ML080300307

Relief Request No. RR-6, Implementation of BWRVIP Guidelines in Lieu of ASME Section XI Code Requirements on Reactor Vessel Internals Components Inspection

ML080300307
Person / Time
Site:	FitzPatrick
Issue date:	02/28/2008
From:	Mark Kowal NRC/NRR/ADRO/DORL/LPLI-1
To:	Entergy Nuclear Operations
muniz A, ADRO/DORL/415-4044
References
TAC MD4758
Download: ML080300307 (12)

Text

February 28, 2008 Vice President, Operations Entergy Nuclear Operations, Inc James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - RELIEF REQUEST NO. RR-6, IMPLEMENTATION OF BWRVIP GUIDELINES IN LIEU OF ASME CODE, SECTION XI REQUIREMENTS ON REACTOR VESSEL INTERNALS COMPONENTS INSPECTION (TAC NO. MD4758)

Dear Sir or Madam:

By letter dated February 27, 2007, as supplemented by letters dated August 20, 2007 and December 4, 2007, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request No. RR-6 for James A. FitzPatrick Nuclear Power Plant (JAFNPP). The licensees submittal proposed to use various Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines as an alternative to certain requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for inservice inspection (ISI) of reactor vessel internal components. The request was made pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i).

As documented in the enclosed safety evaluation (SE), the Nuclear Regulatory Commission (NRC) staff reviewed your submittal and concluded that, with the exception of the proposed uses of BWRVIP-41, Revision 1 and BWRVIP-138, the proposed alternative to the ASME Code requirements is acceptable. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), relief is authorized for the fourth 10-year interval ISI program.

If you have any questions regarding this matter, please contact Adrian Muniz at 301-415-4093.

Sincerely,

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

As stated cc w/encl: See next page

February 28, 2008 Vice President, Operations Entergy Nuclear Operations, Inc James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - RELIEF REQUEST NO. RR-6, IMPLEMENTATION OF BWRVIP GUIDELINES IN LIEU OF ASME CODE, SECTION XI REQUIREMENTS ON REACTOR VESSEL INTERNALS COMPONENTS INSPECTION (TAC NO. MD4758)

Dear Sir or Madam:

By letter dated February 27, 2007, as supplemented by letters dated August 20, 2007 and December 4, 2007, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request No. RR-6 for James A. FitzPatrick Nuclear Power Plant (JAFNPP). The licensees submittal proposed to use various Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines as an alternative to certain requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for inservice inspection (ISI) of reactor vessel internal components. The request was made pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i).

As documented in the enclosed safety evaluation (SE), the Nuclear Regulatory Commission (NRC) staff reviewed your submittal and concluded that, with the exception of the proposed uses of BWRVIP-41, Revision 1 and BWRVIP-138, the proposed alternative to the ASME Code requirements is acceptable. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), relief is authorized for the fourth 10-year interval ISI program.

If you have any questions regarding this matter, please contact Adrian Muniz at 301-415-4093.

Sincerely,

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

As stated cc w/encl: See next page Distribution:

PUBLIC GCheruvenki RidsNrrLASLittle RidsNrrPMAMuniz LPL 1-1 Reading RidsNrrDciCvib RidsNrrPMJBoska RidsOGCMailCenter RidsAcrsAcnw&mMailCenter RidsNrrDorlLpla Accession Number: ML080300307 *With Comments OFFICE LPL3-1\PM LPL1-1/PM LPL1-1\LA CVIB/BC OGC LPL1-1\BC NAME AMuniz JBoska SLittle MMitchell JAdler NLO MKowal DATE 2/13/08 2/25/08 2/27/08*

Official Record Copy

FitzPatrick Nuclear Power Plant cc:

Senior Vice President Mr. Paul Tonko Entergy Nuclear Operations, Inc. President and CEO P.O. Box 31995 New York State Energy, Research, and Jackson, MS 39286-1995 Development Authority 17 Columbia Circle Vice President Oversight Albany, NY 12203-6399 Entergy Nuclear Operations, Inc.

P.O. Box 31995 Mr. John P. Spath Jackson, MS 39286-1995 New York State Energy, Research, and Development Authority Senior Manager, Nuclear Safety & Licensing 17 Columbia Circle Entergy Nuclear Operations, Inc. Albany, NY 12203-6399 P.O. Box 31995 Jackson, MS 39286-1995 Mr. Paul Eddy New York State Dept. of Public Service Senior Vice President and COO 3 Empire State Plaza Entergy Nuclear Operations, Inc. Albany, NY 12223-1350 440 Hamilton Avenue White Plains, NY 10601 Oswego County Administrator Mr. Steven Lyman Assistant General Counsel 46 East Bridge Street Entergy Nuclear Operations, Inc. Oswego, NY 13126 440 Hamilton Avenue White Plains, NY 10601 Supervisor Town of Scriba Manager, Licensing Route 8, Box 382 Entergy Nuclear Operations, Inc. Oswego, NY 13126 James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Mr. James H. Sniezek Lycoming, NY 13093 BWR SRC Consultant 5486 Nithsdale Drive Regional Administrator, Region I Salisbury, MD 21801-2490 U.S. Nuclear Regulatory Commission 475 Allendale Road Mr. Michael D. Lyster King of Prussia, PA 19406 BWR SRC Consultant 5931 Barclay Lane Resident Inspector's Office Naples, FL 34110-7306 James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission Mr. John Doering P.O. Box 136 BWR SRC Consultant Lycoming, NY 13093 P.O. Box 189 Parker Ford, PA 19457 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST NO. RR-6 FOR THE FOURTH 10-YEAR INTERVAL OF THE INSERVICE INSPECTION PROGRAM ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

By letter dated February 27, 2007, as supplemented by letters dated August 20, 2007, and December 4, 2007, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted its fourth 10-year interval inservice inspection (ISI) program plan Request for Relief No. RR-6 for James A. FitzPatrick Nuclear Power Plant (JAFNPP). The licensees submittal proposes to use various Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines as an alternative to certain requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for ISI of reactor vessel internal (RVI) components.

2.0 REGULATORY REQUIREMENTS ISI of ASME Code Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g),

except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). 10 CFR 50.55a(a)(3) states that alternatives to the requirements of 10 CFR 50.55a(g) may be used, when authorized by the NRC if: (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for ISI of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b),

Enclosure

twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable ASME Code of record for the fourth 10-year ISI interval for JAFNPP is the 2001 Edition with 2003 Addenda of the ASME Code,Section XI.

3.0 TECHNICAL EVALUATION

3.1 Components for Which Relief is Requested ASME Code,Section XI, Class 1, Examination Categories B-N-1 and B-N-2.

Code item Numbers:

B13.10, Vessel Interior B13.20, Interior Attachments within Beltline Region B13.30, Interior Attachments beyond Beltline Region B13.40, Core Support Structures 3.2 Examination Requirements from which Relief is Requested ASME Code, Section Xl requires the visual examination (VT) of certain RVI components. These examinations are included in Table IWB-2500-1, Categories B-N-1 and B-N-2, and identified with the following item numbers:

• B13.10 - Examine accessible areas of the RV interior each period using a technique which meets the requirements for a VT-3 examination, as defined in paragraph IWA-2213 of the ASME Code,Section XI.

• B13.20 - Examine interior attachment welds within the beltline region each interval using a technique which meets the requirements for a VT-1 examination as defined in paragraph IWA-2211 of the ASME Code,Section XI.

• B13.30 - Examine interior attachment welds beyond the beltline region each interval using a technique which meets the requirements for a VT-3 examination, as defined in paragraph IWA-2213 of the ASME Code,Section XI.

• B13.40 - Examine surfaces of the core support structure each interval using a technique which meets the requirements for a VT-3 examination, as defined in paragraph IWA-2213 of the ASME Code,Section XI.

These examinations are performed to assess the structural integrity of the RVI components.

3.3 Applicable ASME Code Edition and Addenda The ASME Code of Record for the fourth 10-year ISI interval for JAFNPP is the 2001 Edition with 2003 Addenda, of ASME Code,Section XI.

3.4 Licensees Basis The licensee concluded that the alternative inspections (described below) will maintain an adequate level of quality and safety of the affected welds and will not adversely impact the health and safety of the public. As part of its justification for the relief, the licensee stated that boiling-water reactors (BWRs) now examine RVI components in accordance with BWRVIP guidelines. These guidelines have been written to address the examination of safety significant RVI components using appropriate methods and reexamination frequencies. The licensee also noted that the NRC has agreed with the BWRVIP approach, in principle, and has issued safety evaluations (SEs) for these guidelines. [Note: in principle means that, for some reports, final SE reports have been written, but the final BWRVIP acceptance reports which incorporate these SEs for some of the reports may not have been issued]. Relief from examinations in Table IWB-2500-1 of the ASME Code are requested pursuant to 10 CFR 50.55a(a)(3)(i).

3.5 Alternative Examination In lieu of the requirements of the 2001 Edition with 2003 Addenda of the ASME Code, Section Xl, the licensee proposed to examine the RVI components in accordance with BWRVIP Guideline requirements. The licensee stated that the particular guidelines that are applicable to the various RVI components are:

• BWRVIP-18-A, BWRVIP Core Spray Internals Inspection and Flaw Evaluation Guidelines"

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

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

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

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

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

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

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

• BWRVIP-76, BWR Core Shroud Inspection and Flaw Evaluation Guidelines

• BWRVIP-138, BWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines The licensee made a commitment to incorporate the requirements of the BWRVIP-94 Report, "Program Implementation Guideline," at JAFNPP. The BWRVIP-94 Report states that where guidance in existing BWRVIP documents has been supplemented or revised by subsequent correspondence approved by the BWRVIP Executive Committee, the most current approved guidance will be implemented.

In addition to the BWRVIP reports noted above, the licensee identified NUREG-0619 BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking, as the basis for its proposed alternative examinations for the feedwater sparger tee welds and the feedwater sparger piping and brackets.

The licensee, in its submittal dated February, 27, 2007, provided a comparison of the required ASME Code,Section XI Category B-N-1 and B-N-2 examination requirements with the above current BWRVIP Guideline requirements that are applicable to JAFNPP. In response to the NRC staffs request for additional information (RAI) (2B), by licensee letter dated August 20, 2007, the licensee provided RVI component inspection histories including results from the last inspections performed during the most recent refueling outage (RO17, October 2006). Furthermore, the licensee identified the applicable inspection program for the RVI components and the total number of welds in each of the RVI components. The licensee, as an example, provided additional information regarding the BWRVIP inspection requirements for the following welds of the RVI components and their subcomponents representing each of the aforementioned ASME Code,Section XI category/item numbers (Item Numbers B13.10, B13.20, B13.30, and B13.40).

• Core Spray

• Jet pump

• Core Shroud Support

• Vessel Attachment Welds (e.g., steam dryer hold-down brackets, guide rod brackets, and surveillance specimen holders The licensee claimed that these examples demonstrated that the inspection techniques that are recommended by the BWRVIP inspection guidelines are superior to the inspection techniques mandated by the ASME Code,Section XI ISI program. Additionally, these examples proved that the BWRVIP inspection guidelines require more frequent inspections of the RVI components than the corresponding ASME Code,Section XI ISI program. The licensee claimed that by implementing the BWRVIP inspection guidelines the aging degradation of the RVI components can be identified in a timely manner so that proper corrective action can be taken to restore the integrity of the applicable RVI component. Therefore, the licensee concluded that implementation of the BWRVIP inspection guidelines for the JAFNPPs RVI components would provide an acceptable level of quality and safety. The licensees proposed alternative for the RVI components and subcomponents covered under the scope of this Relief Request is summarized in the Attachment to this SE.

3.6 NRC Staff Evaluation The NRC staff reviewed the information provided by the licensee in its submittal dated February 27, 2007, regarding its proposed alternatives to the ASME Code,Section XI ISI requirements and the technical bases for the licensees proposed alternatives. The NRC staff reviewed the status of each of the referenced BWRVIP guidance documents and the applicability of the information provided in NUREG-0619. The NRC staff found all of the referenced BWRVIP reports (with the exception of the BWRVIP-41, Revision 1 and BWRVIP-138 reports) to be acceptable, with any additional conditions associated with the implementation of the subject BWRVIP reports outlined in the corresponding NRC staff SE for that report. The NRC staff also confirmed the applicability of the information given in NUREG-0619 to supporting the licensees proposed alternative for the feedwater sparger tee welds and the feedwater sparger piping and brackets. The NRC staff did, however, identify some issues which required additional clarification by the licensee or which required the licensee to modify its proposed alternatives. The following paragraphs address the NRC staffs RAIs, the licensees responses, and the NRC staffs evaluation of the RAIs.

To ensure that the attachments in this relief request were properly identified, in the RAI letter dated August 1, 2007, the NRC staff requested that the licensee indicate attachment numbers 2, 3, 4, and 5 on relevant pages of the relief request. In a letter dated August 20, 2007, consistent with the NRC staffs request, the licensee revised the relevant pages. The NRC staff accepts the licensees revised version and, therefore, considers its concern resolved.

In RAI letter dated August 1, 2007, the NRC staff stated that Section 4.1, item 5 of the BWRVIP-100-A Report, Updated Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds, dated August 2006, indicates that fracture toughness values of stainless steel materials that are exposed to neutron fluence levels greater than 1 X 1021 n/cm2 (E > 1 MeV) are lower than those used in Appendix C of the BWRVIP-76 Report. The NRC staff requested that the applicant confirm that the planned inspections of the JAFNPP core shroud and/or core shroud repair hardware for the units fourth ISI interval are consistent with both BWRVIP-76 and BWRVIP-100-A reports. In a letter dated August 20, 2007, the licensee stated that for core shroud and core shroud repair hardware it will comply with the requirements specified in the BWRVIP-76 and BWRVIP-100-A reports. The NRC staff finds this response acceptable and, therefore, considers its concern resolved.

In Attachment 5 of the licensees response dated August 20, 2007, the licensee indicated that the core plate hold-down bolts will be inspected in accordance with the requirements specified in the ASME Code,Section XI ISI program during the fourth 10-year ISI interval. In the NRC staffs SE (ADAMS Accession Number ML072110136, dated July 31, 2007) for the JAFNPP license renewal application (LRA), the NRC staff accepted a licensee commitment (LRA Commitment #

23) in which it stated that one of the following options will be implemented 2 years prior to the license renewal period:

Option # 1 - Install core plate wedges Option # 2 - Complete plant-specific analysis per the BWRVIP-25 report to ensure maintenance of structural integrity of the core plate and provide inspection plan for the core plate hold-down bolts Based on the aforementioned commitment, the NRC staff determined that during the fourth 10-year ISI interval, the licensee will be implementing the ASME Code,Section XI ISI requirements up until 2 years prior to the license renewal period. At that time, the licensee will be using the inspection guidelines specified in the BWRVIP-25 report in lieu of the ASME Code,Section XI ISI requirements. In a conference call on October 2, 2007, the NRC staff discussed this issue with the licensee, and in its letter dated December 4, 2007, stated that it plans to perform VT-3 inspections of approximately 25 percent of the core plate hold-down bolts prior to implementing its LRA Commitment 23. The NRC staff finds this response acceptable because these inspections will provide information regarding the condition of the core plate hold-down bolts.

Additionally, implementation of LRA Commitment 23 during the fourth 10-year ISI interval will provide reasonable assurance that the radiation induced stress relaxation of the core plate hold-down bolts is adequately monitored during the fourth 10-year ISI interval and beyond.

Consistent with the determination that was made in the NRC staffs SEs which approved each of the cited BWRVIP reports (with the exception of the BWRVIP-41, Revision 1 and BWRVIP-138 reports), the BWRVIP inspection requirements (as supplemented by the NUREG-0619

requirements) incorporated into the licensees proposed alternative will identify aging degradation of the RVI components in a timely manner. Therefore, the NRC staff has concluded that the implementation of the inspection requirements specified in the licensees proposed alternative will ensure that the integrity of the RVI components will be maintained with an acceptable level of quality and safety.

By letter dated July 18, 2007, the EPRI BWRVIP withdrew the BWRVIP-41, Revision 1 and BWRVIP-138 reports from the NRC review process. Therefore, the licensees proposed alternative inspection requirements which rely on the technical bases established by the BWRVIP-41, Revision 1 and BWRVIP-138 are not authorized for the fourth ten-year interval.

The licensee shall follow the applicable ASME Code,Section XI requirements.

The NRC staff, however, notes that a subsequent relief request will be required if the licensee decides to take exceptions to, or deviations from, the NRC staff-approved BWRVIP inspection guidelines (specifically, those inspection requirements listed in the Attachment to this SE) or the ASME Code,Section XI ISI requirements in the future.

Therefore, based on the information in the licensees submittals dated February 27, 2007, August 20, 2007, and December 4, 2007, the NRC staff has confirmed that the licensees proposed alternatives (as documented in the Attachment to this SE) are consistent with the technical bases documented in NUREG-0619 and the BWRVIP Reports cited in Section 3.0 of this SE.

4.0 CONCLUSION

Based on the information provided in the licensee's submittal, the NRC staff concludes that the alternatives proposed in Request for Relief RR-6 (except for the proposed alternatives that rely on the technical bases established by the BWRVIP-41, Revision 1 and BWRVIP-138), and as summarized in the Attachment to this SE, will ensure that the integrity of the RVI components is maintained with an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the licensees proposed alternatives (except for the proposed alternatives that rely on the technical bases established by the BWRVIP-41, Revision 1 and BWRVIP-138), are authorized for the fourth 10-year inspection interval. All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector. Any components that are not included in this relief request will continue to be inspected in accordance with the ASME Code,Section XI requirements.

Attachment:

Tables Principal Contributor: G. Cheruvenki Date: February 28, 2008

James A. FitzPatrick Comparison of ASME Category B-N-1 and B-N-2 Requirements With BWRVIP Guidance Requirements (1)

ASME Item No. Component ASME Exam ASME ASME Applicable BWRVIP BWRVI BWRVIP Frequency Table IWB-2500-1 Scope Exam Frequency BWRVIP Exam P Exam Document Scope B13.10 Reactor Vessel Interior Accessible VT-3 Each BWRVIP-18-A, 25, In accordance with applicable BWRVIP (Note 2) Areas period 26-A, 27-A, 38, document.

(Non- 47-A, 48-A, and 76.

specific)

B13.20 Interior Attachments Within Accessible VT-1 Each 10- BWRVIP-48-A Riser Brace EVT-1 100% in first 12 years Beltline - Jet Pump Riser Welds year Table 3-2 Attachment (with 50% to be Braces Interval inspected in the first 6 years); 25% during each subsequent 6 years Lower Surveillance BWRVIP-48-A Bracket VT-1 Each 10-year Interval Specimen Holder Brackets Table 3-2 Attachment Attachment

ASME Item No. Component ASME Exam ASME ASME Applicable BWRVIP BWRVIP BWRVIP Frequency Table IWB-2500-1 Scope Exam Frequency BWRVIP Exam Exam Document Scope B13.30 Interior Attachments Beyond Accessible VT-3 Each 10- BWRVIP-48-A Bracket VT-3 Each 10-year Interval Beltline - Steam Dryer Hold- Welds year Table 3-2 Attachment down Brackets Interval Guide Rod Brackets BWRVIP-48-A Bracket VT-3 Each 10-year Interval Table 3-2 Attachment Steam Dryer Support BWRVIP-48-A Bracket EVT-1 Each 10-year Interval Brackets Table 3-2 Attachment Feedwater Sparger Brackets BWRVIP-48-A Bracket EVT-1 Each 10-year Interval Table 3-2 Attachment Core Spray Piping Brackets BWRVIP-48-A Bracket EVT-1 Every 4 Refueling Table 3-2 Attachment Cycles Upper and Middle BWRVIP-48-A Bracket VT-3 Each 10-year Interval Surveillance Specimen Table 3-2 Attachment Holder Brackets Shroud Support (Weld H9) BWRVIP-38 Weld H9 EVT-1 or Maximum of 6 years 3.1.3.2, Figure UT for one sided EVT-1, 3-5 Maximum of 10 years for UT Weld H12 Not Applicable Not Not Not Applicable Applicable Applicable

ASME Item No. Component ASME Exam ASME ASME Applicable BWRVIP BWRVIP BWRVIP Frequency Table IWB-2500-1 Scope Exam Frequency BWRVIP Exam Scope Exam Document B13.40 Integrally Welded Core Accessible VT-3 Each 10- BWRVIP-38 Weld H9 EVT-1 or Maximum 6 years for Support Structure - Shroud Surfaces year 3.1.3.2, 3.2.1, and Gusset UT one-sided EVT-1, 10 Support Interval Figures 3-5 and Attachments years for UT 3-6 Shroud BWRVIP-76 Vertical and EVT-1 or Maximum 10 years Figures 3-3 and Top Guide UT (per designer 3-4 Ring recommendations)

Segment Welds BWRVIP-76 Tie-rod VT-3 All 10 tie rods within 3.5 and 3.6 Repair and 10 years EVT-1 Note (1) This Table provides only an overview of the requirements. For more details, refer to the ASME Code,Section XI, Table IWB-2500-1, and the appropriate BWRVIP document.

Note (2) Per New York Port Authority (NYPA) letter to NRC (JPN-97-013), Core Spray Internals Inspection, dated March 24, 1997, JAFNPP informed the NRC of a new commitment to perform Core Spray System piping and spargers inspections inside the RPV in accordance with the BWRVIP-18 guidelines.