BVY 11-007, License Renewal Application Supplemental Information

License Renewal Application Supplemental Information

ML110400114
Person / Time
Site:	Vermont Yankee
Issue date:	02/04/2011
From:	Michael Colomb Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 11-007
Download: ML110400114 (10)

Text

Adahk Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd

'4mýEntergy Vernon, VT 05354 Tel 802 257 7711 Michael J. Colomb Site Vice President BVY 11-007 February 4, 2011 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

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

REFERENCES:

1. Letter, Entergy to USNRC, "License Renewal Application," BVY 06-09, dated January 25, 2006

2. Letter, Entergy to USNRC, "License Renewal Application Annual Update," BVY 10-069, dated December 30, 2010

Dear Sir or Madam:

On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the License Renewal Application (LRA) for the Vermont Yankee Nuclear Power Station (VYNPS) as indicated by Reference 1. In Reference 2, Entergy submitted an annual report of changes to the current licensing basis that materially affect the content of the VYNPS LRA, including the Safety Analysis Report supplement as required by 10CFR54.21(b). This report included revisions made to license renewal commitments that apply to the diesel fuel monitoring program. By teleconference on January 21, 2011, the NRC requested that Entergy provide additional clarifying information on the commitment changes and corresponding changes to the applicable sections of the VYNPS LRA. of this letter provides supplemental information to the LRA to provide clarifying information on the diesel fuel monitoring program commitment changes and corresponding changes to section B.1.9, Diesel Fuel Monitoring, of the LRA. Attachment 2 provides a list of license renewal commitments revised in this'letter.

There are no new regulatory commitments being made in this letter.

Should you have any questions or require additional information concerning this submittal, please contact Mr. Robert Wanczyk at 802-451-3166.

RIM

BVY 11-007 / Page 2 of 2 I declare under penalty of perjury, that the foregoing is true and correct. Executed on February 4,2011.

Sincerely,

[MJC/PLC]

Attachments: 1. License Renewal Application Supplemental Information

2. List of License Renewal Commitments cc: Mr. Eric J. Leeds, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 Mr. William M. Dean, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Robert Kuntz, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11 F1 11555 Rockville Pike Rockville, MD 20852-2738 Mr. James S. Kim, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee 320 Governor Hunt Road Vernon, Vermont 05354 Ms. Elizabeth Miller, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 11-007 Attachment 1 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

License Renewal Application Supplemental Information

BVY 11-007 / Attachment 1 / Page 1 of 5 Vermont Yankee Nuclear Power Station License Renewal Application - Supplemental Information By letter dated December 30, 2010, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) provided revised license renewal commitments related to Section B.1.9 of the Vermont Yankee Nuclear Power Station (VYNPS) license renewal application (LRA), Diesel Fuel Monitoring program. By teleconference on January 21, 2011, the NRC requested that Entergy provide additional clarifying information on the commitment changes and corresponding changes to the applicable sections of the VYNPS LRA.

License renewal commitment 4 was revised to state that the acceptance criterion for the fuel oil storage and fire pump diesel storage (day) tank bottom surface ultrasonic measurements will be in accordance with the applicable American Petroleum Institute (API) or Steel Tank Institute (STI) standard. Section B.1.9 of the LRA previously included a reasonable acceptance criterion for both tanks of greater than or equal to 60% of the nominal tank bottom thickness, but this acceptance criterion was not derived from or necessary to meet any specific regulatory requirement or acceptance criterion in the current licensing basis. From the NRC License Renewal Safety Evaluation Report (SER) for VYNPS:

The applicantalso stated, in the LRA, that for the ultrasonicmeasurements of the diesel fuel storage tank bottom thickness an acceptance criteriaof 60 percent of the nominal thickness will be used.

The GALL Report does not provide an acceptance criterion for the bottom surface thickness of the diesel fuel storage tank. The fuel oil tank is not pressurizedso the staff judged the use of 60 percent of the nominal wall thickness provides sufficient margin to be an acceptable criterion for the ultrasonicthickness measurements. The use of this acceptance criterion will provide additionalassurance that the effects of aging will be detected before the loss of intended function.

The API and STI publish standards for above ground steel tank inspections that contain acceptance criteria for tank bottom thickness. The fuel oil storage tank was fabricated in accordance with National Fire Protection Association Standard, NFPA No. 30. Section 22.17 of Chapter 22 of the 2008 Edition of NFPA No. 30 provides guidance for the inspection and maintenance of aboveground storage tanks. Subsection 22.17.2 states that each aboveground steel tank shall be inspected and maintained in accordance with API 653, Tank Inspection, Repair,Alteration, and Reconstruction, or STI SPOO1, Standard for Inspection of Aboveground Storage Tanks. API 653 is applicable to the fuel oil storage tank. The fire pump diesel storage tank was shop-fabricated and falls within the scope of STI SPOO1. Use of the tank bottom thickness acceptance criteria contained within the applicable standards for the fuel oil storage tank (API 653) and the fire pump diesel day tank (STI SP001) will provide adequate assurance that corrective action will be taken before the loss of intended function during the period of extended operation (PEO). For clarification, license renewal commitment 4 is revised to read as follows.

Commitment 4 The Diesel Fuel Monitoring Program will be enhanced to specify that UT measurements of the fuel oil storage tank bottom surface will have acceptance criterion in accordance with American Petroleum Institute standard API 653 and UT measurements of the fire pump diesel storage (day) tank bottom surface will have acceptance criterion in accordance with Steel Tank Institute standard STI SPOO1.

BVY 11-007 / Attachment 1 / Page 2 of 5 License renewal commitments 46 and 47 were revised to allow use of later revisions of fuel oil testing standard ASTM D975-02 for analyzing the fuel oil in the fire pump diesel storage (day) tank (46) and common portable fuel oil storage tank (47). VYNPS Technical Specification (TS) 4.10.C.2 requires that diesel fuel oil be sampled and checked for quality in accordance with the applicable ASTM standard.

In 2007, VYNPS switched from low sulfur fuel oil to ultra low sulfur fuel oil (ULSF) for use in safety-related systems in response to new EPA regulations and NRC Information Notice 2006-

22. ASTM D975-09 Table 1 contains specifications for testing ULSF (Grade No. 2-D S15). By letter dated September 28, 2009, VYNPS provided to the NRC revised bases for TS 4.10.C.2 to reflect that ASTM standard ASTM D975-09 is used for performing viscosity, water and sediment tests. The test results are considered acceptable if they are within the acceptance limits of Table 1 of ASTM D975-09. Additionally, VYNPS Technical Requirements Manual Section 4.13.B.2.b requires that the fire pump diesel fuel oil storage tank be sampled and meet the acceptance limits of Table 1 of ASTM D975-09 with respect to viscosity, water and sediment.

ASTM D975-04 is the most recent revision of the standard referenced in the Generic Aging Lessons Learned Report (GALL) Final Report (NUREG-1801 Revision 2) Aging Management Program (AMP) XI.M30, "Fuel Oil Chemistry." GALL AMP XI.M30 states that "ASTM D975-04 or other appropriate standards may be used to develop fuel oil acceptance criteria."

A comparison of ASTM D975-09, ASTM D975-04 and ASTM D975-02 Table 1 specification requirements shows that all of the requirements contained in the D975-02 and D975-04 editions are contained in the D975-09 edition. The D975-09 edition contains a specific requirement for ULSF not included in the two earlier editions. ASTM D975-09 is therefore an appropriate standard for sampling and analyzing fuel oil during the PEO. The enhancements to analyze fuel oil in the fire pump diesel storage (day) tank, John Deere diesel storage tank and common portable fuel oil storage tank for particulates in accordance with ASTM D2276 remain unchanged. The appropriate standard for testing for water and sediment in ULSF is ASTM D2709, not ASTM D1796. Therefore, analyzing the common portable fuel oil storage tank in accordance with ASTM D1796 is not appropriate. License renewal commitment 47 is revised to specify that the fuel oil in the common portable fuel oil storage tank will be analyzed according to ASTM D2709 for water and sediment. VYNPS is also revising license renewal commitments 46 and 47 as follows to remove reference to a specific revision of ASTM D975.

Commitment 46 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the fire pump diesel storage (day) tank will be analyzed according to ASTM D975 and for particulates per ASTM D2276. Also, fuel oil in the John Deere diesel storage tank will be analyzed for particulates per ASTM D2276.

Commitment 47 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the common portable fuel oil storage tank will be analyzed according to ASTM D975, per ASTM D2276 for particulates, and per ASTM D2709 for water and sediment.

Section B.1.9 of the LRA is revised as follows to specify that the revision in use at VYNPS is ASTM D975-09. New text is underlined. Deleted text is shown as strikethrough.

B.1.9 Diesel Fuel Monitoring

BVY 11-007 / Attachment 1 / Pagle 3 of 5 Program Description The Diesel Fuel Monitoring Program at VYNPS is comparable to the program described in NUREG-1801,Section XI.M30, Fuel Oil Chemistry Program.

The program entails sampling to ensure that adequate diesel fuel quality is maintained to prevent corrosion of fuel systems. Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by periodic draining and cleaning of selected tanks and by verifying the quality of new oil before its introduction into storage tanks.

Sampling and analysis activities are in accordance with technical specifications on fuel oil purity and the guidelines of ASTM standards D4057-88 and D975-092,Q, %-.,' F Exceptions to NUREG-1801 The Diesel Fuel Monitoring Program at VYNPS is consistent with the program described in NUREG-1 801,Section XI.M30, Fuel Oil Chemistry Program, with the following exceptions.

Attributes Affected Exceptions 1 .Scope of Program The guidelines of ASTM Standard 6.Acceptance Criteria D6217 are not used along with those of D2276 for determination of particulates.1 ,

2.Preventive Actions No additives are used beyond what the refiner adds during production.2 3.Parameters Monitored / Inspected Only ASTM Standard Q-1-769D2709 6.Acceptance Criteria is used for determination of water and sediment, rather than Standards D1796 and D2709.3 3.Parameters Monitored / Inspected Determination of particulates may be 6.Acceptance Criteria according to ASTM Standard D2276, rather than modified ASTM D2276 Method A.4 Exception Notes: f A*m m * ..... I

• g

1. XIVNP'C rnrnnicil sneoIintinne~ 5'n-'nrn Use ef ACT' r)I '- 01 Whii rrrnmmnnr e"nic Use-(of iCR M00 The D2276 acceotance criterion is more strinaent than that of D6217. Therefore. ASTM D6217 is not necessary for determination of particulates.

2. VYNPS does not add biocides, stabilizers, or corrosion inhibitors to the diesel fuel. Plant-specific operating experience has not indicated significant problems related to MIC. Since water contamination in the diesel fuel storage tanks is minimized, the potential for MIC is limited.

3. NUREG-1801 states that ASTM Standards D1796 and D2709 are used for determination of water and sediment. However, these standards describe the determination of water and sediment for oils with different viscosities. Eithor standard ic appkicable to the 42 dicsel fo-el Ail used at VYNPS. VINPS ASTM Standard D2709 is the appropriate standard for determination of water and sediment in the VYNPS fuel oil.

4. Determination of particulates may be according to ASTM Standard D2276 which conducts particulate analysis using a 0.8 micron filter, rather than the 3.0 micron filter specified in NUREG-1 801. Use of a filter with a smaller pore size results in a larger sample of particulates since smaller particles are retained.

Thus, use of a 0.8 micron filter is more conservative than use of the 3.0 micron filter specified in NUREG-1801.

BVY 11-007 / Attachment 1 / Page 4 of 5 Enhancements The following enhancements will be initiated prior to the period of extended operation.

Attributes Affected Enhancement

4. Detection of Aging Effects Ultrasonic thickness measurement of the fuel oil storage and fire pump diesel storage (day) tank bottom surfaces will be performed every 10 years during tank cleaning and inspection.

6. Acceptance Criteria UT measurements of the fuel oil storage tank bottom surface will have acceptance criterion in accordance with American Petroleum Institute standard API 653 and UT measurements of the fire pump diesel storage (day) tank bottom surface will have acceptance criterion in accordance with Steel Tank Institute standard STI SPOO1.

U1T meauFcmc*nmt of tho fuol oi1storago and firo pump diesel 6torago (day) tn bottom 6urface6 will, have accoptanc criterion > 60% Tnom.

3. Parameters Monitored/Inspected Fuel oil in the fire pump diesel storage (day) tank will be analyzed according to ATSM D975-092 and for particulates per ASTM D2276

3. Parameters Monitored/Inspected Fuel oil in the John Deere diesel storage tank will be analyzed for particulates per ASTM D2276

3. Parameters Monitored/Inspected Fuel oil in the common portable fuel oil storage tank will be analyzed according to ASTM D975-092, per ASTM D2276 for particulates, and ASTM D---796D2709 for water and sediment.

References:

1. Letter, Entergy to USNRC, Vermont Yankee Nuclear Power Station, License No. DPR-28, "License Renewal Application," BVY 06-09, dated January 25, 2006

2. Letter, Entergy to USNRC, Vermont Yankee Nuclear Power Station, License No. DPR-28, "License Renewal Application Annual Update," BVY 10-069, dated December 30, 2010

BVY 11-007 / Attachment 1 / Page 5 of 5

3. Letter, Entergy to USNRC, Vermont Yankee Nuclear Power Station, License No. DPR-28, "Revision of Technical Specifications Bases Page," BVY 09-055, dated September 28, 2009

BVY 11-007 Attachment 2 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

License Renewal Application List of License Renewal Commitments

BVY 11-007 / Attachment 2 / page 1 of 1 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST 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 the revised license renewal commitments made in this submittal, along with the implementation schedule and the source of the commitment..

ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ

_Comments 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 tank bottom surface will have BVY 07-018 regional acceptance criterion in accordance with American Petroleum Institute BVY 10-069 inspection standard API 653 and UT measurements of the fire pump diesel storage BVY 11-007 (day) tank bottom surface will have acceptance criterion in accordance with Steel Tank Institute standard STI SPOO1.

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 BVY 10-069 inspection D975 and for particulates per ASTM D2276. Also, fuel oil in the John Deere BVY 11-007 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 BVY 10-069 inspection D975, per ASTM D2276 for particulates, and ASTM D2709 for water and BVY 11-007 sediment. I I I _I