BVY 06-058, 2006/07/06-Vermont Yankee - License Renewal Application, Amendment 3

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2006/07/06-Vermont Yankee - License Renewal Application, Amendment 3
ML061920284
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 07/06/2006
From: Ted Sullivan
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
%dam200611, BVY 06-058, TAC MC8634
Download: ML061920284 (9)


Text

Entergy Nuclear Operations, Inc.Vermont Yankee P.O. Box 0500 E-=0,r 185 Old Ferry Road En te gy Brattleboro, VT 05302-0500 Tel 802 257 5271 July 6, 2006 Docket No. 50-271 BVY 06-058 TAC No. MC 8634 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

1. Letter, Entergy to USNRC, "Vermont Yankee Nuclear Power Station, License No.DPR-28, License Renewal Application," BVY 06-009, dated January 25, 2006.

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)License Renewal Application.

Amendment 3 On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the License Renewal Application for the Vermont Yankee Nuclear Power Station (VYNPS) as indicated by Reference

1. Attachment 1 transmits the VYNPS License Renewal Commitments List, Revision 0, that would go into effect upon NRC approval of the License Renewal Application.

Should you have any questions concerning this letter, please contact Mr. James DeVincentis at (802)258-4236.I declare under penalty of perjury that the foregoing is true and correct. Executed on July 6, 2006.Ted A. Sullivan Site Vice President Vermont Yankee Nuclear Power Station Attachment 1 cc: See next page.

BVY 06-058 Docket No. 50-271 Page 2 of 2 cc: Mr. James Dyer, Director U.S. Nuclear Regulatory Commission Office 05E7 Washington, DC 20555-00001 Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Jack Strosnider, Director U.S. Nuclear Regulatory Commission Office T8A23 Washington, DC 20555-00001 Mr. Johnny Eads, Senior Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike MS-O-1 1 F1 Rockville, MD 20853 Mr. James J. Shea, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G9A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 (for mail delivery)Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street -Drawer 20 Montpelier, Vermont 05620-2601 BVY 06-058 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station License Renewal Application

-Amendment 3 License Renewal Commitment List -Revision 0 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 During the development and review of the Vermont Yankee Nuclear Power Station License Renewal Application, Entergy made commitments to provide aging management programs to manage the effects of aging on structures and components during the extended period of operation.

The following table lists these license renewal commitments, along with the implementation schedule and the source of the commitment.

ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 1 Guidance for performing examinations of buried piping will be enhanced to March 21, 2012 BVY 06-009 B.1 .1/Audit specify that coating degradation and corrosion are attributes to be Items 5 & 130 evaluated.

2 Fifteen (15) percent of the top guide locations will be inspected using As stated in the BVY 06-009 B.1.7/Audit enhanced visual inspection technique, EVT-1, within the first 18 years of commitment Item 14 the period of extended operation, with at least one-third of the inspections to be completed within the first 6 years and at least two-thirds within the first 12 years of the period of extended operation.

Locations selected for examination will be areas that have exceeded the neutron fluence threshold.

3 The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonic March 21, 2012 BVY 06-009 B.1.9 thickness measurement of the fuel oil storage tank bottom surface will be performed every 10 years during tank cleaning and inspection.

4 The Diesel Fuel Monitoring Program will be enhan6ed to specify UT March 21, 2012 BVY 06-009 B.1.9 measurements of the fuel oil storage tank bottom surface will have acceptance criterion

> 60% Tnom.5 The Fatigue Monitoring Program will be modified to require periodic update March 21, 2012 BVY 06-009 B.1.11 of cumulative fatigue usage factors (CUFs), or to require update of CUFs if the number of accumulated cycles approaches the number assumed in the design calculation.

6 A computerized monitoring program (e.g., FatiguePro) will be used to March 21, 2012 BVY 06-009 B.1.11 directly determine cumulative fatigue usage factors (CUFs) for locations of interest.7 The allowable number of effective transients will be established for March 21, 2012 BVY 06-009 B.1.11 monitored transients.

This will allow quantitative projection of future margin.Attachment 1 Page I of 6 BVY 06-058 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 8 Procedures will be enhanced to specify that fire damper frames in fire March 21, 2012 BVY 06-009 B.1.12.1/Audit barriers will be inspected for corrosion.

Acceptance criteria will be Items 35,151, enhanced to verify no significant corrosion.

152 & 153 9 Procedures will be enhanced to state that the diesel engine sub-systems March 21, 2012 BVY 06-009 B.1.12.1/Audit (including the fuel supply line) will be observed while the pump is running. Items 33, 150 Acceptance criteria will be enhanced to verify that the diesel engine did not & 155 exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.10 Fire Water System Program procedures will be enhanced to specify that in March 21, 2012 BVY 06-009 B.1.12.2 accordance with NFPA 25 (2002 edition), Section 5.3.1.1.1, when sprinklers have been in place for 50 years a representative sample of sprinkler heads will be submitted to a recognized testing laboratory for field service testing.This sampling will be repeated every 10 years.11 The Fire Water System Program will be enhanced to specify that wall March 21, 2012 BVY 06-009 B.1.12.2/Audit thickness evaluations of fire protection piping will be performed on system Items 37 & 41 components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These inspections will be performed before the end of the current operating term and during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.12 Implement the Heat Exchanger Monitoring Program as described in LRA March 21, 2012 BVY 06-009 B.1.14 Section B.1.14.13 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as March 21, 2012 BVY 06-009 B.1.17 described in LRA Section B.1.17.14 Implement the Non-EQ Instrumentation Circuits Test Review Program as March 21, 2012 BVY 06-009 B.1.18 described in LRA Section B.1.18.15 Implement the Non-EQ Insulated Cables and Connections Program as March 21, 2012 BVY 06-009 B.1.19 described in LRA Section B.1.19. 1 1 1 _1 Attachment 1 Page 2 of 6 BVY 06-058 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 16 Implement the One-Time Inspection Program as described in LRA Section March 21, 2012 BVY 06-009 B.1.21/Audit B.1.21. Include destructive or non-destructive examination of one (1) Item 330 socket welded connection using techniques proven by past industry experience to be effective for the identification of cracking in small bore socket welds. Should an inspection opportunity not occur (e.g., socket weld failure or socket weld replacement), a susceptible small-bore socket weld will be examined either destructively or non-destructively prior to entering the period of extended operation.

17 Enhance the Periodic Surveillance and Preventive Maintenance Program March 21, 2012 BVY 06-009 B.1.22 as necessary to assure that the effects of aging will be managed as described in LRA Section B.1.22.18 Enhance the Reactor Vessel Surveillance Program to proceduralize the March 21, 2012 BVY 06-009 B.1.24 data analysis, acceptance criteria, and corrective actions described in the program description in LRA Section B.1.24.19 Implement the Selective Leaching Program as described in LRA Section March 21, 2012 BVY 06-009 B.1.25 I B.1.19. I I 20 Enhance the Structures Monitoring Program to specify that process facility crane rails and girders, condensate storage tank (CST) enclosure, CO 2 tank enclosure, N 2 tank enclosure and restraining wall, CST pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man-way seals and gaskets, and hatch seals and gaskets are included in the proaram.March 21, 2012 BVY 06-009 B.1.27.2 21 Guidance for performing structural examinations of wood to identify loss of material, cracking, and change in material properties will be added to the Structures Monitoring Program. _22 Guidance for performing structural examinations of elastomers (seals and gaskets) to identify cracking and change in material properties (cracking when manually flexed) will be enhanced in the Structures Monitoring Program procedure.

Attachment 1 Page 3 of 6 BVY 06-058 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 23 Guidance for performing structural examinations of PVC cooling tower fill to March 21, 2012 BVY 06-009 B.1.27.2 identify cracking and change in material properties will be added to the Structures Monitoring Program procedure.

24 System walkdown guidance documents will be enhanced to perform March 21, 2012 BVY 06-009 B.1.28/Audit periodic system engineer inspections of systems in scope and subject to Items 187, 188 aging management review for license renewal in accordance with 10 CFR & 190 54.4 (a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject system will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(2).25 Implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast March 21, 2012 BVY 06-009 B.1.29 Austenitic Stainless Steel (CASS) Program as described in LRA Section B.1.29.26 Procedures will be enhanced to flush the John Deere Diesel Generator March 21, 2012 BVY 06-009 B.1.30.1/Audit cooling water system and replace the coolant and coolant conditioner every Items 84 & 164 three years. I _I Attachment 1 Page 4 of 6 BVY 06-058 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 27 For each location that may exceed a CUF of 1.0 when considering March 21, 2012 BVY-06-058 4.3.3/ Audit environmental effects, VYNPS will implement one or more of the following:

Items 29, 107 (1) further refinement of the fatigue analyses to lower the predicted CUFs to March 21,2010 for & 318 less than 1.0; performing a fatigue (2) management of fatigue at the affected locations by an inspection analysis that program that has been reviewed and approved by the NRC (e.g., periodic addresses the effects non-destructive examination of the affected locations at inspection intervals of reactor coolant to be determined by a method acceptable to the NRC); environment on (3) repair or replacement of the affected locations, fatigue (in accordance with an NRC Should VYNPS select the option to manage environmental-assisted fatigue approved version of during the period of extended operation, details of the aging management the ASME Code)program such as scope, qualification, method, and frequency will be provided to the NRC prior to the period of extended operation.

28 Revise program procedures to indicate that the Instrument Air Program will March 21, 2012 BVY 06-009 B.1.16/Audit maintain instrument air quality in accordance with ISA S7.3 Item 47 29 VYNPS will either install core plate wedges or complete a plant-specific March 21, 2012 BVY 06-009 B.1.7/ Audit analysis to determine acceptance criteria for continued inspection of core Item 9 plate hold down bolting in accordance with BWRVIP-25.

30 Revise System Walkdown Program to specify C02 system inspections March 21, 2012 BVY 06-009 B.1.28/ Audit every 6 months. Items 30,141, 146 & 298 31 Revise Fire Water System Program to specify annual fire hydrant gasket March 21, 2012 BVY 06-009 B.1.12.2/

Audit inspections and flow tests. Items 39 & 40 32 Implement the Metal Enclosed Bus Program. March 21,2012 BVY 06-058 Audit Item 97 (Details to be provided in a LRA Amendment) 33 Enhance the Structures Monitoring Program to ensure an engineering March 21, 2012 BVY 06-009 B.1.27/ Audit evaluation is made on a periodic basis of groundwater samples to assess Item 77 aggressiveness of groundwater to concrete.

I Attachment 1 Page 5 of 6 BVY 06-058 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 34 Implement the Bolting Integrity Program. March 21, 2012 BVY 06-058 Audit Items (Details to be provided in a LRA Amendment) 198, 216, 218, 237, 331 & 333 35 Enhance the System Walkdown Training Program as appropriate to March 21,2012 BVY 06-058 Audit Item document biennial refresher training of Engineers to demonstrate inclusion 384 of the methodology for aging management of plant equipment as described in EPRI Aging Assessment Field Guide or comparable instructional guide.36 If technology to inspect the hidden jet pump thermal sleeve and core spray March 21, 2010 BVY-06-058 Audit Item 12 thermal sleeve welds has not been developed and approved by the NRC at least two years prior to the period of extended operation, VYNPS will initiate plant-specific action to resolve this issue. That plant specific action may be justification that the welds do not require inspection.

Attachment 1 Page 6 of 6 BVY 06-058