BVY 08-008, Vermont Yankee July 2008 Evidentiary Hearing - Applicant Exhibit E2-09-VY, VY LRA Amendment 35

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Vermont Yankee July 2008 Evidentiary Hearing - Applicant Exhibit E2-09-VY, VY LRA Amendment 35
ML082490419
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 02/05/2008
From: Ted Sullivan
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
SECY RAS
References
06-849-03-LR, 50-271-LR, BVY 08-008, Entergy-Applicant-E2-09-VY, RAS M-272
Download: ML082490419 (21)
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Text

V C'I k-Es te--gy DOCKETED USNRC Entergy Nuclear Operations, Inc.

August 12, 2008 (11:00am) mbEntergy OFFICE OF SECRETARY RULEMAKINGS AND Vermont Yankee P.O Box 0250 320 Governor Hunt Road Vernon, VT 05354 ADJUDICATIONS STAFF Tel 802 257 7711

  • February 5, 2008 BVY 08-008 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

References:

1) Letter, Entergy to USNRC, "Vermont Yankee Nuclear Power Station, License No. DPR-28, License Renewal Application," BVY 06-009, dated January 25, 2006
2) Letter, Entergy to USNRC, "Update of Aging Management Program Audit Q&A Database," BVY 07-079, dated November 14, 2007
3) Letter, USNRC to Entergy, "Update on Extension of Schedule for the Conduct of Review of the Vermont Yankee Nuclear Power Station License Renewal Application," NVY 07-157, dated November 27, 2007
4) Letter, Entergy to USNRC, "License Renewal Apllication, Amendment 33," BVY 07-082, dated December 11, 2007
5) Letter, Entergy to USNRC, "License Renewal Application, Amendment 34," BVY 08-002, dated January 30, 2008

Subject:

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

License Renewal Application. Amendment 35 On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted Reference (1), the License Renewal Application (LRA) for the Vermont Yankee Nuclear Power Station (VYNPS).

VYNPS submitted Reference (2) following an NRC audit of the VYNPS Aging Management Program and subsequently received Reference (3), which included an NRC Request for Additional Information. References (4) and (5), respectively, provided the initial response to Reference (3) and later clarifications to that response. Additional clarification and details regarding recirculation nozzle Cumulative Usage Factor (CUF) and water chemistry effects are provided in Attachments 1 and 2 to this letter. VYNPS information meeting the NRC's position on Extended Power Uprate (EPU) operating experience evaluation for Aging Management Programs is also discussed below.

VYNPS had not yet entered operation at EPU levels at the time Reference (1) was submitted. EPU power ascension began in March of 2006. To ensure that operating experience at EPU levels is properly, addressed by aging management programs, Entergy Will perform an evaluation of operating experience at EPU levels, prior to, the period of extended operation. In addition to VYNPS operating experience, -the evaluation will include operating experience from other BWR plants operating at EPU levels.

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U.S. NUCLEAR REGULATORY COMMISON WWooasP40&JZi I Official Exhibit N________

O$TERED by-7 pica-nt(Ltcen- Intervenor_______

NRC staff Other______

QEWRjm-1&y-%ijqyWdnmsjPaneg d13zC 1-Acdot~aenREJECTED WITHDRWN

BVY 08-008 Docket No. 50-271 Page 2 of 3 This is a new commitment, and has been entered as Commitment #51 on the VYNPS License Renewal Commitment List, Revision 9 (Attachment 3).

Should you have any questions concerning this submittal, please contact Mr. David Mannai at (802) 451-3304.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 5, 2008.

Sincerely,.

5 ice resident Vermont Yankee Nuclear Power Station : Additional Information Regarding Recirculation Nozzle CUF : Additional Information Regarding Water Chemistry Effects : License Renewal Commitment List, Revision 9 cc: Mr. James Dyer, Director U.S. Nuclear Regulatory Commission Office 05E7 Washington, DC 20555-00001 Mr. Samuel J. Collins, Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 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. Jonathan Rowley, Senior Project Manager U:S. Nuclear Regulatory Commission 11555 Rockville Pike MS-O-11 F1 Rockville, MD 20853

BVY 08-008 Docket No. 50-271

]Page 3 of 3 Mr. Mike Modes USNRC RI 475 Allendale Road King of Prussia, PA 19406 Mr. James S. Kim, Project Manager U.S. Nuclear Regulatory Commission Mail Stop O-8-C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601 Diane Curran, Esq.

Harmon, Curran, Spielberg & .Eisenberg, LLP 1726 M Street, N.W., Suite 600 Washington, DC 20036

BVY 08-008 Attachment 1 Vermont Yankee Nuclear Power Station License No. DPR-28 (D6cket No. 50-271)

License Renewal Application Amendment 35 Additional Information Regarding Recirculation Nozzle CUF

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT 35 ATTACHMENT 1 Additional Information Regarding Recirculation Nozzle CUF NRC Request:

Demonstrate why the confirmatory analysis for the feedwater nozzle bounds the geometry of the recirculation outlet nozzle.

Response

The feedwater nozzle was chosen for the, confirmatory analysis since it has the largest number of, and most severe, transients and the highest calculated fatigue usage of the three nozzles which used the VY fatigue analysis approach. The analysis of the feedwater nozzle is bounding for the recirculation outlet nozzle since the calculated usage factors and thermal transient stresses are significantly less than those for the feedwater nozzle.

As pointed out during the January 8, 2008 presentation to the NRC Staff, the recirculation outlet nozzle has a different geometry (i.e., "skewed") as compared to the other nozzles.

However, the feedwater nozzle configuration remains conservative and bounding when following reasons:

compared to the recirculation outlet nozzle configuration for the

" The previous comparisons of nozzle corner stress factors from BWRVIP-108, which included evaluation of a recirculation outlet nozzle, demonstrate that the recirculation outlet nozzle configuration does not provide results that-are significantly different from the other nozzle configurations.

" The transients experienced by the recirculation outlet nozzle are significantly less severe and less numerous than the transients that affect the feedwater nozzle.

" The most significant thermal transient (improper start causing reverse flow)was modeled directly in the Finite Element Model due to its unique characteristics.

  • Inthe nozzle corner, the thermal stresses are small compared to the pressure stresses.

" The previous analyses for all three nozzles for VY yielded significantly lower fatigue usage for the recirculation outlet nozzle compared to the feedwater nozzle.

" Industry experience for the BWR fleet has repeatedly demonstrated that the recirculation outlet nozzle fatigue usage is significantly lower than feedwater nozzle fatigue usage.

BVY 08-008 Docket No. 50-271 Attachment I Page 1 of'I

BVY 08-008 Attachment 2.

Vermbnt Yankee Nuclear Power Station LicenseNo. DPR-28 (Docket No. 50-271)

License Renewal Application Amendment 35, Additional Information Regarding Water Chemistry Effects

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT 35 ATTACHMENT 2 Additional Information Regarding Water Chemistry Effects NRC Request:

Describe how water chemistry effects were accounted for in the evaluation of environmentally assisted fatigue.

Response

Per Section X.M1 of NUREG 1801 (GALL Report) the environmentally assisted fatigue (EAF) evaluations used appropriate Fatigue Life Correction Factors (Fen) calculated using the methodology in NUREG/CR-6583 for carbon and low alloy steels and NUREG/CR-5704 for stainless steels.

For carbon and low alloy steels the Fen factor relationships are shown on page 69 of NUREG/CR-6583. As shown on page 60 of NUREG/CR-6583, the input values used to develop the Fen factors are sulfur content, strain rate, temperature, and dissolved oxygen content in the fluid. Input values for these parameters were chosen to maximize the Fen factors calculated for all components.

The Fen factor relationship for stainless steels is shown on page 31 of NUREG/CR-5704.

As shown on page 25 of NUREG/CR-5704, the input values used to develop the Fen factors are strain rate, temperature, and dissolved oxygen content in the fluid. Similar to the carbon and low alloy steel calculations, the input values were chosen to maximize the Fen factors.

The inputs were selected as follows:

  • For the carbon and low alloy steel expressions, the transformed sulfur content parameter was set equal to the maximum value of 0.015 to maximize the effects of this parameter.
  • For all expressions, the transformed strain rate parameter was set equal to the minimum strain rate (i.e., less than 0.001%/o/sec) for all transients to maximize the effects of this parameter.

For all expressions, the transformed temperature parameter was computed using 550°F for all locations. This temperature envelopes normal operating temperatures to maximize the effects of this parameter, and is very conservative for feedwater temperature.

° For the transformed dissolved oxygen parameter, dissolved oxygen (DO) data was taken from recorded plant data for the feedwater line. For all other locations evaluated in the reactor coolant system, the EPRI BWRVIA code was used to determine DO levels. The EPRI BWRVIA model was used to determine DO at component locations at original licensed power (OLP) for both BWR normal water chemistry (NWC) and noble metal water chemistry (NMCA+HWC). Also, current licensed power with NMCA+HWC was evaluated.

BVY 08-008 Docket No. 50-271 Attachment 2 Page 1 of 2

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT 35 ATTACHMENT 2 For the purposes of ensuring that the DO effects on Fen are conservative and bounding with respect to water chemistry, the Fan values used accounted for variations in plant recorded feedwater DO data. It is noted that excursions observed in the plant data used are small in number and are of short duration. Approximately 13 years of recorded feedwater DO measurements, including excursions, were evaluated for input to the EAF analysis. A DO value (50 ppb) was used to calculate bounding Fan value for the feedwater piping. This represents the mean of the measured data plus one standard deviation.

For locations in the reactor coolant system, the BWRVIA model was run varying the DO content for the power/water chemistry conditions discussed above. The results of these sensitivity studies showed that the resulting variations in DO at component locations are significantly less than the changes input to the feedwater DO. The variation of feedwater DO (mean plus one standard deviation) was evaluated: This resulted in less than a 2%

change in the bounding Fen used in the EAF analysis for the low alloy steel components in the beltline and lower sections of the reactor vessel. There is no effect on the bounding Fn values from the input feedwater DO variations for the stainless steel components.

The Fn factors are determined using several parameters and, collectively, these parameters were chosen to conservatively maximize their contribution. The Fan factors are bounding for each location based on all of the input values. The bounding Fan factors for each location and material were used for all stress range pairs in the cumulative usage factor calculations.

BVY 08-008 Docket No. 50-271 Attachment 2 Page 2 of 2

BVY 08-008 Attachment 3 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271).

License Renewal Application Amendment 35 License Renewal Commitment List Revision 9

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 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 No./

Comments 1 Guidance.for performing examinations. of buried piping will be enhanced to March 21, 2012 BVY 06-009 B.1.1 specify that coating degradation and corrosion are attributes to be Audit Items 5 &

evaluated. 130 130 2 Fifteen (15) percent of the top guide locations will be inspected using As stated in the BVY 06-009 B.1.7 enhanced visual inspection technique, EVT-1, within the first 18 years of commitment Audit 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 and thickness measurement of the fuel oil storage and fire pump diesel storage BVY 07-018 regional (day) tank bottom surfaces will be performed every 10 years during tank inspection cleaning and inspection.

4 The Diesel Fuel Monitoring Program will be enhanced to specify UT March 21, 2012 BVY 06-009 B.1.9 and measurements of the fuel oil storage and fire pump diesel storage (day) BVY 07-018 regional tank bottom surfaces will have acceptance criterion a 60% Tnom. inspection Page I of 11 BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 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.

8 Procedures will be enhanced to specify that fire damper frames in fire March 21, 2012 BVY 06-009 B.1.12.1 barriers will be inspected for corrosion. Acceptance criteria will be Audit Items 35, enhanced to verify no significant corrosion. 151,152,153 and 159 9 Procedures will be enhanced to state that the diesel engine sub-systems March 21, 2012 BVY 06-009 B.1.12.1 (including the fuel supply line) will be observed while the pump is running. - Audit Items 33, Acceptance criteria will be enhanced to verify that the diesel engine did not 150 & 155 exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.

Page 2 of 11 BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section No./

Comments 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 thickness evaluations of fire protection piping will be performed on system Audit Items 37 &

components using non-intrusive techniques (e.g., volumetric testing) to 41 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.

Page 3 of 11 BVY 08-008 Attachment. 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE ,Comments 16 Implement the One-Time Inspection Program as described in LRA Section March 21, 2012 BVY 06-009 B.1.21 B.1.21,. BVY 07-009 Audit Items 239, 240, 330, 331 17 Enhance the Periodic Surveillance and Preventive Maintenance Program to March 21, 2012 BVY 06-009 B.1.22 assure that the effects of aging will be managed as described in LRA -Audit Item 377 Section B.1.22. A 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 B.1.25.

20 Enhance the Structures Monitoring Program to specify that process facility March 21, 2012 BVY 06-009 B.1.27.2 crane rails and girders, condensate storage tank (CST) enclosure, CO 2 Audit Item 377 tank enclosure, N2 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 program.

21 Guidance for performing structural examinations of wood to identify loss of March 21, 2012 BVY 06-009 B.1.27.2 materia!, cracking, and change in material properties will be added to the Structures Monitoring Program.

Page 4 of 11 BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

~Comments SCHEDULE Cmet 22 Guidance for performing structural examinations of elastomers (seals and March 21, 2012 BVY 06-009 B.1.27.2 gaskets) to identify cracking and change in material properties (cracking when manually flexed) will be enhanced-in the Structures Monitoring Program procedure.

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 periodic system engineer inspections of systems in scope and subject to Audit Items 187, aging management review for license renewal in accordance with 10 CFR 188 & 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 cooling water system and replace the coolant and coolant conditioner every Audit Items 84 &

three years. 164 Page 5 of 11 BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE Comments At least 2 years prior to entering the period of extended operation, for the 27 March 21, 2012 BVY-06-058 4.3.

locations identified in NUREG/CR-6260 for BWRs of the VY vintage, VY will refine our current fatigue analyses to include the effects of reactor water Audit Items 29, environment and verify that the cumulative usage factors (CUFs) are less 107 & 318 March 21, 2010 for than 1. This includes applying the appropriate Fen factors to valid CUFs performing a fatigue determined in accordance with one of the following: analysis that

1. For locations, including NUREG/CR-6260 locations, with existing addresses the effects fatigue analysis valid for the period of extended operation, use the of reactor coolant existing CUF to determine the environmentally adjusted CUF. environment on
2. More limiting VY-specific locations with a valid CUF may be added in fatigue (in accordance addition to-the NUREG/CR-6260 locations. with an NRC
3. Representative CUF values from other plants, adjusted to or approved version of enveloping the VY plant specific external loads may be used if the ASME Code) demonstrated applicable to VY.
4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.

During the period of extended operation, VY may also use one of the following options for fatigue management ifongoing monitoring indicates a potential for a condition outside the analysis bounds noted above:

1) Update and/or refine the affected analyses described above.
2) Implement an inspection program that has been reviewed and approved by the NRC (e.g.,-periodic nondestructive examination of the affected locations at inspection intervals to be determined by a method acceptable to theNRC).
3) Repair or replace the affected locations before exceeding a CUF of 1.0.

Page 6 of 11 BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA S Section NoJ SCHEDULE Comments 28 Revise program procedures to indicate that the Instrument Air Program will March 21, 2012 BVY 06-009 B.1.16 maintain instrument air quality in accordance with ISA S7.3 Audit Item 47 29 VYNPS will perform one of the following: March 21, 2012 BVY 06-009 B.1.7

1. Install core plate wedges, or, Audit Item 9
2. Complete a plant-specific analysis to determine acceptance criteria for continued inspection of core plate hold down bolting in accordance with BWRVIP-25 and submit the inspection plan and analysis to the NRC two years prior to the period of extended operation for NRC review and approval.

30 Revise System Walkdown Program to specify C02 system inspections March 21, 2012 BVY 06-009 B.1.28 every 6 months. Audit 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 inspections and flow tests. Audit Items 39 &

40 32 Implement the Metal Enclosed Bus Program. March 21, 2012 BVY 06-058 Audit Item 97 Details are provided in a LRA Amendment 16, Attachment 3 and LRA BVY 07-003 Amendment 23, 7. BVY 06-091 Page 7 of 11 BVY 08-008 Attachment 1 Docket 50-271

0 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST

. REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section No./

Comments 33 Include within the Structures Monitoring Program provisions that will ensure March 21, 2012 BVY 06-009 B.1.27 an engineering evaluation is made on a periodic basis (at least once every Audit Item 77 five years) of groundwater samples to assess aggressiveness of groundwater to concrete. Samples will be monitored for sulfates, pH and RAI 3.5-7 chlorides.

34 Implement the Bolting Integrity Program. March 21, 2012 BVY 06-058 Audit Items 198, Details are provided in a LRA Amendment 16, Attachment 2 and LRA BVY 07-003 216,218,237, 331 & 333 Amendment 23, Attachment 5.

BVY 06-09 1 35 Provide within the System Walkdown Training Program a process to March 21, 2012 BVY 06-058 Audit Item 384 document biennial refresher training of Engineers to demonstrate inclusion 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 BVY06-058 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.

37 Continue inspections in accordance with the Steam Dryer Monitoring March 21, 2010 BVY 06-079. Audit Item 204 Program, Revision 3 in the event that the BWRVIP-139 is not approved prior to the period of extended operation.

Page 8 of 11 BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section NoJ SCHEDULE Cmet Comments 38 The BWRVIP-1 16 report which was approved by the Staff will be March 21, 2012 BVY 06-088 Response to implemented at VYNPS with the conditions documented in Sections 3 and RAI B.1.24-1 4 of theStaff's final SE dated March 1,2006, for the BWRVIP-116 report.

39 If the VYNPS standby capsule is removed form the reactor vessel without March 21, 2012 BVY 06-088 Response to the intent to test it, the capsule will be stored in a manner which maintains it RAI B.1.24-2 in a condition which would permit its future use, including during the period of extended operation, if necessary.

40 This Commitment has been deleted and replaced with Commitment 43. N/A BVY 07-018 N/A 41 This Commitment has been deleted and replaced with Commitment 43.. N/A BVY 07-018 N/A 42 Implement the Bolted Cable Connections Program. March 21, 2012 BVY 07-003 Response to:

BVY 07-018 RAI 3.6.2.2-Wn01 Details are provided in LRA Amendment 23, attachment 7.

3.6.2.1 A.2.1.39 B. 1.33 Table 3.6.1 Table 3.6.2-1 43 Establish and implement a program that will require testing of the two 13.8 March 21, 2012 BVY 07-009 Am. 24 kV cables from the two Vernon Hydro Station 13.8 kV switchgear buses to BVY 07-018 Response to:

the 13.8 kV / 69 kV step up transformers before the period of extended RAIs operation and at least once every 10 years after the initial test. 3.6.2.2-N-08-2 3.6.2.2-N-08-4 Page 9 of 11.

BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 44 Guidance for performing examinations of buried piping will be revised to March 21, 2012 BVY 07-018 Regional include the following. "A focused inspection will be performed within the inspection first 10 years of the period of extended operation, unless an opportunistic inspection (or an inspection via a method that allows an assessment of pipe condition without excavation) occurs within this ten-year period."

45 Enhance the Service Water Integrity Program to require a periodic visual March 21, 2012 BVY 07-018 Regional inspection of the RHRSW pump motor cooling coil internal surface for loss inspection Of material.

46 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the March 21, 2012 BVY 07-018 Regional fire pump diesel storage (day) tank will be analyzed according to ASTM inspection D975-02 and for particulates per ASTM D2276. Also, fuel oil in the John Deere diesel storage tank will be analyzed for particulates per ASTM D2276.

47 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the; March 21, 2012 BVY 07-018 Regional common portable fuel oil storage tank will be analyzed according to ASTM inspection D975-02, per ASTM D2276 for particulates, and ASTM D1!796 for water and sediment.

.48 Perform an internal inspection of the underground Service Water piping March 21, 2012 BVY 07-018 Regional before entering the period of extended operation. inspection 49 Revise station procedures to specify fire hydrant hose testing, inspection, March 21, 2012 BVY 07-009 Audit Item 38 and replacement, if necessary, in accordance with NFPA code specifications for fire hydrant hoses. _ _ j _ _ _

Page 10 of 11 BVY 08-008 Attachment 1 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 9 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section NoJ SE LComments 50 During the period of extended operation, review the Vernon Dam owner March 21, 2012 BVY 06-009 RAI FERC required report(s) at a minimum of every five years to confirm that BVY 07-047 3.6.2.2.N-08-1 the Vernon Dam owner is performing the required FERC inspections.

Document deficiencies in the Entergy Corrective Actions Program and evaluate operability as described in BVY 96-043 and BVY 97-043 if it is determined that the required inspections are not being performed.

51 Entergy will perform an evaluation of operating experience at extended March 21, 2012 BVY-08-008 N/A power uprate (EPU) levels prior to the period of extended operation to ensure that operating experience at EPU levels is properly addressed by the aging management programs. The evaluation will include Vermont Yankee (VY) and other BWR plants operating at EPU levels.

Page11 of 11 BVY 08-008 Attachment 1 Docket 50-271

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