ML070670343

Containment Inservice Inspection (CII) Program, Evaluation of Aging Management Programs, 01/25/2006

ML070670343
Person / Time
Site:	Vermont Yankee
Issue date:	01/25/2006
From:	Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation
References
LRPD-02, Rev 1
Download: ML070670343 (68)

Text

il i LRPD-02 Revision 1 Page 162 of 275 VYNPS License Renewal Project Aging Management Program Evaluation Results Containment Inservice Inspection (CII)

Program 4.14.2 Containment Inservice Inspection (CII)

Program A. Proaram DescriDtion The WNPS Containment Inservice Inspection (CII) Program is a plant-specific program encompassing the requirements for the inspection of Class MC pressure-retaining components (Primary Containment) and their integral attachments in accordance with the requirements of 1 OCFR50.55a(b)(2) and the 1998 Edition of ASME Section XI with 2000 Addenda, Inspection Program B. Subarticle IWA-4540 of the 2003 Addenda of the 2001 Edition of ASME Section XI has also been adopted. (Ref. Section 1.3, PP 7024) This program is credited in the following. AMRC-01, Primary Containment

6. Evaluation

1. Scope of Program The CII Program, under ASME Section XI Subsection IWE, manages loss of material and cracking for the primary containment and its integral attachments.

The primary containment is a General Electric Mark I pressure suppression containment system. The system consists of a drywell (housing the reactor vessel and reactor coolant recirculation loops) , a pressure suppression chamber (housing a water pool), and the connecting vent system between the drywell and the water pool, isolation valves, and containment cooling systems. The code of construction for the containment structure is the ASME Section Ill, 1965 with winter addenda. (Ref. Section 1.2, PP 7024) 2. Preventive Actions The CII Program is a monitoring program that does not include preventive actions. 3. Parameters Monitorednnspected The primary containment and its attachments are inspected for evidence of cracks, wear, and corrosion. (Ref. Section 5.1.2, ENN-EP-S-001 and Section 4.2, PP 7024) 4. Detection of Aging Effects The CII Program manages loss of material and cracking for the primary containment and its integral attachments. (Ref. AMRC-01)

LRPD-02 Revision 1 Page 163 of 275 VYNPS License Renewal Project Aging Management Program Evaluation Results Containment lnservice Inspection (CII) Program 5. 6. 7. 0. 9. 10. The primary inspection method for the primary containment and its integral attachments is visual examination. Visual examinations are performed either directly or remotely with sufficient illumination and resolution suitable for the local environment to assess general conditions that may affect either the containment structural integrity or leak tightness of the pressure retaining component. The program includes augmented ultrasonic exams to measure wall thickness of the containment structure. (Ref. Section 5.1.1, ENN-EP-S-001 and Sections 1.3 and 4, PP 7024) Monitoring and Trending Results are compared, as appropriate, to baseline data and, other previous test results. If indications are accepted for continued use by analytical evaluation, the areas containing such flaws are monitored during successive inspection periods. (Ref. Section 5.1.5, ENN-EP-S-001)

Acceptance Criteria Results are compared, as appropriate, to baseline data, other previous test results, and acceptance criteria of the ASME Section XI, Subsection IWE for evaluation of any evidence of degradation. (Ref. Section 5.2, ENN-EP-S-001)

Corrective Actions Subsection IWE states that components whose examination results indicate flaws or areas of degradation that do not meet the acceptance standards are acceptable if an engineering evaluation indicates that the flaw or area of degradation is nonstructural in nature or has no effect on the structural integrity of the containment. Except as permitted by 10 CFR 50.55a(b)(ix)(D), components that do not meet the acceptance standards are subject to additional examination requirements, and the components are repaired or replaced to the extent necessary to meet the acceptance standards. (Ref. Section 5.2, ENN-EP-S-001 and Section 4.2.4, PP 7024) Confirmation Process This attribute is discussed in Section 2.0, Background. Administrative Controls This attribute is discussed in Section 2.0, Background.

Operating Experience Operating experience provides assurance that the program will be effective in managing effects of aging so that components crediting this program can perform their intended function consistent with the current licensing basis during the period of extended operation. For more information on applicable operating

1. LRPD-02 Revision 1 Page 164 of 275 VYNPS License Renewal Project Aging Management Program Evaluation Results Containment lnservice Inspection (CII) Program experience, see VYNPS Report LRPD-05, Operating Experience Review Results. C. References ENN-EP-S-001, Rev. 00, ENN Engineering Standard - IWE General Visual Containment Inspection PP 7024, Rev. 04, LPC 01, Containment Inservice Inspection Program (IWE) D. Summarv The Containment lnservice Inspection Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Vermont Yankee Nuclear Power Station License Renewal Application Technical Information In addition, wall thickness evaluations of fire protection piping are periodically performed on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

A sample of sprinkler heads will be inspected using the guidance of NFPA 25 (2002 Edition) Section 5.3.1.1.1, which states, "Where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing."

This sampling will be repeated every 10 years after initial field service testing. I A.2.1.44 ..J &I I A.2.1 .I 5 u A.2.1 .I 6 Flow-Accelerated Corrosion Program The Flow-Accelerated Corrosion Program applies to safety-related and nonsafety-related carbon steel components carrying two-phase or single-phase high-energy fluid 2 2% of plant operating time. The program, based on EPRl recommendations for an effective flow-accelerated corrosion program, predicts, detects, and monitors FAC in plant piping and other pressure retaining components.

This program includes (a) an evaluation to determine critical locations, (b) initial operational inspections to determine the extent of thinning at these locations, and (c) follow-up inspections to confirm predictions. The program specifies repair or replacement of components as necessary.

Heat Exchanger Monitoring Program The Heat Exchanger Monitoring Program inspects heat exchangers for degradation.

If degradation is found, then an evaluation is performed to evaluate its effects on the heat exchanger's design functions including its ability to withstand a seismic event.

Representative tubes within the population of heat exchangers are eddy current tested at a frequency determined by internal and external operating experience to ensure that effects of aging are identified prior to loss of intended function. Along with each eddy current test, visual inspections are performed on accessible heat exchanger heads, covers and tube sheets to monitor surface condition for indications of loss of material.

The population of heat exchangers includes the HPCl gland seal condenser, HPCl lube oil cooler, RClC lube oil cooler, CST steam reheat coil, drywell atmospheric cooling units (RRU-I , 2, 3 & 4), reactor recirculation pump seal water coolers, reactor recirculation pump motor upper and lower bearing oil coolers, and reactor recirculation pump motor air coolers. lnservice Inspection-Containment lnservice Inspection (Cll) Program The WNPS Containment lnservice Inspection (CII) Program is a plant-specific program encompassing the requirements for the inspection-of Ckss MC pressure-retaining Appendix A Updated Final Safety Analysis Report Supplement Page A-15 Vermont Yankee Nuclear Power Station License Renewal Application Technical Information components (primary containment) and their integral attachments in accordance with the requirements of lOCFR50.55a(b)(2) and the 1998 Edition of ASME Section XI with 2000 Addenda, Inspection Program B. The primary inspection method for the primary containment and its integral attachments is visual examination. Visual examinations are performed either directly or remotely with sufficient illumination and resolution suitable for the local environment to assess general conditions that may affect either the containment structural integrity or leak tightness of the pressure retaining component.

The program includes augmented ultrasonic exams to measure wall thickness of the containment drywell shell. I 1 .f A.2.1 .17 Inservice Inspection-Inservice Inspection (ISI) Program The WNPS lnservice Inspection (ISI) Program is based on ASME Inspection Program B (IWA-2432), which has 10-year inspection intervals.

Every 10 years the program is updated to the latest ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission in lOCFR50.55a. On September 1, 2003 VYNPS entered the fourth IS1 interval.

The Code Edition and Addenda used for the fourth interval is the 1998 Edition with 2000 addenda. The program consists of periodic volumetric, surface, and visual examination of components and their supports for assessment, signs of degradation, flaw evaluation and corrective actions. u A.2.1.18 Instrument Air Quality Program n The Instrument Air Quality Program ensures that instrument air supplied to components is maintained free of water and significant contaminants, thereby preserving an environment that is not conducive to loss of material. Dewpoint, particulate contamination, and hydrocarbon concentration are periodically checked to verify the instrument air quality is maintained.

A.2.1 .I 9 Non-EQ Inaccessible Medium-Voltage Cable Program 1 In the Non-EQ Inaccessible Medium-Voltage Cable Program, in-scope medium-voltage cables, not designed for, but exposed to significant moisture and voltage are tested at least once every ten years to provide an indication of the condition of the conductor insulation. The specific test performed is a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, polarization index, or other testing that is state-of-the-art at the time the test is performed.

Significant moisture is defined as periodic exposures that last more than a few days. Significant voltage exposure is defined as being subjected to system voltage for more than 25% of the time.

~ Appendix A Updated Final Safety Analysis Report Supplement Page A-I 6 Vermont Yankee Power Station License Renewal Application Technical Information B.l .I 5.1 Proaram Descrir>tion The VYNPS Containment Inservice Inspection (CII) Program is a plant-specific program encompassing the requirements for the inspection of Class MC pressure-retaining components (Primary Containment) and their integral attachments in accordance with the requirements of IOCFR50.55a(b)(2) and the 1998 Edition of ASME Section XI with 2000 Addenda, Inspection Program B. Evaluation Containment Inservice Inspection f 1. 2. 3. 4. Scope of Program The CII Program, under ASME Section XI Subsection IWE, manages loss of material and cracking for the primary containment and its integral attachments. The primary containment is a General Electric Mark I pressure suppression containment system. The system consists of a drywell (housing the reactor vessel and reactor coolant recirculation loops), a pressure suppression chamber (housing a water pool), and the connecting vent system between the drywell and the water pool, isolation valves, and containment cooling systems. The code of construction for the containment structure is the ASME Section Ill, 1965 with winter addenda. Preventive Actions The CII Program is a monitoring program that does not include preventive actions. Parameters Monitoredllnspected The primary containment and its attachments are inspected for evidence of cracks, wear, and corrosion.

Detection of Aging Effects The CII Program manages loss of material for the primary containment and its integral attachments. The primary inspection method for the primary containment and its integral attachments is visual examination.

Visual examinations are performed either directly or remotely with sufficient illumination and resolution suitable for the local environment to assess general conditions that may affect either the containment structural integrity or leak tightness of the pressure retaining component.

The program includes augmented ultrasonic exams to measure wall thickness of the containment structure.

Appendix B Aging Management Programs and Activities Page 8-53

_. i 3 3 Vermont Yankee Nuclear Power Station License Renewal Application Technical Information

5. Monitoring and Trending Results are compared, as appropriate, to baseline data and other previous test results. If indications are accepted for continued use by analytical evaluation, the areas containing such flaws are monitored during successive inspection periods.

6. Acceptance Criteria Results are compared, as appropriate, to baseline data, other previous test results, and acceptance criteria of the ASME Section XI, Subsection IWE for evaluation of any evidence of degradation.

7. Corrective Actions Subsection IWE states that components whose examination results indicate flaws or areas of degradation that do not meet the acceptance standards are acceptable if an engineering evaluation indicates that the flaw or area of degradation is nonstructural in nature or has no effect on the structural integrity of the containment. Except as permitted by 10 CFR 50.55a(b)(ix)(D), components that do not meet the acceptance standards are subject to additional examination requirements, and the components are repaired or replaced to the extent necessary to meet the acceptance standards.

8. Confirmation Process This attribute is discussed in Section B.0.3. 9. Administrative Controls This attribute is discussed in Section B.0.3. IO. Operating Experience RFO 21 inspections found only two areas of potential age-related degradation; the drywell floor to metal containment moisture barrier had missing paint, cracked paint, and areas of corrosion on the base metal in the seal area; and corrosion was found in the area of the X-5G penetration. Engineering evaluation was performed and no significant wall loss was identified. Base metal was prepared, primed and painted to protect it from further corrosion, and the moisture barrier was replaced.

RFO 22 inspections found two more areas of potential age-related degradation; surface pitting of primary containment vent headers and vent pipe bowls; and corrosion on torus penetrations X-207A-H.

Evaluation determined that the components have significant margin to code minimum wall thickness and that the rate of corrosion is low due to the inerted containment environment during operation. Augmented inspections were not necessary since none of the identified corrosion was significant.

RFO 24 inspections revealed flaking coating and rust staining on the bay 3 inner torus wall. Subsequent Appendix B Aging Management Programs and Activities Page 8-54 Vermont Yankee Power Station License Renewal Application Technical Information ultrasonic examination revealed no material loss. Also, visual inspection of drywell head exterior surface revealed areas of localized missing coating and primer with light corrosion, but no material loss. Resolution of these issues prior to loss of component intended function provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

RFO 24 visual inspections of drywell interior surfaces, stabilizer assembly interior surfaces, torus penetrations, and drywell penetrations revealed areas of localized missing coating where the primer is intact, but no corrosion or material loss. Visual inspection of new drywell moisture barrier resulted in no recordable indications.

Absence of aging effects on these components provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

QA surveillance during RFO 24 revealed a problem with program administrative controls.

The issue was addressed and closed. The program was revised to require that engineering evaluations of indications that do not meet acceptance criteria be completed before the containment is declared operable.

QA surveillance revealed an issue that could impact effectiveness of the program. Resolution of this issue provides evidence that the program remains effective at managing aging effects for primary containment and its integral attachments.

A recent engineering system health report revealed no issues or findings that could impact effectiveness of the program. u Conclusion The CII Program has been effective at managing aging effects. The CII Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

B.1 .I 5.2 Inservice Inspection A .I i I f 1 Proaram DescriDtion The VYNPS Inservice Inspection (19) Program is a plant-specific program encompassing ASME Section XI Subsection IWA, IWB, IWC, IWD and IWF requirements.

The VYNPS IS1 Program is based on ASME Inspection Program B (IWA-2432), which has 10- year inspection intervals.

Every 10 years the program is updated to the latest ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission in 1 OCFR50.55a.

On September 1, 2003 VYNPS entered the fourth IS1 interval.

The Code Edition and Addenda used for the fourth interval is the 1998 Edition with 2000 addenda. The current program ensures Appendix B Aging Management Programs and Activities Page B-55 1 ~age45of122 J 0 perat in g Experience Rev nca u La Issue During RFO 23, QA surveillances confirmed personnel qualifications, test equipment, testing methods, and documentation are consistent with program. QA performs audits and surveillances of the program almost every cycle - no significant findings have been identified.

QA audit and surveillances are positive. (e.g., Audit Report AR- Item OE Evaluation QA surveillances revealed no issues or findings that could impact effectiveness of the program.

QA audits and surveillances revealed no issues or findings that could impact effectiveness of the program. QA Surveillances 41C, and QS- VY SR-2002- 2004-VY-079 2003-22).

NRC monitors IS1 Program each Program Owner Interview Result: IS1 Program Program Owner Interview Result: 1st Program Engineering Program Health Report: Inservice

Inspection Program NRC inspections revealed no issues outage. NRC has nothad findings in past 2 inspections, e.g., NVY-04-075. Program status in 1st quarter of 2004 was "Green" indicating site compliance with program objectives.

or findings that could impact effectiveness of the program. Engineering program health report revealed no issues or findings that could impact effectiveness of the program. Section 4.4.1 5 presents conclusions regarding the effectiveness of this program for managing 3.4.16. Containment Inservice Inspection Program I The VYNPS Containment Inservice Inspection Program is a plant specific condition monitoring program encompassing the requirements of ASME Section XI Subsection IWE. The program implements the requirements of Code of Federal Regulations I OCFR50.55a pertaining to inspection and testing of the primary containment.

The attributes of this program are described 1 f ,j in LRPD-02 (Ref. 5.17).

The results of OE reviews described in Section 2.0 are as follows.

WNPS License Renewal Project Operating Experience Review Results Item Program Owner Interview Result: Containment IS1 WE) LRP D -05 Revision 0 Page 46 of 122 ISI-IWE RFO-21 Inspection

Results ISI-IWE RFO-21 Inspection Resu I ts ISI-IWE RFO-22 Inspection Results ISI-IWE RFO-22 Inspection Results Issue Inspections of the drywell floor to metal containment moisture barrier identified missing paint, cracked paint, and areas of corrosion on the base metal in the seal area. Engineering evaluation was performed, the base metal was prepared, primed and painted to protect it from further corrosion, and the moisture barrier was replaced. (CR-VTY-I 999-1 954) Inspection of drywell surfaces revealed corrosion in the area of the X-5G penetration.

No significant wall loss was identified.

Area was prepared, primed and painted to protect it from further corrosion.

Inspection of 43% of the drywell penetrations resulted in noage- related degradation.

inspection of 57% of the drywell penetrations resulted in no age- related degradation.

Inspection of torus penetrations identified corrosion on penetrations X-207A-H. More than the minimum required wall thickness remains, so penetrations were acceptable for continued use.

OE Evaluation Resolution of this issue provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

Resolution of this issue provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

Absence of aging effects on drywell penetrations provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

Absence of aging effects on drywell penetrations provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments. Resolution of this issue provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

VYNPS License Rene ' - ' -' I LRPD-05 7 Item ISI-IWE RFO-22 Inspection Results ISI-IWE RFO-24 Inspection Results ISI-IWE RFO-24 Inspection Results ISI-IWE RFO-24 Inspection Results ISI-IWE RFO-24 Inspection Results ISI-IWE RFO-24 Inspection Results Issue Inspections identified general corrosion and surface pitting of primary containment vent headers and vent pipe bowls.

Evaluation determined that primary containment has significant margin to code minimum wall thickness and that the rate of corrosion is low due to the inerted containment environment during operation. Augmented inspections were not necessary since none of the identified corrosion was sian ifica n t. Visual inspection of interior surfaces of 16 torus bays revealed flaking coating and rust staining on the bay 3 inner torus wall.

Subsequent ultrasonic examination revealed no material loss. Visual inspection of drywell interior surfaces revealed areas of localized missing coating where the primer is intact, but no corrosion or material loss. Visual inspection of drywell head exterior surface revealed areas of localized missing coating where the primer is intact. There are also areas of missing primer with light corrosion, but no material loss. Visual inspection of stabilizer assembly A-H interior surfaces revealed areas of localized missing coating where the primer is intact, but no corrosion or material loss. Visual inspection of torus and-drywell penetrations revealed areas of localized missing coating where the primer is intact, but no corrosion or material loss. OE Evaluation Resolution of this issue provides evidence that the program is effective at managing aging effects for primary containment and its integral attach men ts. Resolution of this issue provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

Absence of aging effects on drywell interior surfaces provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

Absence of aging effects on drywell interior surfaces provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

Absence of aging effects on stabilizer interior surfaces provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

Absence of aging effects on torus and drywell penetrations provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

VYNPS License Renewal Project A.A-... D-r.mICe 1 Issue Vendor (ATC Associates, Inc.)

reviews instrument air system quality every 6 months. No findings have resulted from reviews. (Ref. Semi-Annual Analysis of Instrument Air, dated June 16-17, 2003, dated December 17-18, 2002, and August 20-21, 2001). LRPD-05 1 Revision 0 OE Evaluation Absence of findings indicates that acceptance criteria have been met. Therefore, the program is effective at ensuring that instrument air supplied to components is maintained free of water and significant contaminants, the re by preventing loss of material.

I Page 48 of 122 Operating Experience R=VWV C\G~UIL~ Item Inspection Results ISI-IWE RFO-24 Quality Assurance Surveillance QS-2004-W-110 CR-VTY-2004-01 526 Engineering Program Health Report: Primary Containment Inspection (IWE) Program Issue Visual inspection of new (see Program Owner Interview Result, above) drywell moisture barrier resulted in no recordable indications.

QA surveillance during RFO 24 revealed that the program had deficient administrative controls.

The program was revised to require that engineering evaluations of indications that do not meet acceptance criteria be completed before the containment is declared operable.

Program status in 1st quarter of 2004 was "Green" indicating site compliance with program objectives.

Absence of aging effects on the moisture barrier provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments. Actions to preclude recurrence of identified conditions are effective.

QA surveillance revealed an issue that could impact effectiveness of the program. Resolution of this issue provides evidence that the program remains effective at managing aging effects for primary containment and its integral attachments. Engineering program health report revealed no issues or findings that could impact effectiveness of the program. Section 4.4.1 6 presents conclusions regarding the effectiveness of this program for managing aging effects.

3.4.17. Instrument Air Quality Program Under the VYNPS Instrument Air Quality Program, air quality is monitored and maintained within specified limits to ensure that instrument air supplied to components is maintained free of water and significant contaminants, thereby preventing loss of material.

The attributes of this program are described in LRPD-02 (Ref. 5.17). The results of OE reviews described in Section 2.0 are as follows. Program Owner Interview Result:

Instrument Air Quality Program WNPS License Renewal Project Operating Experience Review Results 4.4.14. Flow-Accelerated Corrosion Program LRPD-05 Revision 0 Page 72 of 122 Recent inspection results (RFO 23) revealed that repairs or replacements were not necessary. Turbine cross-around piping inspections found that 1995 repairs mitigated the rate of erosion and that wall thickness is acceptable. Absence of loss of material due to flow-accelerated corrosion provides evidence that the program is effective for managing loss of material for carbon steel lines containing high-energy fluids.

Also, past repairs, replacements, and modifications have been effective in mitigating FAC. QA surveillances and self-assessments from 1999 to 2004 revealed no issues or findings that could impact effectiveness of the program. The Flow Accelerated Corrosion Program has been effective at managing aging effects. The Flow Accelerated Corrosion Program provides reasonable assurance that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

4.4.1 5. Inservice Inspection Program Pressure boundary components, including bolting, are evaluated using non-destructive examinations and visual inspections. Deviations from acceptance criteria are properly resolved. Inspections since 2001 revealed erosion of valve body internals, weld indications, recirculation pump bolting corrosion and RHR valve bolting corrosion. The scope of welding inspections was expanded when rejectable indications were identified.

Condition reports were used to document indications and ensured resolution of those conditions. Corrective actions included repair and replacement of components.

These actions provide evidence that the program is effective at managing aging effects for applicable components.

QA audits, QA surveillances, engineering system health reports, and NRC inspections from 2001 to 2004 revealed no issues or findings that could impact effectiveness of the program. The lnservice Inspection Program has been effective at managing aging effects. The Inservice Inspection Program provides reasonable assurance that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

4.4.16. Containment Inservice Inspection Program RFO 21 inspections found only two areas of potential age-related degradation; the drywell floor to metal containment moisture barrier had missing paint, cracked paint, and areas of corrosion on the base metal in the seal area; and corrosion was found in the area of the X-5G penetration. Engineering evaluation was performed and no significant wall loss was identified.

Base metal was prepared, primed and painted to protect it from further corrosion, and the moisture barrier was replaced. RFO 22 inspections found two more areas of potential age-related degradation; surface pitting of primary containment vent headers and vent pipe bowls; and corrosion on torus penetrations X-207A-H. Evaluation determined that the components have significant margin to code minimum wall thickness and that the rate of corrosion is low due to the inerted containment environment during operation.

Augmented inspections were not necessary since I WNPS License Renewal Project Operating Experience Review Results none of the identified corrosion was significant.

RFO 24 inspections revealed flaking coating and rust staining on the bay 3 inner torus wall. Subsequent ultrasonic examination revealed no material loss. Also, visual inspection of drywell head exterior surface revealed areas of localized missing coating and primer with light corrosion, but no material loss. Resolution of these issues prior to loss of component intended function provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

LRPD-05 Revision 0 RFO 24 visual inspections of drywell interior surfaces, stabilizer assembly interior surfaces, torus penetrations, and drywell penetrations revealed areas of localized missing coating where the primer is intact, but no corrosion or material loss. Visual inspection of new drywell moisture barrier resulted in no recordable indications.

Absence of aging effects on these components provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

QA surveillance during RFO 24 revealed that the program had deficient administrative controls. The program was revised to require that engineering evaluations of indications that do not meet acceptance criteria be completed before the containment is declared operable.

QA surveillance revealed an issue that could impact effectiveness of the program. Resolution of this issue provides evidence that the program remains effective at managing aging effects for primary containment and its integral attachments.

A recent engineering system health report revealed no issues or findings that could impact effectiveness of the program. The Containment lnservice Inspection Program has been effective at managing aging effects. The Containment lnservice Inspection Program provides reasonable assurance that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

4.4.17. Instrument Air Quality Program Recent analyses revealed all parameters are maintained within acceptance criteria.

Absence of degradation of instrument air quality provides evidence that the program is effective at ensuring that instrument air supplied to components is maintained free of water and significant contaminants, thereby preventing loss of material. The Instrument Air Quality Program has been effective at managing aging effects. The Instrument Air Quality Program provides reasonable assurance that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

4.4.18. Oil Analysis Program A negative trend was noted in the lube oil analysis report for the P-40-1A diesel fire pump. Oil was drained, flushed, and refilled.

A lube oil sample taken on the B emergency diesel generator indicated an abnormally high silicon level. Cause was determined to be gasket sealant materials used during the last EDG overhaul causing a temporarily high non-abrasive silicon level in the oil. Although acceptance criteria do not include an upper threshold for silicon, re-

2. Approved by: Robert Pennv hdr Date: 3/g/7 Engineering Standar I LPI ENN ENGINEERING STANDARD ENN-EP-S-001 Rev. 0 Effective Date: 3/19/04 IWE General Visual Containment Inspection IP1 0 Applicable Site(s): IP2 Ix] IP3 IxI JAF IxI PNPS [x1 VY IxI Safety Related: X Yes No c Prepared by: Glen Smith Engineering Standard ENN NUCLEAR MANAGEMENT MANUAL Containment Inspection a Entwgy IWE General Visual Requirements and Revision Summary ENN-EP-S-001 Revision 0 Page - 2 of Revision No. Date 0 ! Changes Original issue t ENN NUCLEAR MANAGEMENT MANUAL I ENN-EP-S-001 Revision 0 I Engineering Standard IWE General Visual - 3 of 18 Containment Inspection TABLE OF CONTENTS Section - Title 1 .o PURPOSE ....................................................................................

4

2.0 REFERENCES

.............................................................................

4 3.0 DEFINITIONS

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5 4.0 RESPONSIBILITIES

....................................................................

7 5.0 DETAILS ......................................................................................

7 6.0 RECORDS ..................................................................................

I1 I 1 7.0 ATTACHMENTS

........................................................................

1 2 COATED AND UNCOATED SURFACES ............

13 EVALUATION FORM .......................................

14 ATTACHMENT 7.1, GENERAL VISUAL EXAMINATION CHECKLIST FOR A~ACHMENT 7.2, IWE GENERAL VISUAL EXAMINATION ATTACHMENT 7.3, QUALIFICATION OF EQUIPMENT.

.................... .I5 u 3 ATTACHMENT 7.4, PERSONNEL QUALIFICATION FORM ....................

16 BOLTING ASSEMBLIES

..................................

17 CONTAINMENT SUPPORTS ............................

18 A~ACHMENT 7.5, GENERAL VISUAL EXAMINATION CHECKLIST FOR ATTACHMENT 7.6, GENERAL VISUAL EXAMINATION CHECKLIST FOR Engineering Standard ENN-EP-S-001 Revision 0 "Entwgy a IWE General Visual Page - 4 of 18 Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL 1.0 PURPOSE 1 .I This engineering standard is written to document the requirements to perform the IWE visual containment examination.

The visual examination is performed to assess the general condition of the containment and to detect evidence of degradation that may affect structural integrity or leak tightness. This examination satisfies the requirements of the ASME Boiler and Pressure Vessel Code, 1992 Edition, 1992 Addenda,Section XI, Subsection IWE examination Category E-A, Item No. El .I 1 and 1998 Edition up to 2000 Addenda,Section XI, Subsection IWE Examination Category E-A, Item No. E1.lO. This engineering standard applies to personnel examining components identified in the site specific Containment In-service Inspection Program Plan (CIIPP) identified in references 2.14, 2.15, 2.21,2.22 and 2.23. This procedure applies to class MC components consisting of the containment structure and connecting penetrations, appurtenances and parts that form the containment leak tight boundary. The components in the boundary includes:

1.2 1.3 1.3.1 Drywell and Drywell head 1.3.2 Suppression Chamber (Torus) exterior surface 1.3.3 Suppression Chamber vapor phase surface

1.3.4 Containment

surfaces (including reinforcing structures such as stiffening rings, manhole frames, and reinforcement around openings)

1.3.5 Suppression

Chamber submerged surfaces (at Pilgrim for Detailed Visual Examination only) 1.3.6 Drywell vent system including vent piping, vent header, and downcomers (at Pilgrim Detailed Visual Examination only) 1.3.7 Drywell exterior and penetrations

1.3.8 Containment

dome/wall/basement liner 1.3.9 Penetration sleeves 1.3.10 Personnel Air IocklEquipment Hatch 1.3.1 1 Fuel Transfer Tube

2.0 REFERENCES

2.1 1 OCFR50 Appendix J 2.2 2.3 2.4 2.5 2.6 ASME Boiler and Pressure Vessel Code,Section XI, "Rules for In-service Inspection of Nuclear Power Plant Components, Subsection IWE and IWL, 1992 Edition, 1992 Addenda. IP2 RR-49; NRC SER TAC NO. MA6949, dated 2/4/00 IP2 RR-43 and RR-48; NRC SER TAC NO. MA6235, dated 10/7/99 10 CFR50.55a, "Codes and Standards" ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWE, Rules for In-service Inspection of Nuclear Power Plant Components, 1998 Edition, up to 2000 Addenda E .Y P e Engineering Standard ENN-EPS-001 Revision 0 IWE General Visual Page - 5 of 18 Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL $1 B 3 2.7 2.8 2.9 2.10 2.1 1 2.12 2.13 2.14 2.1 5 2.1 6 2.17 2.1 8 2.1 9 2.20 ENN-DC-105; "Configuration Management" 2.21 2.22 2.23 2.24 2.25 2.26 IP3 RR-3-24; NRC SER TAC NO. MA 9757, dated 5/17/2001 American Society of Testing Material (ASTM) D 610-95, "Standard Test Method for Evaluating Degree of Rusting on Painted Steel Surfaces".

ASTM D 660-93, "Standard Test Method for Evaluating Checking of Exterior Paints".

ASTM D 661-93, "Standard Test Method for Evaluating Degree of Cracking of Exterior Paints". ASTM D 714-87, "Standard Test Method for Evaluating Degree of Blistering of Paints". ASTM D 772-86, "Evaluating Degree of Flaking (scaling) of Exterior Paints". Appendix A to Document ID

1. 9.1450.044-S-001, "Design Margins of the IP2 Containment STEEL LINER" RAYTHEON Engineers

& Constructors 2-RPT-00003, Rev. 0, "IP2 Containment In-service Inspection Program, First Containment Interval (09/09/96-05/09/08)".

IP3-RPT-VC-03071, Rev. 4, "IP3 Containment In-service Inspection First Ten Year Class MC and CC Program" IP3-CALC-VC-03067, "Reactor Containment-Minimum Liner Thickness" IP3-RPT-STR-03398, Rev. 0,"ASME Section XI, IWE MC and Metallic Liners of Class CC Components Inspection

EP-ML-2002-054, "IWE Remote Visual Equipment Qualification", 7/17/02 Appendix E to Report SL-5408, Rev. 0, "IS1 Acceptance Criteria for Containment Liner Thickness" PP 7024, "VY Containment In-service Inspection Program (IWE)"

JAF-RPT-PC-04088, "JAF First Containment In-service Inspection Interval Program Plan" QA 20.03, "PNPS First Ten Year Interval IWE Containment Inspection Program" QA IT1 50.90, "Visual Examination of IWE Components" QA IT1 50.91, "IWE Augmented Examinations" ENN-AD-103, "Records management and Document Control Activities"

3.1 Accessibility

- Visual access by line of sight with adequate lighting from permanent plant structures, equipment, or components, provided these surface areas do not require augmented examination. Arc strike - A loss or displacement of base metal, caused by the introduction of an electric current of sufficient intensity to change phase from solid to liquid.

Arc strikes are rounded depressions in the base metal with some discoloration.

3.2 Engineering

Standard ENN-EP-S-001 Revision 0 6 of 18 -==- Entwgy 445 IWE General Visual Page - Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.1 1 3.12 3.13 3.14 3.15 3.16 3.17 3.18 Blisters - Large or small, round or hemispherical projections of the coating from the surface and are either dry or liquid filled. The usual cause of the condition is the penetration of moisture through an area of poor adhesion.

Chalking - A surface phenomenon that appears soft or powdery. The cause is a breakdown in coating binder, which disintegrates, leaving the surface covered with pigment.

Checking - Small breaks in coating surfaces that are formed as coating ages and becomes harder and more brittle. Checking, for the most part, is a formulation related reaction, where the resins and pigments do not properly combine.

Chipping - Small void in coating system, caused by impact from foreign object.

Class MC components - This term applies to pressure retaining metallic components (including their integral attachments) within the boundaries established in the site specific CllPP for inspection under requirements of ASME Section XI, Subsection IWE as modified by 10 CFR 50.55a. For the purpose of this procedure, all metallic components subject to examination under IWE by 10 CFR 50.55a shall be referred to as Class MC components regardless of the design classification of the component.

Corrosion - The degradation of a substance (usually metal) or its properties because of a reaction with the environment. Cracking (coating) - A non-linear line running through the coating system.

Cracking is caused by expansion or contraction throughout the film (layer) and the film and the substrate (primer or metal surface).

Cracking (metal) - A base metal indication, fissure or separation, either linear or non-linear.

The crack will have length and depth. Dent - The movementldisplacement of the base material from its original plane, without signs of metal stress or paintkoating distress.

Discoloration - Change in color of the coating, fading. Cause could be age, heat, dye or pigment bleeding or surface contamination (dye penetrant, grease, dirt, etc.).

Engineering Evaluation - An evaluation done for a reportable condition to determine if the structural integrity or leak tightness of the containment is jeopardized.

Flaking - (Also referred to as scaling or peeling) -the detaching of one layer of a coating from another or from the base metal. Flaking is generally preceded by cracking, checking, or blistering and is the result of loss of adhesion, usually due to stress strain factors. General corrosion - An approximately uniform wastage of a surface of a component, through chemical or electrochemical action, free of deep pits or cracks. General Visual Exam - A visual examination performed either directly or remotely to assess the general condition of the accessible primary containment surfaces and to detect evidence of degradation that may affect structural integrity or leak tightness.

Gouge - A loss of base metal caused by impact with a foreign object. Base metal may have sharp edges or be pushed to the far edge of the area of impact.

Integral attachments - Those structural attachments that have a containment pressure retaining function or are in the containment vessel's support load path and are welded, cast, or forged integrally to the inside or outside surface of the containment pressure boundary.

Engineering Standard ENN-EP-S-001 Revision 0 "Enter- a IWE General Visual Page - 7 of @ Containment inspection ENN NUCLEAR MANAGEMENT MANUAL 3.19 3.20 3.21 3.22 3.23 3.24 3.25 3.26 3.27 Leak-tightness - Ability of a component to maintain a prescribed maximum leakage rate under service conditions. Non-integral attachment - (Also referred to as nonstructural, temporary or minor permanent attachments) those structural attachments that do not perform a containment pressure retaining function nor are in the containment vessel's support load path. Non-integral attachments include such items as insulation supports, nameplates, locating and lifting lugs, lighting supports, shear plates or rings, retainer rings, and walkway supports. corrosion that generally produces sharply defined open or closed cavities in a metal surface. Relevant Condition - A condition observed during a visual examination that requires supplemental examination, corrective measure, and correction by repaidreplacement, or analytical evaluation. Responsible Individual - Individual responsible for implementation of the containment IWE inspection program as described in the program plan, references 2.14, 2.15, 2.21, 2.22, and 2.23. Rusting - The presence of oxidation in the form of iron oxide on steel. Structural Integrity - The ability of a structure of component to withstand prescribed design loads. Undercutting (coating) - Appears as a raised coated rust bloom. Undercutting is actually rust forming under the coating and acting as a wedge to push the coating off the metal surface. The undercutting may crack the coating surface. Wear - A gradual removal of a substance caused by friction.

In paint or coating the wear may appear as a different color or thickness.

In base metal the wear areas may appear brighter in appearance or as a low area. 4.0 RESPONSIBILITIES 4.1 WPO Enaineerina Prosrams or Site Enaineerinq has the responsibility to develop and maintain the Containment IWE program. This may include establishing basis for program content, issuing inspection scope and providing implementation support (scheduling, coordination of inspection, maintaining inspection procedures, etc.).

The examination will be performed at intervals specified in the site specific CIIPP. The Responsible Individual (RI), or designee, from the Engineering Programs group or Site Engineering has the responsibility to evaluate the examination results.

The individual is experienced in evaluating the condition of Class MC components.

Enaineerina Personnel and/or Certified Inspectors shall perform the examination in accordance with the requirements of Table IWE-2500-1 as delineated in the site specific CIIPP. Inspectors shall be qualified in accordance with site-specific requirements.

4.2 4.3 5.0 DETAILS 5.1 General Instructions Engineering Standard ENN NUCLEAR MANAGEMENT MANUAL m -==- Entwgy \WE General Visual Containment Inspection 5.1.1 The General Visual examination shall be performed either directly or remotely with sufficient illumination and resolution to assess the general condition of the accessible Containment surfaces (inside and outside). The examination shall be documented using Attachments 7.1, 7.5, and 7.6 or site-specific documentation. Equipment demonstration and validation reports should be maintained or referenced in the work order; in the inspection report identified in section 6.0 or other appropriate site process. 5.1. I .1 Inaccessible areas are not required to be examined unless specifically identified as an inaccessible area requiring examination by either the site specific CllPP or the RI. Accessible areas requiring examination are defined in the site specific CIIPP.

ISI-IWE drawings in the site specific CllPP define the components and boundaries for inspection. Examiners shall visually examine non-coated and coated surface areas to be inspected and document the examination results, which require evaluation on the IWE General Visual Examination Evaluation Form (Attachment 7.2). 5.1.1.2 5.1.1.3 5.1.2 5.1.2.1 5.1.2.2 Painted or coated areas shall be examined for evidence of flaking, blistering, peeling, discoloration, and other signs of distress.

Non-coated areas shall be examined for evidence of cracking, discoloration, wear, pitting, excessive corrosion, gouges, surface discontinuities, dents, and other signs of surface irregularities.

ENN-EP-S-001 Revision 0 8 of 18 Page - Note: Bolted connections need not be disassembled for performance of general Visual examination.

5.1.2.3 Pressure retaining bolting (if required in site CIIPP) shall be examined for defects that may cause the bolted connection to violate either leak tightness or structural integrity.

5.1.3 If no indications exceeding the inspection criteria of Sections 5.3, 5.4, 5.5 and 5.6 are noted, the examination is complete. The closeout of the General Visual examinations will be documented in the form of Work Orders written expressly for the performance of the General Visual examinations or other site-specific documentation. Following completion of the examinations the detailed results should be documented in an inspection report or other site-specific process. This report will contain a summary of the inspection, including Attachments

7.1 through

7.6 and any pictures, videotapes, CR's, etc. It will cover the IWE examinations performed during the period.

If the examiners note indications which need further evaluation:

5.1.4 5.1.4.1 The IWE General Visual Examination Evaluation Form (Attachment 7.2) shall be completed.

The forms shall be immediately brought to the Rl's attention.

The RI shall evaluate the results and determine acceptability; or request a 1: I I PY $"

Engineering Standard ENN-EP-S-001 Revision 0 IWE General Visual Page - 9 of 18 Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL detailed visual, VT-1, examination (or additional examinations as determined by the RI, i.e. UT). Note: The objective of this examination is to provide sufficient data to the RI to conduct an evaluation. When a detailed visual, VT-1, (or additional examinations) are required, access to the area to be examined must be sufficient to allow for valid measurements of the dimensional data reauired for the evaluation.

5.1.5 At the direction of the RI, the examination personnel will note the condition of the surfaces requiring examination. Areas of specific interest may be photographed and/or videotaped. This will serve as a reference condition to be compared with the results of the next inspection.

5.2 Evaluation

of Results Note: The inspection criteria are presented as a guide for IWE examination personnel to determine when an existing condition is acceptable or requires further evaluation. The guide is not intended to be all-inclusive.

It relies upon the inspectors' general knowledge of material conditions.

When a questionable condition is encountered, the IWE examination personnel should always be conservative and request an evaluation.

5.2.1 5.2.2 5.2.3 5.2.4 The inspection criteria (Sections 5.3, 5.4, 5.5 and 5.6) form the basis for accepting existing conditions in plants. These inspection criteria have been evaluated and acceptable by calculation or code and do not deter or compromise the structural integrity of the primary containment pressure boundary.

Indications which do not exceed the inspection criteria are not required to be reported and are considered acceptable without the Rl's review.

The RI will determine if the conditions exceeding the inspection criteria are acceptable. A Condition Report (CR) shall be generated for all unacceptable conditions. Acceptance evaluation for conditions exceeding the inspection criteria will be in accordance with site-specific requirements. Reference drawings and previous examination results should be utilized as necessary.

The RI shall document the results of the acceptance review of the General Visual and, if required, detailed visual, VT-1, examination results. 5.3 Uncoated Surface Areas 5.3.1 If any of the relevant conditions listed below are present, further evaluation may be required. Initiate a CR as required by section 5.2.3. The condition must be recorded on the IWE General Visual Examination Evaluation Form (Attachment 7.2) or other site-specific document and forwarded to the RI for acceptance review. 5.3.1.1 Cracking in base metal Engineering Standard ENN NUCLEAR MANAGEMENT MANUAL a Entwgy IWE General Visual Containment Inspection 5.3.1.2 5.3.1.3 5.3.1.4 Discoloration resulting from age, heat, of corrosion Wear that could exceed 10% of the nominal wall thickness Pits, dents, or gouges of the base metal with depth that could exceed 10%

of the nominal wall thickness of the material (e.g. 0.025 inches for a 0.25 inch nominal thickness) Corrosion, which results in discernable, base metal loss that could exceed 10 Oh of the nominal wall thickness.

5.3.1.5 5.3.1.6 Discernable bulges 5.3.1.7 Arc strikes 5.3.1.8 Other conditions such as mechanical damage causing discernable degradation of the base metal ENN-EP-55-00?

Revision 0 Page - IO of 9 5.4 Coated Surface Areas 5.4.1 If any of the relevant conditions listed below are present, further evaluation may be required.

Initiate a CR as required by section 5.2.3. The condition must be recorded on the IWE General Visual Examination Evaluation Form (Attachment 7.2) or other site-specific document and forwarded to the RI for acceptance review.

5.4.1.1 5.4.1.2 Absence of coating 5.4.1.3 5.4.1.4 5.4.1.5 5.4.1.6 5.4.1.7 5.4.1.8 Any of the conditions listed in Section 5.3.1 for uncoated surfaces Blisters equal to or greater than size No. 6 as specified in ASTM D 714-87 Checking equal to or greater than standard No. 2 as specified in ASTM D Cracking equal to or greater than standard No. 6 as specified in ASTM D Flaking equal to or greater than standard No. 6 as specified in ASTM D 772- 86 Rusting equal to or greater than Rust Grade 7 as specified in ASTM 0 610 - 95 Other distress to the coating that may indicate degradation of the underlying base metal 660-93 661 -93 5.5 Bolting Assemblies (As required in site CIIPP) 5.5.1 If any of the relevant conditions listed below are present, further evaluation may be required.

Initiate a CR as required by section 5.2.3. The condition must be recorded on the IWE General Visual Examination Evaluation Form (Attachment 7.2) or other site-specific document and forwarded to the RI for acceptance review.

Bending, twisting, stretching or deforming of bolts or studs Missing or loose bolts, studs, nuts, or washers 5.5.1.1 5.5.1.2 i I 1. f.

Engineering Standard ENN-EP-S-001 Revision 0 "Entergv m IWE General Visual Page - I1 of 18 Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL 5.5.1.3 Fractured bolts, studs, or nuts 5.5.1.4 5.5.1.5 5.5.1.6 Bolting degradation 5.5.1.7 Localized excessive corrosion Degradation of protective coatings on bolting surfaces Evidence of coolant leakage near bolting 5.5.1.8 Misalignment of connection or bolting 5.6 Containment Supports (As required in site CIIPP) 5.6.1 If any of the relevant conditions listed below are present, further evaluation may be required. Initiate a CR as required by section 5.2.3. The condition must be recorded on the IWE General Visual Examination Evaluation Form (Attachment 7.2) or other site-specific document and forwarded to the RI for acceptance review.

5.6.1 .I 5.6.1.2 5.6.1.3 5.6.1.4 5.6.1.5 Misalignment of supports 5.6.1.6 5.6.1.7 5.6.1.8 5.6.1.9 5.6.1 .IO Any signs of surface irregularities Deformations or structural degradations of fasteners, clamps or other support items, and loss of integrity at bolted or welded connections. Missing, detached, or loose support parts and bolting. Arc strikes, weld spatter, paint, scoring, roughness, or general corrosion on close tolerance, machined or sliding surfaces. Improper clearances of guides and stops Wear which visibly reduces the cross-sectional area of the support Abnormal corrosion which reduces the load bearing capacity of the support Crack like or linear sulface flaws Evidence of clamp or non-integral attachment movement, damage, or movement of component insulation due to support movement 6.0 RECORDS An ASME,Section XI, IWE MC Components Inspection Report or other site-specific process shall be used to document all examinations, findings, and evaluations. If a report is written, it shall be referenced in the Work Orders used to implement the examinations.

The report shall include Attachments

7.1 through

7.6. The ASME,Section XI, IWE MC Component Inspection Report is a controlled record, and is transmitted to Administrative Services in accordance with ENN-AD-103C-105, "Document Control and Configuration Management Activities".

Engineering Standard ENN NUCLEAR MANAGEMENT MANUAL IWE General Visual Containment Inspection ENN-EP-S-001 Revision 0 Page 12 of 18 7.1 7.2 7.3 Qualification of Equipment

7.4 Personnel

Qualification Form 7.5 7.6 General Visual Examination Checklist for Coated and Uncoated Surfaces IWE General Visual Examination Evaluation Form General Visual Examination Checklist for Bolting Assemblies General Visual Examination Checklist for Containment Supports

~ Note: Site approved equivalents are acceptable for use in lieu of the following attachments.

i I Engineering standard ENN-EP-S-001 Revision 0 "Enterggy m IWE General Visual Page - 13 of 18 1 Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL AITACHMENT

7.1 GENERAL

VISUAL EXAMINATION CHECKLIST FOR COATED AND UNCOATED SURFACES Sheet 1 of 1 Yes = exceeds the recording criteria No = does not exceed the recording criteria Examination performed by: Date: Quality Record Engineering Standard ENN-EP-S-001 Revision 0 IWE General Visual Page - 14 of 18 I Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL ATTACHMENT 7.2, IWE GENERAL VISUAL EXAMINATION EVALUATION FORM Sheet 1 of 1 Component Number or Zone Number (*) Existing Condition Being Evaluated Evaluation of Existing Condition Evaluation Performed By: Evaluation Approved By: Quality Record

.'L 1

-- I if .- 'I ENN NUCLEAR MANAGEMENT MANUAL I ~ ~~~~~ Engineering Standard ENN-EP-S-001 Revision 0 I - 15 of 18 1 Page IWE General Visual Containment Inspection ATTACHMENT

7.3 QUALIFICATION

OF EQUIPMENT

==

Introduction:==

Demonstration of remote examination equipment is required to be performed prior to executing General Visual examinations when the use of remote equipment is required. This demonstration needs to be performed once at the beginning of this examination to qualify the light source and the remote equipment used. The commitments of each site specific Relief Request or Technical Position are to be utilized when qualifying the equipment.

Performance Qualification:

Type of equipment used: Maximum examination distance:

Description of demonstration:

Demonstration distance: Demonstration performed by: Demonstration witnessed by (ANII): Date: Date: Quality Record Engineering Standard ENN-EP-S-004 Revision 0 ENN NUCLEAR MANAGEMENT MANUAL IWE General Visual Page - 16 of Containment Inspection z - ATTACHMENT

7.4 PERSONNEL

QUALIFICATION FORM p___I - P - Inspection Personnel Qualification Form for General Visual Examination Name: Education:

Experience:

Eye Exam: On the basis of the above, I have determined that the subject individual is capable of performing General Visual Examinations at IP2, IP3, JAF, Pilgrim, and/or Vermont Yankee as required by ASME Section XI 1992 Edition, 1992 Addenda, or 1998 Edition, no Addenda, Subsection IWE, Subparagraph IWE-3510.1 This qualification expires one year from the date of the eye examination. .I . Responsible Individual Date Quality Record Engineering Standard IWE General Visual Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL ATTACHMENT

7.5 GENERAL

VISUAL EXAMINATION CHECKLIST FOR BOLTING ASSEMBLIES ENN-EP-S-001 Revision 0 - 17 of 18 Page Yes = exceeds the recording criteria Examination performed by: Date: Quality Record

• I- ,- Engineering Standard ENN-EP-S-001 Revision 0 18 of 18 "Entergy !a IWE General Visual Page - Containment Inspection ENN NUCLEAR MANAGEMENT MANUAL I I I 1 ATTACHMENT

7.6 GENERAL

VISUAL EXAMINATION CHECKLIST FOR CONTAINMENT SUPPORTS - - I__ Yes = exceeds the recording criteria Comments Examination performed by: Date: Ref. Drawings for JAF: 3.72-6C, 3.72-9E, and 3.72-17 Quality Record VERMONT YANKEE NUCLEAR POWER STATION n PROGRAM PROCEDURE 1 01/24/06 3,4, & 12 of 13; Table 1 Pgs 5,6 & 7 of 21 PP 7024 REVISION 4 CONTAINMENT INSERVICE INSPECTION PROGRAM W) USE CLASSIFICATION:

INFORMATION RESPONSIBLE PROCEDURE OWNER: Manager, Systems Engineering REQUIRED REVIEWS I Yes/No E-Plan I 10CFRSO. LPC Effective 1 No. I Date I Affected Pages I ImDlementation Statement:

NIA I Effective Date: 071 2 1 /05 PP 7024 Rev. 4 Page 1 of 13 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 TABLE OF CONTENTS PURPOSE, SCOPE, AND DISCUSSION

...................................................................................

3 DEFINITIONS

................

,..- .........

.................................... , ...................................

........................

6 - PRIMARY RESPONSIBILITIES

.................................................................................................

7 PROCEDURE

...............

., .................................................................................

.... .....................

8 REFERENCES AND COMMITMENTS

..................................................................................

11 FINAL CONDITIONS

..,,......

......................................................................................................

12 ATTACHMENTS

........ .-, .............................................................................................................

13 QA REQUIREMENTS CROSS REFERENCE

........................................................................

13 PP 7024 Rev. 4 Page 2 of 13 1 1 .o 1.1. 1.2. fi f 1.3. PURPOSE, SCOPE, AND DISCUSSION Purpose ENN-DC-120, ASME Section XI Code Promams, in concert with PP 7024 implements the requirements for the Fourth Ten-Year Interval Containment Insavice Inspection Program (Program) in accordance with Title 10 Code of Federal Regulations, Part 50, Section 50.55a, Codes and Standards (10CFR50.55a) dated September 26,2002, pertaining to inspection and testing of the Primary Containment for the three periods of the Interval.

Scope The Primary Containment System is a GE Mark I Pressure Suppression Containment System. The system consists of a Drywell (housing the reactor vessel and reactor coolant recirculation loops), a Pressure Suppression Chamber (housing a water reservoir), and the connecting vent system between the Drywell and the water pool, isolation valves, and containment cooling systems. The code of construction for the containment structure is the ASME Section 111, 1965 WNinter Addenda. Discussion The Code of Record (Code) for the Program is the American Society for Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components" (ASME Section XI - 1998 Edition with the 2000 Addenda). The utilization of a single code edition ensures a uniform application of the Code requirements by the synchronizing the four implementing programs (i.e., PP 7015, PP 7034, AP 0070, and PP 7024). The Code of Record was modified by the adoption of subsubarticle IWA-4540 of the 2003 Addenda of the ASME Section XI - 2001 Edition. The adoption was approved by the NRC Safety Evaluation (NVY 05-094) dated July 25,2005.

ENVY developed PP 7024, Containment Inservice Inspection Promam CITE) (i.e., the Program) to comply with the September 9,1996 mandate of 1 OCFR50.55a requiring licensees to incorporate Subsection IWE of ASME Section XI - 1992 with the 1992 Addenda into the Inservice Inspection Program. The Initial IWE Interval ran concurrent with the Third Ten-Year Inservice Inspection Interval.

Both the Initial TWE Interval and the Third Ten-Year Inservice Inspection Interval schedules and fkequencies are based on IWA-2432 of the Code, "Inspection Program By" consisting of four ten-year intervals with three periods per interval.

August 3 1 , 2003 ends the Third Ten-Year Inservice Inspection Interval and has been established as the end of the Initial WE Interval, midway though the Second Period. As of September 1, 2003, the Program is aligned with the Fourth Ten-Year Inservice Inspection Interval (Fourth ISI). PP 7024 Rev. 4 Page 3 of 13 LPC #I The Program continuity (periodicity and frequency) has been maintained by aligning the remaining Initial IWFi Interval Second Period (RFO 24) with the Fourth IS1 First Period (RFO 24). During the Initial IWE Interval First Period, 100% of the required examinations were completed.

Additionally, no examinations were scheduled or conducted during the first portion of the Second Period (RFO 23) of the Initial IWE Interval.

The relative interval and period starting and ending dates are outlined in the following matrix: Period 1 1 Interval 2'd Interval 3'd Interval 4'b Interval Period 2 I Period3 May 1, 1983 Sep 1,1986 to to sep 1, 1990 to Aug 31,1986 Sep 1,1993 to I to Aug 31, 1996 Aug 31,2000 Aug 31,2003 I to Aug 31,1990 Aug 31, 1993 Sep 1, 1996 sep 1,2000 Period 1 Sep 9,1998 Period 2 Period 3 Sep 9,2001 Sept 9,2005 Initial IWE Interval to Sep 8,2001 [RFO 21,223 to to Sep 8,2005 Sep 8,2008 [RFO 23,24,25]

[RFO 26,271 Sep 1,2003 The 1" IS1 Interval was five years long, due to the delay in the development and implementation of ASME Section XI. The end date of the lst IS1 Interval was extended by five months, in accordance with IWA-2430(c), to permit inspections concurrent with a plant reheling outage. Consequently, the subsequent intervals and periods were adjusted forward five months. The end date of 2"d IS1 Interval - Period 1 was extended by four months to reflect the 1985-86 pipe replacement and reheling outage (9 months duration) in accordance with IWA-2430(e).

Consequently, the subsequent intervals and periods were adjusted forward four months. The Initial IWE Interval ended on August 3 1,2003 in order to align the Program with the other ASME Section XI programs.

ENVY'S operating license expires March 21,2012. 1 2 3 4 5 [FWO 19,20,21]

[RFO 22,233 Sep 1,2006 sep 1,2010 The Program scope has been adjusted as required to comply with the Code. Two (2) Examination Categories have been retained from the Initial IWEi Interval Program: containment surfaces (E-A) and containment surfaces requiring augmented examination (E-C). to Aug 31,2006 [RFO 24,251 Parts scheduled for examination by percentage to complete for each period in the qfh Interval are PP 7024 Rev. 4 Page 4 of 13 LPC #1 to to Aug 31,2010 Aug 31,2013 ' [RFO 26,27,28]

[RFO 29,301 ii iI 1..3 d The Program incorporates the following specified limitations and modifications listed in 10CFR50.55a dated Sept. 26,2002: e VT-1 and VT-3 visual examinations must be conducted in accordance with IWA-2200. Personnel conducting VT-1 or VT-3 visual examination meth&hall be qualified in accordance with TWA-2300.

VT-1 visual examinations will be conducted in lieu of the "Detailed Visual" examinations of IWE-23 1O(c) for Examination Category E-C Item E4.11. VT-3 visual examinations will be conducted in lieu of the "General Visual" examinations of IWE-23 lo@) for Examination Category E-A Items El. 12 and El .20 and specifically for the bolting of Item El. 1 1. Flaws or degradation identifieadwing the conduct of the VT-3 visual examination of Containment bolting, must be examined in accordance with the VT-1 visual examination method. The criteria in the material sDecification or IWT3-3517.1 must be used to evaluate the Containment bolting or degradation.

An evaluation of the acceptability of inaccessible areas shall be conducted when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas. For each inaccessible area identified, the following shall be included in the IS1 Summary Report as required by IWA-6000:

1. 2. 3. A description of the type, estimated extent, and conditions that led to the degradation; An evaluation of each area, including the result of the evaluation; A description of the corrective actions, if necessary.

The Program incorporates the alternative requirements for containment inspection and testing as outlined in Regulatory Guide 1.147, as needed. Presently, the following Code Cases are being implemented:

N-532-1 , Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission The Program additionally incorporates the alternative requirements for containment inspection and testing, or corrective measures as outlined in relief requests.

Presently, the following relief requests are being implemented:

None The Program does not have to be submitted to the NRC staff for approval. However, the program elements and the required documentation must be maintained on site for audit. PP 7024 Rev. 4 Page 5 of 13 2.0 2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 2.8. 2.9. DEFINITIONS Accessible Surface Area:

An area capable of direct or remote visual examination from existing vantage points. Aumented Examination Area: Surface areas likely to experience accelerated degradation and aging. Auxili~ Lwhting: - An artificial light source used as a visual aid to improve viewing conditions and visual perception. Coating: Materials (including paints) applied that are used to protect an ASME Code Class MC component against corrosion. Component: Metallic vessels, liners, appurtenances, etc. that have been classified as ASME Code Class MC. i I i i Containment Non-Structural and Temporary Attachments:

Attachments that do not perform a insulation supports, nameplates, locating and lifting lugs, lighting supports, walkway supports, etc. pressure retaining function nor are in the component's supports load path including such items as (Containment Structural) Intearal

Attachment:

Attachments that have a containment pressure retaining function or are in the containment vessel support load path that are welded, cast, or forged integrally to the inside or outside surface of the containment pressure retaining component.

Defect: A flaw (imperfection or unintentional discontinuity) of such size, shape, orientation, location, or properties as to be unacceptable. Inaccessible Surface Areas: Those areas that are embedded or otherwise obstructed from direct or remote visual examination. Some examples include but are not limited to areas:

8': e 0 0 that are permanently embedded in concrete that are covered and permanently sealed by insulation to prevent the intrusion of moisture that access (to conduct the visual examination) is permanently obstructed for the examination personnel and/or equipment L 0 that are sealed by a moisture barrier that is designed to prevent intrvsion of moisture i PP 7024 Rev. 4 Page 6 of 13

3.0 PRIMARY

RESPONSIBILITIES This procedure defines the organizational responsibilities as are currently being implemented at Vermont Yankee. As part of the transition to the ENN programs and procedures, the ISI-IWE program ownership responsibilities will be assumed by PJPO Engineering Programs in accordance with ENN-DC-120, ASME Section XI Code Programs. When the transition plan is developed, in accordance with ENN-PL155, Change Management Policy, PP 7024 will be revised accordingly.

3.1. Manager, System Engineering, is responsible to ensure: 3.1.1. Implementation of AP 0098, Appendix A, for the Program. 3.1.2. The Program is defined and maintained per the requirements of 10CFR50.55a, in accordance with ASME Section XI - 1998 Edition through the 2000 Addenda, in compliance with Regulatory Guide 1.147 and approved relief requests.

3.1.3. The assignment of the Containment Inservice Inspection (rWE) Coordinator, the Program owner and Responsible Individual of IWE-2320.

3.1.4. Approval

of changes to the Program (Le., PP 7024 and implementing procedures).

3.2. Manager, Design Engineering, is responsible to ensure: 3.2.1. Control of the Design Basis documentation that affects the Program. 3.2.2, Design compliance with the requirements of the Program. Manager, Planning and Scheduling Outage, is responsible to ensure:

3.3.1. Work Order planning complies with the requirements of the Program. 61 3.3. ra P 3.3.2. Outage planning complies with the requirements of the Program. F 1 Activity Report Form OAR-1. 3.4. Inservice Inspection (ISI) Coordinator is responsible to assimilate VT-1 and VT-3 visual examination results for inclusion, as needed, in the NISI Summary Reports or the Owner's 3.5. ASME Section XI Repair and Replacement Program (RRP) Coordinator is responsible to assimilate VT-1 , VT-2, and VT-3 visual examination results for inclusion, as needed, in the NIS-2 or MS-2A Summary Reports. 3.6. Primary Containment Leak Rate Testing Program Coordinator is responsible to conduct the requisite testing in accordance with 10CFR50 Appendix J. PP 7024 Rev. 4 Page 7 of 13 Y- I- IP I 3.7. Containment Inservice Inspection Coordinator (IWE Coordinator and Responsible Individual of IWE-2320) is responsible to ensure:

3.7.1. Implementation

and administration of the Program including the maintenance and revision of "Containment Inservice Inspection Program (IWE)," PP 7024. 3.7.2. Coordination of the periodic and interval required General, VT-1 and VT-3 visual examinations.

E-- 3.7.3. Evaluations, as required, by the Program.

3.7.4. Provide

VT-1, VT-3, and the pressure testing with VT-2 visual examination results as input to the IS1 and RRP Coordinators for the development of the NIS-1, NIS-2, NIS-2A or OAR-1 Summary Reports. 3.7.5. Assignment of certified examiners for conducting General, VT-1, VT-2, and VT-3 visual examinations. Examiners are certified in accordance with ENN-NDE-2.12, Certification of Visual Testing (VT) Personnel, or other ENVY approved procedures.

3.7.6. Define

areas for augmented examination and revise Table 2 as necessary.

i 1 I 3.7.7. Evaluate components whose examination results reveal flaws or areas of degradation that do not meet the acceptance standards.

4.1. Administration

I I The Program provides for two processes: the first is for the performance of Code required periodic and interval examinations for Category E-A components; the second is for the examination for Category E-C augmented components as required by IWE-1240.

4.1.1. Program

Procedure e e e e The Program text contains general information common to the functions.

Appendix A - Containment Inservice Inspection Program (WE) Relief Requests Table 1 - Examination Category E-A Table 2 - Examination Category E-C - presentIy blank PP 7024 Rev. 4 Page 8 of 13

4.1.2. Implementing

Procedures ENN-EP-001, IWE General VisuaI Containment Inspection, is used to execute the examination process for Category E-A, Items El. 1 1 and El .30. .. ENN-NDE-10.01, VT-1 Examination, is used to executee examination process for Category E-C, Item E4.11. 0 EW-NDE-10.03, VT-3 Examination, is used to execute the examination process for Category E-A, Items El.ll (bolting), E1.12, andE1.20.

4.1.3. Records

I The Program administrative and implementing procedures, analyses, evaluations, calculations, visual examination results, and other records required to define and execute the Program are retained per AP 6806 and AP 6807. Copies of selected records shall be retained in the IWE Coordinator files. : '1 .-. 4.1.4. Reports Reports will be generated as required per the Code. A copy of the report shall be retained in the IWE Coordinator files. 4.1.5. Reportability Conditions adverse to Technical Specifications must be assessed for Emergency Notification System reporting under lOCFR5O.?2(b)( l)(ii) and (b)(2)(i), and for a Licensee Event Report under lOCF'RSO.73(a)(2)(ii).

4.1.6. Evaluations

The Program requires evaluations for various reasons (e.g., for the requisite Post Modification and Maintenance Testing requirements, etc.).

These evaluations shall be documented and a copy retained in the IWE Coordinator files. PP 7024 Rev. 4 Page 9 of 13

4.1.7. Examinations

0 General visual examinations will be conducted in accordance with the criteria of ENN-EP-001 at the frequency specified in Table 1. 0 VT-3 Examination will be conducted in accordance wit.-ENN-NDE-10.03 at the frequency specified in Table 1. 0 VT-1 Examinations will be conducted in accordance with ENN-NDE-10.01 at the frequency specified in Table 2. 0 Examination results that exceed the acceptance criteria shall be documented in I accordance with EN-LI-102. 4.2. Program Positions i 4.2.1. The Program excludes process piping and systems penetrating the Primary Containment. Inservice Inspection Program; PP 7034, Inservice Inspection Pressure Test Program; Primary Containment Leak Rate testing Program. Boundary between the containment and piping is: I I The excluded process piping and systems are addressed in PP 7015, Vermont Yankee AP 0070, ASMB Section XI Repair and Replacement Procedure, andor PP 7006, ib ( 0 The first circumferential joint exclusive of the connecting weld in welded connections 0 The face of the first flange in bolted flange connections 0 The first threaded joint in mechanical connections 4.2.2. The Primary Containment System is a GE Mark I Pressure Suppression Containment System consisting of a Drywell, a Pressure Suppression Chamber (Torus), and the connecting Vent System between the Drywell and the Torus. The Primary Containment System is subject to Table Iw)3-2500-1 Examination Category E-A. Table IWE 2500-1 is further divided into:

0 Item El. 1 1, Accessible Surface Areas - applicable to the Drywell and Torus e Item E1.12, Wetted Surfaces of Submerged Areas - applicable to the Torus 0 Item E1.20, BWR Vent System Accessible Surface Areas - applicable to the eight circular pipes connecting the Drywell to the Torus; the eight Jet Deflectors; the Vent Header interconnecting piping; the ninety-six downcorners; and the ten Vacuum Breakers including the interconnecting piping from the Torus to the Vent S ys tem 0 Item E1.30, Moisture Barriers - applicable to the Drywell shell to Concrete floor intersection at elevation 238' PP 7024 Rev. 4 Page 10 of 13 m !4J 5.0 5.1. ! 5.2. 4.2.3. Paint and coating inspections for removal and replacement of coating or paint are included in the Program inspection requirements.

An examination of painted or coated surfaces is requited to indicate the condition of the substrate.

The examinations shall be included in the applicable work documents for the paint or coating surface preparation and application.

Following the application of new paint or coatings the area must be rebase-lined to establish the condition of the substrate in the area-of new application.

0 Surfaces subject to general visual and VT-3 Examinations will be examined with paint and coatings in an "as is" condition of lWE-2600(a).

a Surfaces subject to VT-1 Examinations will be examined with paint and coatings in an "as is" condition of WE-2600 (a) or if required in accordance with IWE-2600@)

4.2.4. Repair

and replacement activities shall be conducted in accordance with Ap 0070 and inspected and documented per the requirements of the Code. 4.2.5. During the implementation of the program, the moisture barrier required per drawing 5920-233 at the intersection of the interior of the drywell shell and the concrete floor at elevation 238' was determined to have been degraded and effective reconfiguration of the seal was not performed (ER 99-1954).

A minor modification was developed (MM 2000-010) to install a replacement seal.

The drywell shell and the concrete floor were stripped of all paint, coatings, and sealant for approximately a six inch band either side of the intersecting joint. The drywell shell was examined by VT-3, VT-1, and ultrasonic measurement processes. The shell was determined to be satisfactory in accordance with the criteria of VYC-2043.

The drywell shell was coated and the seal was replaced. Though not required by the Code of Record, the moisture barrier will be examined each refueling outage until RFO 27. Table 1 has been annotated to reflect this program position.

4.2.6. Inaccessible

Areas will be listed in Table 1, as identified REFERENCES AND COMMITNENTS Technical Specifications and Site Documents

5.1.1. Technical

Specification Section 3.6.EI4.6.E Administrative Limits 5.2.1. None PP 7024 Rev. 4 Page 11 of 13 5.3. 5.4. 5.5. 6.0 6.1. 6.2. Codes, Standards, and Regulations 5.3.1. ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition through 2000 Addenda 5.3.2. Code of Federal Regulations, 1 OCFR50.2 Definitions 5.3.3. Code of Federal Regulations, 10CFR50.55a dated September 26,2002 5.3.4. Code of Federal Regulations, IOCFRSO Appendix J 5.3.5. Regulatory Guide 1.147, Inservice Inspection Code Case Applicability 5.3.6. Regulatory Guide 1.26, Rev 3, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants 5.3.7. NS-22, Draft 4, Rev 1, Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants

5.3.8. Safety

Evaluation by the Office Nuclear Reactor Regulation,

Subject:

Safety Evaluation of Request to use Later Addenda of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Code) - Vermont Yankee Nuclear Power Station CNVy 05-094 dated July 25,2005) Commitments 5.4.1. None Supplemental References 5.5.1. EN-AD-103, Document Control and Records Management Activities 5.5.2. EN-LI-102, Corrective Action Process 5.5.3. ENN-EP-001, WE General Visual Containment Inspection 5.5.4. ENN-NDE-2.12, Certification of Visual Testing (VT) Personnel 5.5.5. ENN-NDE-10.01, VT-1 Examination 5.5.6. ENN-NDE-10.03, VT-3 Examination 5.5.7. AP 0095, Plant Procedures 5.5.8. AP 0098, Procedure Writer's Guide 5.5.9. AP 6806, Transfer of Quality Assurance Records to RIMS 5.5.10. PP 7006, Primary Containment Leak Rate Testing Program FINAL CONDITIONS The Program Owner shall ensure that the required information from the Containment Inservice Inspection Program (WE) is included in the NIS-1 , NIS-2, NIS-2A Reports or OAR-1 . QA records shall be collected, stored and processed in accordance with PP 7801, Quality Assurance Records Program, requirements for QA record handling and storage. I. PP 7024 Rev. 4 Page 12 of 13 LPC #1 7.0 7.1. 7.2. 7.3. 8.0 8.1 8.2 8.3 8.4 I 11 It i I.r I' R A ATTACHMENTS Appendix A - Containment Inservice Inspection Program (lWE) Relief Requests Table 1 - ASME Code Class MC Examination Category E-A Table 2 - ASME Code Class MC Examination Category E-C QA REQUIREMENTS CROSS REFERENCE - Source Document Section Procedure Section QMM B.1.c All QMM B .8 .a- f All QMM B.3.c All QMM *3.9. b 4.1.7 PP 7024 Rev. 4 Page 13 of 13 APPENDIX A Containment Inservice Inspection Program (IWE) Relief Requests 10CFR50.55a Request Number: - Page Intentionally Left Blank Appendix A PP 7024 Rev. 4 Page 1 of 1 TABLE 1 ASME CODE CLASS MC EXAMINATION CATEGORY E-A TORUS and TORUS PENETRATIONS RFO scmm ITEM NUMBER DESCRlIYTION Bay 1 El.ll DRAWING EXAMINATION, PERIOD' NUMBER METHOD 123 6202-200 General 24 27 29 E1.12 El.ll El. 12 VT-3 El.ll 27i E1.12 Bay 2 6202-200 General 24 27 29 I 5920-42 Visual El.ll E1.12 El.ll E1.12 I Bay 3 6202-200 General 24 27 29 5920-42 Visual EL11 El. 12 El.ll E1.12 , Bay 4 6202-200 General 24 27 29 I 5920-42 Visual I VT-3 Ill Visual I 5920-42 I 27i VT-3 I 27i VT-3 27i Bay 5 t 6202-200 General 24 27 29 592042 Visual I Bay 6 6202-200 592042 VT-3 27i General 24 27 29 Visual I VT-3 27i Bay 7 I I I VT-3 27i I 6202-200 General 24 27 29 5920-42 Visual EXAMINATlON CATEGORY E-A REMARKS Accessible areas of interior and exterior surfaces.

Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces.

~ ~. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces.

Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces.

Wetted surfaces of submerged areas.

Accessible areas of interior and exterior surfaces.

Wetted surfaces of submerged areas.

Accessible areas of interior and exterior surfaces.

Wetted surfaces of submerged areas. Table 1 PP 7024 Rev. 4 Page 1 of 21 TABLE 1 (Continued)

TORUS and TORUS PENETRATIONS DRAWING EXAMINATION DESCRIPTION NUMBER METHOD Bay 8 6202-200 General RFO SCHEDULE 123 24 27 =29 PERIOD' ITEM WMBER 31.11 VT-3 !1.12 27i :1.11 Bay 11 Bay 12 31.12 6202-200 General 24 27 29 5920-42 Visual VT-3 27i 6202-200 General 24 27 29 5920-42 Visual 31.11 VT-3 27i ~ 31.12 Bay 14 21.11 6202-200 General 24 27 29 5920-42 Visual 31.12 VT-3 fi1.11 27i 91.12 El.ll El. 12 El.ll El. 12 El.ll El. 12 Visual I 5920-42 1 6202-200 General 5920-42 Visual Bay 10 6202-200 General 5920-42 Visual 5920-42 Visual 5920-42 Visual EXAMINATION CATEGORY E-A REMARKS Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas.

Accessible areas of interior and exterior surfaces. Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces. Wetted surfaces of i submerged areas. Table 1 PP 7024 Rev. 4 Page 2 of 21 TABLE 1 (Continued)

ITEM NUMBER El.ll E1.12 RFO DRAWTNC DESCRIPTION NUMBER Bay.16 6202-200 5920-42 TORUS and TORUS PENETRATIONS 1 24 24 24 24 24 24 24 24 24 PERIOD^ 2 -3 27 29 27i 27 29 27i 27 29 27i 27 29 27 29 27 29 27 29 27 29 27 29 5920-42 I El.ll El.ll El.ll El.ll El.ll El.ll El.11 I X-206B 5920-42 X-206C 5920-42 X-206D 5920-42 X-206E 5920-42 X-206F 5920-42 X-209A 5920-42 X-209B 5920-42 5920-42 24 24 24 EXAMINATION METHOD General Visual 27 29 27 29 27 29 VT-3 General Visual VT-3 General Visual VT-3 General Visual General Visual General Visual General Visual General Visual General Visual General Visual General Visual General Visual EXAMINATION CATEGORY E-A REMARKS Accessible areas of interior and exterior surfaces.

Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces.

Bolting Accessible areas of interior and exterior surfaces.

Bolting Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Bottom 1/3 is inaccessible. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Table 1 PP 7024 Rev. 4 Page 3 of 21 5920-42 5920-42 General visual General Visual 5920-42 5920-42 5920-42 5920-42 5920-42 General Visual General Visual General Visual General Visual VT-3 General Visual TABLE 1 (Continued)

TORUS and TORUS PENETRATIONS RFO SCHEDULE PERIOD' EXAMINATION CATEGORY E-A DRAWING EXAMINATION NUMBER 1 METHOD ITEM WER El.ll 1 2 REMARKS DESCRIPTION X-209D 27 27i 27 - - 27i 27 - Accessible areas of interior and exterior surfaces.

Bottom 1/3 is inaccessible. Accessible areas of exterior surfaces.

Piping covered with insulation. Wetted surfaces of submerged areas.

Accessible areas of exterior surfaces.

Piping covered with insulation.

El.ll X-2 1 OA E1.12 El.ll X-210B Visual Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces.

Exterior piping covered with insulation.

El. 12 El.ll X-211A 24 29 24 - 24 27 - 27 29 Accessible areas of interior and exterior surfaces.

Exterior piping covered with insulation.

El.11 X-211B gr.; i ! 29 Accessible areas of interior and exterior surfaces.

x-212 X-2 13A El.ll El.ll 24 27i 29 - Accessible areas of exterior surfaces.

Piping covered with insulation.

~~ Wetted surfaces of submereed areas. E1.12 El.ll E1.12 24 - 27 27i - - 29 Accessible areas of exterior surfaces. Wetted surfaces of submerged areas.

X-213B VT-3 I Table 1 PP 7024 Rev. 4 Page 4 of 21

.- 24 24 24 24 24 24 24 24 24 I PERIOD' 123 27 29 27 29 27 29 27 29 27 29 27 29 27 29 27 29 27 29 'E, 1 LPC 1 1 TABLE 1 (Continued)

ITEM NUMBER Eli1 1 El.ll El.ll El.ll El.ll El.ll El.ll El.ll El.11 El.ll ORUS and TORUS PENETW X-2 17 5920-42 X-2 1 8 I 5920-42 I X-2 1 9 I 5920-42 x-22 1 5920-42 X-223 5920-42 'IONS ~ ~ XAMINATION METHOD GeIleral Visual General Visual G*3leral Visual General Visual General Visual General Visual General Visual General Visual General Visual General Visual RFO SCHEDULE EXAMINATION CATEGORY E-A - REMARKS Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior sufaces. Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces. Exterior piping covered with insulation.

Accessible areas of exterior surfaces. Exterior piping wvered with insulation. Interior is inaccessible -blocked by 24" - HPCI-3. Accessible areas of interior and exterior surfaces.

Table 1 PP 7024 Rev. 4 Page 5 of 21 LPC #1 TABLE 1 (Continued)

RFO ITEM NUMBER El.ll DESCRIPTION X-224A NUMBER 5920-42 :1.12 METHOD 123 REMARKS General 24 27 29 Accessible areas of 31.1 1 z1.12 VT-3 31.11 E1.12 El.ll El.11 insulation. 27i Wetted surfaces of :-224B <-225 Visual VT-3 c226A Y-226B exterior surfaces.

Piping covered with insulation.

submerged areas. 27i Wetted surfaces of 3 PENETRATIONS DRAW- 27 29 Accessible areas of exterior surfaces.

I/// Piping covered with Visual El. 12 El.ll E1.12 El.ll 27 27i 27 27i 27 271 27 27 I I I I Isuhmereedareas.

29 29 29 29 29 I I I I o-- ~ - - - __ - - - 5920-42 I General I 24 1 27 I 29 IAccessibleareasof X-227 X-228 X-229 5920-42 General 24 Visual VT-3 5920-42 General 24 Visual 5920-42 General 24 Visual 5920-42 General Visual I 1 5920-42 I General I 24 Visual I+ 5920-42 General Visual II :xterior surfaces.

Netted surfaces of iubmerged areas. kcessible areas of :xterior surfaces.

Wetted surfaces of submerrred areas. 4ccessible areas of Zxterior surfaces.

Wetted surfaces of submerged areas. Accessible areas of exterior surfaces.

Wetted surfaces of submerged areas. Accessible areas of exterior surfaces.

Interior is inaccessible - internal to X-202E branch line. Accessible areas of exterior surfaces.

Interior is inaccessible - internal to X-202C branch line. Table 1 PP 7024 Rev. 4 Page 6 of 21 LPC #1 RFO TORUS and TORUS PENETRATIONS SCHEDULE 1 EXAMINATION CATEGORY E-A ITEM NUMBER E1.11 DESCRIPTION X-230 3 29 REMARKS Accessible areas of exterior surfaces.

Interior is inaccessible - internal to X-2023 5920-42 5920-42 General 24 Visual General 24 Visual 29 29 Accessible areas of exterior surfaces.

Wetted surfaces of submerged areas. Accessible areas of interior and exterior surfaces.

I El.ll X-23 1 E I 5920-42 General 24 27 Visual El.ll (X-231G I 5920-42 I General I 24 I 27 29 Accessible areas of interior and exterior surfaces.

I El.11 I X-231H I I I 5920-42 I General 1 24 I 27 TABLE 1 (Continued)

DRAWING EXAMINATION NUMBER I METHOD :RIO 2 27 - - 27 27i 27 - - - 27 27i - X-23 1 A El.ll interior and exterior surfaces.

5920-42 1 General 1 24 El.ll X-23 1 B Visual VT-3 I E1.12 El.ll X-23 1 C Visual El.ll 5920-42 I General I 24 29 Accessible areas of I exterior surfaces.

X-231D Visual VT-3 E1.12 I Wetted surfaces of m interior and exterior surfaces X-23 1 F General Visual 5920-42 El.ll E1.12 1 submerged areas. II 1 visual I+-++ Visual Wetted surfaces of I submeraed areas. E1.12 Table 1 PP 7024 Rev. 4 Page 7 of 21 LPC #I TABLE 1 (Continued)

TORUS and TOR1 RFO S PENETRATIONS SCHEDULE EXAMINATION DRAWING EXAMINATION, PERIOD' CATEGORY E-A NUMBER METHOD 123 REMARKS exterior surfaces.

Interior is inaccessible - internal to X-202E branch line.

27 29 Accessible areas of exterior surfaces. Interior is inaccessible - internal to X-202G branch line.

5920-42 General 24 27 '79 Accessible areas of Table 1 PP 7024 Rev. 4 Page 8 of 21 TABLE 1 (Continued) 1 DEn I r- DRAWING EXAMINATION ITEM NUMBER DESCmON NUMBER METHOD El.ll Drywell 6202- 1 General elevation 238 to 6202-2 Visual elevation 25 1 PERIOD 12- 24 2 - - 39 ~ ~ Accessible areas of interior surfaces.

From 251' floor to 269' floor at 150" for 3' CW; 160" for 22.5' CW, and 206" for 3' CW are inaccessible due to permanent shielding. interior surfaces. - 29 Table 1 PP 7024 Rev. 4 Page 9 of 21 TABLE 1 (Continued)

DRYWELL and DRYWELL -- ITEM RFO I 1 PENETRATIONS SCHEDULE EXAMINATION DRA~EE CATEGORY E-A NUMBER 6202-25 +UMBER METHOD 1112 3 REMARKS General 1 24 I 27 29- Accessible areas of 31.11 6202-25 z1.11 I I VT-3 27i Bolting General 24 27 29 Accessible areas of 31.11 El.ll E1.11 El.ll Visual E1.11 interior surfaces (and exterior surfaces if disassembled).

El.11 6202-25 DESCmION Stabilizer Assembly "B" ~ ~ VT-3 27i Bolting General 24 27 29 Accessible areas of Stabilizer Assembly "C" 6202-25 6202-25 Stabilizer Assembly "D" Visual interior surfaces (and exterior surfaces if disassembled).

VT-3 27i Bolting General 24 27 29 Accessible areas of Visual interior surfaces (and exterior surfaces if disassembled). VT-3 27i Bolting General 24 27 29 Accessible areasof Stabilizer Assembly "E' Visual VT-3 6202-25 General Visual VT-3 6202-25 General Visual I VT-3 5 920-4 1 General Visual I Stabilizer Assembly "F' interior surfaces (and exterior surfaces if disassembled), 27i Bolting 24 27 29 Accessible areas of interior surfaces (and exterior surfaces if disassembled).

27i Bolting 24 27 29 Accessibleareas of interior surfaces (and exterior surfaces if disassembled).

27i Bolting 24 27 29 Accessible areas of interior and exterior surfaces. - Stabilizer Assembly "G' Stabilizer Assembly "H' x- 1 Visual interior surfaces (and exterior surfaces if disassembled).

I- I I a ! ! Table 1 PP 7024 Rev. 4 Page 10 of 21 ELL PENETRATIONS DRAWING I EXAMINATION SCHEDULE PERIOD' 27 27 27i 27 27i 27 27i 27 23 29- 29 29 29 29 5920-41 5920-41 5920-4 1 General 24 Visual VT-3 General 24 Visual VT-3 General 24 Visual 27 27 27 27 27 29 29 29 29 29 G-191179 5920-4 1 G- 19 1 179 5920-41 G-191179 5920-41 G-191179 5920-41 General 24 Visual General 24 Visual General 24 Visual General 24 Visual TABLE 1 (Continued)

I FWO EXAMINATION CATEGORY E-A WELL and DRY DR ITEM NUMBER DESCRIPTION x-2 REMARKS Accessible areas of E1.11 5920-41 General Visual interior and exterior surfaces.

AccessibIe areas of interior and exterior surfaces, includes external flange bellows area. Majority of the interior is blocked b! duct work. Bolting Accessible areas of exterior surfaces (and interior surfaces if disassembled).

Bolting x-3 El.11 El.ll X-4 El.ll X-6 Accessible areas of interior and exterior surfaces. G-191179 General P 5920-41 Bolting Accessible areas of interior and exterior X-7A X-7B El.ll I Visual surfaces.

Accessible areas of interior and exterior surfaces.

I El.ll 5920-41 Visual El.ll x-7c Accessible areas of interior and exterior surfaces.

El.ll X-7D Accessible areas of interior and exterior surfaces.

El.ll X-8 Accessible areas of interior and exterior surfaces.

El.ll X-9A Accessible areas of interior and exterior surfaces.

I I Table 1 PP 7024 Rev. 4 Page 11 of 21

'ELL PENETRATIONS DRAWING I EXAMINATION SCHED PERK ITEM NUMBER DESCRIPTION El.ll E1.11 El.ll El.ll El.ll El.ll El.ll El.ll El.ll X-9B x-10 x-11 x-12 X- 13B X-13A X- 14 X-15 X- 16A G-191179 5920-41 General 24 Visual G-191179 5920-41 G-191179 5920-41 G- 19 1 179 5920-41 General 24 Visual General 24 Visual General 24 Visual G-191179 5920-41 General 24 Visual G-191179 5920-41 General 24 Visual G-191179 5920-41 G-191179 5920-41 G-191179 5920-41 G-191179 5920-41 G-191179 5920-41 General 24 Visual General 24 Visual General 24 Visual General 24 Visual General 24 Visual El.ll X- 16B E1.11 El.ll X-17 X-18 TABLE 1 (Continued)

I RFO EXAMINATION CATEGORY E-A REMARKS NUMBER1 METHOD E Accessible areas of interior and exterior surfaces . 29 29 Accessible areas of interior surfaces.

Exterior of penetration and piping covered with insulation.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

I 24 General 5920-41 Visual G-191179 I 29 Accessible areas of interior and exterior surfaces.

29 Accessible areas of interior and exterior surfaces.

29 Accessible areas of interior and exterior surfaces.

29 29 29 - Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Table 1 PP 7024 Rev. 4 Page 12 of 21 24 24 24 24 24 24 24 24 24 24 24 24 24 scm PEN( 12 27 27 27 27 27 27 27 27 27 27 27 27 27 G-19 1 179 5920-41 General Visual G-191179 5920-41 G-191179 5920-41 G- 19 1 179 5920-41 G-191179 592041 General Visual General Visual General Visual General Visual G- 191 179 5920-41 G-191179 5920-4 1 General Visual General Visual G-191179 5920-4 1 G-191179 5920-41 G-191179 5920-41 General Visual General Visual General Visual G-191179 5920-41 G- 19 1 179 5920-41 General Visual General Visual TABLE 1 (Continued)

RFO JLE 3 D' - WELL and DRY DESCRIPTION ELL PENETRATIONS DRAWING 1 EXAMINATIOfi DR ITEM EXAMINATION CATEGORY E-A REMARKS Accessible areas of interior and exterior NUMBER NUMBER I METHOD El.ll x-19 ?9 29 29 surfaces. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

E1.11 x-20 El.ll EL11 x-21 x-22 El.ll x-23 Accessible areas of interior and exterior surfaces.

El.ll X-24 29 - 29 Accessible areas of interior and exterior surfaces.

EL11 X-25 Accessible areas of interior and exterior surfaces.

29 Accessible areas of interior and exterior surfaces.

X-26 X-27 X-28 X-29 X-30 EL11 El.ll El.ll El.ll 3 M 29 29 29 - Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

E1.11 El.ll X-3 1 5920-41 Visual Table 1 PP 7024 Rev. 4 Page 13 of 21 TABLE 1 (Continued)

DESCRIPTION NUMBER METHOD ~ Y-32 G-191179 General 5920-41 Visual I K-33 G-191179 General 5920-41 Visual x-34 G- 19 1 179 General 5920-41 Visual X-35A G-191179 General 5920-41 visual DRYWELL and DRYWELL PENETRATIONS I DRAWING I EXAMINATION zq PERIOD ITEM NUMBER El.ll El.ll E1.11 El.ll X-3 5B x-35c E1.11 El.ll El.ll VT-3 G-191179 General 5 920-4 1 Visual VT-3 G-191179 General 5920-41 Visual E1.11 El.ll El.ll El.ll El.ll X-35D X-35E X-36 X-37A X-38A X-37B X-38B x-37c X-38C L VT-3 G-191179 General 5920-41 Visual VT-3 G-191179 General 5920-41 Visual VT-3 G- 191 179 General 5920-41 Visual G-191179 General 5920-41 Visual G-191179 General 5920-4 1 Visual G-191179 General 5920-4 1 Visual 24 24 24 27 29 27 29 27 29 EXAMINATION CATEGORY E-A interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Bolting Accessible areas of interior and exterior surfaces.

Bolting Accessible areas of interior and exterior surfaces.

Bolting Accessible areas of interior and exterior surfaces.

Bolting Accessible areas of interior and exterior surfaces.

Bolting Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

I- i c ' Table 1 PP 7024 Rev. 4 Page 14 of 21 TAEKE 1 (Continued)

DRAWING DESCRIPTION NUMBER X-37D G-191179 X-3 8D 5920-4 1 X-39A G-191179 5920-41 X-39B G-191179 5920-41 X-40A G-191179 5920-41 DR ITEM NUMBER EL11 El.11 El.ll El.ll EXAMINATION METHOD General Visual General Visual General Visual General Visual El.ll El.11 24 24 24 24 El.ll 123 27 29 27 29 27 29 27 29 El.ll G-191179 5920-41 1 G-191179 ~ 5920-41 G-191179 5920-41 El.11 El.ll El.ll El.ll El.ll General Visual General Visual General Visual G-191179 5920-41 X-40B x4oc X-4OD General 24 27 29 Visual x-41 G-191179 5920-41 G-191179 5920-41 X-42 x-43 X-44 General 24 27 29 Accessibleareasof Visual interior and exterior General 24 27 29 Accessible areas of Visual interior and exterior surfaces.

x-45 G- 1 9 1 179 X-46 surfaces.

General 24 27 29 Accessible areasof G-191179 surfaces.

General 24 27 29 Accessibleareasof 24 i EXAMINATION surfaces.

27 29 Accessibleareasof

~ CATEGORYE-A REMARKS I Accessible areas of interior and exterior ' surfaces.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

I I surfaces.

Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

5920-41 I Visual I I I Iinteriorandexterior 5920-41 I Visual I I I Iinteriorandexterior 5920-41 Visual I I I interior and exterior Table 1 PP 7024 Rev. 4 Page 15 of 21

~ TABLE 1 (Continued)

L- . RFO SCHEDULE PERIOD' EXAMINATION CATEGORY E-A XATIONS EXAMINATION METHOD General Visual DRYWELL and DRY ELL PENE DRAWING NUMBER ITEM NUMBER DESCRIPTION REMARKS Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

x-47 G-191179 5920-41 El.ll El.ll El.ll El.ll El.11 G-191179 5920-41 General Visual X-48 x-49 G- 19 1 179 5920-41 General Visual Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces.

X-50 General Visual G-191179 5920-41 G-191179 5920-41 G-191179 5920-41 5920-41 X-5 1 General Visual General Visual Accessible areas of interior and exterior surfaces.

El.ll X-52 General Visual Accessible areas of interior and exterior surfaces. Both surfaces have restricted access due to junction box mounting.

Accessible areas of interior and exterior surfaces.

Both surfaces have restricted access due to junction box mounting.

X-100A El.ll El.11 ~ X- lOOB x-1ooc General Visual 5920-4 1 5920-41 Accessible areas of interior and exterior surfaces.

Both surfaces have restricted access due to junction box mounting.

General Visual El.ll Table 1 PP 7024 Rev. 4 Page 16 of 21 i X-1O1B x-I01C TABLE 1 (Continued) 5920-41 592041 DR ITI'EM NUMBER General Visual General Visual El.11 24 27 24 27 El.11 El.ll General Visual El.ll 24 27 El.ll El.ll El.11 x-102 El.ll 5920-4 1 I RFO General Visual General WELL and DRYWELL PENETRATIONS DESCRIPTION NUMBER 24 27 24 27 X-103 5920-41 X-104A I 5920-41 I General I 24 I 27 Visual General 24 27 Visual 29 - 29 29 29 29 - 29 EXAMINATION CATEGORY E-A REMARKS Accessible areas of interior and exterior surfaces.

Both surfaces have restricted access due to junction box mounting. Accessible areas of exterior surfaces.

Interior is inaccessible Accessible areas of interior and exterior surfaces.

Accessible areas of exterior surfaces.

Interior is inaccessible Accessible areas of interior and exterior surfaces. Accessible areas of exterior surfaces.

Interior is inaccessible Accessible areas of exterior surfaces.

Top half exterior is restricted and the interior is inaccessible due to junction box mounting.

Accessible areas of interior and exterior surfaces.

Both surfaces have restricted access due to junction box mounting.

Table 1 PP 7024 Rev. 4 Page 17 of 21 RFO SCHEDuL;E

)1 EXAMINATION CATEGORY E-A 3 -29 REMARKS Accessible areas of interior and exterior surfaces. Exterior is restricted and the interior is inaccessible due to junction box 29 interior and exterior surfaces. Exterior is restricted and the interior is inaccessible due to junction box mounting.

Accessible areas of interior and exterior 29 29 Accessible areas of interior and exterior surfaces. Interior has restricted access due to junction box mounting.

Accessible areas of interior and exterior surfaces. Interior has restricted access due to junction box mountin E. TABLE 1 (Continued)

UTIONS WELL and DRYWELL PENE7 I DRAWING 1 DR ITEM NUMBER ZXAMINATION METHOD General Visual PI 1 24 - _. 24 24 uc 2 27 - - 27 27 Y- 104B 5920-41 Y- 104B 5920-41 El.ll El.ll -I--- 29 Accessible areas of Y- 104C I 5920-41 General Visual General Visual El.ll 5920-41 K- 105A surfaces. Interior has restricted access due to junction box mounting.

Accessible areas of exterior surfaces.

Interior is inaccessible.

General Visual El.ll 5920-41 X-105B El.ll El.11 X-105C General Visual 5920-4 1 X- 105D General Visual 5920-4 1 Table 1 PP 7024 Rev. 4 Page 18 of 21 TABLE 1 (Continued)

WELL, and DRYWELL PENETRATIONS 1 DRAWING EXAMINATION DR ITEM RFO SCHEDULE PERIOD' General Visual General Visual General NUMBER El.ll 24 27 53 24 27 29 24 26 29 El.ll METHUD E1.30 123 Visual I 25 27 EXAMINATION CATEGORY E-A REMARKS Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces. The interface is from the Containment Plate Weld Joint left of X-5B to the Containment Plate Weld Joint right of Penetration X-5E and from the concrete metal interface up -1 foot. Table 1 PP 7024 Rev. 4 Page 19 of 21 TABLE 1 (Continued)

I RFO VENT SYSTEM ASSEMBLIES ITEM 1 I DRAWING I EXAMlNATION SCHEDULE PERIOD' NUMBER El .20 El .20 DESCRIPTION NUMBER METHOD 1 2 9- Bay 2 Vent Line; 5920-13 VT-3 27i Vacuum Breaker 6202-200 Header in Bays 2 & 3; and Downcomers Bay 4 Vent Line; 5920-13 VT-3 27i Vacuum Breaker 6202-200 Header in Bays 4 & 5; and Lines; Vent 6202-21 1 Lines; Vent 6202-21 1 E1.20 Downcomers Bay 6 Vent Line; 5920-13 VT-3 27i Vacuum Breaker Header in Bays 6 & 7; and Lines; Vent 6202-200 6202-2 1 1 El .20 Downcomers Bay 8 Vent Line; 5920-13 VT-3 27i Va&mn Breaker Header in Bays 8 & 9; and Lines; Vent 1 6202-200 6202-21 1 EXAMINATION REMARKS CATEGORY E-A Accessible areas of interior and exterior surfaces.

E1.20 Accessible areas of interior and exterior surfaces.

Downcomers Bay 10 Vent 5920- 13 VT-3 27i Accessible areas of interior and exterior surfaces. Accessible areas of interior and exterior surfaces. Line; Vacuum Breaker Lines; Vent Header in Bays 10 & 11; Accessible areas of interior and exterior surfaces.

Accessible areas of interior and exterior surfaces.

6202-200 6202-2 1 1 I El .20 Table 1 PP 7024 Rev. 4 Page 20 of 21 and Downcomers Bay 12 Vent 5920- 13 VT-3 27i Line; Vacuum 6202-200 Breaker Lines; 6202-2 1 1 Vent Header in Bays 12 & 13; and Downcomers 1

TABLE 1 (Continued)

RFO SCHEDW PERIOD' 123 27i ITEM NUMBER -~ ~ EXAMINATION CATEGORY E-A REMARKS Accessible areas of interior and exterior El .20 DESCRJPTION El .20 i Indica DRAWING EXAMINATION NUMBER METHOD Bay 14 Vent Line; Vacuum Breaker Lines; Vent Header in Bays 14 & 15; and Downcomers 5920- 13 6202-200 6202-21 1 VT-3 Bay 16 Vent Line; Vacuum Breaker Lines; Vent Header in Bays 16 Br 1; and Downcomers 5920-13 VT-3 6202-200 6202-2 1 1 ~- .es refueling outage when an "Interval" test should? Table 1 PP 7024 Rev. 4 Page 21 of 21 TABLE 2 ITEM < NUMBER DESCRIPTION NUMBER METHOD E4.11 None VT- 1 m.12 None VOLUMETRIC ASME CODE CLASS MC EXAMINATION CATEGORY E-C PERIOD CATEGORY E-C 777 REMARKS Visible Surfaces Surface Area Grid, Minimum Wall Thickness Location Table 2 PP 7024 Rev. 4 Page 1 of 1