ML080580199

Request for Approval of Relief Request No. PRR-16, Implementation of BWRVIP Guidelines in Lieu of ASME Section XI Code Requirements on Reactor Vessel Internals and Components Inspection

ML080580199
Person / Time
Site:	Pilgrim
Issue date:	02/14/2008
From:	Bethay S Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PRR-16, TAC MC0960
Download: ML080580199 (22)

Text

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Stephen J. Bethay February 14, 2008 Director, Nuclear Assessment United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Entergy Nuclear Operations, Inc Pilgrim Nuclear Power Station Docket No.: 50-293 License No.: DPR-35 Request for Approval of Pilgrim Relief Request No. PRR-16, Implementation of BWRVIP Guidelines in lieu of ASME Section XI Code Requirements on Reactor Vessel Internals and Components Inspection

REFERENCE:

(1) NRC Letter to Michael Kansler, "Relief Request No. RR-39, Implementation of BWRVIP Guidelines in Lieu of ASME Section Xl Code Requirements on Reactor Vessel Internals and Components (TAC No. MC8587), dated August 30, 2006.

(2) Vermont Yankee Relief No. R1 -01, dated September 19, 2005 (TAC No. MC0960)

LETTER NUMBER: 2.08.008

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy submits the attached Pilgrim Relief Request, PRR-16 (Attachment 1) for NRC approval to implement various Boiling Water Reactor Vessel Internals Program (BWRVIP) Guidelines in lieu of the American Society of Mechanical Engineers (ASME) Section X1 Code Inspection Requirements on reactor vessel internals and components.

Pilgrim Nuclear Power Station (PNPS) requests relief from the Inservice Inspection (ISI)

Program requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. The request applies to reactor vessel internals and components, and includes the technical basis for relief on each applicable component, or group of components. is a comparison of the ASME Examination Requirements and the BWRVIP Guideline requirements. Attachment 3 is the reactor internals inspection history, including the most recent refueling outage (RFO16, Spring 2007). Attachment 4 is a list of the applicable components in the Pilgrim Reactor Vessel Internals Inspection Program and the number of welds for these components. Additionally, the ASME Code does not have specific inspection requirements for the steam dryer. Entergy will use the guidelines in BWRVIP-139, "BWRVIP Steam Dryer Inspection and Flaw Evaluation Guidelines" for the steam dryer inspections.

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

/6q7

Entergy Nuclear Operations, Inc. Letter No. 2.08.008 Pilgrim Nuclear Power Station Page 2 A similar relief request was approved for Entergy's James A. Fitzpatrick and Vermont Yankee Nuclear Power Plants (References 1 and 2).

Entergy requests approval of the relief request by March 2009, in support of the Pilgrim Refueling Outage (RFO)-17, Spring 2009.

Should you have any questions concerning this letter, please contact Pilgrim Licensing Manager, Mr. Joseph R. Lynch, at (508) 830-8403.

There are no new commitments made in this letter.

Sincerely, Steve J. Bethay WGL/dl Attachments: 1. Pilgrim Relief Request (PRR)-16, Relief from ASME Section XI Examination Requirements in lieu of BWRVIP Requirements for Pilgrim RPV Internals and Components (8 pages)

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

3. Pilgrim Power Plant Reactor Internals Inspection History (Updated through RFO-16, Spring 2007) (9 pages)

4. Scope of Examination of Pilgrim RPV Internals and Components (2 pages) cc: Mr. James S. Kim, Project Manager Plant Licensing Branch I-1 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North O-8C2 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region 1 U.S. Nuclear Regulator Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector Pilgrim Nuclear Power Station

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16)

PILGRIM RELIEF REQUEST PRR-16, Relief from ASME Section XI Examination Requirements in lieu of BWRVIP Guideline Requirements for Pilqrim RPV Internals and Components Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

1.0 ASME Code Component(s) Affected Code Class: Class 1 Examination Categories: B-N-i, Interior of Reactor Vessel, and B-N-2, Welded Core Support Structures and Interior Attachments to Reactor Vessels Item Numbers: B13.10, Vessel Interior B133.20, Interior Attachments within Beltline Region B13.30, Interior Attachments beyond Beltline Region B13.40, Core Support Structure 2.0 Applicable Code Edition and Addenda The Code of Record for the fourth Inservice Inspection Interval is ASME Section Xl Code, 1998 Edition, 2000 Addenda.

3.0 Applicable Code Requirements ASME Section XI requires the examination of components within the Reactor Pressure Vessel. These examinations are included in Table IWB-2500-1, Examination Categories B-N-1 and B-N-2 and are identified with the following item numbers:

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

B13.20 Examine interior attachment welds within the beltline region each interval by the VT-1 method.

B13.30 Examine interior attachment welds beyond the beltline region each interval by the VT-3 method.

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

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

Page 1 of 8

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16)

4.0 Reason for Request

To conserve radiological exposure 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, 1998 Edition, 2000 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-18-A, "BWRVIP Core Spray Internals Inspection and Flaw Evaluation Guidelines"

• BWRVIP-25, "BWRVIP Core Plate Inspection and Flaw Evaluation Guidelines"

• BWRVIP-26-A, "BWRVIP Top Guide Inspection and Flaw Evaluation Guidelines"

• BWRVIP-27-A, "BWRVIP BWR Standby Liquid Control System/Core Plate delta P Inspection and Flaw Evaluation Guidelines"

• BWRVIP-38, "BWRVIP Shroud Support Inspection and Flaw.Evaluation Guideline"

• BWRVIP-41, Revision 1, "BWRVIP Jet Pump Assembly Inspection and Flaw Evaluation Guidelines"

• BWRVIP-47-A, "BWR Lower Plenum Inspection and Flaw Evaluation Guidelines"

• BWRVIP-48-A, "Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines"

• BWRVIP-76, "BWR Core Shroud Inspection andFlaw Evaluation Guidelines"

• BWRVIP-138, "BWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines" Attachment 2 compares the required ASME Category B-N-1 and B-N-2 examination requirements with the above current BWRVIP Guideline requirements that are applicable to PNPS. Attachment 3 is a summary of PNPS reactor internals inspection history, including results from the last inspections performed during the most recent refuel outage (RFO16 Spring 2007). Attachment 4 identifies the applicable component in the reactor internal inspection program and the total number of welds in each component.

In addition, the requirements of BWRVIP-94, Revision 1 "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 implemented. Therefore, the attached Table only represents a most current comparison.

Page 2 of 8

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16) 6.0 Basis for Use These BWRVIP Guidelines were developed and maintained to provide guidance in the examination of BWR internals and components. These Guidelines have been written to address the safety significant vessel internal components and to examine these components using appropriate methods and re-examination frequencies. The NRC has agreed with the BWRVIP approach in principle and has previously issued Safety Evaluations for these guidelines (see References). The technical basis for the proposed alternative inspection of each component, or group of components, is discussed in the following paragraphs by Code Subsections. Each section includes several examples of a component or weld that belong in each Code Subsection.

6.1 B13.10, Reactor Vessel Interior Accessible Areas B-N-1 The ASME Section Xl Code requires a VT-3 examination 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 examination of surfaces made accessible during refueling. The various BWRVIP Inspection and Evaluation guidelines require, as a minimum, a VT-3 inspection of reactor vessel interior components.

Additionally, the BWRVIP guidelines require that many component welds and weld heat affected zones in this category be inspected by a VT-1, EVT-1, or UT examination method. The BWRVIP inspection method meets (VT-3) or exceeds (VT-1, EVT-1, or UT) the inspection method requirement specified by the ASME Code.

The Core Spray piping and sparger are used as examples for comparison between the ASME Code and the BWRVIP inspection requirements.

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

• The Section Xl Code requires a VT-3 each period (3 1/3 years) of each 10 year interval of the Core Spray internal piping and sparger accessible surfaces.

The BWRVIP requires either an EVT-1 of the core spray pipe creviced welds and weld heat affected zones each refuel outage (2 year) along with 25% of the non creviced weld locations on a rotated basis or UT. If UT is performed on the creviced weld locations, then the frequency is every other outage (4 years).

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

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

The BWRVIP inspection methods are superior to the ASME 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 examinations have superior crack detection and characterization capability as compared to the Code VT-3 examination. The inspection of highly susceptible creviced weld locations every outage (visual EVT-1) or every other outage (UT) is superior in crack detection and inspection Page 3 of 8

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16) frequency to the VT-3 examination required every period. The sparger bracket inspection method (VT-1) is superior to the code inspection method (VT-3) and the inspection intervals are similar. The 25% sampling of non creviced welds ensure that 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 ASME Code requirements 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 B13.20, Interior Attachments Within the Beltline (B-N-2)

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

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

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

Jet Pump Riser Braces (BWRVIP-41, Revision 1 and 48-A) 0 The ASME Code requires a 100% VT-1 inspection of the Jet Pump riser brace-to-reactor vessel wall pad welds each 10 year interval.

The BWRVIP requires an EVT-1 inspection of all the Jet Pump Beam riser brace-to-reactor vessel wall pad welds the first 12 years and then 25% during each subsequent 6 years.

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

The Code VT-1 visual inspection method requires that a letter character with a height of 0.044 inches can be read at a maximum distance of 2 feet. The BWRVIP EVT-1 is a visual inspection method where the equipment and environmental conditions are such that they can achieve a 1/22 mil (0.0005 inch) resolution on the inspection surface.

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

Page 4 of 8

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16)

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 ASME Code. The enhanced flaw detection capability of an EVT-1, with a less frequent inspection schedule and the same flaw evaluation criteria, results in the BWRVIP inspection requirement providing the same level of quality and safety to that provided by the ASME Code.

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

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

As described in Attachment 2, the following components have the same VT-3 method of examination, the same scope of inspection (accessible welds), the same inspection frequency (each 10 year interval) and ASME Section XI flaw evaluation criteria:

Therefore, the level of quality and safety provided by the BWRVIP requirements are equivalent to that provided 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 (BWRVIP-48-A)

Additionally, there are interior attachment welds outside the beltline region that the BWRVIP requires an EVT-1 inspection instead of the Code required VT-3 inspection.

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

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

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

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

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

Page 5 of 8

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16)

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 ASME Code.

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

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

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

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

• Core Shroud Repair Tie-rods (BWRVIP-76)

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

BWR Core Shroud Inspection and Flaw Evaluation Guideline (BWRVIP-76) 0 The Code requires a VT-3 of accessible surfaces every 10 years.

• The BWRVIP requires an EVT-1 or UT of each core shroud design reliant weld every 10 years (maximum). When the EVT-1 method is used for one-sided weld inspection due to inaccessible surfaces, the inspection interval shall be 6 years (maximum).

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

7.0 Conclusion Pursuant to 10 CFR 50.55a(a)(3)(i), using these BWRVIP guidelines as an alternative to the ASME Section Xl Code requirements provides an acceptable level of quality and safety. In many cases the BWRVIP examination requirements exceed the requirements, of ASME Xl by requiring more detailed examination criteria (for example, VT-1 and UT Page 6 of 8

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16) for shroud welds vs. VT-3). The BWRVIP Guidelines also provides 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 Pilgrim Nuclear Power Station.

9.0 Precedents Similar relief requests were approved for James A. FitzPatrick Nuclear Power Plant (Reference NRC SER (TAC No. MC8587), dated August 30, 2006) and Vermont Yankee Relief RR-01 (Reference NRC SER, TAC No. MC0960, dated September 19, 2005).

10.0 Attachments:

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

Attachment 3 Pilgrim Nuclear Power Plant Reactor Internals Inspection History (Updated through RFO16, Spring 2007)

Attachment 4 Scope of Examination of Pilgrim RPV Internals and Components

11. References 11.1 Letter No.2.96.091 to NRC, "Pilgrim Station 1996 On-line and 1997 Refueling Outage 11 Inservice Inspection (ISI) Plan", October 30, 1996 11.2 Letter No.2.99.035 to NRC, "Pilgrim Station 1999 On-line and 1999 Refueling Outage 12 Inservice Inspection (ISI) Plan", March 23, 1999 11.3 NRC Letter to BWRVIP, dated July 29,1997, "BWR Utility Commitments to the BWRVIP" 11.4 BWRVIP Letters to NRC, dated May 30 and October 30,1997, "BWR Utility Commitments to the BWRVIP" 11.5 NRC letter to BWRVIP, dated April 27, 1998, "Final Supplement to the Safety Evaluation of the BWRVIP, BWRVIP-07 Report" 11.6 NRC letter to BWRVIP, dated September 15, 1998, "Safety Evaluation of the BWRVIP, BWRVIP-06 Report" 11.7 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-107285, December 1996" Page 7 of 8

Attachment 1 To Entergy Letter No. 2.08.008 (PRR-16) 11.8 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" 11.9 NRC letter to BWRVIP, dated October 6, 1999, "Staff Reevaluation of Table 1 in the BWRVIP-07 Report' 11.10 NRC letter to BWRVIP, dated October 13, 1999, "Final Safety Evaluation of

'BWRVIP, BWR Lower Plenum Inspection and Flaw Evaluation Guidelines (BWRVIP-47),' EPRI Report TR-108727" 11.11 NRC letter to BWRVIP, dated December 2, 1999, "Final Safety Evaluation of BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines (BWRVIP-18)"

11.12 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" 11.13 NRC letter to BWRVIP, dated July 24, 2000, "Final Safety Evaluation of the

'BWRVIP, BWR Shroud Support Inspection and Flaw Evaluation Guidelines (BWRVIP-38),' EPRI Report TR-108823" 11.14 Entergy Letter JAFP-01-0021 to NRC, dated January 26, 2001, "In-Vessel Visual Inspection Summary Report 2000 Refuel Outage (Reload 14/Cycle 15)"

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

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

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

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

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

11.18 BWRVIP-27-A, "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 Pilgrim Nuclear Power Station (Updated after RFO1 6), Spring 2007.

11.20 NRC Letter to BWRVIP, dated July 27, 2006, "Safety Evaluation of Proprietary EPRI Report, BWRVIP, Core Shroud and Inspection and Flaw Evaluation Guidelines (BWRVIP-76)".

Page 8 of 8

Attachment 2 To Entergy Letter No. 2.08.008 (PRR-16)

(~nmnari~nn of A5~ME CatAnarv B-N-i and B-N-2 Examination Reauirements with BWR VIP Guideline Reauirements (2)

Comnarison of SME Catenorv B-N-1and B-N-2Examination Reauirements with BWRVIP uideline Reauirements (2)

I ASME Item Component ASME Exam ASME ASME Applicable BWRVIP BWRVIP BWRVIP BWRVIP Frequency No. Table Scope Exam Frequency Document Exam Scope Exam IWB-2500-1 B13.10 Reactor Vessel Interior Accessible VT-3 Each period BWRVIP-18-A, 25, 26-A, In accordance with applicable BWRVIP Document.

(Note 1) Areas 27-A, 38, 41 Rev. 1, 47-(Non-specific) A, 48-A, 76, 138 B13.20 Interior Attachments Within Accessible VT-1 Each 10-year BWRVIP-48-A Table 3-2 Riser Brace EVT-1 100% in first 12 years (with 50%

Beltline - Jet Pump Riser Welds Interval Attachment to be inspected in the first 6 Brace years); 25% during each subsequent 6 years Lower Surveillance BWRVIP-48-A Table 3-2 Bracket VT-1 Each 10-year Interval Specimen Holder Brackets Attachment B13.30 Interior Attachments Accessible VT-3 Each 10-year BWRVIP-48-A Table 3-2 Bracket VT-3 Each 10-year Interval Beyond Beltline - Steam Welds Interval Attachment Dryer Hold-down Brackets Guide Rod Brackets BWRVIP-48-A Table 3-2 Bracket VT-3 Each 10-year Interval I_ Attachment Steam Dryer Support BWRVIP-48-A Table 3-2 Bracket EVT-1 Each 10-year Interval Brackets Attachment Feedwater Sparger BWRVIP-48-A Table 3-2 Bracket EVT-1 Each 10-year Interval Brackets Attachment Core Spray Piping BWRVIP-48-A Table 3-2 Bracket EVT-1 Every 4 Refueling Cycles Brackets Attachment Upper Surveillance BWRVIP-48-A Table 3-2 Bracket VT-3 Each 10-year Interval Specimen Holder Brackets Attachment Shroud Support - Weld BWRVIP-38 Weld H1 1 EVT-1 or Maximum of 6 years for EVT-1, H 1I (BWRVIP H9 weld) 3.1.3.2, Figure 3-5 (BWRVIP H9) UT Maximum of 10 years for UT B13.40 Integrally Welded Core Accessible VT-3 Each 10-year BWRVIP-38 Weld H1 1 EVT-1 or Maximum 6 years for EVT-1, 10 Support Structure - Surfaces Interval 3.1.3.2, 3.2.1, Figures and Gusset UT years for UT Shroud Support 3-5 and 3-6 Attachments (Note 3)

Shroud BWRVIP-76 3.3 and Vertical and EVT-1 or Per Shroud Repair Designer 3.4 Top Guide UT Recommendations.

Ring Seg.

Welds BWRVIP-76 Tie-rod Repair EVT-1 and PNPS has a shroud repair 3.5 and 3.6 (Note 4) VT-3 consisting of four tie-rods.

Inspection frequency is within 1_ 10 years Notes: (1) Per Letters to NRC (Nos. 2.96.091 and 2.99.035), PNPS informed the NRC of a new commitment to perform Core Spray sparger inspections inside the reactor vessel in accordance with BWRVIP-18 guidelines (Reference 11.1 and 11.2).

(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.

(3) PNPS shroud configuration does not have an H12 weld as the design does not incorporate support legs (reference BWRVIP-38, Figure 2-5). _

(4) The PNPS tie rod repair structurally replaces welds H1 through H10 (BWRVIP H1-H8).

Page 1 of 1

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Pilgrim Nuclear Power Plant Reactor Internals Inspection History (Updated through RFO16, Spring 2007)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections CORE SHROUD RFO 7 UT RFO 7 UT all 48 bolts; RFO 8 partial VT.

Shroud Head Bolts RFO 8 VT No indications. RFO 10 UT of 100% of RFO 10 UT bolts, no indications. RFO 11 replaced 50% of bolts.

RFO 16 VT-3 Examined 25% of shroud head bolts with one relevant indication noted and dispositioned.

Shroud RFO 10 VT-3 and VT (modification and partial VT) Shroud captured to limit extent under VT-3 exams of RPV Interior performed each period.

No indications. RFO 10 PDC 94-43 VT exams only.

RFO 11 UT and EVT-1 UT of 134" (25% of total) of vert. welds V17 and V18 from shroud I.D.EVT-1 of 14 of 21 ring segment welds. EVT-3 of 315 degree tie rod and core plate wedges, EVT-1 of 315 degree gusset welds.

RFO-12 EVT- 1 Examined V15, V16, V17, V18, V22 and V23. Total of vertical weld examined from both sides by UT in RFO 11 and EVT-1 in RFO 12 is 46 %, with partial credit for one sided examinations the total is 51 %. This' is the maximum available with current tooling. No indications.

RFO 13 EVI-1 Examined Ring Segment weld V11 from the OD. (no indications).

RFO 15 EVT-1 Examined 100% vertical/or radial welds V9, V10, V11, V12, V13, V14 and V22 (all OD side) with no relevant indications noted (NRI's). Examined 70% of weld V23 (OD side) (NRI's). There was no OD side access to welds V7, V8, V30 and V31.

Also, there was no ID side access to welds V7, V8, V22 and V23. Technical Justification #TJ-076-04, defers UT inspection of several vertical welds to RFO16.

Page 1 of 9

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections Shroud (cont'd) Examined 100% of vertical welds V32 and V33 in shroud support cylinder (all OD side) (NRI's). There was no access to vertical weld V34.

RFO 16 UT Examined 100% of vertical welds V7 & V8 (NRI's). There was no OD side access to welds V30 & V31. Also, there was no access to shroud support weld V34. A deviation disposition (DD-2007-001) will address the issue.

RFO 16 UT Examined the accessible surfaces, contact points, seating surfaces, locking devices and critical contact areas for the four tie-rods per BWRVIP-76, industry OE's and repair vendor requirements.

Replaced the upper supports at tie-rods 450 and 2250 locations. Plans are to replace the remaining two upper supports at 1350 and 3150 (NRI's) in RFO 17.

SHROUD SUPPORT RFO 8 UT UT exam in RFO 8 was for circ. Cracking Access Hole Covers RFO 9 VT only. No indications. RFO 10 visual RFO 10 VT and UT indication at 0 degree cover verified non-relevant by UT. VT of 180 degree cover.

RFO14 EVT-1 Examined at 00 and 1800 (NRI's).

RFO16 VT-1 Examined at 00 and 180 (NRI's).

Shroud Support Plate to RFO 10 EVT-1 Enhanced VT-1 RFO 10. No indications.

RPV (H1 1) Weld RFO 12 EVT-1 Examined 10% of weld length with no indications.

RFO 15 EVT-1 Examined 16% of weld length (top side)

(NRI's).

VT-3 Examined 3600 of weld length (top side) with NRI's.

Shroud Support Plate RFO 10, RFO 11 EVT-1 Enhanced VT-1 RFO10 of 4 gussets Gusset Welds (1 gusset) (modification attach. Points), VT-1 all others (18). No indications. RFO 11 EVT-1 of gusset at 315 az.

RFO 12 EVT-1 Examined gusset welds at 225,135, 45, 15 and 345 degrees with no indications.

RFO 14 EVT-1 Examined gusset welds at 75, 165, 195, 255, and 300 degrees.

Page 2 of 9

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections Shroud Support Plate RFO 15 EVT-1 Examined all gusset welds at 300, 1200 Gusset Welds (Cont'd) and 2400 (NRI's).

VT-3 Examined gusset-to-RPV welds at 30°,

60°, 90°, 1050, 120°, 150°, 2100, 2400, 2700, 2850 and 3300 (NRI's).

RF016 EVT-1 Examined gusset welds at 450, 1350, 2250 and 3150 (NRI's).

Core Spray Piping RFO 6, 7, 8, 9, UT and EVT-1 3" long indications recorded previously in 10, and 11 of piping 1980, 81 and 84 on 'B' sparger between welds T-Box and B-25 nozzle. RFO 7 and 8 exams show no indications. GE suspected scale as possible source of previous indications. RFO 11 UT revealed six cracked piping welds.

RFO 12 EVT-1 and UT EVT-1 of welds examined by EVT-1 in RFO 11 revealed no indications. UT of the four P8b welds with indications from RFO 11 revealed the indications to be geometric reflectors. All P9 welds were examined by UT with no indications. UT of 1P5 and 3P5 , which had indications in RFO 11, revealed slight growth in the indication in 1P5.

I RFO 13 EVT-1 Examined all target welds excluding those with RFO 12 ultrasonic results (no indications).

RFO 14 EVT-1 Examined target welds, no indications, one weld at lower, one mil, sensitivity.

RFO 15 EVT-1 Examined all creviced and tee box-to-pipe welds; and 25% rotating sample of pipe elbow welds (NRI's).

EVT-1/

RFO 15 Examined all piping brackets (4 total)

VT-3 support welds (NRI's).

RFO 16 EVT-1 Examined all creviced and tee box-to-pipe

/

elbow welds; and 25% rotating sample of pipe elbow welds (NRI's).

Core Spray Sparger RFO 13 EVT-1/ EVT-1 of all S1, S2, and S4 welds.

VT-1 VT-1 of all SB and 50% of the S3 welds, these were the upper sparger (no indications).

Page 3 of 9

9 Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections Core Spray Sparger RFO 15 EVT-1/ Examined by EVT-1 all S1, S2, and S4 (cont'd) VT-1 welds. Examined by VT-1 all SB and 50%

of S3a,b welds; these are the lower spargers (NRI's). No S3c(drains) were found.

Top Guide (rim, etc.) RF 6, 7, 8 and VT-1 Partial exams each outage. Some 9 scratches, wear marks; no cracking found.

Top Guide Aligner RFO 12 VT'1 Examination of assemblies at 0 and 90 Assembly degrees revealed no indications. r RFO 16 VT-1 Examined accessible surfaces of grid beams at six cell locations (most at high fluence areas) (NRI's).

Core Plate (rim, etc.) RFO 16 VT-3 Examined all core plate wedges at 450, 1350, 2250 and 315' (NRI's).

JET PUMP ASSEMBLY RF 8,10, and VT-1 No indications. RFO 10 100% done.

Jet Pump Riser Braces 11 Completed 50% each RFO per OE item.

RFO 11 VT-1 of braces 5 through 14 (50%).

RFO 12 EVT-1 All Riser Braces were examined atRB-1 and RB-2 except for Jet Pump 3 and 5.

No indications were found.

RFO 13 EVT-1 All RB la,b & 2 a, b for Risers A,B,C,D,E,H and J(no indications).

RFO 14 EVT-1 Riser braces for pumps 1,2,8,9,10,12,13,14,16,17 and 20.No indications.

RFO 16 EVT-1 Examined RB-ia,b and RB-2a,b welds at JP #17/18 (NRI's).

Jet Pump Sensing RFO 7, 8, and 9 VT No indications.

Lines Jet Pump Beam Replaced RFO 6, UT and VT RFO 11 (UT of 100%; VT of Jet Pumps 5 Assemblies RFO 11 through 14).

RFO 12 UT All beams examined at BB-1 and BB-2 I__ Iwith no indications.

Page 4 of 9

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections RFO 16 UT Examined all twenty beams at BB-1, BB-2 and BB-3 (NRI's).

EVT-1 Examined beam at JP# 7 (NRI's).

Jet Pump Adjusting RF 8,10, and UT No indications RFO 8. Gaps found RFO Screws 11 10, minor mechanical damage.

Inspection tied to Rise Brace cracking.

RFO 11 VT of 100% of screws.

RFO 12 VT-3 Gaps were measured for in all pumps except for 5,6,7 and 11.

RFO 13 VT-3 Gaps were measured for on pumps 1,4,6,7,8,9,16, and 17 (no change).

RFO 16 VT-1/VT-3 Examined the "as found/as left" set screw gap measurements for aux wedge installation at JP #01, 02, 8, 9, 11, 17 &

20, including the aux wedge addition (NRI's).

Jet Pump Restrainer RFO 11 VT-3 RFO 11 VT-3 of 100% of the swing gates, Bracket and Swing wedges and screws. Found 10 out of 20 Gate Assemblies swing gates in the unlatched position.

RFO 12 VT-3 Inspected all Swing Gate assemblies except for 5 and 11.

RFO 13 r VT-3 Inspected assemblies for pumps 1,4,6,7,8,9,16,and 17(no indications),

VT-1 Examined WD-1 on pumps 1 to 10 (no indications).

RFO 15 VT-1 Examined WD-1 restrainer wedges on jet pumps #1, 2,4, 6, 7, 8, 9,10,12,13, 14, 15, 16, 17, 19 and 20, with relevant indications noted only on JP-16 and JP-

17. Examined RK-1, RK-2 and RK-3 at jet pumps #16 and #17 (NRI's).

RFO 16 VT-1 Examined WD-1 restrainer wedges at JP

1. 3, 5, 11 & 18. Recordable indications were identified on the wedge handle at JP's #5 & 11. These were satisfactorily dispositioned. Re-inspect in RFO 17.

Examined RK-1, 2& 3 welds at JP#17 (NRI's).

Page 5 of 9

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize' the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections Jet Pump Restrainer RFO-16 VT-3/VT-1 Examined "as found/as left" condition of Bracket and Swing existing/replaced swing gates and Gate Assemblies wedges at JP's #01, 4, 6, 7, 8, 9,16 & 17 (cont'd)

(NRI's).

Jet Pump Mechanical RFO 11 VT-3 RFO 11 VT-3 of 50% of Jet Pumps (Jet Joints Pumps 5 through 14) rams head-to-transition pieces and lower slip joint-to-

/I diffuser areas.

RFO 12 VT-3 Inlet mixer to diffuser for 1 to 4, and 15 to 20.

RFO 13 VT-3 Examined rams head to transition piece and lower slip joint to diffuser areas for pumps 1,4,6,7,8,9,16, and 17 (no indications).

RFO 16 VT-3 Examined slip joint at JP #17 (NRI's).

Jet Pump Riser Welds RFO 11 EVT-1 All RS-1 and RS-2 examined with no indications.

RFO 12 EVT-1 RS-3 of risers A to E examined with no indications.

RFO 13 EVT-1 Examined RS-4, RS-5, RS-8 and RS-9 for risers A,B,C,D and E (no indications).

RFO 14 EVT-1 RS-3 of risers F to K, no indications.

RFO 16 EVT-1 Examined the following JP riser welds J with NRI's:

RS-1, RS-2 and RS-3 at'JP's 5/6 RS-4 and RS-5 at JP's 15/16 RS-8 and RS-9 at JP's 13/14 & 15/16.

Jet Pump Diffuser I RFO 13 VT-3 Examined IN-5 for pumps 1 to 10 (no indications).

EVT-1 Examined MX-1 for pumps 1 to 10 (no indications).

EVT-1 and UT Examined MX-3, DF-1, DF-2, AD-3a, b, AD-1, AD-2 on pumps 13,14,15,16 and 17 by UT and pumps 11, 12,18,19 and 20 by EVT-1 (no indications).

RFO 14 EVT-1 Examined AD-2,AD-1 ,DF-2, and AD-3a,b for pumps 1 to 10, no indications.

Page 6 of 9

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections Jet Pump Diffuser RFO 16 VT-3 Examined IN-5 at JP #15 & 16 (NRI's).

(cont'd)

EVT-1 Examined MX-1 at JP #15 & 16 (NRI's)

Examined MX-3 and DF-1 at JP #5 & 6 (NRI's).

CRD Guide Tube RFO 7 N/A No indications.

Handle Attachment RFO 13 N/A FS/GT -ARPIN-1 at 8 locations. No indications.

RFO 14 VT-3/EVT-1 CRGT1, 2 and 3 for 8 tubes, no indications.

RFO 16 VT-3/EVT-1 Examined FS/GT-ARPIN-1. CRGT-1, 2 &

3 at 2 tubes (NRI's).

CRD Stub Tube RFO 7 VT-3 No indications.

RFO 16 VT-3 Examined accessible surfaces in lower plenum at several locations (NRI's).

In-core Housing RFO 16 VT-3 Examined accessible surfaces in lower plenum at several locations (NRI's).

Dry Tube RFO 16 VT-1 Examined four (4) dry tubes per SIL-409, Rev. 2 requirements (NRI's).

Instrument Penetrations RFO 15 VT-2 System Leakage Test (no leaks detected).

RFO 16 VT-2 System Leakage Test (no leaks detected).

Vessel ID Brackets RFO 10 VT-1/VT-3 3 locations. No indications.

Surveillance Specimen Brackets Attachment RFO 15 VT-1/VT-3 Examined attachment welds at all 3 Welds locations (NRI's). Re-engaged the lower end of sample holder at 2100 back to the proper location (CR-PNP-2005-02137).

Guide Rod Bracket RFO 10, 11 (180 VT-3 No indications.

Attachment Welds az guide rod)

RFO 15 VT-3 Examined guide rod attachment welds at 00 and 1800. No relevant indications noted.

Abandoned Start-up RFO 11 VT-1 Brackets welded to RPV wall at 90 and Instrumentation Bracket 150 az received VT-1 in RFO 11.

Page 7 of 9

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections Steam Dryer Drain RFO 8, 9, and 11 VT-1 No indications.

Channels RFO 12 VT-3 No indications.

RFO 16 VT-1 No indications.

Steam Dryer Leveling RFO 7, 8, 9, 10, VT Cracked tack welds RFO 7; no growth Screws and 11 observed in RFO 8, 9, and 10. RFO 11 VT showed increased cracking of tack welds at 35 and 215 degree leveling screws, with 215 az screw loose.

RFO 12 VT-3 No change from RFO 11.

RFO 13 VT-3 No change from RFO 12.

RFO 14 VT-3 Change in cracks.

RFO 15 VT-1 Examined leveling screws at 350, 1450, 2150 and 3250. There was no change in tack weld cracks at 350 and 2150 and NRI's at 1450 and 3250.

RFO 16 VT-1 Examined leveling screws at 350, 1450, 2150 and 3250. There was no noticeable change in tack weld cracks at 350 and 2150 and NRI's at 1450 and 3250.

Steam Dryer Baffle RFO 7 and 11 VT-3 No Indications.

Plate Steam Dryer Support RFO 7, 8, 9, 10, VT-3 No Indications.

Bracket and 11 RFO 15 VT-3/ Examined support bracket attachment EVT-1 welds at all four locations (NRI's).

Steam Dryer Hold- RFO 10 VT-1 Located underside of RPV head. No Down Bracket Welds indications.

(on head)

RFO 15 VT-3 Examined hold-down bracket attachment welds at all four locations (NRI's).

VT-3/ Code and BWRVIP examination of all Feedwater Bracket RFO 14 Attachment Weld EVT-1 attachments.

RFO 14 VT-1 SIL 644.

Page 8 of 9

Attachment 3 To Entergy Letter No. 2.08.008 (PRR-16)

Components in Date or Inspection Summarize the Following Information:

BWRVIP Scope Frequency of Method Used Inspection Results, Repairs, Inspection Replacements, Reinspections Steam Dryer Integrity RFO 15 VT-1 Examined steam dryer integrity per SIL 644, Rev. 1 guidelines on OD side above dryer supporting ring. Examination included all vertical welds, horizontal welds at end banks and end welds at all ten tie-bars. Relevant indications were noted at an end weld'of each tie-bar #3, 4, 5 and 9 (CR-PNP-2005-01608). A total of seven tie-bars were replaced and further examined to establish inspection baseline. These are #1, 2, 3, 4, 5, 9 and 10.

RFO 16 VT-1/VT-3 Completed steam dryer integrity examinations per requirements of BWRVIP-139 (this included ID and OD side). Examined welds on the original and replaced (RFO 15) tie-bars; guide channels; guide followers; upper support ring; internal Hood A and E horizontal and vertical welds and internal drain channels.

Relevant indications were found on the ID side of the dryer at vane Bank E weld and in the weld at divider plate anchor #5 between Bank C and D. Indications were satisfactorily dispositioned (Plan to re-inspect again the indication in the divider plate anchor).

Examined all four lifting rod assemblies and attachment welds (NRI's).

Moisture Separator RFO 16 VT-3 Examined all four lifting rod assemblies and attachment welds (NRI's).

Feedwater Spargers RF 6,7,8,9,10 VT-3/VT-1 No indications.

._and RFO14 I All spargers, no indications.

Page 9 of 9

Attachment 4 To Entergy Letter No. 2.08.008 (PRR-16)

Scope of Examination of Pilqrim RPV Internals and Components Reactor Internal Component BWRVIP Reference Document Number2 ofperWelds/Components Component Control Rod Drive Guide Tube Body Welds BWRVIP-47-A, Table 3.3 Control Rod Drive Guide Tube Lug and Pin BWRVIP-47-A, Table 3.3 2 per Component Core Plate Rim Hold-Down Bolts/Wedges BWRVIP-25, Table 3-2 24 Clamps, 8 Wed es Core Shroud Horizontal Welds (1-1, H2, 1-3) BWRVIP-76, Figure 3.1 3 Core Shroud Horizontal Welds (H4-H9) BWRVIP-76, Figure 3.1 6 Core Shroud Vertical Welds BWRVIP-76, Figure 3-3 11 Core Shroud TG Ring Segment Welds BWRVIP-76, Section 3.4 6 Core Shroud CP Ring Segment Welds BWRVIP-76, Section 3.4 6 Core Shroud Flange Ring Segment Welds BWRVIP-76, Section 3.4 6 Core Shroud Tie-Rod Repair BWRVIP-76, Section 3.5 4 Tie Rods Core Shroud Support Welds (H10) BWRVIP-76, Figures 3-1 1 Core Shroud Support Welds (H-11) BWRVIP-38, Figure 3-5 1 Core Shroud Support Gussets BWRVIP-38, Figure 3-6 Section 3.2.1 and 2 Core Spray Thermal Sleeve Welds (Hidden) BWRVIP-18-A, Section 3.2.4 3 per loop (2 loops)

Core Spray Piping Welds (except P9) BWRVIP-18-A, Table 3-5 22 per loop (2 loops)

Core Spray P9 Welds BWRVIP-18-A, Section 3.2.4 2 per loop (2 loops)

Core Spray Sparger Large Circ Welds BWRVIP-18-A, Table 3-5 5 per loop (4 loops)

Core Spray Sparger Nozzle Welds BWR VIP-i8-A, Table 3-5 Multiple nozzles per loop (4 loops See Note 1 on next page)

Core Spray Piping Brackets BWRVIP-18-A, Table 3-5 2 per loop (2 loops)

Core Spray Sparger Brackets BWRVIP-i 8-A, Table 3-5 5 per loop (4 loops)

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

Page 1 of 2

Attachment 4 To Entergy Letter No. 2.08.008 (PRR-16)

Scope of Examination of Pilgrim RPV Internals and Components (Cont'd)

Reactor Internal Component BWRVIP Reference Document Number of Welds/Components Feedwater Sparger End Bracket Attachment BWRVIP-48-A, Table 3-2 2 per loop (4 loops)

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

BWRVIP-41, Rev.1, Table 3.3-1 20 Jet Pump Beams and BWRVIP-13, Sections 4 and 6 2 per Jet Pump inletnozzle nozzle BWRVIP-41, Rev.1, Table 3.3-1 (10 Jet Pump inlet Jet Pump Thermal Sleeve Welds (Hidden) (10 Jet Pump inlet nozzles)

Jet Pump Riser Welds (RS-1, RS-2, RS-3) BWRVIP-41, Rev.1, Table 3.3-1 3 per Jet Pump Assembly (10 Jet Pump Assemblies)

Jet Pump Riser Welds (RS-4, RS-5, RS-8, BWRVIP-41 Rev.1, Table 3.3-1 4 per Jet Pump Assembly RS-9) (10 Jet Pump Assemblies)

BWRVIP-41, Rev.1, Table 3.3-1 4 per Jet Pump Assembly Jet Pump Riser Brace Welds (10 Jet Pump Assemblies)

Jet Pump Inlet Bolted Connection' BWRVIP-41 Rev.1, Table 3.3-1 1 connection per Jet pump (4 bolts per connection) (20 Jet Pumps)

BWRVIP-41, Rev.1, Table 3.3-1 1 per Jet Pump Jet Pump Restrainer Wedges (20 Jet Pumps) 14 (20per JetJet Pump Pumps)

Jet Pump Adapter/Diffuser Welds "BWRVIP-41, Rev.1, Table 3.3-1 (0JtPms Lower Plenum (CRD) BWRVIP-47-A 145 CRDs Miscellaneous Vessel Internal Attachments BWRVIP-48-A, Table 3-2 12 Orificed Fuel Support Castings BWRVIP-47-A, Table 3-3 145 SLC Nozzle-to-Safe End Weld BWRVIP-27-A, Section 3.3.1 1 Steam Dryer Support and Holdown Bracket BWRVIP-48-A, Table 3-2 8 Top Guide Hold-down Assemblies BWRVIP-26-A, Table 3-2 4 Top Guide Grid Beams BWRVIP-26-A, Section 3.2 Multiple Note 1: There are between 2 and 4 welds per nozzle depending on nozzle configuration. There are two drain nozzles on 2 lower spargers.

Page 2 of 2