ML062200226
| ML062200226 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/30/2006 |
| From: | Richard Laufer NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Kansler M Entergy Nuclear Operations |
| Boska J, NRR, 301-415-2901 | |
| References | |
| TAC MC8587 | |
| Download: ML062200226 (14) | |
Text
August 30, 2006 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - RELIEF REQUEST NO.
RR-39, IMPLEMENTATION OF BWRVIP GUIDELINES IN LIEU OF ASME SECTION XI CODE REQUIREMENTS ON REACTOR VESSEL INTERNALS AND COMPONENTS INSPECTION (TAC NO. MC8587)
Dear Mr. Kansler:
By letter dated October 7, 2005, as supplemented by letters dated April 3, 2006, and May 31, 2006, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request RR-39 for James A. FitzPatrick Nuclear Power Plant (JAFNPP). The licensees submittal proposed to use various Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines as an alternative to certain requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for inservice inspection (ISI) of reactor vessel internal components. The request was made pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i).
As documented in the enclosed safety evaluation (SE), the Nuclear Regulatory Commission (NRC) staff reviewed your submittal and concluded that the proposed alternative to the ASME Code requirements is acceptable. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), relief is granted for the third 10-year interval ISI program.
It should be noted that the BWRVIP-76 and BWRVIP-138 reports are currently under review by the NRC staff. Therefore, the licensees proposed alternative inspection requirements for the core shroud and the jet pump subcomponents which rely on the technical bases established by the BWRVIP-76 and BWRVIP-138 reports, respectively, may need to be revised based on any conditions documented in the NRC staffs final SEs on these reports. Similarly, the licensees proposed alternative inspection requirements for the shroud support welds may need to be revised based on any conditions documented in the NRC staffs final SE on the BWRVIP-104 report. Also, the licensee has committed to follow the guidelines of the BWRVIP-94 report, which would require the licensee to address any conditions imposed on use of the BWRVIP-76, BWRVIP-104, and BWRVIP-138 reports resulting from the NRC staffs final SEs.
M. Kansler If you have any questions regarding this matter, please contact John Boska, the NRC project manager for JAFNPP, at 301-415-2901.
Sincerely,
/RA/
Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosure:
As stated cc w/encl: See next page
M. Kansler If you have any questions regarding this matter, please contact John Boska, the NRC project manager for JAFNPP, at 301-415-2901.
Sincerely,
/RA/
Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrDciCvib RidsAcrsAcnwMailCenter LPL 1-1 Reading RidsNrrLASlittle RidsOGCMailCenter BSingal, DORL DPR RidsNrrPMBoska RidsNrrDorlLpla GCheruvenki Accession Number: ML062200226 *See SE dated June 21, 2006 OFFICE LPL 1-1/PM LPL 1-1/LA CVIB/BC OGC LPL 1-1/BC NAME JBoska SLittle MMitchell* JMoore RLaufer DATE 8/16/06 8/16/06 6/21/2006 8/30/06 8/30/06 Official Record Copy
FitzPatrick Nuclear Power Plant cc:
Mr. Gary J. Taylor Ms. Charlene D. Faison Chief Executive Officer Manager, Licensing Entergy Operations, Inc. Entergy Nuclear Operations, Inc.
1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. John T. Herron Mr. Michael J. Colomb Sr. VP and Chief Operating Officer Director of Oversight Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Peter T. Dietrich Mr. David Wallace Site Vice President Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant James A. FitzPatrick Nuclear Power Plant P.O. Box 110 P.O. Box 110 Lycoming, NY 13093 Lycoming, NY 13093 Mr. Kevin J. Mulligan Mr. James Costedio General Manager, Plant Operations Manager, Regulatory Compliance Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant James A. FitzPatrick Nuclear Power Plant P.O. Box 110 P.O. Box 110 Lycoming, NY 13093 Lycoming, NY 13093 Mr. Oscar Limpias Assistant General Counsel Vice President Engineering Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Regional Administrator, Region I Mr. Christopher Schwarz U.S. Nuclear Regulatory Commission Vice President, Operations Support 475 Allendale Road Entergy Nuclear Operations, Inc. King of Prussia, PA 19406 440 Hamilton Avenue White Plains, NY 10601 Resident Inspector's Office James A. FitzPatrick Nuclear Power Plant Mr. John F. McCann U. S. Nuclear Regulatory Commission Director, Licensing P.O. Box 136 Entergy Nuclear Operations, Inc. Lycoming, NY 13093 440 Hamilton Avenue White Plains, NY 10601
FitzPatrick Nuclear Power Plant cc:
Mr. Charles Donaldson, Esquire Mr. Garrett D. Edwards Assistant Attorney General 814 Waverly Road New York Department of Law Kennett Square, PA 19348 120 Broadway New York, NY 10271 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Oswego County Administrator Mr. Steven Lyman 46 East Bridge Street Oswego, NY 13126 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. James H. Sniezek BWR SRC Consultant 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster BWR SRC Consultant 5931 Barclay Lane Naples, FL 34110-7306
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST RR-39 FOR THE THIRD 10-YEAR INTERVAL OF THE INSERVICE INSPECTION PROGRAM ENTERGY NUCLEAR OPERATIONS, INC.
JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION
By letter dated October 7, 2005, Agencywide Documents Access and Management System (ADAMS) accession number ML052900075, as supplemented by letters dated April 3, and May 31, 2006, ADAMS accession numbers ML061040275 and ML061640320, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request RR-39 for James A.
FitzPatrick Nuclear Power Plant (JAFNPP). The licensees submittal proposes to use various Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines as an alternative to certain requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for inservice inspection (ISI) of reactor vessel internal (RVI) components.
2.0 REGULATORY EVALUATION
ISI of ASME Code Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g), except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). 10 CFR 50.55a(a)(3) states that alternatives to the requirements of 10 CFR 50.55a(g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if: (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for ISI of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b),
twelve months prior to the start of the 120-month interval, subject to the limitations and Enclosure
modifications listed therein. The applicable ASME Code of record for the third 10-year ISI interval for JAFNPP is the 1989 Edition with no Addenda of ASME Code,Section XI.
3.0 TECHNICAL EVALUATION
3.1 Components for Which Relief is Requested ASME Code,Section XI, Class 1, Examination Categories B--1 and B--2.
Code 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 3.2 Examination Requirements From Which Relief is Requested ASME Code, Section Xl requires the visual examination (VT) of certain RVI components.
These examinations are included in Table IWB-2500-1, Categories B--1 and B--2, and identified with the following item numbers:
- B13.10 - Examine accessible areas of the reactor vessel interior each period by the VT-3 method.
- B13.20 - Examine interior attachment welds within the beltline region each interval by the VT-1 method.
- B13.30 - 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 the RVI components.
3.3 Applicable ASME Code Edition and Addenda The ASME Code of Record for the third 10-year ISI interval for JAFNPP is the 1989 Edition with no Addenda, of ASME Code,Section XI.
3.4 Licensees Basis The licensee concluded that the alternative inspections (described below) will maintain an adequate level of quality and safety of the affected welds and will not adversely impact the health and safety of the public. As part of its justification for the relief, the licensee stated that boiling-water reactors (BWRs) now examine RVI components in accordance with BWRVIP guidelines. These guidelines have been written to address the examination of safety-significant RVI components using appropriate methods and reexamination frequencies. The licensee also
noted that the NRC has agreed with the BWRVIP approach, in principle, and has issued safety evaluations (SEs) for these guidelines. Note that in principle means that final NRC SEs have been written for these reports (with the exception of BWRVIP-76, 104, and 138, which are discussed later), but the final BWRVIP acceptance reports which incorporate these SEs may not have been issued for some of the reports. Relief from examinations in Table IWB-2500-1 of the ASME Code are requested pursuant to 10 CFR 50.55a(a)(3)(i).
3.5 Alternative Examination:
In lieu of the requirements of the 1989 Edition of the ASME Code, Section Xl, the licensee proposed to examine the RVI components in accordance with BWRVIP guidelines. The particular guidelines that are applicable to the various RVI components are:
BWRVIP-18-A, BWRVIP Core Spray Internals Inspection and Flaw Evaluation Guidelines" BWRVIP-25, BWRVIP Core Plate Inspection and Flaw Evaluation Guidelines BWRVIP-26-A, BWRVIP Top Guide Inspection and Flaw Evaluation Guidelines BWRVIP-27-A, BWRVIP BWR Standby Liquid Control System/Core Plate Delta P Inspection and Flaw Evaluation Guidelines BWRVIP-38, BWRVIP Shroud Support Inspection and Flaw Evaluation Guidelines 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-104, BWRVIP Evaluation and Recommendations to Address Shroud Support Cracking in BWRs BWRVIP-138, BWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines The licensee made a commitment to incorporate the guidelines of the BWRVIP-94 report, "Program Implementation Guideline," at JAFNPP. The BWRVIP-94 report 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.
In addition to the BWRVIP reports noted above, the licensee identified NUREG-0619, BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking, as the basis for its proposed alternative examinations for the feedwater sparger tee welds and the feedwater sparger piping and brackets.
The licensee, in its submittal dated October 7, 2005, provided a comparison of the required ASME Code,Section XI Category B--1 and B--2 examination requirements with the above current BWRVIP guidelines that are applicable to JAFNPP. In addition, the licensee provided RVI component inspection histories including results from the last inspections performed during the most recent refueling outage (refueling outage 16, October 2004). Furthermore, the licensee identified the applicable inspection program for the RVI components and the total number of welds in each of the RVI components.
The licensee, as an example, provided additional information regarding the BWRVIP inspection guidelines for the following welds of the RVI components and their subcomponents representing each of the aforementioned ASME Code,Section XI category/item numbers (Item Numbers B13.10, B13.20, B13.30, and B13.40).
- Jet pump
- Core Shroud Support
- Vessel Attachment Welds (e.g., steam dryer hold-down brackets, guide rod brackets, and surveillance specimen holders)
The licensee claimed that these examples demonstrated that the inspection techniques that are recommended by the BWRVIP inspection guidelines are superior to the inspection techniques mandated by the ASME Code,Section XI ISI program. Additionally, these examples proved that the BWRVIP inspection guidelines require more frequent inspections of the RVI components than the corresponding ASME Code,Section XI ISI program. The licensee claimed that by implementing the BWRVIP inspection guidelines, the aging degradation of the RVI components can be identified in a timely manner so that proper corrective action can be taken to restore the integrity of the applicable RVI component. Therefore, the licensee concluded that implementation of the BWRVIP inspection guidelines for the JAFNPPs RVI components would provide an acceptable level of quality and safety. The licensees proposed alternative for the RVI components and subcomponents covered under the scope of this relief request is summarized in the Attachment to this SE.
3.6 NRC Staff Evaluation The NRC staff reviewed the information provided by the licensee in its submittal dated October 7, 2005, regarding its proposed alternatives to the ASME Code,Section XI ISI requirements and the technical bases for the licensees proposed alternatives. The NRC staff reviewed the status of each of the referenced BWRVIP guidance documents and the applicability of the information provided in NUREG-0619. The NRC staff found all of the referenced BWRVIP reports (with the exception of the BWRVIP-76, BWRVIP-104, and BWRVIP-134 reports, which are under NRC staff review) to be acceptable, with any additional conditions associated with the implementation of the subject BWRVIP reports outlined in the corresponding NRC staff SE for that report. The NRC staff also confirmed the applicability of the information given in NUREG-0619 to support the licensees proposed alternative for the feedwater sparger tee welds and the feedwater sparger piping and brackets. The NRC staff did, however, identify some issues which required additional clarification by the licensee or which required the licensee to modify its proposed alternatives. The following paragraphs address the NRC staffs requests for additional information (RAIs), the licensees responses, and the NRC staffs evaluation of the RAIs.
In the RAI letter dated February 9, 2006, the NRC staff stated that the inspection frequency for the core shroud welds as indicated in Section 6.4 of the submittal dated October 7, 2005, is not consistent with the frequencies specified in Sections 3.3 and 3.4 of the BWRVIP-76 report.
Therefore, the NRC staff requested that the licensee revise the inspection frequency requirements for the subject welds in Section 6.4 of the submittal dated October 7, 2005. The licensee, in its response dated April 3, 2006, revised Section 6.4 of the submittal dated
October 7, 2005, to include inspection frequency that is consistent with the BWRVIP-76 guidelines. The NRC staff finds this response acceptable.
In the RAI letter dated February 9, 2006, the NRC staff also requested that the licensee include inspection intervals for the core shroud horizontal welds H1, H2, and H8. The licensee, in its response dated April 3, 2006, stated that H1, H2, and H8 welds were structurally replaced by the tie rod repairs, and the tie rods, consistent with the BWRVIP-76 guidelines, are inspected at 10-year intervals. The NRC staff finds this response acceptable because the inspection interval for the tie rods is consistent with the BWRVIP-76 guidelines and a 10-year inspection interval has been found acceptable by the NRC for similar components.
In the RAI letter dated February 9, 2006, the NRC staff stated that the inspection frequency specified in the licensees submittal dated October 7, 2005, for the top guide ring segment radial welds is not consistent with Figure 3-3 of the BWRVIP-76 guidelines. Therefore, the NRC staff requested that the licensee revise the inspection frequency requirement for the subject welds in its submittal dated October 7, 2005. The licensee, in its response dated April 3, 2006, stated that the shroud repair designer recommends that the subject welds be inspected using enhanced visual (EVT-1) or ultrasonic test (UT) methods every 10 years, which is consistent with the BWRVIP-76 guidelines. The licensee also indicated that previous inspections of the subject welds did not show any indications. Since there is no active degradation in the subject welds, the NRC staff agrees that the licensees proposed inspection frequency is acceptable.
Previous experience in BWRs indicated that noble metal chemical application (NMCA), in conjunction with hydrogen addition to the reactor water, mitigated intergranular stress-corrosion cracking (IGSCC). IGSCC is one of the most prominent aging degradation mechanisms in the RVI components. In a conference call on March 8, 2006, the NRC staff requested that the licensee provide information regarding the implementation of NMCA at JAFNPP. The licensee in its letter dated April 3, 2006, stated that it uses hydrogen water chemistry (HWC) and NMCA with a hydrogen to oxygen molar concentration value greater than 3 to 1. The NRC staff finds this response acceptable because the aforementioned hydrogen to oxygen molar concentration value is effective in mitigating IGSCC in the RVI components. The NRC staff believes that implementation of HWC and NMCA in conjunction with the implementation of the applicable BWRVIP inspection guidelines for the JAFNPPs RVI components would ensure their integrity and would provide an acceptable level of quality and safety.
With respect to the NRC staffs inquiry related to the inspection criteria for the core shroud H12 weld, and the jet pump riser welds (RS-4 and RS-5), the licensee, in its response dated April 3, 2006, has stated that JAFNPP does not have the H12 weld or the jet pump riser welds RS-4 and RS-5. The NRC staff finds this response acceptable.
In the RAI letter dated February 9, 2006, the NRC staff also requested that the licensee provide inspection requirements and the inspection frequency for the JAFNPPs RVI components. The licensee, in its response dated April 3, 2006, provided a listing of the JAFNPPs RVI components, with corresponding inspection bases, and the currently planned inspection schedule through the year 2014. The NRC staff reviewed the licensees response and identified an inconsistency between the inspection methods proposed by the licensee and the inspection methods contained in the BWRVIP-25 guidelines for the core plate hold-down bolts.
In a conference call on May 11, 2006, the NRC staff requested that the licensee revise its submittal dated April 3, 2006, to include inspection methods that are consistent with the BWRVIP-25 guidelines for the core plate hold-down bolts. The licensee, in its response dated May 31, 2006, withdrew core plate hold-down bolts from this relief request and stated that it will inspect the core plate hold-down bolts in accordance with the requirements specified in the ASME Code,Section XI ISI program. The NRC staff finds this response acceptable.
Therefore, based on the information in the licensees submittals dated October 7, 2005, April 3, and May 31, 2006, the NRC staff has confirmed that the licensees proposed alternatives (as documented in the attachment to this SE) are consistent with the technical bases documented in NUREG-0619 and the BWRVIP reports cited in Section 3.0 of this SE.
Consistent with the determination that was made in the NRC staffs SEs which approved each of the cited BWRVIP reports (with the exception of the BWRVIP-76, BWRVIP-104, and BWRVIP-138 reports), the BWRVIP inspection guidelines (as supplemented by the NUREG-0619 guidelines) incorporated into the licensees proposed alternative will identify aging degradation of the RVI components in a timely manner. Therefore, the NRC staff has concluded that the implementation of the inspection requirements specified in the licensees proposed alternative will ensure that the integrity of the RVI components will be maintained with an acceptable level of quality and safety.
It should be noted that the BWRVIP-76 and BWRVIP-138 reports are currently under review by the NRC staff. Therefore, the licensees proposed alternative inspection requirements for the core shroud and the jet pump subcomponents which rely on the technical bases established by the BWRVIP-76 and BWRVIP-138 reports, respectively, may need to be revised based on any conditions documented in the NRC staffs final SEs on the BWRVIP-76 and the BWRVIP-138 reports. Similarly, the licensees proposed alternative inspection requirements for the shroud support welds may need to be revised based on any conditions documented in the NRC staffs final SE on the BWRVIP-104 report. This will, however, be addressed as the licensee has committed to follow the guidelines of the BWRVIP-94 report, which would require the licensee to address any conditions imposed on use of the BWRVIP-76, BWRVIP-104, and BWRVIP-138 reports resulting from the NRC staffs final SE. The NRC staff's initial review of BWRVIP-76, 104, and 138 indicates that the proposed inspections will provide an acceptable level of quality and safety. If the licensee decides to take any exceptions to or deviations from the NRC staff-approved inspection guidelines specified in the aforementioned BWRVIP reports or the ASME Code,Section XI ISI requirements, then it shall submit a revised relief request indicating the exceptions or deviations to the NRC staff. The licensee shall obtain NRC staff approval for the revised relief request prior to implementing the revised inspection guidelines for the JAFNPPs RVI components.
4.0 CONCLUSION
Based on the information provided in the licensee's submittals, the NRC staff concludes that the alternatives proposed in Relief Request RR-39, and as summarized in the attachment to this SE, will ensure that the integrity of the RVI components is maintained with an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the licensees proposed alternatives are authorized for the third 10-year inspection interval. All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector. Any
components that are not included in this Relief Request will continue to be inspected in accordance with the ASME Code,Section XI requirements.
Principal Contributor: G. Cheruvenki Date: August 30, 2006
ATTACHMENT James A. FitzPatrick Comparison of ASME Category B--1 and B--2 Requirements (1)
With BWRVIP Guidance ASME Item No. Component ASME Exam ASME ASME Applicable BWRVIP BWRVIP BWRVIP Frequency Table IWB-2500-1 Scope Exam Frequency BWRVIP Exam Exam Document Scope (2)
B13.10 Reactor Vessel Interior Accessible VT-3 Each BWRVIP-18-A, In accordance with applicable BWRVIP document.
Areas period 25, 26-A, 27-A, (Non-specific) 38, 41, 47-A, 48-A, 76, 104 and 138 B13.20 Interior Attachments Within Accessible VT-1 Each 10- BWRVIP-48-A Riser Brace EVT-1 100% in first 12 years Beltline - Jet Pump Riser Welds year Table 3-2 Attachment (with 50% to be Braces Interval inspected in the first 6 years); 25% during each subsequent 6 years Lower Surveillance Specimen BWRVIP-48-A Bracket VT-1 Each 10-year Interval Holder Brackets Table 3-2 Attachment B13.30 Interior Attachments Beyond Accessible VT-3 Each 10- BWRVIP-48-A Bracket VT-3 Each 10-year Interval Beltline - Steam Dryer Hold- Welds year Table 3-2 Attachment down Brackets Interval Guide Rod Brackets BWRVIP-48-A Bracket VT-3 Each 10-year Interval Table 3-2 Attachment Steam Dryer Support Brackets BWRVIP-48-A Bracket EVT-1 Each 10-year Interval Table 3-2 Attachment Feedwater Sparger Brackets BWRVIP-48-A Bracket EVT-1 Each 10-year Interval Table 3-2 Attachment Core Spray Piping Brackets BWRVIP-48-A Bracket EVT-1 Every 4 Refueling Table 3-2 Attachment Cycles Upper and Middle Surveillance BWRVIP-48-A Bracket VT-3 Each 10-year Interval Specimen Holder Brackets Table 3-2 Attachment Shroud Support (Weld H9) BWRVIP-38 Weld H9 EVT-1 or Maximum of 6 years for 3.1.3.2, Figure 3-5 UT one sided EVT-1, and BWRVIP-104 Maximum of 10 years for UT Weld H12 Not Applicable Not Not Not Applicable Applicable Applicable
ATTACHMENT James A. FitzPatrick Comparison of ASME Category B--1 and B--2 Requirements With BWRVIP Guidance (1)
ASME Item No. Component ASME ASME ASME Applicable BWRVIP BWRVIP BWRVIP Frequency Table Exam Exam Frequenc BWRVIP Exam Scope Exam IWB-2500-1 Scope y Document B13.40 Integrally Welded Core Accessible VT-3 Each 10- BWRVIP-38 Weld H9 and EVT-1 or Maximum 6 years Support Structure - Shroud Surfaces year 3.1.3.2, Gusset UT for one-sided Support Interval 3.2.1, Attachments EVT-1, 10 years for Figures 3-5 UT and 3-6 &
BWRVIP-104 Shroud BWRVIP-76 Vertical and EVT-1 or Maximum 10 years Figures 3-3 Top Guide UT (per designer and 3-4 Ring recommendations)
Segment Welds BWRVIP-76 Tie-rod VT-3 and All 10 tie rods within 3.5 and 3.6 Repair EVT-1 10 years Notes:
- 1. This Table provides only an overview of the requirements. For more details, refer to the ASME Code,Section XI, Table IWB-2500-1, and the appropriate BWRVIP document.
- 2. Per New York Power Authority (NYPA) letter to NRC (JPN-97-013), Core Spray Internals Inspection, dated March 24, 1997, JAFNPP informed the NRC of a new commitment to perform Core Spray System piping and spargers inspections inside the RPV in accordance with the BWRVIP-18 guidelines.