Text

Request for Relief - Use of the Boiling Water Reactor Vessel and Internals Project (BWRVIP) Guidelines in Lieu of Specific ASME Code Requirements
	ML112101480
Person / Time
Site:	Fermi
Issue date:	07/28/2011
From:	Plona J; Detroit Edison, DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-11-0039
	Download: ML112101480 (45)
	v • d • e

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 10 CFR 50.55a July 28, 2011 NRC-11-0039 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

Reference:

Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Request for Relief - Use of the Boiling Water Reactor Vessel and Internals Project (BWRVIP) Guidelines in Lieu of Specific ASME Code Requirements Pursuant to 10 CFR 50.55a(a)(3)(i), Detroit Edison is requesting relief from specific portions of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," on the basis that the proposed alternative provides an acceptable level of quality and safety. Specifically, this proposed alternative requests the use of the Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines in lieu of specific ASME Code Requirements. provides the relief request; Enclosure 2 provides a comparison of Code examination requirements with BWRVIP examination requirements; and Enclosure 3 provides the Fermi 2 reactor internal inspection history through the fourteenth refueling outage.

Detroit Edison requests NRC approval of this relief request by January 31, 2012 to support planned inspections for the third ten-year Inservice Inspection/ Nondestructive Examination Interval during the upcoming fifteen refuel outage scheduled to start on March 26, 2012.

There are no new commitments included in this document.

USNRC NRC-11-0039 Page 2 Should you have any questions or require additional information, please contact Mr.

Alan I. Hassoun, Manager-Nuclear Licensing, at (734) 586-4287.

Sincerely, Enclosures

1. 10 CFR 50.55a Request Number RR-A39

2. Comparison of Code Examination Requirements to BWRVIP Examination Requirements

3. Reactor Internals Inspection History through RF14 cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

Enclosure 1 to NRC-11-0039 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 10 CFR 50.55a Request Number RR-A39 to NRC-11-0039 Page 1 10 CFR 50.55a Request Number RR-A39 Proposed Alternative In Accordance with 10CFR 50.55a(a)(3)(i)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected ASME Code Class: Code Class 1

References:

ASME Section XI, 2001 Edition with 2003 Addenda Examination Category: B-N-1 and B-N-2 Items Numbers: B13.10, B13.20, B13.30 and B13.40

Description:

Use of Boiling Water Vessel Internals Project (BWRVIP)

Guidelines in Lieu of ASME Code Requirements Components: Code Items Numbers: B13.10-Vessel Interior, B13.20-Interior Attachments, within Beltline Region, B13.30-Interior Attachments beyond beltline Region and B13.40-Core Support Structure

2. Applicable Code Edition and Addenda

ASME Section XI, 2001 Edition, through 2003 Addenda

3. 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 Categories B-N-1 and B-N-2 and identified with the following item numbers:

B 13.10 Examine accessible areas of the reactor vessel interior each period by the VT-3 method (B-N-1).

B 13.20 Examine interior attachment welds within the beltline region each interval by the VT-1 method (B-N-2).

to NRC-11-0039 Page 2 B 13.30 Examine interior attachment welds beyond the beltline region each interval by the VT-3 method (B-N-2).

B 13.40 Examine surfaces of the welded core support structure each interval by the VT-3 method (B-N-2).

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

4. Reason for Request

In accordance 10 CFR 50.55a(a)(3)(i), Detroit Edison is requesting NRC approval of a proposed alternative to the Code requirements provided above on the basis that the use of the BWRVIP guidelines discussed below will provide an acceptable level of quality and safety.

The BWRVIP Inspection and Evaluation (I&E) guidelines have recommended aggressive specific inspections by BWR operators to completely identify material condition issues with BWR components. A wealth of inspection data has been gathered during these inspections across the BWR industry. The BWRVIP I&E guidelines focus on specific and susceptible components, specify appropriate inspection methods capable of identifying real anticipated degradation mechanisms, and require re-examination at conservative intervals. In contrast, the Code inspection requirements were prepared before the BWRVIP initiative and have not evolved with BWR inspection experience.

Use of this proposed alternative will maintain an adequate level of quality and safety and avoid unnecessary inspections, while conserving radiological dose.

5. Proposed Alternative Pursuant to 10CFR50.55a(a)(3)(i), Detroit Edison requests authorization to utilize the alternative requirements of the BWRVIP Guidelines in lieu of the requirements of ASME Section XI. The proposed alternative is detailed in Table 1 for Examination Category B-N-1 and B-N-2.

Detroit Edison will satisfy the Examination Category B-N-1 and B-N-2 requirements as described in Table 1 in accordance with BWRVIP guideline requirements. This relief request proposes to utilize the identified BWRVIP guidelines in lieu of the associated Code requirements, including examination method, examination volume, frequency, training, successive and additional examinations, flaw evaluations, and reporting.

Not all of the components addressed by these guidelines are Code components. The particular guidelines that are applicable to Code components are:

to NRC-11-0039 Page 3 BWRVIP-03, "BWR Vessel and Internals Project, Reactor Pressure Vessel and Internal Examination Guidelines" BWRVIP-18-A, "BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines" BWRVIP- 25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines."

BWRVIP- 26-A, "BWR Top Guide Inspection and Flaw Evaluation Guidelines" BWRVIP- 27-A, "BWR Standby Liquid Control System/Core Plate AP Inspection and Flaw Evaluation Guidelines."

BWRVIP- 38, "BWR Shroud Support Inspection and Flaw Evaluation Guidelines" BWRVIP- 41, "BWR 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-100-A, "Updated Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds" Note: If flaw evaluations are required for BWRVIP-76 examinations, the fracture toughness values of BWRVIP-100-A will be utilized.

Table 1 compares present ASME Examination Category B-N-1 and B-N-2 requirements with the above current BWRVIP guideline requirements, as applicable, for BWR/4 units.

Any deviations from the referenced BWRVIP Guidelines for the duration of the proposed alternative will be appropriately documented and communicated to the NRC, per the BWRVIP Deviation Disposition Process. Currently, the only Detroit Edison deviation from the subject guidelines is for the inspection of Core Plate Bolting. (Reference 11)

Inspection services, by an Authorized Inspection Agency, will be applied to the proposed alternative actions of this relief request.

6. Basis for Use BWRs now examine reactor internals in accordance with BWRVIP guidelines. These guidelines have been written to address the safety significant vessel internal components and to examine and evaluate the examination results for these components using appropriate methods and reexamination frequencies. The BWRVIP has established a reporting protocol for examination results and deviations. The NRC has agreed with the BWRVIP approach in principal and has issued Safety Evaluations for many of these guidelines (References 1 - 10).

Therefore, use of these guidelines, as an alternative to the subject Code requirements, provides an acceptable level of quality and safety and will not adversely impact the health and safety of the public.

to NRC-11-0039 Page 4 As additional justification, Enclosure 2, Comparison of Code Examination Requirements to BWRVIP Examination Requirements, provides specific examples that compare the inspection requirements of ASME Code Item Numbers B13.10, B13.20, B13.30, and B13.40 in Table IWB-2500-1, to the inspection requirements in the BWRVIP documents. Specific BWRVIP documents are provided as examples. This comparison also includes a discussion of the inspection methods. These comparisons demonstrate that use of these guidelines, as an alternative to the subject Code requirements, provides an acceptable level of quality and safety and will not adversely impact the health and safety of the public.

7. Duration of Proposed Alternative The duration of the alternative is for the remainder of the Third Interval which started on May 2, 2009.

8. Precedence

1. Letter from U. S. Nuclear Regulatory Commission (USNRC) to Entergy Nuclear Operations, "Safety Evaluation of Relief Request RI-01, Vermont Yankee Nuclear Power Station (TAC NO. MC0690)", dated September 19, 2005

2. Letter from USNRC to Exelon, Relief Request to Use BWRVIP Guidelines in Lieu of Specific ASME Code Requirements (TAC Nos. MD5352 thru MD5363), dated April 30, 2008

9. References

1. Letter USNRC to BWRVIP, dated September 2, 2005, "NRC Approval Letter of BWRVIP-18-A, "BWR Vessel and Internals Project Boiling Water Reactor Core Spray Internals Inspection and Flaw Evaluation Guideline"

2. Letter USNRC to BWRVIP, dated December 19, 1999, "Safety Evaluation of BWR Vessel and Internals Project, BWR Core Plate Inspection and Flaw Evaluation Guidelines (BWRVIP-25)," (Accession Nos. ML993620267 and ML993620274)

3. Letter USNRC to BWRVIP, dated August 29, 2005, "NRC Approval Letter of BWRVIP-26-A, "BWR Vessel and Internals Project Boiling Water Reactor Top Guide Inspection and Flaw Evaluation Guidelines"

4. Letter USNRC to BWRVIP, dated June 10, 2004, Proprietary Version of NRC Staff Review of BWRVIP-27-A, "BWR Standby Liquid Control System/Core Plate AP Inspection and Flaw Evaluation Guidelines" to NRC-11-0039 Page 5

5. Letter USNRC to BWRVIP, dated July 24, 2000, "Final Safety Evaluation of the "BWR Vessel and Internals Project, BWR Shroud Support Inspection and Flaw Evaluation Guidelines (BWRVIP-38)," EPRI Report TR-108823 (TAC NO.

M99638)"

6. Letter USNRC to BWRVIP, dated February 4, 2001, "Final Safety Evaluation of the "BWR Vessel and Internals Project, BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines (BWRVIP-41)," (TAC NO. M99870)"

7. Letter USNRC to BWRVIP, dated September 1, 2005, "NRC Approval Letter of BWRVIP-47-A, "BWR Vessel and Internals Project Boiling Water Reactor Lower Plenum Inspection and Flaw Evaluation Guidelines" "

8. Letter USNRC to BWRVIP, dated July 25, 2005, "NRC Approval Letter of BWRVIP-48-A, "BWR Vessel and Internals Project Vessel ID Attachment Weld Inspection and Flaw Evaluation Guideline" "

9. Letter USNRC to BWRVIP, dated July 28, 2006, "Safety Evaluation of the "BWR Vessel and Internals Project, BWR Core Shroud Weld Inspection and Evaluation Guidelines (BWRVIP-76)"

10. Letter USNRC to BWRVIP, dated November 1, 2007, "NRC Approval Letter with Comment for BWRVIP-100-A, BWR Vessel and Internals Project, Updated Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds" (Accession No. ML073050135)"

11. Detroit Edison letter to NRC, NRC-11-0022, Notification of Deviation from BWRVIP-25 Guidelines, dated May 2, 2011

Enclosure 1 to NRC-11-0039 Page 6 TABLE 1 Comparison of ASME Examination Category B-N-1 and B-N-2 Requirements With BWRVIP Guidance Requirements (1)

ASME Item Applicable ASME Exam ASME A BWRVIP Exam BWRVIP No. Table Component Sce Scope ASME Exam Fre e BWRVIP .P Exam BWBWRVIP Frequency Frequency m Scope Exam IWB-2500-1 __ Document B13.10 Reactor Vessel Interior Accessible Areas VT-3 Each period BWRVIP-18, Overview examinations of components during BWRVIP (Non-specific) 26, 38, 41, 47, examinations are performed to satisfy Code VT-3 inspection 48, 76 requirements.

B13.20 Interior Attachments Within Accessible Welds VT-1 Each 10-year BWRVIP-48 Riser Brace EVT-1 100% in first 12 Beltline - Riser Braces Interval Table 3-2 Attachment years, 25% during each subsequent 6 years Lower Surveillance Specimen BWRVIP-48, Bracket VT-1 Each 10-year Interval Holder Brackets Table 3-2 Attachment B13.30 Interior Attachments Beyond Accessible Welds VT-3 Each 10-year BWRVIP-48 Bracket VT-3 Each 10-year Interval Beltline - Steam Dryer Hold- Interval Table 3-2 Attachment down Brackets Guide Rod Brackets BWRVIP-48, Bracket VT-3 Each 10-year Interval Table 3-2 Attachment Steam Dryer Support BWRVIP-48, Bracket EVT-1 Each 10-year Interval Brackets Table 3-2 Attachment Feedwater Sparger Brackets BWRVIP-48, Bracket EVT-1 Each 10-year Interval Table 3-2 Attachment Core Spray Piping Brackets BWRVIP-48, Bracket EVT-1 Every 4 Refueling Table 3-2 Attachment Cycles Upper Surveillance Specimen BWRVIP-48, Bracket VT-3 Each 10-year Interval Holder Brackets Table 3-2 Attachment Shroud Support (Weld H9) BWRVIP-38, Weld H9 EVT-1 or UT Maximum of 6 years including gussets 3.1.3.2, Including for EVT-1, Maximum Figures 3-2 and gussets of 10 years for UT 3-5

Enclosure 1 to NRC-11-0039 Page 7 ASME Item Applicable ... .......

ASME Item C poASME Exam ASME BWRVP Exam BWRVIPIPEam No. Table Component Scope ASME Exam BWRVIP BWRVIP Frequency Scope Frequency Scope Exam IWB-2500-1 y DF ocument S B13.40 Integrally Welded Core Accessible VT-3 Each 10- BWRVIP-38, Shroud Support EVT-1 or UT Based on as-found Surfaces Support Structure year Interval 3.1.3.2, including conditions, to a Figures 3-2, 3-5 gussets maximum 6 years for one side EVT-1, 10 years for UT where accessible Shroud Horizontal welds BWRVIP-76, Welds H1- H7 UT or EVT-1 Based on as-found 2.2 as applicable conditions, to a maximum of 10 years for UT when inspected from both sides of the welds Shroud Vertical welds BWRVIP-76, Vertical Welds EVT-1 or UT Maximum 10 years 2.3 as applicable for UT based on inspection of horizontal welds NOTE:

1) This Table provides only an overview of the requirements. For more details, refer to ASME Section XI, Table IWB-2500-1, and the appropriate BWRVIP document.

Enclosure 2 to NRC-11-0039 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Comparison of Code Examination Requirements to BWRVIP Examination Requirements to NRC-11-0039 Page 1 Comparison of Code Examination Requirements to BWRVIP Examination Requirements The following discussion provides a comparison of the examination requirements provided in ASME Code Item Numbers B13.10, B13.20, B13.30, and B13.40 in Table IWB-2500-1, to the examination requirements in the BWRVIP guidelines. Specific BWRVIP guidelines are provided as examples for comparisons. This comparison also includes a discussion of the examination methods.

1. Code Requirement - B13.10 - Reactor Vessel Interior Accessible Areas (B-N-1)

The ASME Section XI Code requires a VT-3 examination of reactor vessel accessible areas, which are defined as the spaces above and below the core made accessible during normal refueling outages. The frequency of these examinations is specified as the first refueling outage, and at intervals of approximately 3 years, during the first inspection interval, and each period during each successive 10-year Inspection Interval. Typically, these examinations are performed every other refueling outage of the Inspection Interval. This examination requirement is a non-specific requirement that is a departure from the traditional Section XI examinations of welds and surfaces. As such, this requirement has been interpreted and satisfied differently across the domestic fleet. The purpose of the examination is to identify relevant conditions such as distortion or displacement of parts; loose, missing, or fractured fasteners; foreign material, corrosion, erosion, or accumulation of corrosion products; wear; and structural degradation.

Portions of the various examinations required by the applicable BWRVIP Guidelines require access to accessible areas of the reactor vessel during each refueling outage. Examination of Core Spray Piping and Spargers (BWRVIP-18-A), Top Guide (BWRVIP-26-A), Jet Pump Welds and Components (BWRVIP-41), Interior Attachments (BWRVIP-48-A), Core Shroud Welds (BWRVIP-76), Shroud Support (BWRVIP-38) and Lower Plenum Components (BWRVIP-47-A) provides such access. Locating and examining specific welds and components within the reactor vessel areas above, below (if accessible), and surrounding the core (annulus area) entails access by remote camera systems that essentially performs equivalent VT-3 examination of these areas or spaces as the specific weld or component examinations are performed. This provides an equivalent method of visual examination on a more frequent basis than that required by the ASME Section XI Code. Evidence of wear, structural degradation, loose, missing, or displaced parts, foreign materials, and corrosion product buildup can be, and has been observed during the course of implementing these BWRVIP examination requirements. Therefore, the specified BWRVIP Guideline requirements meet or exceed the subject Code requirements for examination method and frequency of the interior of the reactor vessel. Accordingly, these BWRVIP examination requirements provide an acceptable level of quality and safety as compared to the subject Code requirements.

to NRC-11-0039 Page 2

2. Code Requirement - B 13.20 - Interior Attachments Within the Beltline (B-N-2)

The ASME Section XI Code requires a VT-1 examination of accessible reactor interior surface attachment welds within the beltline each 10-year interval. In the boiling water reactor, this includes the jet pump riser brace welds-to-vessel wall and the lower surveillance specimen support bracket welds-to-vessel wall. In comparison, the BWRVIP requires the same examination method and frequency for the lower surveillance specimen support bracket welds, and requires an EVT-1 examination on the remaining attachment welds in the beltline region in the first 12 years, and then 25% during each subsequent 6 years.

The jet pump riser brace examination requirements are provided below to show a comparison between the Code and the BWRVIP examination requirements.

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

The ASME Code requires a 100% VT-1 examination of the jet pump riser brace-to-reactor vessel wall pad welds each 10-year interval.

The BWRVIP requires an EVT-1 examination of the jet pump riser brace-to-reactor vessel wall pad welds the first 12 years and then 25% during each subsequent 6 years.

BWRVIP-48-A specifically defines the susceptible regions of the attachment that are to be examined.

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 and is additionally specified to detect potentially very tight cracks characteristic of fatigue and inter-granular stress corrosion cracking (IGSCC), the relevant degradation mechanisms for these components. General wear, corrosion, or erosion although generally not a concern for inherently tough, corrosion resistant stainless steel material, would also be detected during the process of performing a BWRVIP EVT-1 examination.

The ASME Section XI Code 2001 through 2003 Addenda, VT-1 visual examination method requires that a letter character with a height of 0.044 inches can be read. The BWRVIP EVT-1 visual examination method requires the same 0.044 inch resolution on the examination surface and additionally the performance of a cleaning assessment and cleaning as necessary.

While the jet pump riser brace configuration varies depending on the vessel manufacturer, BWRVIP-48-A includes diagrams for each configuration and prescribes examination for each configuration including Fermi 2 (Combustion Engineering).

to NRC-11-0039 Page 3 The calibration standards used for BWRVIP EVT-1 exams utilize the same Code characters, thus assuring at least equivalent resolution compared to the Code. Although the BWRVIP examination may be less frequent, it is a more comprehensive method. Therefore, the enhanced flaw detection capability of an EVT-1, with a less frequent examination schedule provides an acceptable level of quality and safety to that provided by the ASME Code.

3. Code Requirement - B13.30 - Interior Attachment Beyond the Beltline Region (B-N-2)

The ASME Section XI Code requires a VT-3 examination of accessible reactor interior surface attachment welds beyond the beltline each 10-year interval. In the boiling water reactor, this includes the core spray piping primary and supplemental support bracket welds-to-vessel wall, the upper surveillance specimen support bracket welds-to-vessel wall, the feedwater sparger support bracket welds-to-reactor vessel wall, the steam dryer support and hold down bracket welds-to-reactor vessel wall, the guide rod support bracket weld-to-reactor vessel wall, the shroud support plate-to-vessel wall, and shroud support gussets.

BWRVIP-48-A requires as a minimum the same VT-3 examination method as the Code for some of the interior attachment welds beyond the beltline region, and in some cases specifies an enhanced visual examination technique EVT-1 for these welds. For those interior attachment welds that have the same VT-3 method of examination, the same scope of examination (accessible welds), the same examination frequency (each 10 year interval) and ASME Section XI flaw evaluation criteria, the level of quality and safety provided by the BWRVIP requirements are equivalent to that provide by the ASME Code.

For the Core Spray support bracket attachment welds, the steam dryer support bracket attachment welds, the feedwater sparger support bracket attachment welds, and the shroud support plate-to-vessel welds, as applicable, the BWRVIP Guidelines require an EVT-1 examination at the same frequency as the Code, or at a more frequent rate. Therefore, the BWRVIP requirements provide the same level of quality and safety to that provided by the ASME Code.

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

Comparison to BWRVIP Requirements - Core Spray piping Bracket Welds (BWRVIP-48-A)

The Code examination requirement is a VT-3 examination of each weld every 10 years.

The BWRVIP examination requirement is an EVT-1 for the core spray piping bracket attachment welds with each weld examined every four cycles (8 years for units with a two year fuel cycle).

to NRC-11-0039 Page 4 The BWRVIP examination method EVT-1 has superior flaw detection and sizing capability, the examination frequency is greater than the Code requirements, and the same flaw evaluation criteria are used.

The Code VT-3 examination is conducted to detect component structural integrity by ensuring the components general condition is acceptable. An enhanced EVT-1 is conducted to detect discontinuities and imperfections on the examination surfaces, including such conditions as tight cracks caused by IGSCC or fatigue, the relevant degradation mechanisms for BWR internal attachments.

Therefore, with the EVT-1 examination method, the same examination scope (accessible welds), an increased examination frequency (8 years instead of 10 years) in some cases, the same flaw evaluation criteria (Section XI), the level of quality and safety provided by the BWRVIP criteria is superior than that provided by the Code.

4. Code Requirement - B13.40 - Integrally Welded Core Support Structures (B-N-2)

The ASME Code requires a VT-3 examination of accessible surfaces of the welded core support structure each 10-year interval. In the boiling water reactor, the welded core support structure has primarily been considered the shroud support structure, including the shroud support plate (annulus floor) the shroud support ring, the shroud support welds, the shroud support gussets. In later designs, the shroud itself is considered part of the welded core support structure. Historically, this requirement has been interpreted and satisfied differently across the industry. The proposed alternate examination replaces this ASME requirement with specific BWRVIP guidelines that examine susceptible locations for known relevant degradation mechanisms.

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

The BWRVIP requires as a minimum the same examination method (VT-3) as the Code for integrally welded Core Support Structures, and for specific areas, requires either an enhanced visual examination technique (EVT-1) or volumetric examination (UT).

BWRVIP recommended examinations of integrally welded core support structures are focused on the known susceptible areas of this structure, including the welds and associated weld heat affected zones. As a minimum, the same or superior visual examination technique is required for examination at the same frequency as the code examination requirements. In many locations, the BWRVIP guidelines require a volumetric examination of the susceptible welds at a frequency identical to the Code requirement.

For other integrally welded core support structure components, the BWRVIP requires an EVT-1 or UT of core support structures. The core shroud is used as an example for comparison between the Code and BWRVIP examination requirements as shown below.

to NRC-11-0039 Page 5 Comparison to BWRVIP Requirements - BWR Core Shroud Examination and Flaw Evaluation Guideline (BWRVIP-76)

The Code requires a VT-3 examination of accessible surfaces every 10 years.

The BWRVIP requires an EVT-1 examination from the inside and outside surface where accessible or ultrasonic examination of each core shroud circumferential weld that has not been structurally replaced with a shroud repair at a calculated "end of interval" (EOI) that will vary depending upon the amount of flaws present, but not to exceed ten years.

The BWRVIP recommended examinations specify locations that are known to be vulnerable to BWR relevant degradation mechanisms rather than "all surfaces". The BWRVIP examination methods (EVT-1 or UT) are superior to the Code required VT-3 for flaw detection and characterization. The BWRVIP examination frequency is equivalent to or more frequent than the examination frequency required by the Code. The superior flaw detection and characterization capability, with an equivalent or more frequent examination frequency and the comparable 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.

Enclosure 3 to NRC-11-0039 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Reactor Internals Inspection History to NRC-11-0039 Page 1 RR-A39 Fermi 2 - Reactor Internals Inspection History thru RF14 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections Core Shroud RF04 VT-1 (1mil Inspected: 100% ID welds H2, H3, and, (BWRVIP-07/76) wire) H4; 100% OD welds H1-H7; accessible areas H8 & H9 VT-1/VT-3 The only indications identified were two <1" vertical in orientation above the H2 weld at azimuth 125 degrees.

These were evaluated against established flaw screening criteria and found acceptable.

RF05 EVT-1 Inspected approximately 60-70 degrees (1/2mil arc on the core shroud in area of wire) previous indications. H2-H4 inspected on shroud ID, H1-H7 inspected on shroud OD. No new indications, no change observed in previous indications above H2 weld.

RF06 UT Performed focused phased array UT examination of the H3, H4, H5 and H7 welds utilizing GE's universal carousel.

No indication of cracking was identified.

EVT-1 A cursory exam was performed on H-3 weld to confirm UT results for information only. No new indications and no change was observed in the previous indication above H2 weld.

RF07 EVT-1 Re-inspected the indication above the H2 weld on the inside of the shroud.

No change in appearance. The control rod blade was withdrawn to perform to NRC-11-0039 Page 2 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections the examination.

RF08 N/A No inspections performed on the Core Shroud. Inspections were performed on the Shroud Support RF09 N/A No inspections performed on the Core Shroud. Inspections were performed on the Shroud Support RF10 N/A No inspections performed on the Core Shroud. Inspections were performed on the Shroud Support RF11 N/A No inspections performed on the Core Shroud. Inspections were performed on the Shroud Support RF12 UT Performed phased array UT examination of the H3, H4, H5 and H7 welds from both sides utilizing AREVA's demonstrated technique. No indication of cracking was identified.

Inspection coverage exceeded 60% for all welds with coverage spaced around the entire circumference.

RF13 UT No inspections performed on the Core Shroud. Inspections were performed on the Shroud Support.

RF14 UT No inspections performed on the Core (10/10) Shroud. Inspections were performed on the Shroud Support.

Shroud Support RF03 VT-3 Inspected shroud support gusset welds (BWRVIP-3 8/104) and H8/H9 in conjunction with jet Access Hole Cover pump inspections. No indications (BWRVIP-180)

RF04 VT-1/VT-3 Inspected areas in conjunction with jet Spumps, included were gusset welds H8 to NRC-11-0039 Page 3 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections and H9. H8 and H9 welds inspected at 0 and 180 degrees with 1 mil wire. No indications.

RF05 EVT-1 Inspected sample area 60-70 degree arc (1/2 mil) plus 180 degrees location on H8, H9, and gussets. No indications.

RF06 VT-3 Inspection performed in conjunction with jet pump inspections.

Approximately 50% of the gussets and H8 and H9 welds were inspected. This was a best effort exam which ranged from MVT-1 to VT-3 depending on camera angle and lighting. No cleaning was performed. No indications identified.

RF07 EVT-1 Inspection performed in conjunction with jet pump inspections. Remaining 50% of the gusset welds were inspected. This was a best effort exam which ranged from EVT-1 to VT-3 depending on camera angle and lighting. (Credited as an EVT-1 exam)

No cleaning was performed or needed.

No indications identified. The H8 and H9 welds were inspected in detail at 0 and 180 Deg. Azimuth to EVT-1 standards where there were no obstructions.

RF08 EVT-1 The H8 and H9 welds were re-inspected to achieve required coverage.

22% of both welds were inspected and included the areas at 0 and 180 degrees as well as adjacent to Jet Pumps 2 and

3. Accessible areas on Gussets 1, 3, 11, 12, and 22 were inspected. No indications of cracking identified.

to NRC-11-0039 Page 4 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF09 EVT-1 The H8 and H9 welds were inspected VT-1 adjacent to Jet Pumps 3 and 4(Coverage obtained 1% and 8.3%).

Accessible areas on Gussets 2 and 15 inspected (90% coverage on each obtained). Both access hole covers were inspected (VT-1). No indications identified.

RF10 EVT-1/ The H8 and H9 welds were inspected VT-1 adjacent to Jet Pump 5(Coverage obtained 1% and 8.3%). Accessible areas on Gussets 7 and 8 inspected (70/90% coverage obtained @VT-1 quality, EVT-1 not credited, CARD 05-20378). No indications identified.

RF11 EVT-1 The H8 and H9 welds were inspected at 0 and 180 degrees as well as several other locations. Coverage obtained was 24% for H8 and 30% for H9.

Accessible areas on Gussets 5, 6, 7, 8, 9, 10, 18, and 21 were inspected with 50% to 80% coverage obtained @

EVT-1. No indications identified.

UT A portion of the H9 weld was examined from the vessel outside diameter using a manual technique as required by BWRVIP-104. Approximately 19.6%

of weld was examined with no indications.

RF12 EVT-1 Accessible areas on Gussets 4 and 13 were inspected with 55% to 80%

coverage obtained using EVT-1. No indications identified. Both Access Hole covers were inspected per draft BWRVIP -180 requirements. Cracking identified on 0 degree cover. Reference OE 25794.

to NRC-11-0039 Page 5 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF13 EVT-1 Accessible areas on Gussets 5 and 6 were inspected with 75% coverage obtained using EVT-1. No indications identified. The O Degree Access Hole cover was re-inspected and no additional cracking was identified. No repair installed.

RF14 EVT-1 Accessible areas on Gussets 1, 21, and (10/10) 22 were inspected with 50% - 60%

coverage obtained using EVT-1. No indications identified. All 3 welds on the 0 Degree Access Hole Cover were re-inspected and no additional cracking was identified. No repair installed.

Core Spray Piping each outage VT-1 During RF-01 two small arc strikes (BWRVIP-18/18-A) RF01 thru (Imil) were identified on loop piping. These RF04 have been re-inspected each outage.

No change in condition. Inspections performed per IEB 80-013 and SIL 289. No indication of cracking.

RF05 EVT-1 All welds brushed prior to inspection (1/2mil) using 1/2 mil wire. Remainder of loop VT-1 piping inspected without brushing. No indication of cracking.

RF06 EVT-1 Inspected all welds on both loops of core spray to EVT-1 standards as opposed to BWRVIP-18 requirements of MVT-1. Cleaning assessment was performed - cleaning was not necessary. No indication of cracking.

RF07 EVT-1 Inspected all welds on both loops of core spray to EVT-1 standards.

Cleaning assessment was performed -

cleaning was not necessary. No indication of cracking.

to NRC-11-0039 Page 6 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF08 EVT-1 Inspected all welds on both loops of core spray to EVT-1 standards.

Cleaning assessment was performed, cleaning was not necessary. No indication of cracking.

RF09 EVT-1 Inspected all target welds on both loops of core spray and sample welds on Div 2 to EVT-1 Stds. Cleaning assessment was performed, cleaning was not necessary. No indications of cracking.

RF10 EVT-1 Inspected all target welds on both loops of core spray and rotating sample welds on Div 2 to EVT-1. Cleaning assessment was performed, cleaning was necessary for selected locations and welds were brushed. No indications of cracking. Inspection coverage reported separately but generally >80%.

RF11 EVT-1 Inspected all target welds on both loops of core spray and rotating sample welds on Div 1 to EVT-1. Cleaning assessment was performed, cleaning was necessary for selected locations and welds were brushed. No indications of cracking. Inspection coverage reported separately but generally >80%.

RF12 EVT-1 Inspected all target welds on both loops of core spray and rotating sample welds on Div 1 to EVT-1. Cleaning assessment was performed, cleaning was necessary for selected locations and welds were brushed. No indications of cracking. Inspection

_coverage reported separately but to NRC-11-0039 Page 7 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections generally >55%.

RF13 EVT-1 Inspected all target welds on both loops of core spray and rotating sample welds on Div 2 to EVT-1. Cleaning assessment was performed, cleaning was necessary for selected locations and welds were brushed. No indications of cracking. Inspection coverage reported separately but generally >55%.

RF14 EVT-1 Inspected all target welds on both loops (10/10) of core spray and rotating sample welds on Div 2 to EVT-1. Cleaning was performed for all locations and welds were hydrolazed or brushed. No indications of cracking. Inspection coverage reported separately but generally >60%.

Core Spray Sparger each outage VT-1 (1 During RF01 one arc strike identified (BWRVIP-18/18-A) RF01-RF04 mil) on upper CS sparger. Re-inspections have not identified any changes. No indication of cracking RF05 VT- 1/2 mil wire used for junction box 1/EVT-1 remainder utilized Imil wire. No (1/2mil) indication of cracking.

RF06 EVT-1, Inspected per BWRVIP-18 using EVT-MVT-1 1 for sparger T-box and end caps and MVT-1 for remaining locations. No indications of cracking.

RF07 EVT- Inspected per BWRVIP-18 using EVT-1/VT-i 1 for sparger T-box welds, end cap welds, drain plug welds, and support brackets and welds, and VT-1 for flow nozzles and tack welds. No indications

_of cracking identified.

to NRC-11-0039 Page 8 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF08 EVT- Inspected per BWRVIP-18 using EVT-1/VT-I 1 for S1, S2 and S4 welds. Selected S3a, S3b welds inspected using VT-1.

Selected S3c welds as well as selected SB bracket welds were inspected using EVT-1 technique. A best effort exam was performed on all accessible areas.

No indications of cracking identified.

RF09 EVT- Inspected per BWRVIP-18 using EVT-1/VT-1 1 for 50% of the S1, S2 and S4 welds and VT-1 for 50% of the S3a, S3b and S3c welds on the same spargers. 9 SB bracket welds were inspected using EVT-1 technique. Coverage for specific welds will be reported separately. No indications of cracking were identified.

RF10 EVT- Inspected per BWRVIP-18 using EVT-1/VT-I 1 for 50% of the S1, S2 and S4 welds and VT-1 for 50% of the S3a, S3b and S3c welds on the same spargers. 6 SB bracket welds were inspected using EVT-1 technique. Coverage for specific welds will be reported separately but was > 60% for welds and

>85% for brackets. No indications of cracking were identified.

RF11 EVT- Inspected per BWRVIP-18-A using 1/VT-1 EVT-1 for 50% of the S1, S2 and S4 welds on the same spargers. 6 SB bracket welds were inspected using VT-1 technique. Coverage for specific welds will be reported separately but was > 50% for welds and >75% for brackets. No indications of cracking were identified to NRC-11-0039 Page 9 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF12 EVT- Inspected per BWRVIP-18-A using 1/VT-1 EVT-1 for 50% of the S1, S2 and S4 welds on the same spargers. 6 SB bracket welds were inspected using EVT-1 technique. Coverage for specific welds will be reported separately but was > 40% for welds and

>75% for brackets. No indications of cracking were identified.

RF13 EVT- Inspected per BWRVIP-18-A using 1/VT-1 EVT-1 for 50% of the S1, S2 and S4 welds on the same spargers. 6 SB bracket welds were inspected using EVT-1 technique. Coverage for specific welds will be reported separately but was > 50% for welds and

>70% for brackets. No indications of cracking were identified.

RF14 EVT- Inspected per BWRVIP-18-A using (10/10) 1/VT-1 EVT-1 for 50% of the S1, S2 and S4 welds on the C and D spargers. 6 SB bracket welds and S3 nozzle welds were inspected using VT-1 technique.

Coverage for specific welds will be reported separately but was > 40% for welds and >60% for brackets. No indications of cracking were identified.

Top Guide (Rim, Each outage VT-3 Inspected rim each outage. No etc.) indications.

Beams (BWRVIP-

26) RF03 VT-1 Inspected 6 locations (RICSIL 059). No (BWRVIP-183) indications.

RF04 VT-1 Inspected 6 locations (SIL 554). No indications.

RF05 VT-1 Inspected 15 locations (SIL 554). No indications.

to NRC-11-0039 Page 10 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF06 VT-1 Inspected bottom edge of beams at 11 core locations per SIL 554. No indication of cracking.

RF07 VT-1 Inspected bottom edge of beams at 8 core locations per SIL 554. No indication of cracking.

RF08 VT-1 Inspected bottom edge of beams at 5 core locations per SIL 554. No indication of cracking.

RF09 VT-1 Inspected bottom edge of beams at 6 core locations per SIL 554. No indication of cracking.

RF10 VT-1 Inspected bottom edge of beams at 2 core locations per SIL 554. No indication of cracking.

RF11 VT-1 Inspected bottom edge of beams at 2 core locations per SIL 554. No indication of cracking. Inspected 90 degree segment of top guide rim and no indications were identified.

RF12 VT-1/VT-3 Inspected intersection and bottom edge of beams at 5 core locations per SIL 554. No indication of cracking.

RF13 EVT-1 Inspected intersection and bottom edge of beams at 5 core locations per BWRVIP-183 utilizing a new visual inspection tool. No indication of cracking.

RF14 EVT-1 No inspections performed RF14.

(10/10)

Core Plate Rim RF05 VT-1 (Imil Inspected 6 core plate bolts located to NRC-11-0039 Page 11 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections Bolts, etc. wire) between 100 and 160 degrees and (BWRVIP-25) adjacent area. No indications.

RF06 VT-3 Inspected tops of approximately 20 bolts per SIL 588. No indications identified.

RF07 VT-3 Inspected tops of approximately 20 bolts per SIL 588. No indications identified.

RF08 VT-3 Inspected tops of approximately 20 core plate bolts (VT-3) per SIL 588.

Did not meet BWRVIP requirements.

No indications identified.

RF09 N/A No inspections performed. BWRVIP analysis concluded that inspections are not required. (Reference BWRVIP 2003-117 and TJ-2003-01)

RF10 N/A No inspections performed. BWRVIP analysis concluded that inspections are not required. (Reference BWRVIP 2003-117 and TJ-2003-01)

RF11 N/A No inspections performed. BWRVIP analysis concluded that inspections are not required. (Reference BWRVIP 2006-041 and DD-2006-01)

RF12 N/A No inspections performed. BWRVIP analysis concluded that inspections are not required. (Reference BWRVIP 2006-041)

RF13 N/A No inspections performed. BWRVIP analysis concluded that inspections are not required. (Reference BWRVIP 2006-041) to NRC-11-0039 Page 12 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF-14 N/A No inspections performed. BWRVIP (10/10) analysis concluded that inspections are not required. (Reference BWRVIP 2006-041) BWRVIP 2010- 243 now requires preparation of a Deviation Disposition by 3/31/2011.

SLC RF04 VT-3 Performed a visual inspection from (BWRVIP-27) Reactor penetration to shroud support when access was provided during jet pump beam replacement. No indications.

RF05 - N/A No inspections performed as access RF07 was not provided.

RF08 VT-2* Performed enhanced inspection on nozzle area from inside skirt area, but did not remove mirror insulation box from safe-end. No leakage observed.

RF09 VT-2* Performed enhanced inspection on nozzle area from inside skirt area, and removed cover on the mirror insulation box for the safe-end for direct inspection. No leakage observed.

RF10 VT-2* Performed enhanced inspection on nozzle area from inside skirt area, and removed cover on the mirror insulation box for the safe-end for direct inspection. No leakage observed.

RF11 VT-2* Performed enhanced inspection on nozzle area from inside skirt area, and removed cover on the mirror insulation box for the safe-end for direct inspection. No leakage observed.

RF12 VT-2* Performed enhanced inspection on nozzle area from inside skirt area, and to NRC-11-0039 Page 13 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections removed cover on the mirror insulation box for the safe-end for direct inspection. No leakage observed.

RF13 VT-2*/UT Performed enhanced inspection on nozzle area from inside skirt area, and removed cover on the mirror insulation box for the safe-end for direct inspection. No leakage observed.

Performed a manual PDI qualified ultrasonic inspection of the nozzle to safe end weld as well as additional base material of bored material. No indications identified.

RF-14 VT-2* Performed enhanced inspection on (10/10) nozzle area from inside skirt area, and removed cover on the mirror insulation box for the safe-end for direct inspection. No leakage observed.

Jet Pump Assembly Each outage VT-1 VT- Jet pump assemblies are inspected each (BWRVIP-41) examine at 3 outage from top to bottom. During RF-least 50% 04 all (20) hold down beams were thru RF05 replaced as a preventative measure and to avoid performing UT's on the old style/original beams. Inspections are performed to the recommendations of SIL 551, 574, 465 S-1, and RICSIL 078. During RF05 one of the 80 restrainer screw tack welds was found to be cracked. This was evaluated and was not repaired during RF05.

RF06 MVT-1, Performed inspections to the intent of VT-3 BWRVIP-41 as well as augmented VT-3 of selected areas on jet pumps 1-10.

Inspections included all High, Medium and Low Priority locations. Inspected RS-1 and RS-2 welds on jet pumps 11-

20. One indication identified on RS-1 to NRC-11-0039 Page 14 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections weld, 1.75" long. JCO performed prior to start-up. No other new indications identified.

RF07 EVT-1 Performed inspections to the intent of BWRVIP-41 including EVT-1's as well as augmented VT-1 and VT-3's of selected areas on jet pumps 11-20.

Inspections included all High, Medium and Low Priority locations. Re-inspected previously identified indication on RS-1 weld, 1.75" long that was identified in RF06. No change in indication length or appearance.

Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit. No other indications or changes in previous indications identified.

RF08 EVT-1 Performed re-inspections to the intent of BWRVIP-41 including EVT- l's as well as augmented VT-1 and VT-3's of selected areas on jet pumps 1& 2.

Inspections included all High, Medium and Low Priority locations. Re-inspected previously identified 1.75" long indication on RS-1 weld for Jet Pumps 7&8 that was identified in RF06. No change in indication length or appearance. Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit.

Inspected all 20 jet pumps per recommendations of SIL 629 and verified no wedge damage (WD-1) as well as full contact with restrainer screws. No damage identified on any location. Re-inspected all restrainer screw tack welds with no changes observed.

to NRC-11-0039 Page 15 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF09 EVT-1 Performed re-inspections to BWRVIP-41 including EVT-1 's as well as augmented VT-1 and VT-3's of selected areas on Jet Pumps 3 & 4. Inspections included all High, Medium and Low Priority locations. Re-inspected previously identified 1.75" long indication on RS-1 weld for Jet Pumps 7&8 that was identified in RF06. No change in indication length or appearance. Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit. Inspected all 20 Jet Pump Hold Down Beams by UT for BB1, BB2, and the transition area BB3 using the latest available technique from General Electric. No indications identified on the beams. Reinspected all restrainer screw tack welds, contact area, and wedges after both tack welds on Jet Pump 15 were found cracked.

No other damage or indications identified on any location. Jet Pump 15 permanently repaired by the installation of an auxiliary spring wedge.

(Reference CARD 03-16929)

RF10 EVT-1 Performed re-inspections to BWRVIP-41 including EVT- 's as well as augmented VT-1 and VT-3's of selected welds on Jet Pumps 4, 5, 6, 7, & 8. Re-inspected previously identified 1.75" long indication on RS-1 weld for Jet Pumps 7 & 8 that was identified in RF06. No change in indication length /

appearance. Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit. Re-inspected auxiliary spring wedge on Jet Pump 15.

No other damage or indications to NRC-11-0039 Page 16 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections identified on any location.

RF11 EVT-1 Performed re-inspections to BWRVIP-41 including EVT-1 's as well as augmented VT-1 and VT-3's of selected welds on Jet Pumps 7, 8, 9, & 10. Re-inspected previously identified 1.75" long indication on RS-1 weld for Jet Pumps 7 & 8 that was identified in RF06. No change in indication length /

appearance. Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit. Inspected all Jet Pump wedges after wear was identified on JP2 restrainer bracket. Performed inspection of other welds on Jet Pump 2 as required by BWRVIP-41.

Auxiliary spring wedges installed on Jet Pumps 1 and 2 and a slip joint clamp was installed on Jet Pump 2 to restore integrity. No other damage or indications identified.

RF12 EVT-1 Performed re-inspections to BWRVIP-41 including EVT-1 's as well as augmented VT-1 and VT-3's of selected welds on Jet Pumps 7, 8, 9, 10, 11, &

12. Re-inspected previously identified 1.75" long indication on RS-1 weld for Jet Pumps 7 & 8 that was identified in RF06. No change in indication length /

appearance. Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit. Inspected all 20 Jet Pump Hold Down Beams. Inspected 12 Jet Pump wedges including the wedges and hardware (auxiliary spring wedges and slip joint clamp) installed in RF11. No other damage or indications identified.

to NRC-11-0039 Page 17 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF13 EVT-1 Performed re-inspections to BWRVIP-41 including EVT-1 's as well as augmented VT-1 and VT-3's of selected welds on Jet Pumps 7, 8, 9, 10, 13, 14, 15, and 16. Re-inspected previously identified indication on RS-1 weld for Jet Pumps 7/8 identified in RF06. No change in indication length or appearance. Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit. Inspected 9 Jet Pump wedges. No other damage or indications identified.

RF14 EVT-1 Performed re-inspections to BWRVIP-(10/10) 41 including EVT-1's as well as augmented VT-1 and VT-3's of selected welds on most Jet Pumps including RS-8/9 welds on all pumps. Re-inspected previously identified indication on RS-1 weld for Jet Pumps 7/8. No change in indication length or appearance.

Existing Flaw Evaluation on hand prepared by GE referenced as acceptance limit.

Inspected all 20 Jet Pump wedges.

Minor movement noted but no other damage or indications identified.

Jet Pump Diffuser Each outage VT-3 Diffusers will be sample inspected (BWRVIP-41) during refueling outages.

RF06 MVT-1 BWRVIP-41 on Jet Pumps 1-10 except inaccessible areas. No cracking.

RF07 EVT-1 BWRVIP-41 on Jet Pumps 11-20 except inaccessible areas. No cracking identified. Welds DF-3, AD-1, and AD-2 are inaccessible for inspection.

to NRC-11-0039 Page 18 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF08 EVT-1 BWRVIP-41 re-inspection on Jet Pumps 1 and 2 except inaccessible areas. No cracking identified. Welds DF-3, AD-1, and AD-2 are inaccessible for inspection.

RF09 EVT-1 BWRVIP-41 re-inspection on Jet Pumps 3 and 4 except inaccessible areas. No cracking identified. Welds DF-3, AD-1, and AD-2 are inaccessible for EVT-1 visual inspection, VT-3 performed. (TJ-2003-02 prepared as justification)

RF10 EVT-1 BWRVIP-41 re-inspection of selected DF-1 and DF-2 welds on Jet Pumps 5, 6, 7, & 8. Performed access study for future performance of UT examinations of welds DF-3, AD-1, and AD-2.

These welds are inaccessible for visual inspection. VT-3 performed. No indications identified (Reference TJ-2003-02)

RF11 EVT-1 BWRVIP-41 re-inspection of selected DF-2 welds on Jet Pumps 9 & 10.

UT Performed of UT examinations on a portion of a total of 17 DF-3, AD-1, and AD-2 welds using specialized tooling. These welds are inaccessible for visual inspection. No indications identified (Reference DD-2006-02)

RF12 EVT-1 BWRVIP-41 re-inspection of selected DF-1 and 2 welds on Jet Pumps 6, 11,

& 12.

UT No UT examinations performed during RF12 due to tooling failures. These welds are inaccessible for visual to NRC-11-0039 Page 19 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections inspection. (Reference DD-2006-02)

RF13 EVT-1 BWRVIP-41 re-inspection of selected DF-1 and 2 welds on Jet Pumps 7, 13,

&14.

UT No UT examinations performed during RF13 due to tooling failures. These welds are inaccessible for visual inspection. (Reference DD-2006-02)

RF14 EVT-1 BWRVIP-41 re-inspection of selected (10/10) DF-1 and 2 welds on Jet Pumps 7, 8, 9, and 13-18. No indications identified.

UT Completed baseline UT examinations on all 20 Jet Pumps Diffuser/Adapter DF-3, AD-1 and AD-2 welds, (60 welds) since these welds are inaccessible for visual inspection.

Deviation Disposition is no longer needed.

CRD Guide Tube RF04 VT-3 Inspected lower portion of peripheral (BWRVIP-47) guide tubes and stub tubes when access was provided during jet pump hold down beam replacement. No indications identified.

RF07 EVT-1 and Performed best effort exam on CRGT-3 VT-3 as weld was not visible on inside of tube. CRGT-2 not accessible due to flow and ARPIN was not felt to be accessible. No indications identified.

RF08 EVT-1 and Performed best effort exam on CRGT-3 VT-3 as weld was not visible on inside of tube. CRGT-2 not accessible due to flow and FS/GT-ARPIN was not felt to be accessible. No indications identified.

to NRC-11-0039 Page 20 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF09 EVT-1 and Performed exams on CRGT-1, CRGT-VT-3 2, CRGT-3, and FS/GT-ARPIN at 10 Control Rod Guide Tubes/locations.

No indications identified.

RF10 EVT-1 and No inspection performed in RF10.

VT-3 RF11 EVT-1 and No inspection performed in R 1.

VT-3 RF12 VT-3 Performed exams on CRGT-1 and FS/GT-ARPIN at 5 Control Rod Guide Tubes/locations. CRGT-2 and CRGT-3 not performed or credited due to high flow conditions. No indications identified.

RF13 EVT-1 and No inspections performed in RF 13.

VT-3 RF14 EVT-1 and Completed all remaining baseline (10/10) VT-3 inspections on the Control Rod Guide Tubes. Inspections performed on (4)

CRGT-1, and FS/GT-ARPIN locations and on (9) CRGT-2 and CRGT-3 locations. One manufacturing flaw identified that did not impact the functionality of the component.

CRD Stub Tube RF04 VT-3 Inspected lower portion of peripheral (BWRVIP-47) guide tubes and stub tubes when access was provided during jet pump hold down beam replacement. No indications identified.

In-Core Housing RF04 VT-3 Small portion visible during jet pump (BWRVIP-47) beam replacement. No indication of degradation.

to NRC-11-0039 Page 21 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections Dry Tube Each outage VT-1 9 of 12 tubes found not completely (BWRVIP-47) seated. Performed all inspections per SIL 409 and RICSIL 073. No indications of cracking.

RF06 VT-1 Re-inspected 12 dry tubes. No change from previous condition. No cracking.

RF07 VT-1 Inspected all 12 original design Dry Tubes. No change from previous conditions identified. No cracking identified.

RF08 VT-1 Inspected all 12 original design Dry Tubes from two sides. No change from previous conditions identified. No cracking identified.

RF09 N/A-1 No inspections performed in RF09.

RF10 VT-1 Inspected all 12 original design Dry Tubes from two sides. Linear indications identified on 7 tubes in the collar region above the pressure boundary weld. Evaluated as acceptable for one cycle of operation.

Plan to replace in RF 11. (Reference CARD 04-25703)

RF11 VT-1 Replaced all 12 Dry Tubes in RF11.

Performed baseline VT-1 and verified proper engagement in Top Guide.

RF12 VT-1 No inspections performed in RF 12.

RF13 VT-1 No inspections performed in RF 13.

RF14 VT-1 No inspections performed in RF14.

(10/10) to NRC-11-0039 Page 22 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections Instrument Penet. Each outage VT-3 Inspected jet pump sensing lines and (BWRVIP-49 & 41) brackets each outage.

RF04 VT-3 SLC and peripheral bottom head penetrations inspected. No indications.

RF06 VT-3 Inspected JP sensing lines for pumps 1-

10. No indications.

RF07 VT-3 Inspected JP sensing lines for pumps 11 thru 20 only. No indications.

RF08 VT-3 Inspected JP sensing lines for Pumps 1

& 2 only. No indications.

RF09 VT-3 Inspected JP sensing lines for Pumps 3

& 4 only. No indications.

RF10 VT-1 Inspected JP sensing lines for Pumps 5, 6, 7, 16, & 17. No indications RF11 VT-1 Inspected JP sensing lines for Pumps 6, 7, 16, & 17. No indications.

RF12 VT-1 Inspected JP sensing lines for Pumps 6, 7, 11, 12, 16, & 17. No indications.

RF13 VT-1 Inspected JP sensing lines for Pumps 6, 7, 13, 14, 16, & 17. No indications.

RF14 VT-1 Inspected JP sensing lines for Pumps 6, (10/10) __7, 15, 16, 17, & 18. No indications.

Vessel ID Brackets Each outage VT-1/3 Inspect sample population each outage.

(BWRVIP-48) We have inspected most brackets each outage (core spray, feedwater). Jet pump riser brace, steam dryer support lugs, guide rod brackets and specimen holder brackets are sample inspected.

No indications of cracking identified.

to NRC-11-0039 Page 23 Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Inspection Results, Repairs, Inspection Used Replacements, Re-inspections RF06 MVT-1 6 feedwater brackets.

All core spray piping brackets.

4 steam dryer brackets 1 guide rod bracket 1 specimen bracket.

No indication of cracking.

RF07 EVT-1 6 feedwater brackets.

All core spray piping brackets.

4 steam dryer brackets 1 guide rod bracket No indication of cracking identified.

RF08 EVT-1 6 feedwater brackets.

All core spray piping brackets.

4 steam dryer brackets 1 guide rod bracket Surveillance holder and Brackets @ 30 az.