ML062480356
| ML062480356 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/06/2006 |
| From: | Hamer M Entergy Corp |
| To: | Rowley J NRC/NRR/ADRO |
| References | |
| %dam200611, TAC MD2297 | |
| Download: ML062480356 (41) | |
Text
Howad- Y LR D-base 20.0-30.0Pae From: "Hamer, Mike" <mhamer@entergy.com>
To: <jgr@nrc.gov>
Date: 6/6/2006 2:10:36 PM
Subject:
VY LR D-base 200-300
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Subject:
VY LR D-base 200-300 Creation Date 6/6/2006 2:09:28 PM From: "Hamer, Mike" <mhamer@entergy.com>
Created By: mhamer@entergy.com Recipients nrc.gov TWGWPO03.HQGWDO01 JGR (Jonathan Rowley)
Post Office Route TWGWPO03.HQGWDO01 nrc.gov Files Size Date & Time VY LR D-Base 200-300 on 06-06-2006.pdf 2883013 Mime.822 3946837 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed
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200 Category Accepted Request 3.1.1-13-P-01 In many cases, loss of material Is managed using Water chemistry control - BWR. Please confirm that the VYNPS Water Chemistry - BWR AMP is consistent with GALL XI.M32, 'One-Time Inspection,' as well as with XI.M2, 'Water Chemistry.'
Edit from 5/11/2006 email - Inmany cases ( e.g. page 3.1-67 piping& fitting), loss of material Is managed using Water chemistry control - BWR alone. Please confirm that the VYNPS Water Chemistry - BWR AMP Is consistent with GALL XI.M32, 'One-Time Inspection,* as well as with XI.M2, 'Water Chemistry."
Response As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program is consistent with the program described In NUREG-1 801,Section XI.M2, VWater Chemistry.* The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated InLRA Section B.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described In NUREG-1 801,Section XI.M32, 'One-Time Inspection.'
LRA Tables 3.1.1,3.2.1,3.3.1, and 3.4.1 Indicate that the One-Time Inspection Program Is credited along with the water chemistry control programs for line Items for which GALL recommends a one-time inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, it Is also applicable to each line Item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Isconfirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A,SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
201 Category Closed Request 3.1.1-14-P-02 On page 3.1-53, the component type 'weld SLC nozzle to safe end weld (N10)' Is managed using BWR vessel Internals, Water chemistry control -5WR. The AMP applied, BWR VI, Is acceptable, however, this differs from what Is recommended by GALL. Please explain why Note E was not assigned.
Edit from 511112006 email - On page 3.1-53, the component type 'weld SLC nozzle to safe end weld (N10)' Ismanaged using BWR vessel Internals, Water chemistry control - BWR. Please explain how the BWR Vessel Internal program manage loss of material for SLC Nozzle to SE weld (N10) and provide either document or Inspection plan to support this AMR.
Response NUREG-1 801 Item IV.A1-8 specifies the water chemistry program for BWRs augmented to verify program effectiveness by an Inspection program such as the one-time Inspection (OTI) program. The OTI program will be used to verify the effectiveness of the water chemistry - BWR program wherever ItIs applied. Rather than list the OTI program every time the water chemistry - BWR program is listed Inthe 3.x.2 tables, the use of the OTI program IsIdentified Inthe rollup (3.x.1) tables and in the further evaluation discussions. The use of the water chemistry - BWR program augmented by the OTI program Isthe basis for the use of Note A.
Where another program, such as the BWR vessel Internals program could also be used to verify water chemistry program effectiveness, we have conservatively Included It Inthe list of programs; however, it Is considered a supplement to and not different from the NUREG-1 801 Identified programs Revised Answer to Revised Question - The BWRVIP augments the iSi Program for weld N10-SE, the SLC (NiO) safe end to vessel weld. The VYNPS Inspection requirements for this weld are thus In PP 7027, "Reactor Vessel Internals Management Program.' The SLC nozzle to safe end weld examination schedule and history Is discussed Indetail insection 15.0 of Appendix B to PP 7027.
202 Category Open Request 3.1.1-17-P-01 On page 3.1-39, the component type 'reactor vessel shell, Intermediate beltline she4l Ismanaged using reactor vessel surveillance and TLAA - neutron fluence.
Please confirm that the neutron fluence at the LPCI and RHR Injection nozzle will remain <1E17 n/cm2 (E>1MeV) through the end of the period of extended Response As stated In LRA Section 4.2.1, there are no nozzles Inthe vertical section of the reactor vessel IDthat will receive greater than 1E17 n/cm2 (E> 1 MeV) during the period of extended operation.
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203 Categorv Accepted Request 3.1.1-19-P-01 On page 3.1-67, the component type 'piping and fittings <4* NPS' Is managed using water chemistry control - BWR, One-time Inspection. The GALL suggests that a plant-specific program is appropriate for managing SCC of these components. Please identify the Inspection techniques that are to be used and the basis for concluding that one-time Inspection Is appropriate, rather than periodic Inspection.
Edit from 5/11/2006 - On page 3.1-67, the component type 'piping and fittings*<4* NPS' is managed using water chemistry control - BWR, One-time Inspection. Why VY does not credit ISI program?
Response All piping and fittings less than 4 NPS, except for the head seal leak detection line, are covered by NUREG-1.801 item IV.C1-1, which identifies ISI, water chemistry for BWRs and one-time Inspection (OTI) for small bore piping as the applicable aging management programs for cracking. The VYNPS ISI program includes piping and fittings less than 4" NPS. The LRA will be clarified to indicate that ISI Inaddition to water chemistry control - BWR and OTI applies to these components.
204 Category . Open Request 3.1.1-29-P-01 On page 3.1-62, the component type 'steam dryers' Is managed using BWR vessel Internals. The AMR Indicates that cracking of the steam dryers will be managed using the BWR VI program, yet they are not listed Inthe scope of the program. Please provide a plant-specific AMP as recommended by GALL or ensure that each of the 10 attributes of an acceptable management program are to be addressed.
Response VYNPS submitted a steam dryer monitoring plan as part of the recent power uprate application. That plan was approved by the NRC. That plan will continue dryer inspections for at least three consecutive refueling outages after the power uprate.
BWRVIP-139, Steam Dryer Inspection and Flaw Evaluation Guidelines, has been submitted to the NRC for review and approval. This BWRVIP document Is expected to be approved by the NRC prior to the period of extended operation and as such will become a part of the BWR Vessel Intemals Program. The VYNPS vessel Intemals procedure directs VY to comply with every approved BWRVIP, or to notify the NRC Iftaking an exception. As such, VYNPS will manage cracking of the steam dryers per the BWR Vessel Internals Program during the period of extended operation.
205 Category Closed Request 3.1.1-40-P-01 On page 3.1-40, the component type 'CRD stub tubes' is managed using BWR Vessel Intemals, water chemistry control - BWR. For this item, GALL recommends the use of a program consistent with XI.M8, 'BWR Penetrations.' No exception was taken to the scope of VYNPS AMP B.1.4, BWR Penetrations Program. It would also seem appropriate to assign Note E to this item unless the AMP assigned is changed.
Response Although Item IV.A1-5 lists the BWR Penetrations program for cracking, the program description InNUREG-1 801 Chapter XI does not Include the CRD stub tubes are In the program scope. The BWR Vessel Internals program does not specifically address the CRD stub tubes either, but is a more appropriate aging management program for this particular component. Note E is assigned to this line since the program does not match that listed Inthe NUREG-1801 item.
206 Category Closed Request 3.1.1-40-P-02 On page 3.1-41, the component type 'Incore housings' is managed using Inservice Inspection, water chemistry control - BWR. Please confirm that the correct GALL item Is referenced.
Response Inservice Inspection (ISI) and water chemistry - BWR are listed for the management of both loss of material and cracking. The listed NUREG-1 801 Item Iscorrect for both aging effects. For loss of material, the water chemistry- BWRand one-time Inspection programs (see response to question 3.1.1-14-P-02 for discussion on OTI program applicability) are the basis for the use of Note A,and the ISI program is supplemental. For cracking, Note E Is used since the ISI program Is different from the program (BWR Penetrations) listed InNUREG-1 801.
207 Category Closed Request 3.1.1-41-P-01 On page 3.1-72, the component type 'restrictors (ms)' Is managed using water chemistry control - BWR, One-time Inspection. Please provide the basis for excluding this component from the BWR Stress Corrosion. Cracking program.
Edit from 5/11/2006 email - On page 3..1-72, the component type 'restrictors (ms)' Is managed using water chemistry control - BWR, One-time Inspection. Please provide the basis for excluding this component from the BWR Stress Corrosion Cracking program. Isrestrictor (ms) weld Inspection part of SI also?
Response The BWR Stress Corrosion Cracking Program (GALL Section XI.M7) Is designed for pressure boundary piping. The main steam flow restrictors are not pressure boundary components. As such they are not subject to ASME Inspection requirements and were not a good fit for the BWRSCC program. VYNPS opted to manage them by One Time Inspection.
208 Category Closed Request 3.1.1-41-P-02 On page 3.1-41, the component type 'nozzles recirc outlets (Ni), recirc Inlets (N2)' and on page 3.1-43, the component type 'nozzles, core spray (N5), head spray (N6A), head Instrumentation (N6B), head vent (N7), jet pump Instrumentation (N8)' are managed using inservice Inspection, water chemistry control - BWR. The GALL item referenced Inthis AMR Is for Stainless steel and nickel-based alloy components that may be subject to SCC. It does not appear to be appropriate for low-alloy steel. Please Identify a more suitable GALL Item.
Response The material for these components Is Identified as low allow steel with stainless steel cladding. The material exposed to the Internal environment of reactor coolant (treated water) Is the stainless steel cladding. When evaluating surface aging effects such as cracking and loss of material, the stainless steel cladding Is the material that must match the NUREG-1 801 Item. NUREG-1 801 Item IV.A1 -1 provides the best match for the material, environment and aging effect combination within the BWR reactor vessel table.
The applicable material for the external environment (air) Is low alloy steel (or 'steel" In NUREG-1 801 terms).
209 Category Closed Request 3.1.1-41-P-03 On page 3.1-45, the component type 'nozzles flange leak-off (N13, N14)'; on page 3.1-47, the component type 'flanges, head nozzle flanges (N6, N7), blank flanges (N6)'; on page 3.1-51, the component type 'safe ends < 4* core SCLI?P (N10), Instrumentation (Nil, N12)'; and on page 3.1-52, the component type 'thermal sleeves
, feedwater Inlets (N4)' are managed using Inservice Inspection, water chemistry control - BWR. Please explain why these are not managed using the BWR SCC program.
Edit from 5/11/2006 email -on page 3.1-47, the component type 'flanges, head nozzle flanges (N6, N7), blank flanges (N6)'; Instrumentation (Nl.,N12)'; and on page 3.1-52, the component type 'thermal sleeves, feedwater Inlets (N4)' are managed using Inservice Inspection, water chemistry control - BWR. Please confirm these nozzles are less than 4 NPS. Please clarify how to manage feedwater Inlets thermal sleeve with ISI program.?
Response The BWRSCC program (GALL Section XI.M7) applies to stainless steel piping >=4" Indiameter. N13 and N14 are 2" nozzles. Safe ends <4" N10 Is a 2" safe end.
N11 and N12 are 2" nozzles.
N6 and N7 are low alloy steel and thus not susceptible to IGSCC. N6 blank flanges are 6" stainless steel flanges. These flanges were Included In the ISl Program with the rest of the nozzle assembly.
The feedwater thermal sleeves (N4) are a combination of stainless steel and nickel-based alloy Ina 10 Inch nozzle. The BWRSCC program In NUREG-1801 does not appear to Include feedwater thermal sleeves. Therefore, the feedwater thermal sleeves were Included Inthe ISland water chemistry control programs.
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210 Category Closed Request 3.1.1-43-P-01 On page 3.1-56, the component type 'control rod guide tubes, bases' is managed using BWR vessel Internals, water chemistry control - BWR. The component type appears to be described by the structure and/or component column In GALL Table IV.B1. Please clarify the basis for assigning Note D.
Response The matching of component types between the plant and NUREG-1801 Is not always straightforward. Minor differences Incomponent names (as In this example) can lead to uncertainty Inthe Intended scope of components In the NUREG-1801 item. Our approach was to err conservatively, so Notes C and Dwere sometimes used where Notes A and B might have been acceptable. Since the comparison Is equally valid with either set of notes, this conservative approach Is considered appropriate.
211 Category Closed Request 3.1.1-44-P-01 On page 3.1-52, the component type 'thermal sleeves reciro Inlet (N2) core spray (N5)' Is managed using BWR vessel Intemals and water chemistry control - BWR.
Please confirm that for the recirc Inlet nozzle thermal sleeve, Note B would apply.
Edit from 5/11/2006 email - On page 3.1-52, the component type 'thermal sleeves recirc Inlet (N2) core spray (N5)' Ismanaged using BWR vessel Internals and water chemistry control -BWR. Please confirm that for the recIrc Inlet nozzle thermal sleeve, Note B would apply. Please clarify how BWR Vessel Internal Program manages recIrc Inlet thermal sleeves?
Response The reciro Inlet thermal sleeve Isa match for the Jet pump assembly thermal sleeve InNUREG-1 801 Item IV.B1-13, so Note B could be applied to that portion of this line for cracking. However, the core spray thermal sleeve does not match and Note D was selected to conservatively cover both component types. As described Inthe response to question 3.1.1-43-P-01, the comparison Is equally valid with the selection of either Note B or D.
Revised Answer to Revised Question -The recirc Inlet thermal sleeve Is a match for the jet pump assembly thermal sleeve In NUREG-1801 Item IV.B1-13. so Note B could be applied to that portion of this line for cracking. However, the core spray thermal sleeve does not match and Note Dwas selected to conservatively cover both component types. NUREG-1801 Item IV.B1-7 could also have been referenced for the core spray thermal sleeve with a Note B and credit for the same programs. As described In the response to question 3.1.1-43-P-01, the comparison Is equally valid with the selection of either Note B or D.
Appendix B of the application identifies some exceptions to the NUREG-1801 description of the BWR Vessel Internals Program; however, none of these exceptions are related to the reciro Inlet (jet pump assembly) thermal sI.eeve. The VYNPS BWR Vessel Internals Program management of cracking for the recirc Inlet thermal sleeve Is consistent with the NUREG-1 801 program that Is credited In Item IV.B1-13 for this component.
212 Category Closed Request 3.1.1-47-P-01 In many cases (beginning on page 3.1-56), component types are managed using water chemistry control - BWR and not the ISI program. Please provide the basis for excluding them from the ISI program.
Edit from 5/11/2006 email - Inmany cases (beginning on page 3.1-56), component types are managed using water chemistry control - BWR alone for loss of material. Please provide the basis for excluding them from the ISI program.
Response Page 3.1-56 Is the beginning of the reactor vessel Internals (Table 3.1.2-2). In general the reactor vessel Internals are not code parts and are not Included Inthe Inservice Inspection Program. This Is discussed In Item 3.1.1-47 In Table 3.1.1 of the LRA.
Even In cases like the shroud support, where the components are considered code parts, the BWRVIP provides the approved Inspections for these components.
Those Inspections are implemented by augmenting the Inservice Inspection program, but the BWR Vessel Intemals program is credited as the controlling program.
213 Category Closed Request 3.1.1-48-P-02 On page 3.1-73, the component type tank (CRD accumulator)' Is managed using water chemistry control - BWR, One-time Inspection. It Is not clear that the tank is
<NPS4, so IS[ would seem a more appropriate AMP for verification (and a different GALL item may be a more useful reference).
Response The One-Time Inspection Program as described In LRA Appendix B, Section 5.1.21, Includes all piping and valves <4" NPS. The CRD accumulators are Included In this program. While they are slightly larger than 4, they are connected to the RCS by long runs of I inch piping and are therefore treated with that small bore piping.
The CRD accumulators are not reactor coolant pressure boundary parts. Each drive has two accumulators, one of which Is filled with nitrogen and the other with part nitrogen and part water. These components are not subject to ISI. Consequently, Water Chemistry Control augmented by One-Time Inspection Is the best option.
214 Category Closed Request 3.1;1-48-P-03 On page 3.1-63, the component type 'condensing chambers' Is managed using water chemistry control - BWR, One-time Inspection. Please confirm that this component Is <NPS4 Response The One-Time Inspection Program Includes all piping and valves <4* NPS. The instrumentation condensing chambers on the main steam flow elements are Included In this program. While they may be slightly larger than 4', they are connected by 1 Inch Instrument piping and are treated with that small bore piping.
These chambers are not subject to other Inspections such as ISI.
215 Category Closed Request 3.1.1-49-P-01 On page 3.1-62, the component type 'shroud support, ring, cylinder, and legs, access hole cover' Is managed using BWR vessel Internals, water chemistry control -
BWR. For the access hole cover plate, GALL recommends' ISI and water Chemistry. Please Identify the specific inspection(s) for this component under the RVI program.
Response VY performed a VT In 1995 and 1996, a MVT1 In 1998, and an EVT1 In 1999 and 2002. Additional EVT1 inspections are scheduled for 2006 and 2009.
[Appendix A of PP 7027) The examination coverage includes the entire weld surface, In addition to the heat-affected zones.' [Sec 4.3 of NE 80671 216 Category Accepted Request 3.1.1-50-P-01 On page 3.1-36, the component type 'other pressure boundary bolting, flange bolts and nuts (N6A, N6B, N7), CRD flange cap-screws and washers' is managed using Inservlce Inspection. Please confirm that the new Bolting Integrity AMP will be applied to this Item, and identify a more appropriate GALL Item.
Response The Inservice Inspection program Is used to manage cracking of this Class.1 bolting since these components are required to be Inspected In accordance with ASME Section XI IWB requirements. A Bolting Integrity Program Is under development (commitment #34) that will address the aging management of bolting in the scope of license renewal Including the bolting Identified In this line Item. The GALL Bolting Integrity Program XI.M18 states that the ASME Section XI Inservice Inspection Program XI.M1 supplements the Bolting Integrity Program. GALL line Item (IV.A1 -9) Identified In the LRA for comparison Is for BWR high-strength low-alloy steel closure studs and nuts exposed to air with an aging effect of cracking. A review of GALL Chapter IVIdentified no other BWR closure bolting line Items exposed to air with cracking as an aging effect Therefore this line Item was selected as the appropriate comparison and will remain the appropriate comparison with the Inclusion of the Bolting Integrity Program.
217 Category Closed Request 3.1.1-51-P-01 On page 3.1-60, the component type 'Jet pump castings, transition piece Inlet elbow/ nozzle, mixer flange and flare, diffuser collar' Is managed using thermal aging embrittlement of CASS. Please confirm that IV.B1-11 also applies Response NUREG-1801 Item IV.B1-11 also applies. The resulting note would be Note A.
218 Cate-gory Accepted Request 3.1.1-52-P-01 On page 3.1-36, the component type 'ncore housing bolting, flange bolts, flange nut and washer' Is managed using Inservice Inspection. Please confirm that the new Bolting Integrity AMP will be applied to this Item, and Identify a more appropriate GALL Item.
Response Revised answer for 5/11/2006 email - A Bolting Integrity Program Is under development (commitment #34) that will address the aging management of bolting In the scope of license renewal including the bolting identified In this line item. In addition, the Inservice Inspection Program is used to manage cracking of this Class 1 bolting since these components are required to be Inspected In accordance with ASME section Xl IWB requirements. The GALL Bolting Integrity Program XI.M18 states that the ASME Section Xl Inservice Inspection Program XI.M1 supplements the Bolting Integrity Program. The GALL line Item (IV.A2-6) Identified In the LRA for comparison Is for stainless steel flange bolting exposed to air with an aging effect of cracking. A review of GALL Chapter IVIdentified no BWR stainless steel bolting line items exposed to air with cracking as an aging effect. Therefore this line Item was selected as the appropriate comparison.
A Bolting Integrity Program Is under development that will address the aging management of bolting In the scope of license renewal Including the bolting identified In this line Item. The Inservice Inspection program Is used to manage cracking of this Class 1 bolting since these components are required to be inspected in accordance with ASME section XI IWB requirements. The GALL Bolting Integrity Program XI.M18 states that the ASME Section XI Inservice Inspection Program XI.M1 supplements the Bolting Integrity Program. The GALL line Item (IV.A2-6) Identified In the LRA for comparison is for stainless steel flange bolting exposed to air with an aging effect of cracking. A review of GALL Chapter IV Identified no BWR stainless steel bolting line items exposed to air with cracking as an aging effect. Therefore this line item was selected as the appropriate comparison and will remain the appropriate comparison with the Inclusion of the Bolting Integrity Program.
219 Cate-orv Closed Request 3.1.1-55-P-01 On page 3.1-71, the component type 'pump casing and cover (RR)' Is managed using Inservice Inspection. On page 3.1-75, the component type 'valve bodies <4" NPS' Is managed using one-time Inspection. On page 3.1-79, the component type 'valve bodies >=4* NPS' Is managed using inservice Inspection. Please clarify the basis, In each case, for asserting that the AMP used Is different from the one suggested by GALL Response Pump casing and cover - The VYNPS ISI program Is a plant-specific program, not compared to the GALL XI.M1 program. 'Therefore, Note E was applied wherever the ISI program was called for in GALL. Note that earlier on this same page, WCC and ISI are used to manage loss of material and Note A Is used - that is because GALL only requires water chemistry and the use of ISI here Isover and above what GALL requires.
For valve bodies <4" NPS - GALL manages reduction of fracture toughness (ROFT) using ISI, however, ISI only requires Inspections of valves bodies >=4* NPS.
Therefore, the OTI (small bore piping) program Is used to mange ROFT for these small valves.
Valve bodies >=4* NPS - The VYNPS ISI program Is a plant specific program, not compared to the GALL XI.M1 program. Therefore, VYNPS applied Note E wherever the ISI program was Identified In GALL.
220 Category Closed Request 3.1.1-57-P-01 On page 3.1-72, the component type 'restrIctors (ms)' Is managed using one-time Inspection. Please describe how OTI satisfies the recommendations of GALL AMP XI.M12, Thermal Aging Embrittlement of CASS.
Response GALL program XI.M12 is applicable to 'primary pressure boundary and reactor vessel Internals components' and the main steam flow restrictors are neither. As the main steam flow restrIctors are not ASME pressure boundary components, program XI.M12 Is not applicable. Thermal aging embrittlement results inIncreased rates of crack growth, which are evidenced by cracking In the material. The One-Time Inspection Program will be used to verify that reduction of fracture toughness has not progressed to the point that unacceptable cracking of the component has occurred.
221 Categorv Accepted Request 3.3.1-03-K-01 On page 3.3-91, the component type 'heat exchanger (tubes)' Is managed using water chemistry control - BWR. Please confirm that the VYNPS Water Chemistry -
BWR AMP addresses fouling Inheat exchanger tubes.
Response As stated InLRA Section 3.3.2.2.2, reduction of heat transfer due to fouling for stainless steel heat exchanger tubes exposed to treated water Is managed by the Water Chemistry Control - BWR Program. The effectiveness of the Water Chemistry Control-BWR Program will be confirmed by the One-Time Inspection Program through an Inspection of a representative sample of components crediting this program including areas of stagnant flow.
222 Category Accepted Reauest 3.3.1-05-K-01 On page 3.3-74, the component type 'heat exchanger (tubes) ' Is managed using water chemistry control - BWR. GALL recommends a plant-specific program.
Please clarify how each of the attributes of SRP-LR Appendix Al Is addressed by a purely preventive program.
Edit from 5/11/2006 email - On page 3.3-74, the component type 'heat exchanger (tubes) 'is managed using water chemistry control - BWR. GALL recommends a plant-specific program. Please clarify how this component Isaddressed by a purely preventive program.
Response SRP-LR Appendix Al Isapplicable to purely preventive programs. In fact, Section A.1.2.3.3, Item 4, states, 'For prevention and mitigation programs, the parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects. An example is the coolant oxygen level that is being controlled Ina water chemistry program to mitigate pipe cracklng.*
As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program Is consistent with the program described InNUREG-1801,Section XI.M2, MWater Chemistry.* The One-Time Inspection Program, described InLRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated In LRA Section B.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described In NUREG-1 801,Section XI.M32, 'One-Time Inspection."
The 10 attributes of SRP-LR Appendix Al for the Water Chemistry Control - BWR Program and the One-Time Inspection Program are the same as the attributes of the NUREG-1801 programs XI.M2 and XI.M32.
Added Response to 5/11/2006 email -
Page 3.3-74 has multiple line Items for heat exchanger (tubes) managed using Water Chemistry Control - BWR. The response assumes this question refers to the line item for cracking of heat exchanger (tubes) since this line Item references NUREG-1801 item VII.E3-3 which recommends a plant-specific program.
As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program optimizes the primary water chemistry to minimize the potential for loss of material and cracking. This Is accomplished by limiting the levels of contaminants Inthe RCS that could cause loss of material and cracking. Additionally, VYNPS has Instituted hydrogen water chemistry (HWC) with noble metals to limit the potential for Intergranular SCC (IGSCC) through the reduction of dissolved oxygen Inthe treated water Is consistent with the program described In NUREG-1801,Section XI.M2, 'Water Chemistry.! The One-Time Inspection Program, described InLRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring.
223 CategLory Accepted Request 3.3.1-13-K-01 On page 3.3-92, the component type 'neutron absorber (boral)' Is managed using water chemistry control - BWR. GALL recommends a plant-specific program.
Please clarify how each of the attributes of SRP-LR Appendix Al Is addressed by a purely preventive program..
Edit from 5/11/2006 email - On page 3.3-92, the component type 'neutron absorber (boral)' Ismanaged using water chemistry control - BWR. GALL recommends a plant-specific program. Please clarify how this component is addressed by a purely preventive program.
Response Page 3.3-92 has multiple line Items for neutron absorber (boral) managed using Water Chemistry Control - BWR. The response assumes this question refers to the line Item for loss of material for neutron absorber (boral) since this line Item references NUREG-1801 Item VII.A2-3 which recommends a plant-specific program.
SRP-LR Appendix Al Isapplicable to purely preventive programs. In fact, Section A.1.2.3.3, Item 4, states, "For prevention and mitigation programs, the parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects. An example Is the coolant oxygen level that Is being controlled Ina water chemistry program to mitigate pipe cracking."
As stated In LRA Section B.1.30.2, the Water Chemistry Control - SWR Program Isconsistent with the program described InNUREG-1 801,Section XI.M2, "Water Chemistry." The One-Time Inspection Program, described InLRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling is not occurring. As stated In LRA Section 1.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described InNUREG-1801,Section XI.M32, One-Time Inspection."
The 10 attributes of SRP-LR Appendix Al for the Water Chemistry Control - BWR Program and the One-Time Inspection Program are the same as the attributes of the NUREG-1 801 programs XI.M2 and XI.M32.
Added Response per 5/11/2006 email As stated InLRA Section B.1.30.2, the Water Chemistry Control - BWR Program optimizes the primary water chemistry to minimize the potential for loss of material and cracking. This Is accomplished by limiting the levels of contaminants In the RCS that could cause loss of material and cracking. Additionally, VYNPS has Instituted hydrogen water chemistry (HWC) with noble metals to limit the potential for Intergranular SCC (IGSCC) through the reduction of dissolved oxygen Inthe treated water Is consistent with the program described InNUREG-1801,Section XI.M2, 'Water Chemistry." The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Isnot occurring.
224 Category Accepted Request 3.3.1-14-K-01 Inmany cases, beginning on page 3.3-61 for auxiliary systems, component types exposed to oil are managed using the oil analysis program. Please confirm that the VYNPS Oil Analysis AMP Is consistent with GALL XI.M32, 'One-Time Inspection,' as well as with XI.M39, "Lubricating Oil Analysis.'
Response As stated In LRA Section 3.2.2.7, steel piping and components Inauxiliary systems at VYNPS that are exposed to lubricating olI are managed by the Oil Analysis Program, which Includes periodic sampling and analysis of lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment that Is not conducive to corrosion. As stated In LRA Section B.1.20, the Oil Analysis Program Is consistent with the program described In NUREG-1801,Section XI.M39, Lubricating Oil Analysis, with a minor exception.
The Oil Analysis Program Isnot consistent with GALL XI.M32, 'One-Time Inspection," nor are one-time Inspections necessary to verify the effectiveness of the program. Metals are not corroded by the hydrocarbon components of lubricants. Lubricating oils are not good electrolytes and the oil film on the wetted surfaces of components tend to minimize the potential for corrosion. Corrosion Inlube oil systems only occurs as the result of the presence of Impurities or moisture.
Therefore, an effective oil analysis program, which maintains Impurities and moisture below specified limits, precludes the need for one-time Inspections.
Operating experience at VYNPS has confirmed the effectiveness of the Oil Analysis Program In maintaining moisture and Impurities within limits such that corrosion has not and will not affect the Intended functions of these components.
In numerous past precedents (including NUREG-1828, Arkansas Nuclear One Unit 2 SER, Section 3.0.3.3.6, and NUREG-1 831, Donald C. Cook SER, Section 3.0.3.3.8), the staff concluded that an effective oil analysis program, which maintains Impurities and moisture below specified limits, Issufficient to demonstrate that the effects of aging will be adequately managed so that the Intended functions Wi be maintained consistent with the current licensing basis for the period of extended operation.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
This requires and amendment to the LRA.
225 Category Accepted Reauest 3.3.1-20-K-01 Beginning on page 3.3-166, many component types are managed using the diesel fuel monitoring program. Please confirm that the VYNPS Diesel Fuel Monitoring AMP Is consistent with GALL XI.M32, 'One-Time Inspection," as well as with XI.M30, 'Fuel Oil Chemistry.,
Response As stated In LRA Section 3.2.2.9, loss of material due to general, pitting, crevice, and MIC for carbon steel piping and components exposed to fuel oil is managed by the Diesel Fuel Monitoring Program. This program includes sampling and monitoring of fuel oil quality to ensure levels of water, particulates, and sediment remain within the specified limits. Maintaining parameters within limits ensures that significant loss of material will not occur. Ultrasonic inspection of storage tank bottoms where water and contaminants accumulate will be performed to confirm the effectiveness of the Diesel Fuel Monitoring Program. As stated In LRA Section B.1.9, the Diesel Fuel Monitoring Program Isconsistent with the program described in NUREG-1 801,Section XI.M3, Fuel Oil Chemistry Program, with minor exceptions.
The Diesel Fuel Monitoring Program Is not consistent with GALL XI.M32, 'One-Time Inspection,' nor are one-time Inspections necessary to verity the effectiveness of the program. The Diesel Fuel Monitoring Program Includes periodic cleaning, visual Inspection, and ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate to confirm the effectiveness of the oil quality monitoring activities to preserve an environment that is not conducive to corrosion The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
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226 Category Accepted Request 3.3.1-21-K-01 On page 3.3-106, the component type 'heat exchanger (bonnet)'; on page 3.3-141, the component type 'heat exchanger (shell)'; and on page 3.3-78, the component type 'heat exchanger (shell)' are managed using the oil analysis program. Please confirm that the VYNPS Oil Analysis AMP Is consistent with GALL XI.M32, "One-Time Inspection," as well as with XI.M39, "Lubricating Oil Analysis.'
Response As stated in LRA Section 3.2.2.7, steel piping and components Inauxiliary systems at VYNPS that are exposed to lubricating oil are managed by the Oil Analysis Program, which includes periodic sampling and analysis of lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment that is not conducive to corrosion. As stated inLRA Section B.1.20, the Oil Analysis Program Is consistent with the program described in NUREG-1801,Section XI.M39, Lubricating Oil Analysis, with a minor exception.
The Oil Analysis Program Is not consistent with GALL XI.M32, 'One-Time Inspection," nor are one-time Inspections necessary to verify the effectiveness of the program. Metals are not corroded by the hydrocarbon components of lubricants. Lubricating oils are not good electrolytes and the oil film on the wetted surfaces of components tends to minimize the potential for corrosion. Corrosion In lube oil systems only occurs as the result of the presence of impurities or moisture.
Therefore, an effective oil analysis program, which maintains Impurities and moisture below specified limits, precludes the need for one-time Inspections.
Operating experience at VYNPS has confirmed the effectiveness of the Oil Analysis Program Inmaintaining moisture and Impurities within limits such that corrosion has not and will not affect the Intended functions of these components.
Innumerous past precedents (including NUREG-1 828, Arkansas Nuclear One Unit 2 SER, Section 3.0.3.3.6, and NUREG-1 831 , Donald C. Cook SER, Section 3.0.3.3.8), the staff concluded that an effective oil analysis program, which maintains Impurities and moisture below specified limits, is sufficient to demonstrate that the effects of aging will be adequately managed so that the Intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
This requires and amendment to the LRA.
.227 Cate-gory Accepted Request 3.3.1-23-K-01 Beginning on page 3.3-221, component types exposed to treated water are managed using water chemistry control - BWR. Please confirm that the VYNPS Water Chemistry - BWR AMP Is consistent with GALL XI.M32, 'One-Time Inspection," as well as with XI.M2, 'Water Chemistry.'
Response As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program Is consistent with the program described In NUREG-1801,Section XI.M2, "Water Chemistry." The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated In LRA Section B.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described in NUREG-1 801,Section XI.M32. "One-Time Inspection."
LRA Tables 3.1.1, 3.2.1,3.3.1, and 3.4.1 Indicate that the One-Time Inspection Program Is credited along with the water chemistry control programs for line items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, It is also applicable to each line item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendmant to thA lilAnse renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems. BWR and Closed Cooling Water programs to explicitly state One-Time Irspection Program activities will confirm the effectiveness of these programs.
228 Category Closed Request 3.3.1-25-K-01 On page 3.3-65, the component type 'heat exchanger (tubes)' and on page 3.3-129, the component type 'heat exchanger (tubes)' are managed using service water Integrity. GALL recommends a plant-specific program. Please clarify how each of the attributes of SRP-LR Appendix Al Is to be addressed for this Item.
Edit from 5/11/2006 email - On page 3.3-65, the component type 'heat exchanger (tubes)' and on page 3.3-129, the component type 'heat exchanger (tubes)' are managed using service water Integrity. GALL recommends a plant-specific program. Please clarify how service water Integrity program manages this Item..
Response Page 3.3-129 has multiple line Items for heat exchanger (tubes) managed using Service Water Integrity. The response assumes this question refers to the line Item for loss of material for heat exchanger (tubes) exposed to external condensation managed using Service Water Integrity since this line Item matches the line item on page 3.3-65 for heat exchanger (tubes) managed using Service Water Integrity..
These line Items are for reactor building recirculation unit coolers, which are enclosed housing air-handling units with copper cooling coils (tubes). Raw water flows through the copper tubes, while external surfaces of the tubes are exposed to condensation.
Consistent with NUREG-1801 line Item VII.C1 -3, loss of material on the Internal surfaces of these copper heat exchanger tubes Is managed by the Service Water Integrity Program. The Service Water Integrity Program, In accordance with NRC GL 89-13, includes a condition and performance monitoring program which Inspects components for erosion, corrosion, and blockage and verifies the heat transfer capability of safety-related heat exchangers cooled by service water.
Therefore, this program Is equally as effective at managing loss of material on the external surfaces of the heat exchanger tubes as It Is at managing loss of material on the Internal surfaces of the tubes. However, the line items In question were compared with NUREG 1801 item VII.F1-16 (which recommends a plant-specific program) because NUREG 1801 Section VII.C1 does not address the external surfaces of copper alloy heat exchanger tubes containing raw water.
As stated In LRA Section B.1.26, the Service Water Integrity Program Is consistent with the program described In NUREG-1 801,Section XI.M20, "Open-Cycle Cooling Water System," with minor exceptions.
The 10 attributes of SRP-LR Appendix Al for the Service Water Integrity Program are described In the Aging Management Program Evaluation Results (AMPER)
Report, which is available for on-site review.
229 Category Accepted Request 3.3.1-26-K-01 Beginning on page 3.3-80, the components exposed to fuel oil are managed using the oil analysis program. Please confirm that the VYNPS Diesel Fuel Monitoring AMP Is consistent with GALL XI.M32, "One-Time Inspection," as well as with XI.M30, "Fuel Oil Chemistry.'
Edit from 5/11/2006 email - Beginning on page 3.3-80, the components exposed to lube oil are managed using the Oil Analysis program. Please confirm that the VYNPS Oil Analysis AMP Is consistent with GALL XI.M32, "One-Time Inspection," as well as with XI.M39, "Lube Oil Chemistry."
Response As stated In LRA Section 3.2.2.9, loss of material due to general, pitting, crevice, and MIC for carbon steel piping and components exposed to fuel oil Is managed by the Diesel Fuel Monitoring Program. This program Includes sampling and monitoring of fuel oil quality to ensure levels of water, particulates, and sediment remain within the specified limits. Maintaining parameters within limits ensures that significant loss of material will not occur. Ultrasonic inspection of storage tank bottoms where water and contaminants accumulate will be performed to confirm the effectiveness of the Diesel Fuel Monitoring Program. As stated In LRA Section B.1.9, the Diesel Fuel Monitoring Program Is consistent with the program described In NUREG-1801,Section XI.M3, Fuel Oil Chemistry Program, with minor exceptions.
The Diesel Fuel Monitoring Program Is not consistent with GALL XI.M32, "One-Time Inspection," nor are one-time Inspections necessary to verify the effectiveness of the program. The Diesel Fuel Monitoring Program Includes periodic cleaning, visual Inspection, and ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate to confirm the effectiveness of the oil quality monitoring activities to preserve an environment that Is not conducive to corrosion.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
This requires and amendment to the LRA.
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230 Category Closed Request 3.3.1-27-K-01 On page 3.3-69. the component type 'suction barrel' Is managed using service water Integrity. GALL recommends a plant-specific program. Please clarify how each of the attributes of SRP-LR Appendix Al Isaddressed for this Item.
Response Page 3.3-69 has multiple line Items for suction barrel managed using Service Water Integrity. The response assumes this question refers to the line item for loss of material for suction barrel with an external environment of condensation since this line Item references NUREG-1 801 Item VII.F1-1 which recommends a plant-specific program.
These line Items are for residual heat removal service water pump suction barrels which are made of AL6XN which Isa type of stainless steel that Is highly resistant to corrosion. The suction barrels are Incontact with raw water Internally and condensation externally.
As can be seen Inthe other suction barrel line Item, consistent with NUREG-1801 line Item VII.C1-15, loss of material on the Internal surfaces of the suction barrel Is managed by the Service Water Integrity Program. The Service Water Integrity Program, In accordance with NRC GL 89-13, Includes a condition monitoring program which Inspects components such as pump barrels for erosion, corrosion, and blockage. Since the external environment of condensation Is much milder than the Internal environment of raw water, this program Is equally as effective at managing loss of material on the external surfaces of the suction barrels as it Is at managing loss of material on the Internal surfaces of the barrels. However, the line Item Inquestion was compared with NUREG 1801 Item VII.F1-1 (which recommends a plant-specific program) because NUREG 1801 Section VII.C1 does not address the external surfaces of stainless steel components containing raw water.
As stated InLRA Section B.1.26, the Service Water Integrity Program Isconsistent with the program described In NUREG-1 801,Section XI.M20, 'Open-Cycle Cooling Water System,. with minor exceptions.
The 10 attributes of SRP-LR Appendix Al for the Service Water Integrity Program are the same as the 10 attributes of the program described In NUREG-1 801,Section XI.M20 with the exceptions described InLRA Appendix B, Section .13.26 231 Category Closed Request 3.3.1-28-K-01 On page 3.3-102, the component type 'valve body' Is managed using Instrument air quality. Please clarify how the effectiveness of the IAQ program Is to be verified.
Response Page 3.3-102 has multiple line Items for valve body managed using Instrument Air Quality. The response assumes this question refers to loss of material for both copper alloy and stainless steel valves exposed to treated air on Internal surfaces.
As stated InLRA Section B.1.16, the Instrument Air Quality Program maintains humidity and particulates within acceptable limits, thereby preserving the environment of treated air that is not conducive to corrosion. Actions to verify the effectiveness of the program are not necessary. Corrosion Intreated air systems only occurs as the result of the presence of Impurities or moisture. Therefore, an effective Instrument air quality program, which maintains Impurities and moisture below specified limits, precludes the need for Inspections. Operating experience at VYNPS has confirmed the effectiveness of the Instrument Air Quality Program in maintaining moisture and Impurities within limits such that corrosion has not and will not affect the Intended functions of these components.
Ina previously approved staff position (NUREG-1831, Donald C. Cook SER, Section 3.0.3.3.7), the staff concluded that an effective Instrument air quality program, which maintains Impurities and moisture below specified limits, Is sufficient to demonstrate that the effects of aging will be adequately managed so that the Intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
In another precedent (Millstone SER, Section 3.3B.2.3.12 and NUREG-1839, Point Beach SER, Section 3.2.2.3.1), on the basis of its review of current Industry research and operating experience, the staff concluded that air on metal will not result inaging that will be of concern during the period of extended operation. The staff considers a dried air environment benign and that its contact with carbon steel, low-alloy steel, stainless steel, and cast stainless steel surfaces will not result Inaging effects.
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232 Category Accepted Request 3.3.1-30-K-01 Beginning on page 3.3-61, the component types exposed to treated water are managed using water chemistry control - BWR. Please confirm that the VYNPS Water Chemistry - BWR AMP Is consistent with GALL XI.M32, 'One-lime Inspection,' as well as with XI.M2, 'Water Chemistry.'
Response As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program Is consistent with the program described In NUREG-1801,Section XI.M2, 'Water Chemistry." The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated In LRA Section B.1.21. the One-Time Inspection Program Is a new program which will be consistent with the program described in NUREG-1 801,Section XI.M32, 'One-Time Inspection.".
LRA Tables 3.1.1,3.2.1, 3.3.1, and 3.4.1 Indicate that the One-Time Inspection Program Is credited along with the water chemistry control programs for line Items for which GALL recommends a one-time inspection to confirm water chemistry control. For simplicity. the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, It Is also applicable to each line Item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
233 Category Accepted Request 3.3.1-31-K-01 On page 3.2-50 In ESF and page 3.3-146 In auxiliary systems, component types exposed to treated water are managed using water chemistry control - BWR.
Please confirm that the VYNPS Water Chemistry - BWR AMP Is consistent with GALL XI.M32, 'One-Time Inspection,' as well as with XI.M2, 'Water Chemistry.'
Response As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program Is consistent with the program described In NUREG-1801,Section XI.M2. 'Water Chemistry." The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated in LRA Section B.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described In NUREG-1 801,Section XI.M32, "One-Time Inspection.*
LRA Tables 3.1.1,3.2.1,3.3.1, and 3.4.1 Indicate that the One-Time lnspection Program Is credited along with the water chemistry control programs for line Items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, It Is also applicable to each line Item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
234 Category Closed Request 3.3.1-51-K-01 On page 3.3-132, the component type 'piping' Is managed using water chemistry control - auxiliary systems. Please confirm that GALL v2 Item VII.F1 -8 Is intended (not VIII.F1-8). Please confirm that GALL v2 Item VII.F1 -8 Is Intended (not VIII.F1-8).
Response Partial Duplicate of next question.
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235 Category Accepted Request 3.3.1-51-K-01 On page 3.3-131, the component type 'humidifier housing' and on page 3.3-132, the component type 'piping' Is managed using water chemistry control -auxiliary systems. Please confirm that GALL v2 Item VII.F1-8 is Intended (not VIII.F1-8).
Response That Is correct. The NUREG-1801 Vol. 2 Item should be VII.F1-8 rather than VIII.F1-8 for these lines.
This requires an amendment to the LRA.
236 Category Closed Request 3.4.1-M-01 InLRA Table 3.4.1, Item Number 3.4.1-22, the applicant states that their existing 'System Walkdown Program*,...'manages the loss of material for steel bolting through the use of visual Inspections...*. How does the applicant Intend to address the potential loss of bolting material for subject bolting (normally flange bolting) that cannot be readily seen - "visually inspected* - since most such bolting Is usually covered by Insulation/flashing material?
Added Edit from 5/11/2006 email - Note: See generic question 2.
Response As stated In LRA Section B.1.28, the System'Walkdown Program Isconsistent with the program described InNUREG-1801,Section XI.M36, "External Surfaces
- Monitoring." Inaccordance with this program description, surfaces that are Insulated are Inspected when the external surface Is exposed (i.e., maintenance) at such intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
EPRI aging assessment field 1007933 guide was reviewed by the staff.
237 Category Closed Request 3.4.1-M-02 In reference to Question 3.4.1-1 above, ItIs the staffs present understanding that the applicant currently Intends to develop a "GALL-recommended" bolting Integrity program. If such a program Is eventually developed, will it Include Inspections of plant condensate and feedwater system bolting; I.e., specifically flange bolting?
Response A Boiting Integrity Program Is under development that will address the aging management of bolting In the scope of license renewal Including Inscope flange bolting for the feedwater and condensate systems.
This Is LR Commitment #34.
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.238 Category Closed Request 3.4.1-M-03 The staff has recently discovered - during the April VYNPS AMP audit - that plant main condenser tubing contains an admiralty brass-type of material which contains copper &zinc. Such material - copper &zinc - has been known to leach out of condenser tubing via either by direct raw water erosion of the Inside of the condenser tubes and/or by way of phenomena known as *de-zincification.0 Recent third-party chemistry control audits of VYNPS have presented evidence that both copper and zinc Ions are currently leaching out of the main condenser tubing and have been leaching out at a measurable rate for the last five (5) years. However; as noted InVYNPS LRA Table 3.4.1, Item Number 3.4.1-35, the applicant stated that; "....there are no copper alloy components subject to selective leaching Inthe steam and power conversion systems ...'. What'does the applicant Intend to do to reduce and/or eliminate the apparent measurable and continued leaching out of copper and zinc' Ions from the main condenser tubing? What does theapplicant Intend to do to eliminate and/or mitigate the Introduction of these Ions (primarily the copper Ions) Into the reactor core areas of the plant?
Edit from 5/11/2006 emall - The staff has recently discovered - during the April VYNPS AMP audit - that plant main condenser tubing contains an admiralty brass-type of material which contains copper &zinc. Such material - copper &zinc - has been known to leach out of condenser tubing via either by direct raw water erosion of the Inside of the condenser tubes and/or by way of phenomena known as "de-zincificatdon." Recent third-party chemistry control audits of VYNPS have presented evidence that both copper and zinc Ions are currently leaching out of the main condenser tubing and have been leaching out at a measurable rate for the last five (5) years. However;, as noted InVYNPS LRA Table 3.4.1, Item Number 3.4.1-35, the applicant stated that; "....there are no copper alloy components subject to selective leaching Inthe steam and power conversion systems...*. What does the applicant Intend to do to reduce and/or eliminate the apparent measurable and continued leaching out of copper and zinc Ions from the main condenser tubing? What does the applicant Intend to do to eliminate and/or mitigate the Introduction of these Ions (primarily the copper Ions) Into the reactor core areas of the plant?
Response LRA Table 3.4.1, Item Number 3.4.1-35 states that a Selective Leaching Program is not applicable because there are no copper alloy components subject to selective leaching in the steam and power conversion systems. This statement was Intended to mean that there are no copper alloy components requiring an aging management review that are subject to selective leaching In the steam and power conversion systems.
A summary of the aging management review of the main condenser may be seen In LRA Table 3.4.2-1. As shown Inthis table and explained in plant-specific note 401, aging management of the main condenser is not based on analysis of materials, environments and aging effects. Condenser Integrity required to perform the post-accident intended function (holdup and plate-out of MSIV leakage) Iscontinuously confirmed by normal plant operation. This Intended function does not require the condenser to be leak-tight, and the post-accident conditions Inthe condenser will be essentially atmospheric. Since normal plant operation assures adequate condenser pressure boundary Integrity, the post-accident Intended function to provide~holdup volume and plate-out surface is assured. Previously approved staff positions (NUREG-1796, Dresden and Quad Cities SER, Section 3.4.2.4.4, and NUREG-1769, Peach Bottom SER,-Section 3.4.2.3), concluded that main condenser Integrity Is continually verified during normal plant operation and no aging management program Isrequired to assure the post-accident Intended function.
Therefore, loss of material due to leaching of copper and zinc ions from the main condenser tubing Isnot an aging effect requiring management for the condenser tubes.
Leaching of copper and zinc Ions from the main condenser tubing Is also not a license renewal Issue related to aging of other components managed by the Water Chemistry Control - BWR Program and exposed to the copper and zinc Ions from the condenser. BWRVIP-130, BWR Vessel Internals Project BWR Water Chemistry Guidelines - 2004 Revision, states that an assessment of risk to the fuel should be completed Iffeedwater copper values are above 0.1 ppb based on a quarterly average, or If zinc values are above 0.4 ppb based on a quarterly average. These recommendations are followed by VYNPS and there have been no fuel failures attributed solely to elevated feedwater copper or zinc Inthe last 20 years. Since the fuel Is periodically replaced, ItIs not subject to aging management review. Therefore, leaching of copper and zinc Ions from the main condenser tubing Is not a license renewal Issue related to aging of fuel.
The leaching of zinc Ions from the condenser has actually been beneficial Inthat It has helped to mitigate out-of-core dose rates. In fact, many BWRs are Injecting zinc Into the feedwater system to control out-of-core dose rates. VYNPS Is planning to start zinc Injection towards the end of 2006. Zinc also has a synergistic beneficial effect along with hydrogen water chemistry resulting InIncreased resistance of stainless steel and other alloys to Intergranular stress corrosion cracking (IGSCC).
BWRVIP-130 also states that since soluble copper acts as a cathodic reactant like dissolved oxygen, copper can exacerbate corrosion phenomenon such as IGSCC. However, VYNPS Injects low levels of hydrogen Ina Noble metal environment to mitigate IGSCC by keeping stainless steel electrochemical potential (ECP) values less than -230 mV relative to the standard hydrogen electrode. VYNPS has made significant efforts to reduce the amount of copper entering the reactor over the past 10 years. Where cycle average feedwater copper was once around 0.8 ppb. ItIs now near 0.3 ppb. Feedwater copper values for the first 4 months of 2006 were <0.2 ppb.
Since VYNPS Ismaintaining ECP values Inthe desired range and has maintained feedwater copper levels as low as achievable, VYNPS Is following BWRVIP
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guidance for feedwater copper. No other impacts of high copper and zinc levels were Identified In BWRVIP-130. Plant procedures assure that VYNPS will continue to follow BWRVIP guidance for water chemistry. Therefore, further action is not necessary to address leaching of zinc and copper from condenser tubing for the period of extended operation.
239 Category Accepted Request 3.4.2-M-01 The staff has recently discovered, In the applicant's LRA, 'Auxiliary Systems - Miscellaneous Systems" Tables 3.3.2-13-02 and 3.3.2-13-13, that the applicant Intends to use their existing Water Chemistry Control (BWR) Program to control loss of material In their condensate and feedwater systems; I.e., loss of material In carbon steel piping subjected to.steam temperatures >220 degrees F. For these systems, the GALL recommends the Implementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitigate loss of material In system piping. Does the applicant intend to implement a One-Time Inspection Program as well as their existing Water Chemistry Control Program to both Identify and mitigate the loss of material In their condensate and feedwater systems? If yes, does the applicant Intend to formally produce a commitment to Implement both programs? Ifthe applicant does not Intend to Implement both a One-Time Inspection and Water Chemistry Control Program, why not?
Edit from 5/11/2006 email - The staff has recently discovered, In the applicant's LRA, 'Auxiliary Systems - Miscellaneous Systems* Tables 3.3.2-13-02 and 3.3.2-13-13, that the applicant intends to use their existing Water Chemistry Control (BWR) Program to control loss of material In their condensate and feedwater systems; I.e., loss of material In carbon steel piping subjected to steam temperatures >220 degrees F. For these systems, the GALL recommends the Implementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitigate loss of material In system piping. Does the applicant Intend to Implement a One-Time Inspection Program as well as their existing Water Chemistry Control Program to both Identify and mitigate the loss of material In their condensate and feedwater systems? Ifyes, does the ipplicant Intend to formally produce a commitment to implement both programs? Ifthe VYNPS technical justification for continued operation of Entergy Northwest - Vermont Yankee (ENVY) with feedwater copper >0.2 ppb revision #1 was reviewed by applicant does not Intend to Implement both a One-Time Inspection and Water Chemistry Control Program, why not?
the staff.
Response LRA Table 3.3.1 Indicates that the One-Time Inspection Program Is credited along with the water chemistry control programs for line Items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, It is also applicable to each line item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
Also, license renewal commitment 16 has been Issued to Implement the One-Time Inspection Program as described In LRA Section B.1.21. A commitment to Implement the Water Chemistry Control - BWR Program Is not necessary as this Is an existing program, which does not require enhancement.
240 Cate-gory Accepted Request 3.4.2-M-02 The staff has recently discovered, Inthe applicant's LRA, Table 3.4.2-1; "Main Condenser and MSIV Leakage Pathway - Heat Exchanger Tubes," that the applicant Intends to use their existing Water Chemistry Control (BWR) Program to control any loss of material Instainless steel (SS) condenser tubes; I.e., loss of material InSS piping (tubing) subjected to steam temperatures >270 degrees F. For these systems and any future modified systems, the GALL recommends Implementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitigate loss of material Insystem piping (tubing). Does the applicant Intend to Implement a One-Time Inspection Program as well astheir existing Water Chemistry Control Program to both Identify and mitigate loss of material from any future modified heat exchanger tubing that could contain stainless steel that could be subjected to steam (or high temperature and high pressure water) temperatures >270 degrees F? If yes, does the applicant Intend to formally produce a commitment to Implement both programs? Ifthe applicant does not Intend to implement both a One-Time Inspection and Water Chemistry Control Program for future, modified condensers, why not?
Edit from 5/11/2006 Email -The staff has recently discovered, In the applicant's LRA, Table 3.4.2-1; *Main Condenser and MSIV Leakage Pathway - Heat Exchanger Tubes," that the applicant Intends to use their existing Water Chemistry Control (BWR) Program to control any loss of material In stainless steel (SS) condenser tubes; Le., loss of material In SS piping (tubing) subjected to steam temperatures >270 degrees F. For these systems and any future modified systems, the GALL recommends implementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitigate loss of material Insystem piping (tubing). Does the applicant Intend to Implement a One-Time Inspection Program as well as their existing Water Chemistry Control Program to both Identify and mitigate loss of material from any future modified heat exchanger tubing that could contain stainless steel that could be subjected to steam (or high temperature and high pressure water) temperatures >270 degrees F? Ifyes, does the applicant Intend to formally produce a commitment to Implement both programs? If the applicant does not Intend to Implement both a One-Time Inspection and Water Chemistry Control Program for future, modified condensers, why not?
Response LRA Table 3.4.1 Indicates that the One-Time Inspection Program is credited along with the water chemistry control programs for line items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, ItIs also applicable to each line Item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A,SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
Also, license renewal commitment 16 has been Issued to Implement the One-TIme Inspection Program as described In LRA Section B.1.21. A commitment to Implement the Water Chemistry Control - BWR Program Is not necessary as this Is an existing program, which does not require enhancement.
I
241 Category Closed Request 3.4.2-M-03 The staff has recently discovered, Inthe applicant's LRA, 'Table 3.3.2-13-9; 'Circulating Water System,* that the applicant Intends to use their existing Periodic Surveillance and Periodic Maintenance (PSPM)"Program to control loss of material Intheir circulating water condenser tubing (interior); I.e., loss of material In copper alloy material (>15%/6 zinc) subjected to raw water conditions. For this system, the GALL recommends the Implementation of an Open-Cycle Cooling Water Control Program to Identify and mitigate loss of material Insystem piping. Does the applicant Intend to Implement only the PSPM Program to both Identify and mitigate loss of material Inthe main condenser tubes rather than a "GALL-recommended" Open-Cycle Cooling Water Control Program? If yes, does the applicant Intend to formally produce a commitment to modify and implement the PSPM Program for control of material loss from the main condenser tubing? Ifthe applicant does not intend to Implement both a PSPM and "GALL-recommended" Opern-Cycle Cooling Water Control Program, why not?
Edit from 5/11/2006 email -The staff has recently discovered, Inthe applicant's LRA, 'Table 3.3.2-13-9; "Circulating Water System," that the applicant Intends to use their existing Periodic Surveillance and Periodic Maintenance (PSPM) Program to control loss of material in their circulating water condenser tubing (interior);
I.e., loss of material incopper alloy material (>15% zinc) subjected to raw water conditions. For this system, the GALL recommends the implementation of an Open-Cycle Cooling Water Control Program to Identify and mitigate loss of material Insystem piping. Does the applicant Intend to implement only the PSPM Program to both Identify and mitigate loss of material Inthe main condenser tubes rather than a 'GALL-recommended" Open-Cycle Cooling Water Control Program?
Ifyes, does the applicant Intend to formally produce a commitment to modify and implement the PSPM Program for control of material loss from the main condenser tubing? Ifthe applicant does not Intend to Implement both a PSPM and "GALL-recommended" Open-Cycle Cooling Water Control Program, why not?
Response LRA Table 3.3.2-13-9 does contain a line Item for loss of material incopper alloy tubing subjected to raw water conditions. However, this line item does not represent the circulating water. condenser tubing. Rather, Itrepresents copper alloy Instrument tubing In the circulating water system Incooling tower #2. cell 1 that requires aging management review due to potential spatial Interaction.
A summary of the aging management review of the main condenser may be seen In LRA Table 3.4.2-1. As shown Inthis table and explained Inplant-specific note 401, VYNPS does not Intend to Implement an aging management program for the main condenser.
Aging management of the main condenser Is not based on analysis of materials, environments and aging effects. Condenser integrity required to perform the post-accident Intended function (holdup and plate-out of MSIV leakage) Is continuously confirmed by normal plant operation. This Intended function does not require the condenser to be leak-tight, and the post-accident conditions inthe condenser will be essentially atmospheric. Since normal plant operation assures adequate condenser pressure boundary Integrity, the post-accident Intended function to provide holdup volume and plate-out surface is assured. Previously approved staff positions (NUREG-1796, Dresden and Quad Cities SER, Section 3.4.2.4.4, and NUREG-1769, Peach Bottom SER, Section 3.4.2.3), concluded that main condenser Integrity Is continually verified during normal plant operation and no aging management program is required to assure the post-accident Intended function.
242 Category Open Request 3.5.1-13-W-1 InTable 3.5.2-1 on Page 3.5-50 of the LRA, for component Bellows (reactor vessel and drywell, one of the AMPs shown is CIH-IWE, which Is a plant-specific AMP.
ANote C has been assigned to this AMR line item, component Is different, but consistent with material, environment, aging effect, and aging management program for NUREG-1 601 line item. AMP Isconsistent with NUREG-1 801 AMP description. Provide drawings showing how the LRA line Item bellows are different from the GALL Table 1 Une Item 3.5.1-13 bellows. Explain how the plant-specific VYNPS CII-IWE AMP Isconsistent with the GALL specified AMP.
Response Table 3.5.2-1 on Page 3.5-50 of the LRA, for component Bellows (reactor vessel and drywell) Is not consistent with the referenced NUREG-1 801 Vol. 2 Item. The Table 3.5.2-1 line Item "Bellows (reactor vessel and drywell)" and the corresponding line item inTable 2.4-1 should be deleted. The reactor vessel and drywall bellows perform no license renewal Intended function. These components are not safety-related and are not required to demonstrate compliance with regulations Identified In10 CFR 54.4(a)(3). Failure of the bellows will not prevent satlsfactory accomplishment of a safety function. Leakage, Ifany, through the bellows is directed to a drain system that prevents the leakage from contacting the outer surface of the drywell shell.
This requires an amendment to the LRA
243 Categorv Open Reauest 3.5.1-16-W-1 In Table 3.5.2-1 on page 3.5-54 of the LRA for component Drywall floor liner seal, the AMP shown IsStructures Monitoring. The applicant Is asked to verify that the CII-IWE AMP will not be used Instead to manage the aging of the moisture barrier.
Response The aging management activity will be the same whether Included under the umbrella of the Structures Monitoring Program or under the umbrella of the CII-IWE Program, For clarification, the CIi-IWE Program will manage the effects of aging on the moisture barrier through the period of extended operation. Note E remains the correct note since the CII-IWE Program Is plant specific. The LRA will be amended as follows:
Table 3.5.2-1 will be updated to reflect the AMP as CII-IWE Table line Item 3.5.1-16 will be updated to read:
"The aging effects cited In the NUREG-1 801 item are loss of sealing and leakage. Loss of sealing Isa consequence of the aging effects cracking and change In material properties.
For VYNPS, the Containment Leak Rate Program manages cracking and change In material properties for the primary containment seal and gaskets. The Inservice Inspection -IWE manages cracking and change In material properties for the primary containment moisture barrier.'
This requires an amendment to the LRA.
Also see Response #76 244 Category Accepted Request 3.5.1-44-W-1 In Table 3.5.2-6 on Page 3.5-80 of the LRA, for component seals and gaskets (doors, manways and hatches), material rubber In a protected from weather environment, the aging effects are cracking and change In material properties. One of the aging management programs shown is Structures Monitoring. The GALL line Item referenced Is I11.A6-12 and the Table 1 reference Is 3.5.1-44. The note shown Is E, different AMP than shown InGALL. However, GALL Line Item I11.A6-12 and Table 1 Line Item 3.5.1-44 both specify the Structures Monitoring Program. Explain why the note shown Is not Ainstead of E for the lower half of this AMR line Item.
Response Table 3.5.2-6 on Page 3.5-80 of the LRA, for component seals and gaskets (doors, manways and hatches), material rubber Ina protected from weather environment, the aging effects are cracking and change Inmaterial properties. The LRA will be clarified to Indicate that Note 'A"applies to the line for SMP.
This requires an amendment to the LRA.
245 Category Open Request 3.5.1-45-W-1 InTable 3.5.2-5 on Page 3.5-67 of the LRA, for component Vernon Dam external walls above/below grade, material concrete Inan exposed to fluid environment; the AMP shown Is Vernon Dam FERO Inspection. The referenced GALL line item for all three environments Is II1.A6-7. GALL Une Item 111.A6-7 states the following under AMP: Chapter XI.S7, "Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants" or the FERCIUS Army Corp of Engineers dam Inspections and maintenance programs. Since one of the AMPs under this GALL line Item Is FERC dam Inspections, explain why the note assigned to the LRA AMR line Item Is E Instead of A; consistent with GALL.
Response The Vernon Dam FERC Inspection Program was described as a plant-specific program InAppendix B of the application because there Is no program description InNUREG-1801. As a plant-specific program, we selected Note E. Note Awould be an acceptable alternative.
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246 Cateciory Open Request 3.5.1-47-W-1 InTable 3.5.2-5 on Page 3.5-66 of the LRA, for component Vernon Dam structural steel, material carbon steel Inan exposed to weather, protected from weather, and exposed to fluid environment; the AMP shown Is Vernon Dam FERC Inspection. The referenced GALL line Item for all three environments Is II1.A6-1 1. GALL Line Item II1.A6-11 states the following under AMP: Chapter XI.S7, 'Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants' or the FERC/US Army Corp of Engineers dam Inspections and maintenance programs. Since one of the AMPs under this GALL line Item Is FERC dam Inspections, explain why the note assigned to the three LRA AMR line Items Is E Instead of A; consistent with GALL.
Response The Vernon Dam FERC Inspection Program was described as a plant-specific program InAppendix B of the application because there Is no program description In NUREG-1801. As a plant-specific program, we selected Note E. Note Awould be an acceptable alternative.
247 Categorv Closed Request 3.5.1-58-W-1 InTable 3.5.2-6 on Page 3.5-71 of the LRA, for component conduit, material galvanized steel In a protected weather environment; the aging effect Isnone. The GALL line Item referenced Is 11.22-5, which Is for the following components: Support members; welds; bolted connections; support anchorage to building structure. Explain why the LRA AMR line Item has a Note Ashown Instead of a Note C, different component with respect to the GALL line Item. Or as an altemative, a letter Note A with a number note explaining that the component Is different.
Response NUREG-1801 does not mention every type of component that may be subject to aging management review (e.g., conduit Is not InNUREG-i 801) nor does the terminology used at a specific plant always align with that used InGALL. Consequently, matching plant components to NUREG-1801 components Is occasionally subjective. In this particular case, conduit, which has no specific function other than to support and protect cable, was considered a support member and Note A was applied. The use of either Note Aor C has no real impact on the aging management review results.
248 Category Accepted Request 3.5.1-58-W-2 InTable 3.5.2-6 on Page 3.5-72 of the LRA, for component electrical and Instrument panels and enclosures, material galvanized steel Ina protected from weather environment; the aging effect Is none. The GALL line item referenced i~s111.83-3, which Is for the following components: Support members; welds; bolted connections; support anchorage to building structure. Explain why the LRA AMR line Item has a Note Ashown Instead of a Note C, different component with respect to the GALL line Item. Or as an alternative, a letter Note Awith a number note explaining that the component Is different Response NUREG-1801 does not mention every type of component that may be subject to aging management review (e.g., panel Is not InNUREG-1 801) nor does the terminology used at a specific plant always align with that used InGALL. Consequently, matching plant components to NUREG-1801 components is occasionally subjective. Inthis particular case, panels, which have no specific function other than to support and protect electrical equipment, was considered a support member and Note A was applied. The use of either Note Aor C has no real Impact on the aging management review results.
Note 'A"will be changed to Note "C"for component electrical and Instrument panels and enclosures, material galvanized steel Ina protected from weather environment In Table 3.5.2-6 on Page 3.5-72 of the LRA. No change Is required to the other entries for this line Item.
This requires an amendment to the LRA.
249 Category Accepted Request 3.5.1-58-W-3 InTable 3.5.2-6 on Page 3.5-73 of the LRA, for component flood curb, material galvanized steel ina protected from weather environment; the aging effect is none.
The GALL line Item referenced Is 111.15-3, which Is for the following components: Support members; welds; bolted connections; support anchorage to building structure. Explain why the LRA AMR line Item has a Note Ashown Instead of a Note C, different component with respect to the GALL line Item. Or as an alternative, a letter Note Awith a number note explaining that the component Is different.
Response Unlike the conduits and panels compared to supports Inquestions 3.5.1-58-W-1 and W-2, the component flood curb should not have been considered a match.
Note C should be applied here; although the use of either Note A or C has no real Impact on the aging management review results Note A will be changed to Note 'C*for component flood curb, material galvanized steel Ina protected from weather environment InTable 3.5.2-6 on Page 3.5-73 of the LRA. No change Is required to the other entries for this line Item.
This requires an amendment to the LRA.
250 Category Accepted Request 3.5.1-8-W-1 In Table 3.5.2-1 on Page 3.5-53 of the LRA for component Torus shell with the aging effect cracking-fatigue, the note assigned IsE. Note E Isconsistent with NUREG-1 801 material, environment, and aging effect but a different aging management program Iscredited. Explain why this note Is E when the AMP shown for this line Item is TLAA and the referenced GALL Line Item 112.1.1-4 also specifies a TLAA.
Response Note A should be applied here. The LRA will be amended to Indicate Note A.
251 Category Closed Request 3.5.2-2-W-1 InTable 3.5.2-2 on Page 3.5-57 of the LRA, for component Spent fuel pool storage racks, material stainless steel In an exposed to fluid environment; the aging effect Isloss of material. Explain by what aging mechanism loss of material occurs and why the aging effect Is not cracking.
Response As shown InTable 3.5.2-2, the aging effect for component spent fuel pool storage racks Is loss of material. The specific aging mechanism Is pitting and crevice corrosion because stainless steels are susceptible to this aging mechanism when exposed to oxygenated water Ina treated water environment. Cracking Is not an aging effect requiring management for stainless steel Inthe spent fuel pool because cracking due to stress corrosion Is dependent on temperature (>140'F). The spent fuel pool treated water environment Is less than 140°F.
252 Cate-gory Closed Request 3.5.2-4-W-1 InTable 3.5.2-4 on Page 3.5-61 of the LRA, for component Blowout or blow-off panels, material aluminum Inan exposed to weather environment; the aging effect Is none. Reference question A-W-13 and explain how this component is protected from constant wetting and drying conditions.
Response As Identified Inthe response to question A-W-13, loss of material due to pitting and crevice corrosion of aluminum components Inan outdoor environment is not applicable Ifthe atmospheric environment Is non-aggressive. Plant-specIfic Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result In significant loss of material in aluminum components, hence, there are no aging effects requiring management.
253 Category Closed Request 3.5.2-4-W-2 In Table 3.5.2-4 on Page 3.5-61 of the LRA, for component Steel Piles; material carbon steel Inan exposed to weather environment; the aging effect Is none. Note 504 discusses steel piles driven Into soils (a soil environment, not a weather environment) with no significant effects due to corrosion. Explain how the soil environment relates to the weather environment to Justify no aging effect.
Response As Identified In Table 3.5.2-4 on Page 3.5-61 of the LRA, for steel piles, material carbon steel Inan exposed to weather environment; the aging effect Is none.
Although a soil environment Is not Identified, the listed environment, exposed to weather, Is Intended to Include both an above grade environment and a below grade environment as described InTable 3.0-2 of the application. The 1Ielow grade environment applies to the steel piles. As such the statement made inNote 504 Is applicable.
254 Category Closed Request 3.5.2-5-W-1 In Table 3.5.2-5 on Page 3.5-65 of the LRA, for component N2 tank steel supports, material stainless steel in an exposed to weather environment; the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified Inthe response to question A-W-13, loss of material due to pitting and crevice corrosion of stainless steel components Inan outdoor environment is not applicable Ifthe atmospheric environment Is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result Insignificant loss of material Instainless steel components, hence, there are no aging effects requiring management.
255 Category Accepted Request 3.5.2-5-W-2 In Table 3.5.2-5 on Page 3.5-65 of the LRA, for component Transmission towers, material galvanized steel In an exposed to weather environment; the aging effect Is none. Reference question A-W-1 3 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified inthe response to question A-W-13, loss of material Is the aging effect requiring management and the Structures Monitoring Program Isthe aging management program. This Isconsistent NUREG-1801 Vol. 2 Item I1l.B4-7, summarized InTable 1 Item 3.5.1-50, and Note C applies.
This change requires an amendment to the LRA.
256 Category Open Request 3.5.2-5-W-3 InTable 3.5.2-5 on Page 3.5-67 of the LRA, for component Vernon Dam external walls, floor slabs and Interior walls, material concrete Ina protected from weather environment; the aging effect shown Is none with the AMP shown as Vernon Dam FERC Inspection. VYNPS discusses throughout Its LRA Section 3.5 further evaluations that VYNPS concrete does not have aging effects because.the quality of the concrete used during constructiorl was to the standards of ACI-318 and ACI 201.2R. Vernon Dam Is a very old structure and was not built by the owners of VYNPS. Provide documentation and justification that the quality of the concrete used at Vernon Dam Is also to the standards of ACI-318 and ACI 201.R such that the AMR statement None for aging effects of the Dam concrete IsJustified.
Response Since quality of concrete used at Vermon Dam has not been confirmed, it would have been more appropriate to show for the associated aging effects for the line Items Inquestion. However, the same aging management activity, the FERC Inspection, Is still appropriate to manage aging effects associated with the Vernon Dam concrete components.
257 Category Accepted Request 3.5.2-6-W-1 InTable 3.5.2-6 on Page 3.5-71 of the LRA, for component conduit, material galvanized steel In an exposed to weather environment; the aging effect is none.
Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified in the response to question A-W-13, loss of material Is the aging effect requiring management and the Structures Monitoring Program is the aging management program. This is consistent NUREG-1801 Vol. 2 Item 111.14-7, summarized in Table 1Item 3.5.1-50, and Note C applies.
This change requires an amendment to the LRA.
258 Category Accepted Request 3.5.2-6-W-2 InTable 3.5.2-6 on Page 3.5-71 of the LRA, for component conduit support, material galvanized steel Inan exposed to weather environment; the aging effect is none. Reference queston A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified in the response to question A-W-13, loss of material Isthe aging effect requiring management and the Structures Monitoring Program Is the aging management program. This Is consistent NUREG-1801 Vol. 2 Item 111.B4-7, summarized InTable 1Item 3.5.1-50, and Note C applies.
This change requires an amendment to the LRA.
259 Category Accepted Request 3.5.2-6-W-3 InTable 3.5.2-6 on Page 3.5-72 of the LRA, for component electrical and Instrument panels and enclosures, material galvanized steel In an exposed to weather environment the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified In the response to question A-W-13, loss of material Isthe aging effect requiring management and the Structures Monitoring Program Is the aging management prograum. This Is consistent NUREG-1801 Vol. 2 Item I13.B4-7, summarized in Table 1Item 3.5.1-50, and Note C applies.
This change requires an amendment to the LRA.
260 Category Closed Request 3.5.2.6-W-4 InTable 3.5.2-6 on Page 3.5-75 of the LRA, for componentVents and louvers, material aluminum Inan exposed to weather environment; the aging effect Is none.
Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified in the response to question A-W-13, loss of material due to pitting and crevice corrosion of aluminum components In an outdoor environment is not applicable Ifthe atmospheric environment Is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result insignificant loss of material In aluminum components, hence, there are no aging effects requiring management.
261 Category Closed Request 3.5.2-6-W-5 InTable 3.5.2-6 on Page 3.5-76 of the LRA, for component Anchor bolts, material stainless steel Inan exposed to weather environment; the aging effect Is none.
Reference question A-W-13 and explain how this component Isprotected from constant. wetting and drying conditions.
Response As Identified In the response to question A-W-13, loss of material due to pitting and crevice corrosion of stainless steel components in an outdoor environment is not applicable ifthe atmospheric environment Is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment Is non-aggresslve. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result in significant loss of material instainless steel components, hence, there are no aging effects requiring management.
262 Category Closed Request 3.5.2-6-W-6 InTable 3.5.2-6 on Page 3.5-78 of the LRA, for component structural bolting, material stainless steel Inan exposed to weather environment; the aging effect is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified Inthe response to question A-W-13, loss of material due to pitting and crevice corrosion of stainless steel components In an outdoor environment Is not applicable Ifthe atmospheric environment Is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result insignificant loss of material instainless steel components, hence, there are no aging effects requiring management.
263 Category Accepted Request 3.5.2-6-W-7 InTable 3.5.2-6 on Page 3.5-78 of the LRA, for component structural bolting, material galvanized steel Inan exposed to weather environment; the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
Response As Identified In the response to question A-W-13, loss of material Is the aging effect requiring management and the Structures Monitoring Program Isthe aging management program. This Is consistent NUREG-1801 Vol. 2 Item 111.84-7, summarized InTable 1 Item 3.5.1-50, and Note C applies.
This change requires an amendment to the LRA.
264 Cate-gory Closed Request 3.5.2-6-W-8 In Table 3.5.2-6 on Page 3.5-80 of the LRA, for component water stops, material PVC Ina protected from weather environment; the aging effect Is none. By definition the component stops water, so Itcould be exposed to water. In LRA Table 3.5.2-4 on Page 3.5-64 for component Cooling tower fill, material PVC, environment exposed to fluid environment, the aging effects listed are cracking and change Inmaterial properties. Provide a technical basis why PVC water stops do not have any aging effects which need aging management when they could be exposed to a fluid environment also. Provide the specification that called for PVC water stops during construction Instead of rubber.
Response The PVC water stops Identified In Table 3.5.2-6 on Page 3.5-80 of the LRA are used Inthe cooling tower reinforced concrete basin and are not exposed to the same environment as the cooling tower fill material. Therefore the aging effects are not the same. The aging effects attributed to PVC water stops are evaluated based upon Section 7.0 of the Structural Tools. Exposure to water for these commodities Is Insignificant, since the concrete encapsulating the PVC water stop and the protection provided by the surrounding concrete, provides ample protection such that aging management Is not required. USFAR Fig 12.2-33 (G-200357)
"Cooling Tower No. 2 Basin Plan View" Identifies the use of PVC water stops at VYNPS.
265 Category Closed Request 3.5.2-6-W-9 InTable 3.5.2-6 on Page 3.5-78 of the LRA, for component Fire proofing, material Pyrocrete Ina protected from weather environment; the aging effect Is none.
Provide a technical basis why Pyrocrete does not have any aging effects Inthe environment listed.
Response Pyrocrete (used for fire proofing) Is cement base composite material. Pyrocrete Is not Identified InNUREG-1801. As such, our technical evaluation of pyrocrete In determining applicable aging effects was the same as that for concrete which Is based on EPRI 1002950, Aging Effects for Structures And Structural Components (Structural Tools), Revision 1, Section 5. Accordingly, no aging effects were determined for pyrocrete protected from weather. However, as Indicated InTable 3.5.2-6 on Page 3.5-78 of the LRA, the Fire Protection Program and Structures Monitoring Program will confirm the absence of significant aging effects throughout the period of extended operation.
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266 Categorv Accepted Request A-W-01 LRA Table 3.5.1, Item Number 3.5.1-5, has the following statement under the discussion column: The drywell steel where the drywell shell Is embedded is Inspected In accordance with the Containment Inservice Inspection (lWE) Program and Structures Monitoring Program. .This Is an Impossible Inspection. Change this discussion statement to agree with LRA Section 3.5.2.2.1.4 that states: The drywell steel shell and the moisture barrier where the drywel shell becomes embedded Inthe drywell concrete floor are Inspected Inaccordance with the Containment Inservlce Inspection (IWE) Program and Structures Monitoring Program.
Response For LRA Table 3.5.1, Item 3.5.1-5, the discussion column should read, 'The drywell steel shell and the moisture barrier where the drywell shell becomes embedded in the drywell concrete floor are inspected in accordance with the Containment Inservice Inspection (IWE) Program. To be consistent, LRA Section 3.5.2.2.1.4, should Indicate that the drywell to floor moisture barrier will be Inspected under the Containment Inservlce Inspection (IWE) Program. The Inspection Is part of the Containment Inservice Inspection (IWE) Program and will be retained as part of that program through the period of extended operation. The LRA will be amended as stated by formal correspondence.
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267 Category Accepted Request A-W-02 LRA Table 3.5.1, Item Number 3.5.1-9. has the following statement under the discussion column: Not applicable. See Section 3.5.2.2.1.6. However, the following statement Is made In LRA Section 3.5.2.2.1.6: 'Fatigue TLAAs for the steel drywell, tors, and associated penetrations are evaluated and documented InSection 4.6.' The components associated with LRA Table 3.5.1, Item Number 3.5.1-9 are: penetration sleeves, penetration bellows; suppression pool shell, unbraced downcomers. Explain how Item number 3.5.1-9 Is not applicable when a fatigue TLAA has been performed for the tows and penetrations. Explain why the vent line, vent header and vent line bellows are not listed in LRA Sections 3.5.2.2.1.6 and 4.6 as referenced in Table 3.5.1, Une Item 3.5.1-8.
Response The LRA will be amended to reflect the following changes. Fatigue analyses have been evaluated for the tows, drywell to torus vent system, and torus penetrations. The following line for the tows penetrations will be added to Table 3.5.2-1:
Tows mechanical penetrations PB, SSR Carbon steel Protected from weather Cracking (fatigue) TLAA-metal fatigue II.B4-4 (C-13) 3.5.1 9A The evaluation of the drywell to tows vent system fatigue analysis determined that it was not a TLAA. The significant contributor to fatigue of the vent system is post-LOCA chugging, a once In plant-life event As there will still be only one design basis LOCA for the life of the plant, Including the period of extended operation, this analysis Isnot based on a time-limited assumption and Isnot a TLAA. Since fatigue for the vent system Is event driven and Is not an age related effect, the following line will be deleted from Table 3.5.2-1:
Drywell to tows vent system PB, SSR Carbon steel Protected from weather Cracking (fatigue) TLAA-metal fatigue I1.B1.1-4 (C-21) 3.5.1 8A The discussion column entry for Table 3.5.1 Item 3.5.1-8 will be changed to state:
Fatigue analysis Isa TLAA for the tows shell. Fatigue of the tows to drywell vent system Is event driven and the analysis is not a TLAA. See Section 3.5.2.2.1.6.
The discussion column entry for Table 3.5.1 item 3.5.1-9 will be changed to state:
Fatigue analysis is a TLAA for the torus penetrations. See Section 3.5.2.2.1.6.
Section 3.5.2.2.1.6 will be changed to read as follows:
TLAA are evaluated In accordance with 10 CFR 54.21(c) as documented InSection 4. Fatigue TLAAs for the torus and associated penetrations are evaluated and documented inSection 4.6.
Section 3.5.2.3, Time-Umited Aging Analyses, will be changed to state:
TLAA Identified for structural components and commodities Include fatigue analyses for the torus and tows penetrations. These topics are discussed in Section 4.6.
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268 Category Accepted Request A-W-03 LRA Table 3.5.1, Item Number 3.5.1-12, under the discussion column, does not make reference to LRA Section 3.5.2.2.1.8 for further evaluation. Explain why this link Is not made to the further evaluation section. Explain the need for augmented ultrasonic exams to detect fine cracks since a CLB fatigue analysis does exist.
Response A link from Items 3.5.1-12 and 3.5.1.13"will be added to section 3.5.2.2.1.8.
Section 3.5.2.2.1.8 should state:
Cyclic loading can lead to cracking of steel and stainless steel penetration bellows, and dissimilar metal welds of BWR containments and BWR suppression pool shell and downcomers.
Cracking due to cyclic loading is not expected to occur inthe drywell, torus and associated penetration bellows, penetration sleeves, unbraced downcomers, and dissimilar metal welds. A review of plant operating experience did not Identify cracking of the components, and primary containment leakage has not been identified as a concern. Nonetheless the existing Containment Leak Rate Program with augmented ultra sonic exams and Containment Inservice Inspection-IWE, will continue to be used to detect cracking. Observed conditions that have the potential for Impacting an intended function are evaluated or corrected In accordance with the corrective action process. The Containment Inservice Inspection - IWE and Containment Leak Rate programs are described InAppendix B.
This will require an amendment to the LRA 269 Category Accepted Request A-W-04 LRA Table 3.5.1, Item Number 3.5.1-13, under the discussion column, does not make reference to LRA Section 3.5.2.2.1.8 for further evaluation. Explain why this link Is not made to the further evaluation section. Explain the need for augmented ultrasonic exams to detect fine cracks since a CLB fatigue analysis does exist.
Response This requires an amendment to the LRA.
See response to Item 268.
270 Category Accepted Request A-W-05 LRA Table 3.5.1, Item Number 3.5.1-16, under the discussion column, states that seals and gaskets are not Included In the Containment Inservice Inspection Program at VYNPS. One of the components for this item number Is mQisture barriers. Explain how VYNPS seals the joint between the containment drywell shell and drywall concrete floor ifthere is no moisture barrier. Explain why the Inspection of this joint is not part of the Containment Inservice Inspection Program at Response VYNPS uses a moisture barrier to seal the joint between the containment drywell shell and drywell concrete floor. Moisture barrier Is listed In LRA table 3.5.2-1 as drywell floor liner seal. Aging effects on the drywell moisture barrier will be managed under the CIi-IWE program (also see audit question 3.5.1-16-W-1 above).
For clarity, drywell floor liner seal will be changed to drywell shell to floor seal (moisture barrier). (Also see audit questions #76 and 243 which address changes to the LRA)
271 Category Open Request A-W-06 LRA Table 3.5.1, Item Number 3.5.1-17, under the discussion column, states that locks, hinges, and closure mechanisms are active components and are therefore not subject to an aging management review. Provide any license renewal regulatory guidance document or previous LRA NRC SER that has ever stated that locks, hinges, and closure mechanisms are active components. Iflocks, hinges, and closure mechanisms are active components at VYNPS, provide an itemized list of these active components with their qualified life or specified time period of replacement. Explain how VYNPS tracks the active life of these components before replacement.
Response It may be a misnomer to refer to these components as active components since 10CFR54.21(a)(1)(i) does not refer to active or passive components, but rather excludes components from aging management review that perform an intended function, as described In § 54.4, with moving parts or with a change In configuration or properties. Locks, hinges, and closure mechanisms perform their functions with moving parts.
This exception Is not based on a qualified life or specified time period of replacement for a component. 10CFR54.21(a)(1)(ii) provides a separate exclusion for components that are replaced based on a qualified life.
Other precedents for locks, hinges, and closure mechanisms as active components that have received approval by the NRC are found In Peach Bottom (NUREG 1769, Section 3.0.3.14.2 Pg 3-58) and Millstone (NUREG 1838, Section 3.3A.2.1.4 Pg 3-245) 272 Category Open Request A-W-07 LRA Table 3.5.1, Item Number 3.5.1-21, under the discussion column, states that VYNPS plant operating experience has not Identified fretting or lock up due to mechanical wear for the drywell head and downcomers. Plant operating experience does not find fretting or lock up due to mechanical wear, Inspections do.
Explain If VYNPS does not currently Inspect for wear of the drywell head and downcomer pipes under the CLB using the Containment Inservice Inspection Program. IfVYNPS does currently Inspect these components for wear, justify not performing these same inspections during an extended license period. If required, provide drawings showing the spaclal distance between components such that fretting cannot occur.
Response Condition reports are a primary source of operating experience documentation reviewed for license renewal. Condition reports document negative Inspection results. NUREG-1 801 defines neither fretting nor lockup and further confuses the subject by stating that fretting and lockup are caused by mechanical wear which is an aging mechanism resulting In the aging effect loss of material. The definition inNUREG-1801,Section IX.E, merely states that fretting and lockup Isan aging effect along with a cause, but doesn't say what ItIs or what Itlooks like. As Indicated inthe line Item for drywell head InTable 3.5.2-1, the Containment Inservice Inspection-IWE Program and the Containment Leak Rate Program manage loss of material. Loss of material Is the aging effect caused by mechanical wear. VYNPS Inspects the drywell head and downcomers (Torus vent system) per the requirements of ASME Section XI.
In addition, the drywell head Is a stationary or fixed component and the downcomers are stationary, well-braced components and the spacial distance between connecting components makes Itunlikely for fretting and lockup to occur.
273 Category Open Request A-W-08 LRA Table 3.5.1, Item Number 3.5.1-11, under the discussion column, states that cracking due to stress corrosion cracking for stainless steel vent line bellows Is not applicable. Explain Ifthe VYNPS Containment Inservice Inspection Program and Containment Leak Rate Program are used currently to detect cracking of stainless steel vent line bellows by inspection and testing. Explain why it Is not more appropriate to take credit for these two programs to detect cracking without the need for additional enhanced examinations then to say not applicable.
Response The NUREG-1 801 referenced programs Involve visual Inspections and leak testing which are not optimum methods for managing SCC. Therefore, when possible, It Is more appropriate to assess the conditions and identify whether the applicable aging effects require management. As stated In Section 3.5.2.2.1.7, stress corrosion cracking Is not an aging effect requiring management for the penetration sleeves and bellows, since the conditions necessary for SCC do not exist.
However these components are evaluated for other aging effects requiring management, such as cracking, as shown In Table 3.5.2-1.
274 Cate-orv Open Request A-W-09 LRA Table 3.5.1, Item Number 3.5.1-26, under the discussion column, states that freeze-thaw Is not an applicable aging mechanism for these groups of structures at VYNPS. Provide documentation showing the weathering conditions (weathering index) for VYNPS and the specification requiring concrete to have an air content of 3% to 6% and water to cement ratio of 0.35 to 0.45.
Response VYNPS Inaccessible and accessible concrete areas are designed In acc:ordance with American Concrete Institute (ACI) specification ACI 318-63, Building Code Requirements for Reinforced Concrete. VYNPS concrete also meets requirements of later ACI guide ACI 201.2R-77, Guide to Durable Concrete, since both documents use the same American Society for Testing and Material (ASTM) standards for selection, application and testing of concrete.
VYNPS concrete was provided with air content between 3% and 5% and a water/cement ration between 0.44 and 0.60 (Ref. VYNPS site specification EBASCO 15-65, Sections 7.0 and 12.5). VYNPS Is located at severe weathering region (weathering Index >100 day-lnch/yr) as Indicated InASTM C33, FIG. 1.
Although the water/cement ratio falls outside the listed range of 0.35 to 0.45, given all parameters associated with concrete mix design VYNPS concrete meets the quality requirements of ACI to ensure acceptable concrete Is obtained. Nonetheless concrete will be managed under the aging management programs identified in the 3.5.2 tables.
275 Category Open Request A-W-10 For LRA Table 3.5.1, Item Number 3.5.1-27, provide documentation showing that Inaccessible areas concrete was constructed inaccordance with the recommendations InACI 201.2R-77.
Response For construction of concrete, VYNPS site Specification EBASCO 15-65, Concrete Large Work, Identifies the same ASTM standards for achieving durable concrete as those Identified In ACI 201.2R77, 'Guide to durable concrete."
276 Categorv Closed Request A-W-11 For LRA Table 3.5.1, Item Number 3.5.1-33, provide the maximum temperatures that concrete experiences In Group 1 through 5 structures.
Response The VYNPS concrete is expected to experience average general area temperature of 150°F and local area maximum temperature less than 2000F. The drywell cooling system recirculates the drywell atmosphere through heat exchangers to maintain ambient temperature In the drywell between 135 and 1650F (average 150°F). (Ref VYNPS UFSAR 5.2.3.2 and 10.12.3) The concrete temperature around piping penetrations for high temperature lines, such as the steam lines and other reactor system lines Is protected by piping Insulation and air gaps. (Ref UFSAR 5.2.3.4.2).
277 Category Open ReAuest A-W-12 LRA Table 3.5.1, Item Number 3.5.1-41, under the discussion column, states that no vibration Isolation elements at VYNPS are In scope and subject to aging management review. Explain the lack of vibration Isolation elements for HVAC system components, the emergency diesel generator and miscellaneous mechanical equipment.
Response LRA Table 3.5.1 relates only to structures and structural supports. Thus, the statement that no vibration Isolation elements are Inscope and subject to aging management review applies only to structural vibration isolation elements. Vibration Isolation elements for mechanical system components are subject to aging management review. For example, LRA Table 3.3.2-4 contains expansion joint Inthe emergency diesel generator system and LRA Table 3.3.2-10 contains duct flexible connections and expansion joints Inheating, ventilation, and air conditioning systems.
278 Category Accepted Request A-W-13 LRA Table 3.5.1, Item Number 3.5.1-50, under the discussion column, states that loss of material due to pitting and crevice corrosion of groups 82 and B4 galvanized steel, aluminum, and stainless steel components in an outdoor air environment Is not applicable at VYNPS. NUREG-1833 on Page 93 for Item TP-6 states an approved precedent exists for adding this material, environment, aging effect, and program combination to the GALL Report. As shown in RNP SER Section 3.5.2.4.3.2, galvanized steel and stainless steel In an outdoor air environment could result Inloss of material due to constant wetting and drying conditions. Aluminum would also be susceptible to a similar kind of aging effect Inthe outdoor environment. Provide a discussion of the actual group 12 and B4 galvanized steel, aluminum, and stainless steel VYNPS components which are within the scope of license renewal and exposed to an outdoor air environment.
Discuss the location of these components at VYNPS and how they are protected from constant wetting and drying conditions.
Response Loss of material due to pitting and crevice corrosion of aluminum and stainless steel components Inan outdoor environment Is not applicable Ifthe atmospheric environment is non-aggressive. The ambient environment at VYNPS Is not chemically polluted by vapors of sulfur dioxide or other similar substances and the external environment does not contain saltwater or high chloride contenL In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result In any significant loss of material In,aluminum or stainless steel components. The conclusion that no aging effects require management for these materials Inan outdoor air environment Is supported by operating experience and by previously approved staff positions documented inthe Farley SER (NUREG-1825, page 3-314).
Components that may be considered Inthe B2 and B4 grouping consists of those line Items In Table 3.5.2-6 Including the plant specific Note 503. Note 503 provides the basis for concluding the environment is non-aggressive and the conclusion that there are no aging effects requiring management.
The aging management review results for galvanized steel components In outdoor air should Indicate loss of material as an aging effect with structures monitoring as the aging management program. The following discussion applies to the discussion column entry for Item 3.5.1-50.
Consistent with NUREG-1 801 for galvanized steel components Inoutdoor air. The Structures Monitoring Program will manage loss of material.
Loss of material Is not an applicable aging effect for stainless steel or aluminum components In outdoor air. The ambient environment at VYNPS Is not chemically polluted by vapors of sulfur dioxide or other similar substances and the external environment does not contain saltwater or high chlorides. Therefore, loss of material due to pitting and crevice corrosion Is not an aging effect requiring management for aluminum and stainless steel components exposed to the external environment These changes require an amendment to the LRA..
279 Category Open Request A-W-14 LRA Table 3.5.1, Item Number 3.5.1-52, under the discussion column, states that loss of mechanical function due to the listed mechanisms Is not an aging effect.
Proper design prevents distortion, overload, and fatigue due to vibratory and cyclic thermal loads. Explain how loss of mechanical function due to corrosion Is not an aging effect which needs to be managed for the period of extended operation. Ifproper design prevents distortion, overload, and fatigue due to vibratory and cyclic thermal loads, explain Ifthere has never been a component failure at VYNPS due to any of these conditions. Explain ifthere has never been a component failure Inthe nuclear Industry due to any of these conditions. Explain where sliding support bearing and sliding support surfaces are used Incomponent groups B2
.and B4 at VYNPS and provide the environment they are exposed to. '
Response Loss of material due to corrosion Is an aging effect that can cause a loss of Intended function. Loss of mechanical function would be considered a loss of Intended function. Loss of mechanical function Is not an aging effect, but Is the result of aging effects. There have been component failures Inthe Industry due to distortion, overload, and excessive vibration. Such failures typically result from Inadequate design or events rather than the effects of aging. Failures due to cyclic thermal loads are very rare for structural supports due to their relatively low temperatures.
The sliding surface material used at VYNPS Is lubdte, which Isa corrosion resistant material. Components are Inspected under ISI-IWF for torus saddle supports and Structures Monitoring Program for the lubrite components of radial beam seats. Plant operating experience has not identified failure of lubrite components used Instructural applications. No current Industry experience has identified failure associated with lubdte sliding surfaces. Components associated with B2 grouping are limited to the torus radial beam seats and support saddles. There are no sliding support surfaces associated with the B4 component grouping for sliding surfaces at VYNPS.
LRA Table 3.5.1, Item 3.5.1-52 will be revised to read as follows.
"Loss of mechanical function due to the listed mechanisms is not an aging effect. Such failures typically result from Inadequate design or operating events rather than from the effects of aging. Failures due to cyclic thermal loads are rare for structural supports due to their relatively low temperatures."
This requires an amendment to the LRA.
280 Category Open Request A-W-15 LRA Table 3.5.1, Item Number 3.5.1-54, under the discussion column, states that loss of mechanical function due to the listed mechanisms Is not an aging effect.
Proper design prevents distortion, overload, and fatigue due to vibratory and cyclic thermal loads. Explain how loss of mechanical function due to corrosion Is not an aging effect which needs to be managed for the period of extended operation. Ifproper design prevents distortion, overload, and fatigue due to vibratory and cyclic thermal loads, explain Ifthere has never been a component failure at VYNPS due to any of these conditions. Explain ifthere has never been a component failure Inthe nuclear Industry due to any of these conditions. Explain what VYNPS Inspects for during VT-3 visual examinations of groups B1.1, B1.2 and B1.3 components under.its Inservice Inspection Program during its current license and also anticipated VT-3 visual examinations during its possible extended license Response The discussion for Item Number 3.5.1 -54 was not saying that failures have not occurred, but that loss of mechanical function is not an aging effect. For license renewal, Entergy Identifies a number of aging effects that can cause loss of Intended function. Loss of intended function Includes loss of mechanical function.
The loss of function Is not considered an aging effect. Aging effects that could cause loss of mechanical function for components In Item Number 3.5.1-54 are addressed elsewhere inthe aging management reviews. For example, loss of material due to any mechanism is addressed in Table 3.5.2-6 under listings for component and piping supports ASME Class 1, 2, 3 and MC (Page 3.5-70), and component and piping supports (Page 3.5-71). Component failures at VYNPS and in the nuclear industry have certainly occurred due to overload (typically caused by an event such as water hammer) or vibratory and cyclic thermal loads. Because of the low operating temperatures, failures due to cyclic thermal loads are extremely rare for structural commodities. Failures due to distortion or vibratory loads have also occurred due to inadequate design, but rarely ifever, due to the normal effects of aging.
LRA Table 3.5.1, Item 3.5.1-54 will be revised to state:
Loss of mechanical function due to distortion, dirt, overload, fatigue due to vibratory, and cyclic thermal loads Isnot an aging effect requiring management. Such failures typically result from Inadequate design or events rather than the effects of aging. Loss of material due to corrosion, which could cause loss of mechanical function, Is addressed under Item 3.5.1-53 for Groups B1.1, B1.2, and B1.3 support members."
This requires an amendment to the LRA.
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281 Category Open Request A-W-16 LRA Table 3.5.1, Item Number 3.5.1-10, under the discussion column, states that cracking due to stress corrosion cracking for stainless steel penetration sleeves and penetration bellows Is not applicable. Explain Ifthe VYNPS Containment Inservice Inspection Program and Containment Leak Rate Program are used currently to detect cracking of stainless steel penetration sleeves and penetration bellows by inspection and testing. Explain why It is not more appropriate to take credit for these two programs to detect cracking without the need for additional enhanced examinations then to say not applicable.
Response The NUREG-1801 referenced programs involve visual Inspections and leak testing which are not optimum methods for managing SCC. Therefore, when possible, ItIs more appropriate to assess the conditions and identify whether the applicable aging effects require management As stated in section 3.5.2.2.1.7, stress corrosion cracking Is not an aging effect requiring management for the penetration sleeves and bellows, since the conditions necessary for SCC do not exist.
However these components are evaluated for aging effects requiring management, such as cracking, as shown inTable 3.5.2-1 (Reference item for Drywell to torus vent line bellows).
282 Category Open Request A-W-17 LRA Table 3.5.1, item Number 3.5.1-34, under the discussion column, does not make reference to LRA Section 3.5.2.2.2.4 (1)for further evaluation. Explain why this link Is not made to the further evaluation section.
Response NUREG-1 800. Item Number 3.5.1-34 Indicates that further evaluation Is necessary only for aggressive environments. No reference was provided to further evaluation In LRA Section 3.5.2.2.2.4 (1) since the VYNPS environment Is not aggressive as noted InLRA Table 3.5.1, Item Number 3.5.1-34, under the discussion column.
LRA Table 3.5.1, Line Item 3.5.1-34 discussion will be revised to add 'See Section 3.5.2.2.2.4(1)*.
283 Category Open Request A-W-18 LRA Table 3.5.1, Item Number 3.5.1-35, under the discussion column, does not make reference to LRA Section 3.5.2.2.2.4 (2) for further evaluation. Explain why this link is not made to the further evaluation section. Provide a copy of ACI-301 as listed under the discussion.
Response Due to an administrative error the reference to ACI should have been ACl 318 and not ACI 301. LRA Table 3.5.1, Item 3.5.1-35 discussion will be revised to refer to ACI 318. For clarification, a reference to Section 3.5.2.2.2.4(2) will also be added to the discussion.
See also Response 284 This change requires an amendment to the LRA.
284 Category Open Request A-W-19 LRA Table 3.5.1, Item Number 3.5.1-36, under the discussion column, does not make reference to LRA Section 3.5.2.2.2.4 (3)for further evaluation. Explain why this link Is not made to the further evaluation section. The statement: 'See Section 3.5.2.2.2.1 (5)for additional discussion' needs further clarification that this section Isfor Groups 1-5, 7-9, however Itwould apply to accessible Group 6 concrete. Explain why LRA Section 3.5.2.2.2.4 (3) lists cracking of concrete due to Stress Corrosion Cracking (SCC).
Response LRA Table 3.5.1, Une Item Number 3.5.1-36 discussion will be revised to read as follows.
Reaction with aggregates Is not an applicable aging mechanism for VYNPS concrete components.
See Section 3.5.2.2.2.1(5) (although for Groups 1-5, 7, 9 this discussion Is also applicable for Group 6).
See Section 3.5.2.2.2.4(3) additional discussion. Nonetheless, the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components.
Due to an administrative oversight, the heading of LRA Section 3.5.2.2.2.4 (3) Inadvertently lists cracking of concrete due to Stress Corrosion Cracking (SCC). This section heading should have begun with 'Cracking Due to Expansion and Reaction with Aggregates...'. Stress corrosion cracking is not discussed Inthe body of this section.
These changes require an amendment to the LRA.
285 Category Open Request A-W-20 LRA Table 3.5.1, Item Number 3.5.1-37, under the discussion column, states not applicable and makes reference to Section 3.5.2.2.2.4(3). Section 3.5.2.2.2.4(3) discusses Inaccessible areas only. Explain why VYNPS under the discussion section for Item Number 3.5.1-37 does not state: 'Nonetheless, the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components.* This would apply to above grade concrete, like In Line Item 3.5.1-36 for accessible concrete.
Response For clarification, LRA Table 3.5.1, Item Number 3.5.1-37, will be revised to state the following.
'Not applicable. Nonetheless the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components. See Section 3.5.2.2.2.4(3)'.
This change requires an amendment to the LRA.
286 Category Open Request A-W-21 LRA Table 3.5.1, Item Number 3.5.1-40, under the discussion column, states: 'Plant experience has not Identified reduction Inconcrete anchor capacity or other concrete aging mechanisms. Nonetheless, the Structures Monitoring Program will confirm absence of aging effects requiring management for VYNPS concrete components.* The project team cannot find an AMR line Item In Table 2 for this component (Building concrete at locations of expansion and grouted anchors; grout pads for support base plates). Provide the Table 2 number, LRA page number, and component for where this AMR line Item Is evaluated and shown.
Response Building concrete at locations of expansion and grouted anchors; grout pads for support base plates are shown as 'foundation' and 'Reactor vessel support pedestal" In LRA Table 3.5.2-1 (page 3.5-54), 'foundation* InTables 3.5.2-2 thru 3.5.2-5 (pages 3.5-58, 3.5-60, 3.5-62, and 3.5-66), and as 'Equipment pads/foundations" InTable 3.5.2-6 (page 3.5-78). Further evaluation Is provided In LRA section 3.5.2.2.2.6(1), page 3.5-14.
LRA Table 3.5.1, Item Number 3.5.1-40 discussion will be revised to add 'See Section 3.5.2.2.2.6(1)'.
This requires an amendment to the LRA.
287 Category Closed Request 3.1.1-19-P-02 Please clarify the basis for omitting the leak-off lines themselves from Table 3.1.2-1.
Response The head seal leak detection lines are not part of the pressure vessel but are Included InTable 3.1.2-3 with other reactor coolant pressure boundary piping. They are Included on page 3.1-67 with piping and fittings <4"NPS. Plant specific note 104 Identifies the applicability of this aging management review result to the leak detection line.
288 Category Open Request 3.1.1-25-P-01 Please clarify the basis for omitting the jet pump sensing lines from Table 3.1.2-2 Response The jet pump sensing lines do not appear InTable 3.1.2-2 (Reactor Vessel Intemals Summary of Aging Management Evaluation) because the jet pump sensing lines Inside the vessel are not subject to aging management review. These lines are not required to maintain pressure boundary and hence have no license renewal Intended function. The jet pump sensing lines outside the vessel are Included with the piping <4" inTable 3.1.2-3.
289 Category Closed Request 3.1.1-40-P-02 On page 3.1-41, for the stainless incore housings, please confirm that the correct GALL item Is referenced.
Response Many NUREG-1 801, Volume 2 Items are very similar Interms of materials, environment, aging effect and aging management program. Where a NUREG-1 801 item lists the same component, the choice Is straightforward. Where NUREG-1801 does not match the specific component, the selection of the Item to compare to the aging management review results Is somewhat arbitrary. In this case, the components were considered a subset of the reactor vessel (hence the listing within the reactor vessel table) and the comparison was made to the cracking Item within the NUREG-1801 BWR reactor vessel table that best (subjectively) represented the incore housings.
290 Category Closed Request 3.1.1-41-P-02 On page 3.1-41 and 3.1-43, the GALL Items referenced Inthis AMR are for stainless steel and nickel-based alloy components that may be subject to SCO. Itdoes not appear to be appropriate for low-alloy steel. Is there a more suitable GALL Item?
Response The material for these components Is Identified as low allow steel with stainless steel cladding. The material exposed to the Internal environment of reactor coolant (treated water) Is the stainless steel cladding. When evaluating surface aging effects such as cracking and loss of material, the stainless steel cladding Is the material that must match the NUREG-1 801 Item. NUREG-1801 Item IV.A1-1 provides the best match for the material, environment and aging effect combination within the BWR reactor vessel table.
The applicable material for the external environment (air) Is low alloy steel (or steel" InNUREG-1 801 terms).
291 Category Accepted Request 3.1.1-41-P-04 On page 3.1-52, the component type 'thermal sleeves, feedwater Inlets (N4)' is managed using Inservice Inspection andwater chemistry control - BWR. How are the thermal sleeves to be Inspected?
Response The feedwater nozzle thermal sleeves are inTable- 3.1.2-1 BWR. with an Intended function of pressure boundary. Cracking of the thermal sleeves Is managed by Inservice Inspection and Water Chemistry Control Further review of the thermal sleeve design (to determine exactly how ISI Inspects them) determined that the VY sleeves are not welded In place, rather they are an Interference fit. As such, there Is no weld to the pressure boundary piping that can be examined by ISI.
Given that there Is no pressure boundary weld, these sleeves are not part of the pressure boundary. As such they have no Intended function for License Renewal, and with no intended function they are not subject to aging management review1. Therefore, Vermont Yankee will amend the License Renewal Application to Indicate that the feedwater thermal sleeves are not subject to aging management review.
1 The feedwater thermal sleeves have no non-safety affecting safety related (a2) function. They are completely contained within the feedwater piping and cannot spray or leak on other equipment. The feedwater thermal sleeves are a part of the feedwater piping inside the vessel, and failure of that piping does not defeat the delivery of water to the vessel annulus, as any leakage also goes to the vessel annulus.
292 Category Closed Request 3.1.1-51-P-01 On page 3.1-60, the CASS jet pump castings exposed to treated water are managed. Please confirm that GALL item IV.B1-11 applies, and whether there Is a cast orificed fuel support or CRD component that is also managed this way.
Response Same question on #217.
293 Category Accepted Request. 3.3.1-32-K-01 Beginning on page 3.3-94, many component types are managed using the diesel fuel monitoring program. Please confirm that the VYNPS Diesel Fuel Monitoring AMP Is consistent with GALL XI.M32, "One-Time Inspection," as well as with XI.M30, 'Fuel Oil Chemistry.'
Response As stated InLRA Section 3.2.2.9, loss of material due to general, pitting, crevice, and MIC for carbon steel piping and components exposed to fuel oil is managed by the Diesel Fuel Monitoring Program. This program includes sampling and monitoring of fuel oil quality to ensure levels of water, particulates, and sediment remain within the specified limits. Maintaining parameters within limits ensures that significant loss of material will not occur. Ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate will be performed to confirm the effectiveness of the Diesel Fuel Monitoring Program. As stated in LRA Section B.1.9. the Diesel Fuel Monitoring Program is consistent with the program described in NUREG-1801,Section XI.M3, Fuel Oil Chemistry Program, with minor exceptions.
The Diesel Fuel Monitoring Program is not consistent with GALL XI.M32, 'One-Time Inspection,* nor are one-time inspections necessary to verify the effectiveness of the program. The Diesel Fuel Monitoring Program Includes periodic cleaning, visual Inspection, and ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate to confirm the effectiveness of the oil quality monitoring activities to preserve an environment that is not conducive to corrosion.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
This requires and amendment to the LRA.
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294 Catesory Accepted Request 3.3.1-33-K-01 Beginning on page 3.3-71, several component types Ina lube oil environment are managed using the VYNPS oil analysis program. Please confirm that the VYNPS Oil Analysis AMP Isconsistent with GALL XI.M32, "One-Time Inspection," as well as with XI.M39, "Lubricating Oil Analysis." See 3.3.1-14-K-01 Response As stated InLRA Section 3.2.2.7, steel piping and components In auxiliary systems at VYNPS that are exposed to lubricating oil are managed by the Oil Analysis Program, which Includes periodic sampling and analysis of lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment that Is not conducive to corrosion. As stated InLRA Section B.1.20, the Oil Analysis Program Is consistent with the program described InNUREG-1 801,Section XI.M39, Lubricating Oil Analysis, with a minor exception.
The Oil Analysis Program Is not consistent with GALL XI.M32, "One-Time Inspection," nor are one-time Inspections necessary to verify the effectiveness of the program. Metals are not corroded by the hydrocarbon components of lubricants. Lubricating oils are not good electrolytes and the oil film on the wetted surfaces of components tends to minimize the potential for corrosion. Corrosion Inlube oil systems only occurs as the result of the presence of impurities or moisture.
Therefore, an effective oil analysis program, which maintains Impurities and moisture below specified limits, precludes the need for one-time Inspections.
Operating experience at VYNPS has confirmed the effectiveness of the Oil Analysis Program Inmaintaining moisture and Impurities within limits such that corrosion has not and will not affect the Intended functions of these components.
In numerous past precedents (including NUREG-1 828, Arkansas Nuclear One Unit 2 SER, Section 3.0.3.3.6, and NUREG-1831, Donald C. Cook SER, Section 3.0.3.3.8), the staff concluded that an effective oil analysis program, which maintains impurities and moisture below specified limits, Issufficient to demonstrate that the effects of aging will be adequately managed so that the Intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
This requires and amendment to the LRA.
295 Category Accepted Request 3.3.1-38-K-01 Beginning on page 3.3-138, SCC of many stainless steel components exposed to reactor coolant above 140F Is managed by the water chemistry - BWR program.
Provide documentation that demonstrates that these are outside the scope of the BWR SCC program. Also, please clarity how the effectiveness of the AMP will be verified. (Since some of these components are <NPS 4, the review team understands that they are outside the scope of the BWR SCC program. However, it is not clear whether OTI for small-bore piping will be used or the OTI Included Inthe VYNPS water chemistry programs.
Response LRA Table 3.3.2-11 Includes stainless steel post-accident sampling system (PASS) sample line tubing and valves that are.exposed to treated water or steam from the reactor coolant system on internal surfaces.. The components are less than 4" NPS and are outside the Class I reactor coolant system (RCS) pressure boundary. They are, therefore, outside the scope of the BWR SCC program. Aging of the PASS sample line tubing and valves Is managed by the Water Chemistry Control - BWR Program, which Isverified by the One-Time Inspection Program. To provide further clarification, the effectiveness of the Water Chemistry Control -
Auxiliary Systems, BWR, and Closed Cooling Water programs Isconfirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A,SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs. However, inspections performed under the small-bore piping activity, which applies to components within the Class-I RCS pressure boundary, will also provide data useful for evaluating the condition of these downstream components.
296 Category Closed Request 3.3.1-40-K-01 On page 3.3-97, a carbon steel tank Is addressed. Please describe how the system walkdown program will satisfy the recommendations of GALL AMP XL.M29, "Aboveground Steel Tanks."
Response The tanks described on page 3.3-97 are diesel fuel oil tanks with external protective coatings.
The attributes In GALL AMP XI.M29, 'Aboveground Steel Tanks* Include preventive measures to mitigate corrosion by protecting the external surface of steel tanks with paint or coatings Inaccordance with standard Industry practice. This program relies on periodic system walkdowns to monitor degradation of the protective paint or coating. This program also monitors corrosion at Inaccessible locations such as the tank bottom by thickness measurement.
The System Walkdown Program provides the preventive measures to protect the external accessible surfaces by visual Inspection of carbon steel tanks to Identify degradation of coatings, sealants, and caulking plus Indications of leakage. Readily accessible tank surfaces are inspected at least once per refueling cycle and are normally performed more frequently.
Corrosion at Inaccessible locations of the tank Is addressed by thickness measurements conducted as part of the Diesel Fuel Monitoring Program. This program applies to the concrete (ext) environment for the tank bottom as shown on page 3.3-97.
Protective coatings on accessible external surfaces are repaired as part of the corrective action process following periodic Inspection. Corrective action is taken as necessary on the tank bottom should minimum wall requirements not be maintained.
These combined actions satisfy the requirements of the GALL AMP XI.M29, *Aboveground Steel Tanks.
297 Category Accepted Request 3.3.1-47-K.01 Beginning on page 3.3-72, gray cast Iron and carbon steel exposed to treated water Is managed using the WC-CCW program. GALL recommends performance monitoring to confirm the effectiveness of the CCCW program. Please Identify an acceptable alternative method that will be used to verify the effectiveness of the WC - CCW program.
Response The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated inLRA Section B.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described InNUREG-1 801,Section XI.M32, 'One-Time Inspection."
LRA Tables 3.1.1, 3.2.1, 3.3.1, and 3.4.1 Indicate that the One-Time Inspection Program Is credited along with the water chemistry control programs for line Items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program Isapplicable to each water chemistry control program, it Is also applicable to each line item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A,SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
298 Catecgory Accepted Request 3.3.1-58-K-01 On page 3.3-121, loss of material from external surfaces of a tank Is managed using the system walkdown program Instead of the fire protection program. Since the tank In question Is Inthe FP system, please confirm that the FP AMP does not manage this aging effect Response This tank is inthe C02 system. The system walkdown program was selected since ItIs the program that is the most used for managing external aging effects of components Inalmost all systems similar to the External Surfaces Monitoring Program InGALL. Inspections Inthis program must be performed at least once per refueling. The GALL AMP XI.M26, Fire Protection requires visual Inspection once every six months for C02 system components where the system walkdown frequency is once each refueling cycle. Since aging effects for this tank external surface in indoor air would be manifested over several years, it was determined that this variation InInspection frequency is not significant such that system walkdown was still appropriate. However, per license renewal commitment 30, VYNPS will perform C02 system walkdowns every six months starting ho later than the beginning of the period of extended operation.
299 Category Closed Request 3.3.1-68-K-01 On page 3.3-194, ioss of material from carbon steel components Is managed using PS&PM. Please explain the Intended function (pressure boundary) of the instrument air system and how it relates to the a(2) category to which the system has been assigned. Also, please explain how thlis GALL v2 Item was chosen, since it invokes a fire protection AMP.
Response For components Included for (a)(2) the pressure boundary function Istwo fold. The first isthe pressure boundary of the passive component that ensures that the component cannot spatially Interact through spray or leakage onto a safety related components. The second applies for non-safety components connected to safety related components where the non-safety components provide structural support for the safety related such that loss of pressure boundary would be Indicative of structural Integrity. For the carbon steel components containing untreated water that are managed by PSPM the pressure boundary function Is only for preventing spray or leakage.
The Instrument air system Is an auxiliary system. This GALL Item was chosen because inchapter VII for Auxiliary systems Itwas the best match for a material, environment, aging effect combination. A note E was selected since a different program than Fire Protection was Invoked.
300 Categorv Open Request 3.3.1-68-K-02 On page 3.3-213, loss of material from carbon steel components Is managed using OTI. Please explain how this GALL v2 Item was chosen, and Justify the use of OTI for carbon steel exposed to raw water as opposed to a periodic Inspection.
Response The environment for these components Isuntreated water from the radwaste system which Isdefined Intable 3.0-1 of the LRA as water that was originally treated but now may contain contaminants. Carbon steel In treated water Is not expected to experience any significant aging effects. As a result this untreated water environment Isnot expected to result Insignificant aging such as loss of material, however a one time Inspection will be performed to confirm the absence of significant aging effects. Ifsignificant aging Is found to be occurring the corrective action program will determine the need for future inspections Including a periodic inspection or possible replacement.
This GALL line Item was chosen since the radwaste system Isan auxiliary system In GALL chapter VII. For the material, environment, and aging effect combination of this Item, (where untreated water Is equivalent to raw water) this line Item was the most appropriate. A note E was selected since a different program was used.
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