View source for JAFP-07-0102, Response to Request for Additional Information Regarding the James A. FitzPatrick Nuclear Power Plant Fourth Inservice Inspection Interval Inspection Program Plan Relief Request RR-6

{{Adams
| number = ML072400420
| issue date = 08/20/2007
| title = Response to Request for Additional Information Regarding the James A. FitzPatrick Nuclear Power Plant Fourth Inservice Inspection Interval Inspection Program Plan Relief Request RR-6
| author name = Costedio J
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000333
| license number = DPR-059
| contact person = 
| case reference number = JAFP-07-0102, TAC MD4758
| document type = Letter type:JAFP
| page count = 33
| project = TAC:MD4758
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. Fitzpatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315 342 3840 August 20, 2007 JAFP-07-01 02 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

==Subject:==
Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Response to Request for Additional Information Regarding the James A. FitzPatrick Nuclear Power Plant Fourth Inservice Inspection Interval Inspection Program Plan Relief Request RR-6 (TAC NO. MD4758)

==References:==
: 1. Entergy letter JAFP-07-0030, Fourth Inservice Inspection Interval Inspection Program Plan, dated February 27, 2007.
: 2. James A. FitzPatrick Nuclear Power Plant - NRC Request for Additional Information Related to Relief Request RR-6 (TAC NO.
MD4758), dated August 1, 2007.

==Dear Sir or Madam:==

Entergy Nuclear Operations Inc., (Entergy) submitted the Fourth Inservice Inspection Interval Inspection Program Plan, (Reference 1). Entergy received a Request for Additional Information (RAI) with three (3) questions in regard to Relief Request RR-6 (Reference 2). Enclosure 1 to this letter provides the responses to the RAI and Enclosure 2 provides Revision 0-A to Relief Request RR-6. The revised relief request incorporates the responses to the RAI and provides an update to Attachment 5 to RR-6 showing the current schedule of inspections for the fourth ten year interval.
There are no commitments contained in this letter. If you have any questions, please contact Mr. Jim Costedio at (315) 349-6358.
Very truly yours,
/Jim &#xfd;ostedlio Manager, Regulatory Compliance JC:ed Enclosure 1: Request for Additional Information Responses Enclosure 2: Relief Request RR-6 Rev. 0-A cc: next page

JAFP-07-01 02 Page 2 of 2 cc:
Mr. Samuel J. Collins Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. John Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555-0001 NRC Resident Inspector U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093

JAFP-07-01 02 ENCLOSURE I Request For Additional Information Responses

JAFP-07-01 02 ENCLOSURE I RAI-01: Results of inspections that were conducted through refueling outage (RO) 16 (year 2004) are recorded in pages 12 through 24 of the submittal. However, R01 7 (year 2006) inspection results of the RVI components were not included in the submittal. The staff requests that the licensee provide this information so that it can perform an effective review of the Relief Request.
Response: Attachment 3 to Relief Request RR-6 which is titled "Reactor Internals Inspection History (Update through ROW7, October 2006)" was inadvertently submitted without the R01 7 information. Attachment 3 has been updated to include the appropriate information. This correction is reflected in the revised copy of RR-6, designated Rev. 0-A, which is provided as Enclosure 2 to this letter.
RAI-02: Editorial correction -
(A)     The staff requests that the licensee add attachment numbers 2, 3, 4, and 5 to pages 10, 12, 25, and 28 respectively.
(B)     Section 5.0 of the Relief Request indicates that R016 inspection results are recorded in Attachment 3 (page 12). However the title on page 12 reads that R017 inspection results are included in the Attachment 3. The staff requests that the applicant make necessary corrections on page 12 of the submittal.
Response: As requested attachment numbers have been added to each of the relief request attachments. Section 5.0 of the Relief Request has been revised to state, "Attachment 3 is a summary of FitzPatrick's reactor internals inspection history, including results from the last inspections performed during the most recent refuel outage (RO17, October 2006)." These corrections are reflected in the new copy of RR-6, designated Rev. 0-A, and provided as Enclosure 2 to this letter.
RAI-03: Section 4.1 of item 5 of the BWRVIP-1 00-A report, "Updated Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds," dated August 2006, states that fracture toughness values of stainless steel materials that are exposed to neutron fluence values greater than 1 X    1021 n/cm 2 (E>1 MeV) are lower than those used in Appendix C of the BWRVIP-76 report, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines." Confirm that your planned inspections of the JAFNPP core shroud and for core shroud repair hardware for the unit's fourth ISI interval are consistent with both BWRVI P-76 and BWRVI P-100-A.
Response: Core shroud and core shroud repair hardware inspections and intervals will comply with BWRVI P-76 and BWRVI P-1 00-A to the extent applicable.
Page 1 of 1

JAFP-07-01 02 ENCLOSURE 2 Relief Request RR-6 Rev. 0-A-

V JAMES A. FITZPATRICK 4 th INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER: RR-6 REVISION 0-A (Page 1 of 28)
Proposed Alternative In Accordance with IlOCFR5O.55a(a)(3)(i) 1.0      ASME Code Component(s) Affected Code Class:                        Class I Examination Categories:            B-N-I1, Interior of Reactor Vessel, and B-N-2, Welded Core Support Structures and Interior Attachments to Reactor Vessels Item Numbers:                      B13.10,   Vessel Interior B 13.20,  Interior Attachments within Beltl ine Region B 13.3 0, Interior Attachments beyond Beltl ine Region B 13.40,  Core Support Structure 2.0      Applicable Code Edition and Addenda The Code of Record for the fourth Inservice Inspection Interval is ASME Section XI Code, 2001 Edition, 2003 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-I and B-N-2 and are identified with the following item numbers:
B313.10      Examine accessible areas of the reactor vessel interior each period by the VT-3 method.
B 13.20      Examine interior attachment welds within the beltline region each interval by the VT-lI method.
B 13.30      Examine interior attachment welds beyond the beltline region each interval by the VT-3 method.
B 13.40      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.

JAMES A. FITZPATRICK 41h INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER: RR-6 REVISION 0-A (Page 2 of 28) 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, 2001 Edition, 2003 Addenda,, 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-1I8-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 deltaP Inspection aiid Flaw Evaluation Guidelines"
* BWRVIP-38, "BWRVIP Shroud Support Inspection and Flaw Evaluation Guidelines"
* BWRVIP-41, Revision 1, "B WRVIP Jet Pump Assembly Inspection and Flaw Evaluation Guidelines"
     "   BWRVIP-47-A., "BWR Lower Plenumn Inspection and Flaw Evaluation Guidelines"
     "   BWRVIP-48-A,. "BWR Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines"
     "   BWRVIP-76, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines"
     "   BWRVIP-138, "BWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines"  compares the required ASME Category B-N-i and B-N-2 examination requirements with the above current BWRVIP Guideline requirements that are applicable to FitzPatrick. Attachment 3 is a sumnmary of FitzPatrick's reactor internals inspection history, including results from the last inspections performed during the most recent refuel outage (RO 17, October 2006). Attachment 4 identifies the applicable component in the reactor internal inspection program and the total number of welds in each component. Attachment 5 tabulates planned reactor vessel internals inspections for the 4th interval.
In addition., the requirements of BWRVIP-94, Revision I, "Program Implementation Guide", will be followed. BWRVIP-94, Revision 1 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 implemnented. Therefore, the attached Table only represents the most current comparison.

JAMES A. FITZPATRICK 4' INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER: RR-6 REVISION 0-A (Page 3 of 28) 6.0      Basis for Use These BWRVIP Guidelines were developed and maintained to provide guidance in the examnination 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      B313. 10, Reactor Vessel Interior Accessible Areas B-N-I The ASME Section XI 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 mninimum, a VT-3 inspection of reactor vessel interior components. Additionally, the BWRVIP Guidelines require that mnany component welds and weld heat affected zones in this category be inspected by a VT-i, EVT-I, or UT. The BWRVIP inspection method meets (VT-3) or exceeds (VT-i1, 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 Guidelines (BWRVIP-1I8-A) 0         The Section XI 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-1I 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 onl the creviced weld locations, then the frequency is every other outage (4 years).
100% of the pipe brackets are inspected by EVT- I every 4 outages (8 years).
100% of the major Core Spray sparger welds require an EVT-1 IInspection every other outage (4 years). 50% of the other Core Spray sparger welds require a VT- I inspection every other outage (4 years). 100% of the sparger bracket welds are inspected by VT- I every 2 outages (4 years).

JAMES A. FITZPATRICK 4" INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER: RR-6 REVISION 0-A (Page 4 of 28)
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-I) or every other outage (UT) is superior in crack detection and inspection frequency to the VT-3 examination required every period. The sparger bracket inspection method (VT- I) 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 requiremnents by providing an equivalent or in most cases superior inspection methods. Additional examples of components in this category are:
* Top Guide (BWRVIP-26-A)
* Jet Pumps (BWRVIP-41, Revision 1 and BWRVIP-138)
* Control Rod Guide Tube and Fuel Support Castings (BWRVIP-47-A) 6.2      B 13.20. Interior Attachments Within the Beltline (B-N-2)
The ASME Code requires a VT-I 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 beitline 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 Pu~mp Riser Braces (BWRVIP-4 1. Revision I and 48-A) 0        The Code requires a 100% VT- I inspection of the Jet Pump riser brace-to-reactor vessel wall pad welds each 10 year interval.
0       The BWRVIP requires an EVT-1I 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-I 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-i (EVT-I) 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 performning an EVT-1 inspection Would detect Such degradation mechanisms.

JAMES A. FITZPATRICK 4'h INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER: RR-6 REVISION 0-A (Page 5 of 28)
The Code VT- I 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-1I is a visual inspection method where the equipment and environmental conditions are such that they can achieve a Y2 mul (0.0005 inch) resolution onl thle inspection surface.
The ASME Code and thle 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 XI Code.
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        B 13.30. 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 somne 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 samne scope of inspection (accessible welds), the same inspection frequency (each 10 year interval) and ASME Section X1 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:
" Steam Dryer Holddown Brackets (BWRVIP-48-A)
* Guide Rod Brackets (BWRVIP-48-A)
" Surveillance Specimen Upper Holder Brackets (BWvRVIP-48-A)
Additionally, there are interior attachment welds outside the beltline region that the BWRVIP requires an EVT-1I inspection instead of thle Code required VT-3 inspection. The inspection frequency for EVT-1I 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 sarne inspection scope (accessible welds), an increased inspection frequency (8 years instead of 10 years) and the same flaw evaluation criteria (Section XI), thle 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.

JAMES A. FITZPATRICK 4" INSERVICE INSPECTION'INTERVAL RELIEF REOUEST NUMBER: RR-6 REVISION 0-A (Page 6 of 28)
Vessel ID Attachment Weld Inspection and Flaw Evaluation (BWRVIP-48-A)
* The Code inspection requirement is a VT-3 inspection of each weld every 10 years.
0        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.
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      B 13.40, Welded Core Support Structure-Core Support Structure (B-N-2)
Thle 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 thle Code for integrally welded Core Support Structures or either an enhanced visual inspection EVT-1 or volumetric examination UT.
As described in Attachment 2, the following component has the same VT-3 method of inspection, the samne 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-lI 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:
9 Core Shroud Repair Tie-rods (BWRVIP-76)
The BWRVIP may also require either an EVT-1I or UT of core support structures. The core shroud is used as an example for comparison between thle Code and BWRVIP inspection requirements.
BWR Core Shroud Inspection and Flaw Evaluation Guidelines (BWRVIP-76)
* The Code requires a VT-3 of accessible surfaces every 10 years.
* The BWRVIP requires an EVT-1I or UT of each core shroud design reliant weld every 10 years (maximum). When the EVT-1I method is used for one-sided weld inspection due to inaccessible surfaces, the inspection interval shall be 6 years (maximum).

JAMES A. FITZPATRICK 4t1h INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER: RR-6 REVISION 0-A (Page 7 of 28)
Thle 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 50.5 5a(a)(3)(i), using these BWRVIP Guidelines as an alternative to the ASME Section XI Code requirements provides an acceptable level of quality and safety. In many cases the BWRVIP examination requirements exceed the requirements of ASME XI by requiring more detailed examination criteria (for example, VT-I and UT for shroud welds vs. VT-3). The BWRVIP Guidelines also provide detailed inspection areas and guidance for scope expansion if a defect is detected.
8.0      Duration of Proposed Alternative Entergy proposes to use the alternative for the fourth Inservice Inspection Interval for James A.
FitzPatrick Nuclear Power Plant.
9.0      Precedents A similar relief request was approved for the James A. FitzPatrick Nuclear Power Plant (Reference NRC SER (TAC No. MC85 87), dated August 30, 2006).
10.0     Attachments:
Attachment 1             Not Used Attachment 2             Comparison of ASME Category B-N- I 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 RO 17, October 2006) (Reference 11. .19).
Attachment 4             List of Components in the Reactor Internals Inspection Program and the Number of Welds/Components Attachment 5             Reactor Vessel Internals Inspections for the Fourth Interval

JAMES A. FITZPATRICK 4th INSERVICE INSPECTION INTERVAL RELIEF REQUEST NUMBER: RR-6 REVISION 0-A (Page 8 of 28)
: 1. References 1 1,1   NYPA Letter JPN-97-O 13, 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 BWRVIP".
11.3    BWRVIP Letters to NRC, dated May 30 and October 30, 1997, "BWR Utility Commitments to the BWRVIP".
11A4    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- 1072 85, 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- 108724".
11.8   NRC letter to BWRVIP, dated October 6, 1999. "Staff Reevaluation of Table I in the BWRVIP-07 Report".
11.&#xfd;9  NRC letter to BWRVIP, dated October 13, 1999, "Final Safety Evaluation of
           'BWRVIP, BWR Lower Plenumn Inspection and Flaw Evaluation Guidelines (BWRVIP-47),' EPRI Report TR- 108727".
11 .1   NRC letter to BWRVIP, dated December 2, 1999, "Final Safety Evaluation of BWrR 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.&#xfd;12  NRC letter to BWRVIP, dated July 24, 2000, "Final Safety Evaluation of the 'BWvRVIP, BWR Shroud Support Inspection and Flaw Evaluation Guidelines (BWRVIP-38),' EPRI Report TR- 108823".
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, 200 1, "Final Safety Evaluation of the
            'BWRVIP, BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines (B3WRVIP-4 1)".
11 .15  NRC letter to BWRVIP, dated August 20, 200 1, "Final Safety Evaluation of the
           'BWRVIP, Shroud Vertical Weld Inspection and Evaluation Guidelines (BWRVIP-63)".
11.16   Entergy Letter JAFP-02-0251I to NRC, dated December 26, 2002, "In-Vessel Visual Inspections Summary Report 20021 Refuel Outage (Reload 15/Cycle 16)".

JAMES A. FITZPATRICK 4 th INSERVICE INSPECTION INTERVAL RELIEF REOUEST NUMBER: RR-6 REVISION 0-A.
(Page 9 of 28) 11 .17 Reactor Internals Inspection History for James A. FitzPatrick Nuclear Power Plant (Updated through RO 16, 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.
11 .19 Reactor Internals Inspection History for James A. FitzPatrick Nuclear Power Plant (Updated through RO 17, October 2006).

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 2 (Page 10 of 28) 2 Comparison of ASME Category B-N-I and B-N-2 Examination Requirements with BWRVIP Guideline Requirementst( )
ASME Item                    CmoetASME                           Exam      ASME          ASME         Applicable BWRVIP                     BWRVIP          TBWRVIP              B RI        rqec No. Table                                                  ScpIxm                    FeunyDouetEa~oe                                                             Ea
 -                             opoetScp                                     Ea          reunc                   oumn                        xa     coe            EamBRVPFeqec B13.l10           Reactor Vessel Interior             Accessible         VT-3     Each period    BWRVIP-18-A, 25, 26-                In accordance w~ith applicable BWRVIP Document.
(Note 1)                               Areas                                    A,27-A, 38, 41 Rev. 1, (Non-specific)                                  47-A. 48-A, 76, 138 B 13.20           Interior Attachments                Accessible         VT-I     Each 10-year     BWRVIP-48-A Table                   Riser Brace             EVT-lI    100% in first 12 years (with Within Beltline - Jet                  Welds                       Interval                  3-2                     Attachment                       50% to be inspected in the 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 B 13.30           Interior Attachments                Accessible         VT-3     Each 10-year     BWRVIP-48-A Table                      Bracket               VT-3    Each 10-year Interval Beyond Beltline - Steam                Welds                       Interval                  3-2                     Attachment Dryer Hold-down Brackets Guide Rod Brackets                                                               BWRVIP-48-A Table                      Bracket               VT-3    Each I10-year Interval 3-2                     Attachment Steam Dryer Support                                                              BWRVIP-48-A Table                      Bracket              EVT- I   Each I10-year Interval Brackets                                                                                     3-2                     Attachment Feedwater Sparger                                                                BWRVIP-48-A Table                      Bracket              EVT- I   Each I10-year Interval Brackets                                                                                     3-2                     Attachment Core Spray Piping                                                                BWRVIP-48-A Table                      Bracket              EVT-lI   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 H9              EVT- I or Maximum of 6 years for EVT-H9)                                                                                3.1.3.2, Figure 3-5                                         UT      I, Maximum of 10 years for
______________UT B 13.40           Integrally Welded Core              Accessible         VT-3     Each 10-year           BWRVIP-38                       Weld H9              EVT- I or Maximum 6 years for EVT-l1, 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 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___10                ear

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 2 (Page 11I of 28)
Notes: I. 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 11. 1).
: 2. 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.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 12 of 28)
James A. FitzPatrick Nuclear Power Plant Reactor Internals Insvection I istorv (Undated throuuh ROI 7. October 2006)
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, EVTI-lI              94/9.5 Outaue: Planar flaws on H2, 35" leno h intermittent Shroud        present          VT-3 For               (11)101) less than 0.75" depth by UT: two small planar Shroud Tie Rods              flaws on H3, 1.42" length (l[)/OD) by UT .A calculated 136" of vertical weld were inspected by EVT-I or UT with no relevant indications.
96 Outagec: Crack like indications on 1-12 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 6-3.14" in length Out of total 92". and two horizontal 1/2" each (one OD and one MD).
Crack l ike indications werec less than 10% of weld length and are within allowables per BWRVIP-07. Shroud inspections includled 215%1  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 (RO 13)                                 Guidelines (by EVT-l) for all vertical welds. 100% of beitline shroud welds inspected in RO-13). Relevant indications found in 5 welds as follows:
                                                         *SV5A 01)-There are 6 indications with a combined length of 9.3 inches.
                                                         *SV5B 01)-There al-c 18 indications with a combined indication length of 45.8 inches.
                                                         *SV6A OD-There is 1 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 Ind icat ion-Indication is 3 inches firomn SV5A ID and is 6 inches long and goes across the SH4 horizontal weld.
No relevant indications noted on other vertical welds.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 13 of 28)
Components in    Date or   1     Inspection     Summary of Inspection Results, Repairs, Replacements, BWYRVIP     Frequency of     Method Used      and Re-inspections
   .Scope      Inspection  _________             ___________________________
Core Shroud    Fall 2000           EVT- I      Re-inspected per BWRVIP-76 Guidelines: Vertical (cont.)      (RO 14)                        Welds SV5A, SV5B3, SV6A and SV6B3. Relevant 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.
                                                *SV5B3 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.
                                                *SV6B3 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 SV5B3. This indication is branching out near the bottom portion.
Fall 2002           EVT- I      Re-inspected by BWrRVIP-76 Guidelines: Vertical (RO 15)                        Welds SV2B3, SV5B3, and SV8A; and Radial Ring Welds SV3A and SV3D. Relevant indications were only noted on the SV5B3 weld, as follows:
0 SV5B3 ID and OD. There appears to be no discernable changes this outage affecting the cracks length from R0 14; though one additional indication is noted on the ID CCW side of the weld approximately V24"  long. This indication may be associated with indications on the opposite side (OD) at the same location.
Fall 2004           EVT-1I      Inspected Vertical Welds SV2A, SV8C, SV9A, SV9B3 (RO 16)                        and SV9C. No relevant indications noted.
Fall 2006            UT         Inspected Vertical Welds SV4A, SV4B3, SV5A and (RO 17)                        SV5B3. No relevant indications noted for welds SV4A and SV4B3. For Welds SV5A and SV5B3, there is close correlation of flaws from previously seen by EVT-1 in R 14, with lim ited crack growth and no through wallI indications. Identified some additional (short intermittent) flaws at Weld SV5A. All indications were satisfactorily dispositioned.
EVT- I      Inspected Vertical and/or Radial Welds SV3B3, SV3E, SV6A, SV6B3 and SV8B3. Previous indications were observed in Welds SV6A and SV6B3 with no apparent change since R14.
EVT- I      Linear indications (<1/2" length) were observed in the upper section of the shroud where the slot was EDM'd for the tie-rod bracket support. The indications are located at 8 out of 10 tie-rod locations. The indications were satisfactorily dispositioned as having no effect on the structural integrity of the load path between the shroud and the tie-rods for applied vertical or radial loads.

RELIEF REOUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 14 of 28)
Components in             Date or         Inspection             Summary of Inspection Results, Repairs, Replacements, BWRVIP             Frequency of     Method Used               and Re-inspections Scope               Inspection  _____________________________________
1992 to      UT or EVT-lI              92 Outage: Inspected 0 and 180 deg access covers by UT.
Shroud Support 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-lI                Baseline completed per BWRVIP-07 (RO 13)            VT-3                and BWRVIP-38 guidelines for all shroud repaired tie rods and load transfer 'gusset plate welds.
                                                                  *7 out of 10 tie rod assemblies inspected (by EVT-lI/NT-
: 3) in Fall 1998. No relevant indications noted.
                                                                  *All load transfer gusset plate welds and 12 inches of H9 weld each side of the gussets were examined by EVT-1.
7 out of 10 gussets inspected in R013. No relevant indications noted.
Examined by EVT-1I the access hole cover at 180 degyrees. No relevant indications noted.
Fall 2000/2002                              No inspections during R014 and R015 Fall 2004          EVT-lI                Inspected two shroud support gusset plate welds and 12 (RO 16)                                 inches of H9 top weld each side of the gussets. No relevant indications noted.
Fall 2006          EVT-1I                Inspected all ten shroud repair tie-rod systems and (RO 17)                                 corresponding shroud support gusset welds at same locations. No relevant indications were noted.
Inspected top portion of horizontal weld H9 at each side VT- I                of tie-rod locations and between gussets at 1800. No relevant indications were noted.
Inspected the access hole cover at 180', with no relevant indications noted.
Core Spray              1987 to            VT-3,                IEB 80-13 of piping and welds in annulus. One clamp Piping                present         MVT-l or                repair in 1988 at cracked weld in "B" loop at 190 deg EVT-lI                below upper elbow piping. Welds were brushed and inspected by EVT-lI per BWRVIP- 18 in Fall, 1996. No relevant indications found.
Fall 1998          EVT-l1,               Re-inspected 100% of loop "A" and' (R0 13)           MVT-1                 "B" welIds per BWRV IP-18 G uidel ines (by EVT-l1). No relevant indications noted, except for a rub-mark near CSA-
___________     _____________                 10 weld.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 15 of 28)
Components in      Date or           Inspection     Summary of Inspection Results., Repairs, Replacements, BWRV1P        Frequency of       Method Used      and Re-inspections Scope        Inspection    _________
Core Spray       Fall 1998            EVT-l,        Support brackets were examined by MVT-1. No Piping (cont). (R0 13) (cont).         MVT-I         recordable indications noted.
Fall 2000            EVT-lI        Re-inspected all Loop "A" and "B" creviced and T-box-(RO 14)                           to-pipe welds, including repair clamp welds per BWRVIP- 18 Guidelines (by EVT-l1).
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 Ill s assessment is that the indication is now believed to be a scratch.
Fall 2004             EVT-1I       Re-inspected all Loop "A" and "B" creviced and T-box-(R0 16)                           to-pipe welds-, repair clamp welds at Loop "B" downcomer pipe; and rotating sample of pipe elbow upper/lower welds in Loop "A" at 170 degrees. No relevant indications noted.
Fall 2006             EVT-I        Re-inspected all Loop "A" and "B" creviced and T-box-(RO 17)                           to-pipe welds; repair clamp welds at Loop "B" downcomer pipe, and rotating sample of pipe elbow upper/lower welds in Loop "B" at 190 degrees. Also, inspected all bracket support welds, including RPV side for Loop "A" and "B". No relevant indications noted.
Core Spray         1987 to              VT-3,       IEB 80-13 of sparger and welds. MVT-lI and EVT- I Sparger        present           MVT-1 or        inspections per BWRVIP- 18 in Fall, 1996. An indication EVT-1I       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 (R0 13)             MVT-I         per BWRVIP- 18 Guidelines (EVT-lI/MVT- 1) including tee boxes, end caps, drain welds., and support brackets.
No relevant indications noted.
Fall 2000              N/A        Fall2000N/A No inspections during R014

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 16 of 28)
Components in         Date or        Inspection     Summary of Inspection Results, Repairs., Replacements, BWRVIP          Frequency of     Method Used      and Re-inspections Scope           Inspection                     _________________________
Core Spray          Fall 2002          EVT-I       Re-inspected all T-box and end caps to sparger pipe Sparger            (ROl15)                       welds at Loops "A", "B", "C", and "D". No relevant
(*cont.)                                         indications noted.
VT- I      Re-inspected Sparger "C" and "D" nozzle welds, and supporting brackets at "A" and "B". No relevant indications noted.
Fall 2004           VT-I       Re-inspected all sparger bracket support welds at "C" and (RO 16)                       "D". No relevant indications noted.
Fall 2006      EVT-l, and      Re-inspected by EVT-I all T-box and end caps to pipe (R0 17)            VT- I      welds, and by VT-I all bracket welds at spargers "A",
                                                    "B", "C" & "D". Re-inspected by VT- I all nozzle and drain to sparger welds at spargers "A" & "B". No relevant indications noted.
Top Guide         1988, 1992       VT-3, and      2 cells inspected in 1988 and in 1992; 4 cells in 1994.
(Rim., etc.)   and 1994/1995          EVT-lI      Additional inspections included , alignment wedges ,
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 R013 A total of 4 hold down assemblies were examined by VT-Fall 2000   VT-I1, and VT-3)    I and 3 alignment pin assemblies by VT-3 per BWRVIP-(RO 14)                       26 Guidelines. No indications were noted.
Fall 2002 and           N/A       No inspections in ROl15 and R0 16.
2004 Fall 2006   VT-I1, and VT-3    Inspected by VT-I hold-down assemblies at 0 and 180 (R0 17)                       degrees (top only as below top 'guide is inaccessible).
Inspected sampling of top guide surfaces by VT-I/VT-3.
Also, inspected aligner pins at 0 and 180 degrees by VT-I. No relevant indications noted.
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 (RO 13))                      indications noted.
Fall 2000           VT-3       Inspected core plate plugs at 5 core locations. No relevant (RO 14)                       indications noted.
Fall 20021           N/A       No inspections during ROI15 Fall 2004           VT-3       Inspected a total of 6 core plate plugs (at two locations).
____________      (R0 16)   _________No              relevant indications noted.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 17 of 28)
Components in       Date or                  Inspection     Summary of Inspection Results, Repairs, Replacements, BWRVIP        Frequency of               Method Used      and Re-inspections Scope        Inspection           ________
Core Plate       Fall 2006                     VT-3       Inspected core plate plugs and the surrounding core plate (Rim, etc.)       (R0 17)                                 surface at four LPRM locations. No relevant indications (cont). __________________noted.
SLC          Fall 2000                    EVT-2       Performed Enhanced VT-2 on SLC nozzle-to-safe end (RO 14)                                 weld during RPV System Leakage Test per BWRVIP-27 Guidelines. Test was "Accepted".
Fall 20021/2004                  EVT-2       Performned Enhanced VT-2 on SLC nozzle-to-safe end (R0 15/16)                                weld during, RPV System Leakage Test per BWRVIP-27 Guidelines. Test was "Accepted".
Fall 2006                      PT        Performed liquid penetrant examination on SLC nozzle-(RO 17)                                 to-safe end weld per BWRVIP-27 Guidelines with no recordable indications noted.
Jet Pump      1987 to 1994               VT-I ,VT-3      Inspected all riser brace attachment welds by VT-I. No Assembly                                     and UT       relevant indications but found debris at some weld 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-i, and at three welds by VT-3 examination. No cracking was found in the reviewed welds.
Fall 1998            MVT-l, and VT-      Inspected by MVT- 1 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-3 b 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-l1, VT-I1,    Completed inspection of Jet Pumps 5 and 6, and portions (R0 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-lI welds on the inlet-mixer, but there are IN-4 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.

RELIEF REOUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 18 of 28)
Components in     Date or          Inspection     Summary of Inspection Results, Repairs, Replacements, BWRVIP       Frequency of      Method Used      and Re-inspections Scope       Inspection   _________            ____________________________
Jet Pump Assembly       Fall 2004            EVT-1I      Performned "High - priority" riser weld inspections at Jet (cont).       (R0 16)                         Pumps #], 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-l) inspections at Jet Pumps #17 and 18. No relevant indications noted.
Fall 2006              UT         Inspected all twenty jet pump beams with no relevant (RO 17)                          indications recorded.
Inspected "High"- priority welds AD-], AD-2, AD-3a, AD-3b, DF-2 and DF-3 at all 20 jet pumps (JP) with recordable indications at welds DF-2 (JP# 1 & 3) and AD-3b/DF-3 (JP#12 & 17). All indications were satisfactorily dispositioned for one operating cycle.
EVT-1        Inspected "High"-. priority welds DF-2 at JP #1 &3 and DF-3 at JP #17 based on UT results. No recordable indication noted.
EVT-lI       Inspected riser welds RS-l, RS-2 and RS-3 at JP #19/20
                                                  & RS-3 at JP #03/04. Also inspected RS-6, RS-7, RS-8, RS-9 and RB welds at JP #01/02, 03/04, 17/18 & 19/20 with no recordable indications noted.
EVT-I        Inspected weld DF-1 at JP #01/02, 03/04, 17/18 & 19/20 with no recordable indications noted.
VT- I       Inspected wedge bearing surfaces (WD-1I) at JP # 1, 2, 3, 4, 19 & 20 with no relevant indications noted.
Jet Pump      1992 and 94            VT-3        See above.
Diffuiser Fall 1998            MVT-1        See Jet Pump Assembly (above).
(RO 13)
Fall 2000             N/A         No inspections during R014 (RO 14)
Fall 2002/2004      EVT-1/VT-l       See Jet Pump Assembly (above).
(R0 15/16)
Fall 2006         UT/E VT-I       See Jet Pump Assembly (above).
(RO 17)

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 19 of 28)
Components in        Date or          Inspection     Summary of Inspection Results, Repairs, Replacements.,
BWRVIP          Frequency of      Method Used      and Re-inspections Scope         Inspection                       _________________________
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 R0 13.
Fall 2000        EVT-l 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 (R0 15)                         BWRVIP-47 Guidelines. No relevant indications noted.
Fall 2004            N/A         No inspections in R016.
Fall 2006    EVT-1 and VT-3      Inspected accessible surfaces at three Guide Tubes. No
____________    (RO 17)                         relevant indications noted.
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/
2004/2006                        __________________________
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.
2006                         __________________________
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 IRMISRM 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 SR-M Core Dry Tube 20-17 per GE SIL 409 (R0 15)                         and GE RICSIL-073 Guidelines. No relevant indications noted Fall 2004            N/A         No inspections in R016.
Fall 2006            VT- I       Inspected dry tubes at three locations with no relevant (RO 17)     _______             indications noted.
Instrument           1992              VT-I        Two inspected in 1992. No relevant indications noted.
Penetrations Fall 1998            N/A         No inspections in R013..

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 20 of 28)
Components in                   Date or       Inspection        Summary of Inspection Results, Repairs, Replacements, BWRVIP                    Frequency of    Method Used        and Re-inspections Scope                    Inspection                       __________________________
Instrument                   Fall 2000         VT-2           Performed VT-2 ISI System Leak-age Exam Test at 6 Penetrations                   (RO 14)                         instrument nozzles (during RPV System Test) per (cont.)                                                    BWRVIP-49 Guidelines. Test was conducted to the extent possible with insulation installed and shield doors closed. Test was "Accepted".
Fall 2002,         VT-2           Performed a VT-2 leakage test at 6 instrument nozzles 2004 and 2006                       (same as in R014-Fall 2000). Test was "Accepted" with
___________(R015/16/17)                                     no leakage I_______       noted.
Vessel ID                    1987 to          VT-I1,         Section Xl inspections ofjet pump riser brace, dryer, Brackets                    present          VT-3,          feedwater sparger, core spray, and surveillance capsule 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-1I 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 R014 Fall 2002        EVT-lI          Inspected Jet Pump Riser Brace (at JP #5/6 and # 19/20)-,
(RO 15)                         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 (RO 16)                         at two locations., with no relevant indications.
EVT-l1,         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.
Fall 2006         VT- I          Inspected surveillance sample holder brackets (upper and (RO 17)                         lower) at 0300 and 120' to RPV wall, with no relevant indications noted.
VT-3           Inspected guide rod and bracket to RPV weld at 000',
with no recordable indications.
LPCI Coupling                     N/A     J       N/A           Not applicable to this plant.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 21 of 28)
Components in           Date or       Inspection      Summary of Inspection Results, Repairs, Replacements, BWRVIP             Frequency of   Method Used       and Re-inspections Scope            Inspection                     __________________________
Fuel Support          Fall 1998         VT-3         Inspected accessible areas at fuel support castings during Castings            (RO 13)                       in-process control rod blade change-out. No relevant indications noted.
Fall 2000         VT-3         Inspected accessible areas at fuel support castings during (RO 14)                       in-process control rod blade change-out. No relevant indications noted.
Fall 2002         VT-3)        Inspected accessible areas at four fuel support castings (RO 15)                       during in-process control rod blade change-out. No relevant indications noted.
Fall 2004         N/A          No inspections in R0 16 Fall 2006         VT-3         Inspected accessible areas at fuel support castings at four
___________        (RO 17)                       locations. No relevant indications noted.
CRD Nozzle            Fall 1998         VT- I        The Control Rod Drive Nozzle Inner Radius was NIR              (RO 1)                        examined. No relevant indications noted.
Fall 2000        EVT-lI        Examined the CRD Nozzle Inner Radius, including (RO 14)                       adjacent vessel wall area. No relevant indications noted.
Fall'2002,         N/A          No inspections in R0 15, R0 16, and R0 17.
____________2004       and 2006                  _________________________
Steam Dryer           Fall 1998         VT-3         Inspected 25% of shroud head bolts at storage pit. No Moisture             (RO 13)                       relevant indications noted.
Separator Fall 2000       VT-3 and       Re-inspected by VT-3 all areas of the steam dryer support (RO 14)         EVT- I        ring and by EVT-lI previously found cracks (1992/1994).
A total of 10 indications were noted in 2000 (RO 14),
with no discernable changes from previous inspection.
Fall 2004    VT- I and VT-3    Inspected steam dryer integrity per SIL 644 Supplement I (RO 16)                       (steam dryer integrity) and INPO OE 18796 (steam dryer 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 RO017.
VT-3         Inspected steam dryer hold-downs and support brackets and attachment welds with no relevant indications noted.
Inspected steam separator lifting rod eye assemblies, and 25% of shroud head bolts with no relevant indications noted.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 3 (Page 22 of 28)
Components in    Date or              Inspection     Summary of Inspection Results, Repairs, Replacements, BWRVIP      Frequency of          Method Used      and Re-inspections Scope      Inspection       ________
Steam Dryer    Fall 2006                VT-I        Inspected selected welds on the steam dryer (per Moisture      (ROI17)                             requirements of BWRVIP-139 over those recommended Separator                                          by SIL 644). A relevant indication was noted at the (cont).                                          intersection of H-2 and V-7 welds (SW quadrant), and the weld was ground out and repaired in RI17.
Inspected previous relevant indications noted in R16 (i.e..
at eight vibration block welds and at weld adjacent to drain channel weld #8) with no observed change noted since RI16. The linear indication length at one vibration block was re-configured from the previous R16 reporting.
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 Fall 2006                VT- I       Inspected upper and lower mounting bracket welds at (RO 17)                             0300 and 120'. No recordable indications noted.
Lower Plenum    Fall 2000                VT-3        Inspected by VT-3 accessible areas of lower plenum per (RO 14)                 VT-I        BWRVIP-47 Guidelines. No relevant indications noted.
Inspected by VT- I accessible areas of bottom head drain.
After removal of debris the area was re-examined and found acceptable.
Fall 2002,               N/A         No access.
2004, and 2006 (ROI15, R016, and R017)________________                                                                      __
Feedwater     Fall 2002                VT-3        Inspected Sparger pipe assembly at 45, 135, 225 and 315 Sparger      (ROl15)                             degrees azimuth, sparger welds and end brackets. No relevant indications noted.
VT- I       Inspected Junction T-box welds and Nozzle Inner Radius (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.
Fall 2004 and              N/A         No inspections performed.
2006 (R016 &
____ ____     R 1 )       I_                           _   __    _  __I_        __    _  __   _I__          _

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 4 (Page 23 of 28)
List of Components in the Reactor Internals Inspection Program and the Number of Welds/Components Reactor Internals 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        BWRVLP-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 (Hi1,       BWRVLP-76, Figure 3.1                       3 H2, H3)
Core Shroud Horizontal Welds             BWRVIP-76, Figure 3.1                        5 (H4-H7)
Core Shroud Vertical Welds              BWRVLP-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                        1 Core Shroud Support Gussets            BWRVIP-38, Section 3.2.1                      22 and Figure 3-6 Core Spray Thermal Sleeve Welds       BWRVIP- I8-A, Section 3.2.4               1 (loop A)
(Hidden)                                                                        2 (loop B)

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 4 (Page 24 of 28)
Reactor Internals Component        BWRVIP Reference                    Number of Document                   Welds/Components Core Spray Piping Welds (except  BWRVIP-1I8-A, Table 3-5        22 per ioop (2 loops) &
P9)                                                               1 weld repaired with a welded clam shell Core Spray P9 Welds             BWRVLP-1I8-A, Section 3.2.4        2 per loop (2 loops)
Core Spray Sparger Large Circ    BWRVIP-1I8-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 1 on next page Core Spray Piping Brackets       BWRVIP-1I8-A, Table 3-5           2 per loop (2 loops)
Core Spray Sparger Brackets      BWRVIP-1I8-A, Table 3-5           6 per loop (2 loops)
Feedwater Sparger Tee Welds          NUREG 0619                    3 per loop (4 loops)

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 4 (Page 2.5 of 28)
Reactor Internals Component                BWRVIP Reference                          Number of Document                    Welds/Components Feedwater Sparger End Bracket          BWRVIP-48-A, Table 3-2                   2 per ioop (4 loops)
Attachment                        ______________
Feedwater Sparger Piping and                      NUREG 0619                    2 brackets per ioop Brackets                          _______________                                 (4 piping loops)
Jet Pump Beams                        BWRVIP-4 1, Rev. 1, Table                           20 3.3-1 and BWRVIP-13, Sections 4 and 6 Jet Pump Thermal Sleeve Welds         BWRVIP-4 1, Rev.l1, Table                    3 per Jet Pump (Hidden)                                              3.3-1.                        (10 Jet Pumps)
Jet Pump Riser Welds (RS-1, RS-2,      BWRVIP-4 1, Rev. 1, Table                   3 per Jet Pump RS-3)                                                 3.3-1                        (10 Jet Pumps)
Jet Pump Riser Welds (RS-6, RS-7,     BWRVIP-4 1, Rev.l1, Table                    4 per Jet Pump RS-8, RS-9)                                           3.3-1                        (10 Jet Pumps)
Jet Pump Riser Brace Welds            BWRVIP-4 1, Rev. 1, Table                    8 per Jet Pump 3.3-1                        (10 Jet Pumps)
Jet Pump Inlet Bolted Connection      BWRVIP-4 1, Rev. 1, Table                    2 per Jet pump 3.3-1                        (10 Jet Pumps)
Jet Pump Restrainer Wedges             BWRVIP-4 1, Rev. 1, Table                   2 per Jet Pump 3.3-1                        (10 Jet Pumps)
Jet Pump Mixer Weld MX- I              BWRVIP-4 1, Rev. 1, Table                   2 per Jet Pump 3.3-1                        (10 Jet Pumps)
Jet Pump Adapter/Diffuser Welds        BWRVIP-4 1, Rev. 1, Table                  14 per Jet Pump 3.3-1                        (10 Jet Pumps)
Lower Plenum (CRD)                               BWRVIP-47-A                          137 CRI~s Miscellaneous Vessel Internal          BWRVIP-48-A, Table 3-3                              12 Attachments                                                               I_____________________________

RELIEF REOUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 4 (Page 26 of 28)
Reactor Internalls Component                 BWRVIP Reference                      Number of Document                   Welds/Components 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 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.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 5 (Page 27 of 28)
Reactor Vessel Internals Inspections for the Fourth Interval Reactor Internal Component                                             Inspection Bases              ROI18 (2008)   R0 19 (2010)    R020 (2012)   R021 (2014)
Control Rod Drive Guide Tube Body Welds                             BWRVIP-47-A, Table 3-3                             EVT-l1(4)
Control Rod Drive Guide Tube Lug and Pin                            BWRVIP-47-A, Table 3-3                             VT-3(4)
Core Plate Rimi Hold-Down Bolts                      (NOTE I)_______
Core Shroud Vertical & Ring Segment Welds                         BWRVIP-76, Figure 3-3 & 3-4            EVT-I        EVT-l/UT    EVT-lI/UT (IN)      EVT-l Core Shroud Tie-Rod Repair                                          BWRVIP-76, Section 3.5 Core Shroud Support Welds ( H-9)                                     BWRVIP-38, Figure 3-5                                              EVT-l Core Shroud Gusset Welds                                           BWRVIP-38, Figure 3-2 and                                            EVT-l BWRVIP-76, Section 3.6 Core Spray Thermal Sleeve Welds (Hidden)             (NOTE 2)     BWRVIP- I8-A, Section 3.2.4            UT ()UT            (IN)       UIT (IN)       UT (IN)
Core Spray Piping Welds                                             BWRVIP-1 8-A, Table 3-5              EVT-l          EVT-l           EVT-lI        EVT-lI Core Spray Sparger Large Circ Welds                                 BWRV IP-1I8-A, Table 3-5       ______               EVT-lI                        EVT-l Core Spray Sparger Nozzle Welds                       ~BWRVIP-I8-A, Table 3-5                      _______           VT-I (50%)                    VT-I (50%)
Core Spray Piping Brackets                                          BWRVIP- I8-A, Table 3-5                                                           EVT-l Core Spray Sparger Brackets                                         BWRVIP-1 8-A, Table 3-1                              VT- I                         VT- I Feedwvater Sparger Tee Welds                                             NUR-EG 0619        -VT-                              I Feedwater Sparger Bracket Attachment                                BWRVIP-48-A, Table 3-2                              EVT-lI Feedwater Sparger Assembly                                               NU REG 0619                                     VT-3 Jet Pump Beams                                                 BWRVIP.-4 1, Rev.l1,Table 3.3-I and                                        UT BWRVIP-138, Section 6.4 Jet Pumnp Thermal Sleeve Welds (Hidden)              (NOTE 2)    BWRVIP-4 1, RevI.1,Table 3.3-I           UIT ()UT          (IN)       UT (IN)        UT (IN)
Jet Pump Assembly (High Priority Welds)                          BWRVIP-4I1. RevI.1,Table 3.3-I                                     EVT-l (50%)
Jet Pump Assembly (Medium & Low Priority Welds)                  BWRVIP-4 1, Rev. 1, Table 3.3-I                                    EVT-l (25%)
Jet Pump Riser Brace Welds                                       BWRVIP-4 1, RevI. 1,Table 3.3-I                                    EVT-l (25%)
Jet Pump Restrainer Wedges                                       BWRVIP-4 1, RevI.1,Table 3.3-I1     ______         ______           VT-1(25%)
Lower Plenumn Miscellaneous Vessel Internal Attachments Oriticed Fuel Support Cast ings(S amplIing)
BWRVIP-47-A. Section 3.2 BWRVIP-48-A, Table 3-2 BWRVIP-47-A, Table 3.2-I 17-3 1     WHEN ACCESSIBLE 17-3 T-3/EVT-l 1T-3 VT-3/EVT-I (IN) 1T-3 SLC Nozzle-to-Safe End Weld                          (NOTE 2)     BWRVIP-27-A, Section 3.3.1        ______jPT           or EVT-2*   EVT-?2* (IN)  PT or EVT72 Top Guide Hold-down Assemblies         -BWRVIP-26-A,                                Table 3-2       _______1           VT-1(2)    _______            VT-I1 (2)_
ITop Guide Grid Beamns_(Sampling)                                 BWRVIP-26-A, Section 3.2.2                        _______          VT-3NT-11 NOTES: (1) Inspection performed per ASME Code Section XI requirements (this component is excluded from this relief request).
(2) Inspection of these welds to be performed when UT technology is available in accordance with BWRVIP requirements of the applicable BWRVIP document.

RELIEF REQUEST NUMBER: RR-6 REVISION 0-A ATTACHMENT 5 (Page 28 of 28)
Reactor Vessel Internals Inspections for the Fourth Interval Table Key Standard Print   =  Inspections mandated by BWRVIP I & E Guidelines Italics  =  Inspections recommended for Risk-To-Generation purposes UT    =  Ultrasonic Testing planned UT(*      =  Ultrasonic Testing when the technique becomes available VT-3/VT- I(*     =  Contingency examination subject to lower plenum access VT    = Visual Testing planned EVT-lI    =  EVT-I; Enhanced Visual Test to look for cracking; 1/2 mil wire resolution with cleaning assessment EVT-2*       =Enhanced   Leakage Inspection (direct view of component during pressure test)
VT- I   = VT-I; Visual Test to look for cracks, wear, corrosion, etc.; resolution required: 1/32" black line VT-3    = VT-3; Visual Test to determine general mnechanical/structural condition; no resolution requirements PT   =  Surface examination (IN)   =  If necessary, to complete number of inspections not performed in previous outage(s)
(all, number, or %)    = Perform inspection on all or on remainder components, limited number (or percentage) of components, or just flawed components}}