRD Nozzle Fall 1998 VT-I The Control Rod Drive Nozzle Inner Radius was NIR (RO 13) examined. No relevant indications noted.

Fall 2000 EVT-I Examined the CRD Nozzle Inner Radius, including adjacent vessel wall area. No relevant indications noted.

(RO14)

Fall 2002 and N/A No inspections in RO 15 and R016.

2004 Steam Dryer Fall 1998 VT-3 Inspected 25% of shroud head bolts at storage pit. No Moisture (RO13) relevant indications noted.

Separator F12000 VT3 and Re-inspected by VT-3 all areas of the steam dryer support an ring and by EVT-I previously found cracks (1992/1994).

(R014) EVT-I A total of 10 indications were noted in 2000 (R014),

with no discemable changes from previous inspection.

Fall 2004 VT-I and VT-3 Inspected steam dryer integrity per SIL 644 Supplement I (steam dryer integrity) and INPO OE 18796 (steam dryer (RO 16) hood crack and tie bar recordable visual indications) guidelines. Two relevant indications areas were noted.

These indications resulted in expanded scope with additional brushing and evaluations. These indications are in the HAZ of vibration block welds and at a drain channel. All indications were satisfactorily dispositions by calculations. Plans are to re-inspect the indications in R017.

Inspected steam dryer hold-downs and support brackets and attachment welds with no relevant indications noted.

Inspected steam separator lifting rod eye assemblies, and VT-3 25% of shroud head bolts with no relevant indications noted.

Page 8 of 9

JAFP-05-01 51 Attachment 3 Surveillance Fall 2000 VT-I and Inspected at one location, the upper and lower mounting Capsule (RO 14) VT-3 bracket (VT-I) and the condition of the specimen holder Specimen (VT-3) No relevant indications noted.

Holder Lower Plenum Fall 2000 VT-3 Inspected by VT-3 accessible areas of lower plenum per BWRVIP-47 Guidelines. No relevant indications noted.

(RO 14) VT-I Inspected by VT-i accessible areas of bottom head drain.

After removal of debris the area was re-examined and found acceptable.

Feedwater Fall 2002 VT-3 Inspected Sparger pipe assembly at 45, 135, 225 and 315 degrees azimuth, sparger welds and end brackets. No Sparger (RO15) relevant indications noted.

VT-I Inspected Junction T-box welds and Nozzle Inner Radius I

(NIR) at 45, 135, 225 and 315 degrees azimuth. No relevant indications noted.

UT Inspected the NIR at all 4-locations. No relevant indications noted.

Page 9 of 9

JAFP-05-0151 Attachment 4 List of Components in the Reactor Internals Inspection Program and the Number of WeldslComponents Reactor Internal Component BWRVIP Reference Number of Document Welds/Components Control Rod Drive Guide Tube BWRVIP-47-A, Table 3.3 2 per Component Body Welds Control Rod Drive Guide Tube Lug BWRVIP-47-A, Table 3.3 2 per Component and Pin Core Plate Rim Hold-Down Bolts BWRVIP-25, Table 3-2 72 Bolts Core Shroud Horizontal Welds (HI, BWRVIP-76, Figure 3.1 3 H2, H3)

Core Shroud Horizontal Welds BWRVIP-76, Figure 3.1 5 (H4-H7)

Core Shroud Vertical Welds BWRVIP-76, Figure 3-3 11 Core Shroud TG Ring Segment BWRVIP-76, Section 3.4 6 Welds Core Shroud CP Ring Segment BWRVIP-76, Section 3.4 6 Welds Core Shroud Flange Ring Segment BWRVIP-76, Section 3.4 6 Welds Core Shroud Tie-Rod Repair BWRVIP-76, Section 3.5 10 Tie Rods Core Shroud Support Welds (H8) BWRVIP-76, Figures 3-1 1 Core Shroud Support Welds (H9) BWRVIP-38, Figure 3-5 and 1 BWRVIP-104, Section 9.2 Core Shroud Support Gussets BWRVIP-38, Section 3.2.1 22 and Figure 3-6 Core Spray Thermal Sleeve Welds BWRVIP-18-A, Section 3.2.4 1 (loop A)

(Hidden) 2 (loop B)

Core Spray Piping Welds (except BWRVIP-18-A, Table 3-5 22 per loop (2 loops) &

P9) 1 weld repaired with a welded clam shell Core Spray P9 Welds BWRVIP-1 8-A, Section 3.2.4 2 per loop (2 loops)

Core Spray Sparger Large Circ BWRVIP-1 8-A, Table 3-5 5 per loop (4 loops)

Welds Core Spray Sparger Nozzle Welds BWRVIP-18-A, Table 3-5 52 nozzles per loop (4 loops) see Note I on next page Core Spray Piping Brackets BWRVIP-1 8-A, Table 3-5 2 per loop (2 loops)

Core Spray Sparger Brackets BWRVIP-1 8-A, Table 3-5 6 per loop (2 loops)

Feedwater Sparger Tee Welds NUREG 0619 3 per loop (4 loops)

Page 1 of 2

JAFP-05-01 51 Attachment 4 Feedwater Sparger End Bracket BWRVIP-48-A, Table 3-2 2 per loop (4 loops)

Attachment Feedwater Sparger Piping and NUREG 0619 2 brackets per loop Brackets (4 piping loops)

Jet Pump Beams BWRVIP-41, Table 3.3-1 and 20 BWRVIP-13, Sections 4 and 6 Jet Pump Thermal Sleeve Welds BWRVIP-41, Table 3.3-1 3 per Jet Pump (Hidden) (10 Jet Pumps)

Jet Pump Riser Welds (RS-1, RS-2, BWRVIP-41, Table 3.3-1 3 per Jet Pump RS-3) (10 Jet Pumps)

Jet Pump Riser Welds (RS-6, RS-7, BWRVIP-41, Table 3.3-1 4 per Jet Pump RS-8, RS-9) (10 Jet Pumps)

Jet Pump Riser Brace Welds BWRVIP-41, Table 3.3-1 8 per Jet Pump (10 Jet Pumps)

Jet Pump Inlet Bolted Connection BWRVIP-41, Table 3.3-1 2 per Jet pump (10 Jet Pumps)

Jet Pump Restrainer Wedges BWRVIP-41, Table 3.3-1 2 per Jet Pump (10 Jet Pumps)

Jet Pump Mixer Weld MX-1 BWRVIP-41, Table 3.3-1 2 per Jet Pump (10 Jet Pumps)

Jet Pump Adapter/Diffuser Welds BWRVIP-41, Table 3.3-1 14 per Jet Pump (10 Jet Pumps)

Lower Plenum (CRD) BWRVIP-47-A 137 CRDs Miscellaneous Vessel Internal BWRVIP-48-A, Table 3-3 12 Attachments Orificed Fuel Support Castings BWRVIP-47-A, Table 3.2-1 137 SLC Nozzle-to-Safe End Weld BWRVIP-27-A, Section 3.3.1 1 I Steam Dryer Support and Holdown BWRVIP-48-A, Table 3-2 8 Bracket Top Guide Hold-down Assemblies BWRVIP-26-A, Table 3-2 4 Top Guide Grid Beams BWRVIP-26-A, Section 3.2 28 Note 1: There are between 2 and 4 welds per nozzle depending on nozzle configuration. There are two drain nozzles on 2 lower spargers.

Page 2 of 2

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