BVY 11-013, License Renewal Application Supplemental Information

License Renewal Application Supplemental Information

ML110490053
Person / Time
Site:	Vermont Yankee
Issue date:	02/10/2011
From:	Michael Colomb Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 11-013
Download: ML110490053 (9)

Text

Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd vEntergy Vernon, VT 05354 Tel 802 257 7711 Michael J. Colomb Site Vice President BVY 11-013 February 10, 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

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. of this letter provides supplemental information to the LRA to address questions discussed with the NRC staff on teleconferences held on February 9, 2011 and February 10, 2011.

Revised regulatory commitments are provided in Attachment 2.

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

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

Executed on February 10, 2011.

Sincerely,

[MCPC N

[MJC/PLC] A 1-1

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"Ml

BVY 11-013 / Page 2 of 2 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 11-013 Attachment 1 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

License Renewal Application Supplemental Information

BVY 11-013 / Attachment 1 / Page 1 of 3 Vermont Yankee Nuclear Power Station License Renewal Application - Supplemental Information Vermont Yankee Nuclear Power Station (VYNPS) provides the following supplemental information to address questions discussed with the NRC staff on teleconferences held on February 9, 2011 and February 10, 2011. The information covers the following areas:

1. Neutron-absorbing material

2. Buried piping Neutron-Absorbing Material

Background

VYNPS provided additional information related to the Neutron Absorber Monitoring Program in License Renewal Application (LRA) supplemental information letters dated October 14, 2010 (BVY 10-052), December 21, 2010 (BVY 10-058) and February 4, 2011 (BVY 11-010). The program description in Section B.1.31 stated that the first testing of the Boral material would be completed prior to the end of 2014. Based on a teleconference held with NRC staff on February 10, 2011, VYNPS is providing the following supplemental information in order to support the staff's evaluation of the program.

Discussion As stated in BVY 11-010, VYNPS has nine racks installed in the spent fuel pool that were manufactured by Nuclear Energy Services (NES). There are two racks installed which were manufactured by Holtec. Three coupon strings are installed in the NES racks, each holding three Boral coupons.

VYNPS will test one coupon prior to the period of extended operation (PEO) to measure B-10 areal density and to assess the geometric and physical condition of the tested coupon. If coupons are not able to be retrieved and tested or if coupons cannot be demonstrated representative of the Boral in the Holtec racks, then VYNPS will perform neutron attenuation testing using in-situ methods, as described in BVY 11-010, (BADGER or blackness testing method) prior to the end of 2014.

Section A.2.1.37 of Appendix A to the LRA remains unchanged. The program description for Section B.1.31 of Appendix B to the LRA is revised to read as follows:

B.1.31 Neutron Absorber Monitoring Program Proaram Description The Neutron Absorber Monitoring Program is a new program that manages loss of material and reduction of neutron absorption capacity of Boral neutron absorption panels in the spent fuel racks. The program will rely on periodic inspection, testing, monitoring and analysis of the criticality design to assure that the required five percent subcriticality margin is maintained during the period of extended operation.

The program will be initiated prior to the period of extended operation. One coupon will be tested prior to the PEO to measure B-10 areal density and to assess the geometric and physical condition of the tested coupon. If coupons are not able to be retrieved and tested or if coupons cannot be demonstrated representative of the Boral in the Holtec

BVY 11-013 / Attachment 1 / Page 2 of 3 racks, thenneutron attenuation testing using in-situ methods, as described in BVY 11-010, (BADGER or blackness testing method) will be completed prior to the end of 2014.

Commitment 52 is revised to read as follows:

Commitment 52 Implement the Neutron Absorber Monitoring Program as described in LRA Section B.1.31.

Test one coupon prior to the PEO to measure B-10 areal density and assess the geometric and physical condition of the tested coupon. If coupons are not able to be retrieved and tested or if coupons cannot be demonstrated representative of the Boral in the Holtec racks, then perform neutron attenuation testing using in-situ methods, as described in BVY 11-010, (BADGER or blackness testing method) prior to the end of 2014.

Buried Pipingi Backaround VYNPS provided additional information related to the buried piping program in LRA supplemental information letters dated October 14, 2010 (BVY 10-052), December 21, 2010 (BVY 10-058) and February 4, 2011 (BVY 11-010). Based on a teleconference held with NRC staff on February 9, 2011 VYNPS is providing the following supplemental information in order to support the staff's evaluation of the program.

Discussion In BVY 11-010, VYNPS agreed to use a soil corrosivity index greater than 10 as a basis for an increased number of buried piping inspections during the PEO. In accordance with American Water Works Association (AWWA) Standard C1 05, VYNPS will determine the soil corrosivity index based on soil resistivity, pH, redox potential, sulfides and moisture.

Also in BVY 11-010, VYNPS committed to perform at least two inspections of buried carbon steel piping segments in the service water system every 10 years during the PEO, with the number increasing to three inspections if the soil resistivity is < 20,000 ohm-cm or the soil scores higher than 10 points on the soil corrosivity index using AWWA C105. After discussion with NRC staff, VYNPS will revise Commitment 54 to perform at least four inspections of buried carbon steel piping segments in the service water system every 10 years during the PEO. If the soil resistivity is < 20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AWWA C105, the number of inspections of the service water system buried piping will be increased to six.

Inspection Summary System 10 yr prior to PEO 1ist 10 year of PEO 2 nd 10 yr of PEO FP 1 (8')* System monitoring System monitoring DGFO 2 (8% of total)* 8% 8%

SBGT 2 inspections 2 inspections 2 inspections SW 2 (6' and 8')* 4 inspections 4 inspections

• = Inspection already completed

BVY 11-013/ Attachment 1 / Page 3 of 3 If the soil resistivity is < 20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AWWA C105, the number of inspections of the standby gas treatment system buried piping will be increased to three inspections and service water system buried piping will be increased to six inspections and the inspection regime will be as follows.

System 10 yr prior to PEO 1st 10 year of PEO 2nd 10 yr of PEO FP 1 (8')* System monitoring System monitoring DGFO 2 (8% of total)* 12% 12%

SBGT 2 inspections 3 inspections 3 inspections SW 2 (6' and 8')* 6 inspections 6 inspections

= Inspection already completed Commitment 44 addresses performing buried piping inspections during the PEO. This commitment is replaced by Commitment 54; therefore Commitment 44 is deleted. Commitment 54 is revised to read as follows.

Commitment 54 Prior to the PEO, VYNPS will inspect portions of the standby gas treatment system buried piping. The inspections will consist of direct visual examination of a minimum of two sections of piping and cover the entire circumference of at least ten linear feet of piping in each section.

During the PEO, inspections of two carbon steel piping segments in the standby gas treatment system and four carbon steel piping segments in the service water system will be performed every 10 years if measured soil resistivity is > 20,000 ohm-cm and the soil corrosivity index is 10 or less using AWWA C105. If the soil resistivity is <

20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AWWA C105, the number of inspections of the standby gas treatment system buried piping will be increased to three and the number of inspections of the service water system buried piping will be increased to six. Each of these direct visual inspections following excavation will cover the entire circumference of at least ten linear feet of piping.

During the PEO, two inspections covering at least 8% of the total length of in-scope buried fuel oil piping (-40 feet) will be performed at least once every 10 years. If the soil resistivity is < 20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AWWA C105, the percentage of fuel oil buried piping inspected will be increased to 12%.

Soil samples will be taken prior to the period of extended operation and at least once every 10 years thereafter to confirm the initial sample results.

Section A.2.1.1 of Appendix A to the LRA and Section B.1.1 of Appendix B to the LRA remain unchanged.

References:

1. Letter, Entergy to USNRC, "License Renewal Application Supplemental Information," BVY 11-010, dated February 4, 2011

2. Letter, Entergy to USNRC, "License Renewal Application Supplemental Information," BVY 10-052, dated October 14, 2011

3. Letter, Entergy to USNRC, "License Renewal Application Supplemental Information," BVY 10-058, dated December 21, 2011

BVY 11-013 Attachment 2 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

List of License Renewal Commitments

BVY 11-013 / Attachment 2 / page 1 of 2 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 No/

Comments 44 This Commitment has been deleted and replaced with Commitment 54. March 21, 2012 BVY 07-018 Regional inspection BVY 11-013 52 Implement the Neutron Absorber Monitoring Program as described in LRA March 21, 2012 BVY 10-052 B.1.31 Section B.1.31. BVY 10-058 Audit Report BVY 11-013 dated 9/3/10 Test one coupon prior to the PEO to measure B-10 areal density and assess the geometric and physical condition of the tested coupon. If coupons are not able to be retrieved and tested or if coupons cannot be demonstrated representative of the Boral in the Holtec racks, then perform neutron attenuation testing using in-situ methods, as described in BVY 11-010, (BADGER or blackness testing method) prior to the end of 2014.

BVY 11-013 / Attachment 2 / page 2 of 2 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 54 Prior to the PEO, VYNPS will inspect portions of the standby gas treatment March 21, 2012 system buried piping. The inspections will consist of direct visual BVY 10-052 A.2. 1.1, examination of a minimum of two sections of piping and cover the entire A.2.1.32 BVY 10-058 circumference of at least ten linear feet of piping in each section. B.1.1 BVY 11-010 During the PEO, inspections of two carbon steel piping segments in the Audit Report BVY 11-013 standby gas treatment system and four carbon steel piping segments in the dated 9/3/10 service water system will be performed every 10 years if measured soil resistivity is > 20,000 ohm-cm and the soil corrosivity index is 10 or less using AWWA C105. If the soil resistivity is < 20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AWWA C105, the number of inspections of the standby gas treatment system buried piping will be increased to three and the number of inspections of the service water system buried piping will be increased to six. Each of these direct visual inspections following excavation will cover the entire circumference of at least ten linear feet of piping.

During the PEO, two inspections covering at least 8% of the total length of in-scope buried fuel oil piping (-40 feet) will be performed at least once every 10 years. If the soil resistivity is < 20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AWWA C105, the percentage of fuel oil buried piping inspected will be increased to 12%.

Soil samples will be taken prior to the period of extended operation and at least once every 10 years thereafter to confirm the initial sample results.