ML062780255

Email: (PA) VY LRA Lists

ML062780255
Person / Time
Site:	Vermont Yankee
Issue date:	06/21/2006
From:	Hamer M Entergy Nuclear Vermont Yankee
To:	Johnny Eads, Rowley J NRC/NRR/ADRA/DPR
References
%dam200611, TAC MC2297
Download: ML062780255 (36)

Text

. ard - VY LRA Lists "o-.ent oPagei1l From: "Hamer, Mike" <mhamer@entergy.com>

To: "Jonathan Rowley" <JGR@nrc.gov>, "Johnny Eads" <JHE@nrc.gov>

Date: 6/21/2006 5:43:57 PM

Subject:

VY LRA Lists Attached are the VYNPS LRA Amendment List, Rev. 0 and the LR Commitment List Rev. 0. We will be formally communicating the LR Commitment List under Oath and Affirmation on or before 06/28 as Amendment 3 to the LRA.

The letter has been drafted and is being routed for approval.

<<VY LR Comm. List Rev. 0.pdf>> <<VY LRA Amend. List Rev. 0.pdf>>

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VY LRA Lists Creation Date 6/21/2006 5:42:53 PM From: "Hamer, Mike" <mhamer@entergy.com>

Created By: mhamer@entergy.com Recipients nrc.gov TWGWPO03.HQGWDO01 JGR (Jonathan Rowley) nrc.gov OWGWPO02.HQGWDO01 JHE (Johnny Eads)

Post Office Route TWGWPO03.HQGWDOO1 nrc.gov OWGWPO02.HQGWDO01 nrc.gov Files Size Date & Time MESSAGE 349 6/21/2006 5:42:53 PM TEXT.htm 2055 VY LR Comm. List Rev. 0.pdf 415137 VY LRA Amend. List Rev. 0.pdf 1205424 Mime.822 1 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 During the development and review of the Vermont Yankee Nuclear Power Station License Renewal Application, Entergy made commitments to provide aging management programs to manage the effects of aging on structures and components during the extended period of operation. The following table lists these license renewal commitments, along with the implementation schedule and the source of the commitment. I.

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

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

years and at least two-thirds within the first 12 years of the period of extended operation. Locations selected for examination will be areas that have exceeded the neutron fluence threshold.

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

4 The Diesel Fuel Monitoring Program will be enhanced to specify . March 21, 2012 BVY 06-009 B.1.9 UT measurements of the fuel oil storage tank bottom surface will have acceptance criterion ? 60% Tnom.

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

Page 1 of 7 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 I Ib ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 6 A computerized monitoring program (e.g., FatiguePro) will be March 21, 2012 BVY,06-009 B.1.11 used to directly determine cumulative fatigue usage factors (CUFs) for locations of interest.

7 The allowable number of effective transients will be established March 21, 2012 BVY 06-009 B.1.1 1 for monitored transients. This will allow quantitative projection of future margin.

8 Procedures will be enhanced to specify that fire damper frames March 21,'2012 BVY 06-009 B.1.12.1/Audit in fire barriers shall be inspected for corrosion. Acceptance Items 35, criteria will be enhanced to verify no significant corrosion. 151, 152 &

153 9 Procedures will be enhanced to state that the diesel engine sub- March 21, 2012 BVY 06-009 B.1.12.1/Audit systems (including the fuel supply line) shall be observed while Items 33, 150 the pump is running. Acceptance criteria will be enhanced to & 155 verify that the diesel engine did not exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust

___gas leakage.

10 The Fire Water System Program will be enhanced to specify that Within ten years after BVY 06-009 B.1.12.2 a sample of sprinkler heads will be inspected using guidance of entering the period of NFPA 25 (2002.edition), Section 5.3.1.1.1. NFPA 25 also extended operation contains guidance to repeat this sampling every 10 years after initial field service testing. - I Page 2 of 7.

06/21/2006

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ

_Comments 11 The Fire Water System Program will be enhanced to specify that March 21, 2012 BVY,06-009 B.1.12.2/Audit wall thickness evaluations of fire protection piping will be Items 37 &41 performed on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections will be performed before the end of the current operating term and at intervals thereafter during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

12 Implement the Heat Exchanger Monitoring Program as described March 21, 2012 BVY 06-009 B.1.14 in LRA Section B.1.14.

13 Implement the Non-EQ Inaccessible Medium-Voltage Cable March 21, 2012 BVY 06-009 B.1.17 Program as described in LRA Section B.1.17.

14 Implement the Non-EQ Instrumentation Circuits Test Review March 21, 2012 BVY 06-009 B.1.18 Program as described in LRA Section B.1.18.

15 Implement the Non-EQ Insulated Cables and Connections March 21,2012 BVY 06-009 B.1.19 Program as described in LRA Section B.1.19.

16 Implement the One-Time Inspection Program as described in March 21, 2012 BVY 06-009 B.1.21/Audit LRA Section B.1.21. Include destructive or non-destructive Item 330 examination of one (1) socket welded connection using techniques proven by past industry experience to be effective for the identification of cracking in small bore socket welds. Should an inspection opportunity not occur (e.g., socket weld failure or socket weld replacement), a susceptible small-bore socket weld will be examined either destructively or non-destructively prior to entering the period of extended operation.

Page 3 of 7 06/21/2006

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section No./

Comments 17 Enhance the Periodic Surveillance and Preventive Maintenance March 21, 2012 BVY,06-009 B.1.22 Program as necessary to assure that the effects of aging will be 1managed as described in LRA Section B.1.22.

18 Enhance the Reactor Vessel Surveillance Program to March 21, 2012 BVY 06-009 B.11.24 proceduralize the data analysis, acceptance criteria, and corrective actions described in the program description in LRA Section B.1.24.

19 Implement the Selective Leaching Program as described in LRA March 21, 2012 BVY 06-009 B.1.25 Section B.1.19.

20 Enhance the Structures Monitoring Program to specify that March 21, 2012 BVY 06-009 B.1.27.2 process facility crane rails and girders condensate storage tank (CST) enclosure, CO 2 tank enclosure, N2 tank enclosure and restraining wall, CST pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man-way seals and gaskets, and hatch seals and gaskets are included in the I program.

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

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

23 Guidance for performing structural examinations of PVC cooling March 21, 2012 BVY 06-009 B.1.27.2 tower fill to identify cracking and change in material properties will be added to the Structures Monitoring Program procedure.

Page 4 of 7 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section No./

Comments 24 System walkdown guidance documents will be enhanced to March 21, 2012 BVY,06-009 B.1.28/Audit perform periodic system engineer inspections of systems in Items 187, scope and subject to aging management review for license 188 & 190 renewal in accordance with 10 CFR 54.4 (a)(1) and (a)(3).

Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject system will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(2).

25 Implement the Thermal Aging and Neutron Irradiation March 21, 2012 BVY 06-009 B.1.29 Embrittlement of Cast Austenitic Stainless Steel (CASS)

Program as described in LRA Section B.1.29.

26 Procedures will be enhanced to flush the John Deere Diesel March 21, 2012 BVY 06-009 B.1.30.1/Audit Generator cooling water system and replace the coolant and Items 84 &

coolant conditioner every three years. 164 Page 5 of 7 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 27 For each location that may exceed a CUF of 1.0 when March 21, 2012 BVY-06-058 4.3.3/ Audit considering environmental effects, VYNPS will implement one or Items 29, 107 more of the following: March 21,2010 for & 318 (1) further refinement of the fatigue analyses to lower the performing a fatigue predicted CUFs to less than 1.0; analysis that addresses (2) management of fatigue at the affected locations by an the effects of reactor inspection program that has been reviewed and approved by the coolant environment on NRC (e.g., periodic non-destructive examination of the affected fatigue (in accordance locations at inspection intervals to be determined by a method with an NRC approved acceptable to the NRC); version of the ASME (3) repair or replacement of the affected locations. Code)

Should VYNPS select the option to manage environmental-assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be provided to the NRC prior to the 1period of extended operation.

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

30 Revise System Walkdown Program to specify C02 system March 21,2012 BV%406-009 B.1.28/Audit inspections every 6 months. Items 30, 141, 146 &

.1298 Page 6 of 7 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 0 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 31 Revise Fire Water System Program to specify annual fire hydrant March 21, 2012 BVY,06-009 B.1.12.2/

gasket inspections and flow tests. Audit Items 1 _39 &40 32 Implement the Metal Enclosed Bus Program In accordance with March 21, 2012 BVY 06-058 Audit Item 97 a license renewal application amendment.

33 Enhance the Structures Monitoring Program to ensure an March 21, 2012 BVY 06-009 B.1.27/ Audit engineering evaluation is made on a periodic basis of Item 77 groundwater samples to assess aggressiveness of groundwater to concrete.

34 Implement the Bolting Integrity Program in accordance with a March 21, 2012 BVY 06-058 Audit Items license renewal application amendment. 198,216, 218,237,331

& 333 Page 7 of 7 06/21/2006

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment, Nn. Item Nn. *¢tinn Nn. Dlnt. (Yu* I No*I fle~rIntlnn I Tnnk NRC Ar~~~Inn Nn.

001 N/A N/A EPU Power Change ML060800223 03/15/06 NO 002 N/A N/A Drywell Shell Information ML061380079 05/15/06 NO 003 N/A N/A LRA Commitment List 06/28/06 NO 11 B.1.7 Accessible regions of the core shroud welds 1, H2 & H3 are NO UT examined lAW BWRVIP-76. Portions of the total accessible regions of H1, H2 & H3 are characterized as design reliant analysis performed by the shroud repair designer determined the minimum design reliant weld lengths.

1. The exception to the BWR vessel internals program related to the core shroud (page B-27) will be deleted.

2. Exception Note #1 on page B- 29 will be deleted.

26 B.1.10 LRA Appendix B.1.10 will be revised to add the following: NO VYNPS may perform re-analysis of an aging evaluation in order to extend the qualification of electrical components under 10 CFR 50.49 on a routine basis as part of the plant's EQ program. Important attributes for the re-analysis of an aging evaluation Include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions. [See LR D-Base for further details]

48 B.1.17 LRA Appendix B.1.17 will be revised to include the following: NO VYNPS inspection for water accumulation in manholes Is conducted by a plant procedure. An engineering evaluation will be used per EN-LI-1 02 to document and determine the plant experience that Is considered In manhole Inspection frequency.

Page 1 of 26 06/21/2006

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA No. Submittal Commitment -

Item No. Section No. Description I Topic NRC Accession No.

- p I F F

Date I ~

(Yes I No) 51 B.1.18 LRA Appendix B.1.18 will be revised as follows: NO The first test of neutron monitoring system cables that are disconnected during instrument calibrations shall be completed before the period of extended operation and subsequent tests will occur at least every 10 years. In accordance with the Corrective Action Program, an engineering evaluation will be performed when test acceptance criteria are not met and corrective actions, including modified inspection frequency will be implemented to ensure that the intended functions of the cables can be maintained consistent with the current licensing basis for the period of extended operation.

53 B.1.19 The LRA Appendix B.1.19 program description will be NO changed to read as follows:

This program addresses cables and connections at plants whose configuration is such that most cables and connections installed in adverse localized environments are accessible.

This program can be thought of as a sampling program.

Selected cables and connections from accessible areas will be*

inspected and represent, with reasonable assurance, all cables and connections in the adverse localized environments. Ifan unacceptable condition or situation Is identified for a cable or connection in the inspection sample, a determination will be made as to whether the same condition or situation is applicable to other accessible cables or connections. The sample size will be increased based on an evaluation per EN-L-1i 02 - Corrective Action Process.

Page 2 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment*

No. Item No. Section No. Description I Topic NRC Accession No. Date

-- . p p

(Yes I No) 64 B.1.23 As noted in GALL,Section XI.M3, [Element Number ten (10) - NO "Operating Experience']; GALL-recommended programs 1.

should have provisions regarding Inspection techniques and evaluation. VYNPS states, in its explanation of the existing program, that '...recent (2002 and 2) visual and ultrasonic inspections...revealed no recordable indications...". The NRC has asked VYNPS to compare examinations performed In 2002 and 2 with the "exception-stated" examination technique proposed for future examinations and to provide to the staff the results of this comparison.

The 2002 examinations included visual and ultrasonic inspections. The 2 examinations were visual only as per the stated exception. Future examination will be visual only in accordance with ASME Code Case N-652. Code Case N-652 has been endorsed by the NRC per Table 1 of Regulatory Guide 1.147. Revision 14. As this Code Case is now endorsed, this inspection Is no longer an exception to GALL.

The LRA Supplement Letter will revoke this GALL exception.

3.6.2.2.3 & LRA Table 3.6.1 and section 3.6.2.2.3 will be revised as NO Table 3.6.1 shown below:

Table 3.6.1 item # 12 - Transmission conductors and connections.

Aging Effects - Section 3.6.2.2.3 See LR D-Base for details.

B.1.2.3 GALL Exception Changed NO The existing examinations'for the reactor vessel closure studs (Category B-G-2) are based on ASME Code Case N-652.

Code Case N-652 has been endorsed by the NRC per Table 1 of Regulatory Guide 1.147, Revision 14. As this Code Case Is now endorsed, this Inspection Is no longer an exception to GALL. The LRA Supplement Letter will revoke this GALL exception.

Page 3 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment Nn Item Nn Dlaarlrntinn ! Tonie NRC Aeeeaakrn Nn. Date (Yea I No1I -

118 B.1.17 LRA Appendix B.1.17 will be revised to state that the specific NO type of test to be performed will be determined prior to the initial test and Is to be a proven test for detecting deterioration of the insulation system due to wetting as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed.

120 B.1.17 Currently AMP B.1.17 defines medium-voltage cable voltage level from 2kV to 15kV. NO LRA Appendix B.1.17 will be revised to define medium-voltage cable as voltage level from 2kV to 35kV.

124 B.1.19 The VYNPS B.1.19 will be revised to state that the program NO applies to accessible electrical cables and connections within the scope of license renewal that are installed in adverse localized environments caused by heat or radiation in the presence of oxygen.

143 B.1.18 a) B.1.18 will be revised under parameter NO monitored/inspected to state that the parameters monitored are determined from the specific calibration, surveillances or testing performed and are based on the specific instrumentation circuit under surveillance or being calibrated, as documented In plant procedures.

LRPD-02, Rev 2 Incorporated this change.

(b) B.1.18 under parameter monitored/inspected will state that the parameters monitored are determined from the specific calibration, surveillances or testing performed. The parameter for cable testing is determined from the plant procedures.

Cable testing Is performed by plant procedures on cables In-scope of XI.E2 that are disconnected during Instrument calibration.

Page 4 of 26 06/21/2006 T, ........

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment -

No. Ittm No. Rnetlon No. De~crintion I Tonie NRC A .qqlnn Nn flntn I~nr. I Nn*

159 B.1.12.1 Regarding Inspection of fire dampers, surveillance Test #7134 NO is the Operating Cycle Test of Fire Barrier Dampers, using procedure OP 4019. VY will add Fire Dampers to the program description.

165 B.1.30.1 Items 3.3.1-50 and 3.3.1-51 in LRA Table 3.3.1 will be NO updated to reflect that the de-mineralized water system is managed by the Water Chemistry Control - BWR Program,.

as indicated in LRA Table 3.3.2-13-12, aging of components.

203 3.1.1-19 All piping and fittings less than 4" NPS, except for the head NO 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 IS! program includes piping and fittings less than 47 NPS. The LRA will be clarified to indicate that ISI in addition to water chemistry control - BWR and OTI applies to these components.

224 3.3.1 The One-Time Inspection program will be revised to include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

225 3.3.1 The One-Time Inspection program will be revised to Include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

226 3.3.1 The One-Time Inspection program will be revised to include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

Page 5 of 26 06/21/2006

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR" Related Amend. Audit LRA Submittal Commitment NO. Item No. Section No. Desorlotlon I Toolc NRC Ac~cession No. Date (Yes I No*

227 3.3.1 To provide further clarification, the effectiveness of the Water NO.

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.

229 3.3.1 The One-Time Inspection program will be revised to include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

232 3.3.1 To provide further clarification, the effectiveness of the Water NO 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 3.3.1 To provide further clarification, the effectiveness of the Water NO 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.

235 3.3.1 The NUREG-1801 Vol. 2 Item should be VII.F1-8 rather than NO VIII.F1-8 for these lines.

Page 6 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment No. Item No. Section No. Description I Topic NRC Accession No. Date (Yes I No) 239 3.3.1 LRA Table 3.3.1 indicates that the One-Time Inspection YES 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.

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.

J d~ i Page 7 of 26 06/21/2006

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment, No. Item No. Section No. Description ! Tooic NRC Accession No. Date (Yes I No1 240 3.3.1 LRA Table 3.4.1 Indicates that the One-Time Inspection YES 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.

Page 8 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment -

No. Item No. Section No. DescriDtion I Tonic NRC Accession No. Date (Yes I Nol NRC Aceso No bat (Ys/

242 3.5.1 Table 3.5.2-1 on Page 3.5-50 of the LRA, for component NO Bellows (reactor vessel and drywell) is not consistent with the I.

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 in Table 2.4-1 should be deleted. The reactor vessel and drywell bellows perform no license renewal Intended function. These components are not safety-related and are not required to demonstrate compliance with regulations identified in 10 CFR 54.4(a)(3). Failure of the bellows will not prevent satisfactory accomplishment of a safety function. Leakage, if any, through the bellows Is directed to a drain system that prevents the leakage from contacting the outer surface of the drywell shell.

243 3.5.1 The LRA will be amended as follows: NO 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-1801 item are loss of sealing and leakage. Loss of sealing Is a consequence of the aging effects cracking and changes In material properties.

For VYNPS, the Containment Leak Rate Program manages cracking and changes 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."

244 3.5.2 Table 3.5.2.6 on Page 3.5-80 of the LRA, for component seals NO and gaskets (doors, man-ways and hatches), material rubber in a protected from weather environment; the aging effects are cracking and change In material properties. The LRA will be clarified to indicate that Note WA" applies to the line for SMP.

Page 9 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment, No. Item No,. Section No. Descriotlon / Toolc NRC Accession No. Date (Yes I No*

248 3.5.2 Table 3.5.2-6, Page 3.5-72, Note "A"will be changed to Note NO "C" for component electrical and instrument panels and enclosures, material galvanized steel in a protected from weather environment.

249 3.5.2 in Table 3.5.2-6, Page 3.5-73, Note "A"will be changed to NO Note "C"for component flood curb, material galvanized steel In a protected from weather environment.

250 3.5.2 Table 3.5.2-1, Page 3.5-53 for component Torus shell with the NO aging effect cracking-fatigue, the note assigned is E. Note E is consistent with NUREG-1 801 material, environment, and aging effect but a different aging management program Is credited. Note A should be applied here. The LRA will be.

amended to indicate Note A.

255 3.5.2 In Table 3.5.2-5 on Page 3.5-65 of the LRA, for component NO Transmission towers, material galvanized steel in an exposed to weather environment; the aging effect is none.

As identified in the response to question A-W-1 3, loss of material Is the aging effect requiring management and the Structures Monitoring Program is the aging management program. This is consistent NUREG-1 801 Vol. 2 Item !11.B4-7, summarized inTable 1 Item 3.5.1-50, and Note C applies.

257 3.5.2 In Table 3.5.2-6 on Page 3.5-71 of the LRA, for component NO conduit, material galvanized steel in an exposed to weather environment; the aging effect is none As identified in the response to question A-W-1 3, 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 II1.B4-7, summarized in Table 1 Item 3.5.1-50, and Note C applies.

Page 10 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment -

No. Item No. Section No. Descriotion / Tooic Date (Yes I No*

NRC Accession No.

258 3.5.2 In Table 3.5.2-6 on Page 3.5-71 of the LRA, for component NO conduit support, 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.

As identified in the response to question A-W-1 3, 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 11.1.B4-7, summarized in Table 1 Item 3.5.1-50, and Note C applies.

259 3.5.2 Table 3.5.2-6, Page 3.5-72 of the LRA, for component NO 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.

As identif led Inthe 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 Isconsistent NUREG-1 801 Vol. 2 Item Ill.B4-7, summarized InTable 1 Item 3.5.1-50, and Note C applies.

263 3.5.2 Table 3.5.2-6 on Page 3.5-78 of the LRA, for component NO structural bolting, 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.

As Identified in the response to question A-W-1 3, 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 IIl.B4-7, summarized InTable 1 Item 3.5.1-50, and Note C applies.

Page 11 of 26 06/21/2006

• .-. *i,*,f.... ,*: . ".... . .o . ~..

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitments No. Item No. Section No. .Descriotion I Toole NRC Accession No. Date (Yes I Nol

.... I Dat (Ye .. No)..*.

.d 266 3.5.2 For LRA Table 3.5.1, Item 3.5.1-5, the discussion column NO 3.5.1 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 Inservice 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.

Page 12 of 26 06/21/2006 C.*. ...

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment No. Item No. Section No. Description / Topic NRC Accession No. Date

- . .. I (Yes I No) 267 3.5.2 1) The LRA will be amended to reflect the following changes. NO The following line for the torus penetrations will be added to Table 3.5.2-1:

Torus mechanical penetrations PB, SSR Carbon steel Protected from weather Cracking*

(fatigue) TLAA-metal fatigue II.B4-4 (C-13) 3.5.1 9A

2) 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 torus vent system PB, SSR Carbon steel Protected from weather Cracking (fatigue) TLAA-metal fatigue ll.B1.1-4 (C-21) 3.5.1 8 A

3) The discussion column entry for Table 3.5.1 item 3.5.1-8 will be changed to state:

Fatigue analysis is a TLAA for the torus shell. Fatigue of the torus to drywell vent system is event driven and the analysis is not a TLAA. See Section 3.5.2.2.1.6.

4) 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.

5) 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 in Section 4. Fatigue TLAAs for the torus and associated penetrations are evaluated and documented in Section 4.6.

[continued on next page]

I I I I.

Page 13 of 26 06/21/2006

.*. ... *.".. .. *... ....... .. ", ..... . '.... .. °.* .. :....*

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA .

No. Item No. Section No. Submittal Commitment -

Descriation I Tooio NRC Accession No. Date (Yes I No*

-R

.. Ac.......... e so No Cont. Cont. Cont.. 6) Section 3.5.2.3, Time-Umited Aging Analyses, will be Dat . (Ye

/... o NO changed to state:

TLAA Identified for structural components and commodities include fatigue analyses for the torus and torus penetrations.

These topics are discussed in Section 4.6.

268 3.5.2 1) A link from hems 3.5.1-12 and 3.5.1-13 will be added to NO section 3.5.2.2.1.8.

2) 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.

269 3.5.2 See Item 268 Response NO 270 3.5.1 For clarity, drywell floor liner seal will be changed to drywell NO shell to floor seal (moisture barrier). (Also see audit questions

1. 76 and 243 which address changes to the LRA) 278 3.5..2 The aging management review results for galvanized steel NO 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.

See Item 278 in D-Base for additional details.

279 3.5.1 LRA Table 3.5.1, Item 3.5.1-52 will be revised to read as NO 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.'

Page 14 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA No. Item No. Submittal Commitment Section No. Descrlition I Tocio NRC Accession No. Date No. Itm

..... No (Yes INo) 280 3.5.1 LRA Table 3.5.1, Item 3.5.1-54 will be revised to state: Date...* .. .

NO Loss of mechanical function due to distortion, dirt, overload, and fatigue due to vibratory, and cyclic thermal loads is not 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 81.1, B1.2, and B1.3 support members."

282 3.5.2 LRA Table 3.5,1, Line Item 3.5.1-34 discussion will be revised NO to add "See Section 3.5.2.2.2.4(1)".

283 3.5.1 Due to an administrative error the reference to ACI should NO 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 284 284 3.5.1 LRA Table 3.5.1, Line item Number 3.5.1-36 discussion will be NO 3.5.2 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...".

Page 15 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment6 No. Item No. Section No. Description I Toolc NRC Accession No. Date (Yes I No*

285 3.5.1 For clarification, LRA Table 3.5.1, Item Number 3.5.1-37, will NO 3.5.2 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)'.

286 3.5.1 LRA Table 3.5.1, Item Number 3.5.1-40 discussion will be NO revised to add "See Section 3.5.2.2.2.6(1)".

291 3.1.1 VYNPS will amend the LRA to Indicate that the feedwater NO thermal sleeves are not subject to aging management review.

293 3.3.1 The One-Time Inspection program will be revised to Include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

294 3.3.1 The One-Time Inspection program will be revised to include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

Page 16 of 26 06/21/2006.

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment -

No. Item No. Section No. Description I Topic NRC Accession No. Date (Yea I No) 295 3.3.2 LRA Table 3.3.2-11 includes stainless steel post-accident NO 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 is verified 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 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. 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.

-. i I I I Page 17 of 26 06/21/2006

• .. ~* :C ..... ¢, * .. '

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment No. Item No. Section No. Description I Topic NRC Accession No. Date (Yes / No)

.297 3.1.1 LRA Tables 3.1.1, 3.2.1, 3.3.1, and 3.4.1 indicate that the NO 3.2.1 One-Time Inspection Program is credited along with the water 3.3.1 chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry 3.4.1 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.

310 3.1.1 LRA Tables 3.1.1, 3.2.1, 3.3.1, and 3.4.1 indicate that the NO 3.2.1 One-Time Inspection Program is credited along with the water 3.3.1 chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry 3.4.1 control.

To provide further clarification 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.

Page 18 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related' Amend. Audit LRA Submittal Commitment" NO. Item No. Section No. DescrIDtlon I ToDic NRC Accession No. Da~te (Ye I No*

312 B.3.2.2 To clarify that the Water Chemistry Control - Auxiliary NO Systems, BWR, and Closed CoolingWater programs is confirmed by the One-Time Inspection program a change is required to 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.

313 B.3.2.2 To provide further clarification of the Water Chemistry Control NO

- 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.

315 B.3.2.2 The One-Time Inspection program will be revised to Include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

318 4.3.1 LRA table 4.3-1 will be amended to remove the NUREG/CR- YES 6260 values. Entries will be removed for core spraysafe end, feedwater piping, RHR return piping, and RR piping tee.

Page 19 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment "

No. Item No. Section No. Description I Topic NRC Accession No. Date (Yes / No) 319 4.3.1.1 The last paragraph of Section 4.3.1.1 will be clarified as NO follows.

The VYNPS Fatigue Monitoring Program will assure that the allowed number of transient cycles is not exceeded. The program requires corrective action Iftransient cycle limits are approached. Consequently, the TLAA (fatigue analyses) based on those transients will remain valid for the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(i).

However, when the effects of reactor coolant environment on fatigue are added to the existing fatigue analyses, several locations have a projected cumulative usage factor In excess of 1.0. See section 4.3.3 for further discussion of the effects of reactor water environment on fatigue.

320 Ref. 4.3-1 The correct reference Is letter BVY96-96, not 96-48. The NO originator, addressee, title and date were correct, only the letter number was wrong. The following Isthe correct citation for Reference 4.3-1.

4.3-1 Sojka, R. E. (VYNPS), to USNRC Document Control Desk, "Response to Request for Additional Information Regarding Vermont Yankee Core Shroud Modification," BVY 96- 96, letter dated August 7, 1996.

Tables 3.1.2-1,3.1.2-2, and 3.1.2-3 will be revised to eliminate NO

'"TLAA - metal fatigue" whenever there is no corresponding TLAA in Section 4.0.

Page 20 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment No. Item No. Section No. Descrlotion ! Tooic NRC Accession No. Date (Yes I No*

... .. .. ,io ... .. Toni

.I ... . . . .. . . .. Dat . (Ye No)...

4.3.1.3 Section 4.3.1.3 should read as follows. NO "VYNPS replaced reactor recirculation (RR) system piping in 1986. Also replaced were connecting portions of the residual heat removal (RHR) system piping. The new piping was designed and analyzed to ANSI B31.1 but was Inspected and tested to ASME Section III requirements. Stress analyses for the reactor recirculatlon system were performed to B31.1 requirements. These analyses were not based on any time-limited assumptions and as such are not TLAA.

Page 21 of 26 06/21/2006 t:.

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related.

Amend. Audit LRA Submittal Commitment -

No. Item No. Section No. Description / Topic NRC Accession No. Date (Yes I No)

I F I I 335 3.5.2-6 In Table 3.5.2-6 on Page 3.5-80: NO

1) Delete line item:

Penetration sealant (fire, flood, radiation)

- EN, FB, FLB, PB, SNS

- Elastomer

- Protected from weather

- Cracking Change in material properties

- Fire protection Structures Monitoring

-lii.A6-12 (TP-7)

- 3.5.1-44

-C

2) Add line items:

Penetration sealant (fire)

- EN, FB, PB, SNS

- Elastomer

- Protected from weather

- Cracking Change in material properties

- Fire Protection

- VII.G-1 (A-19)

- 3.3.1-61

-B Penetration sealant (flood, radiation)

- EN, FLB, PB, SNS

- Elastomer

- Protected from weather

- Cracking Change in material properties

- Structures Monitoring

- III.A6-12 (TP-7)

- 3.5.1-44

-C

• Page 22 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment NO. Item No. Section No. Description I Topic NRC Accession No. Date (Yes I No) 336 3.3.1 Table 3.5.2-6 on page 3.5-80 of the LRA, the aging effects for NO 3.5.2-6 component Seismic Isolation joint, material elastomers in a protected from weather environment are cracking and change in material properties. The AMP shown Is Fire Protection.

The referenced GALL line item is VII.G-1 and the Table I line item Is3.3.1-61. The following changes will be made.

1) Note C will be changed to Note 'E'

2) The discussion inTable line Item 3.3.1-61, Page 3.3-49 will be clarified to read as follows.

"This line item was not used in the auxiliary systems tables.

Fire barrier seals are evaluated as structural components in Section 3.5. Cracking and change Inmaterial properties of elastomer seals, including seismic isolation joints located In fire barriers, are managed by the Fire Protection Program."

3) An additional line item will be added to read as follows.

Seismic isolation joint

- SSR

- Elastomer

- Protected from weather

- Cracking Change Inmaterial properties

- Structures Monitoring

- III.A6-12 (TP-7).

- 3.5.1-44

-C 337 3.3.1 Table 3.5.2-6 on" Page 3.5-72 of the LRA, the aging effect for NO component Fire doors, material carbon steel In a protected from weather environment is loss of material.

'Note C' will be changed to 'Note B' since the component matches NUREG-1801 and the AMP has exceptions.

Page 23 of 26 06/21/2006

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment' No. Item No. Section No. Deserlotlon ! Tonic NRt~ A~Inn Nn flntgn (Vn*t I Nn*

345 3.3.2-13 LRA line Item error. Stainless steel that Is exposed to outdoor .NO.

air and wet/dry cycling is subject to loss of material. This correction requires an amendment to the LRA to Identify loss of material as an aging effect which Is managed by the system walkdown program.

Page 24 of 26 06/21/2006

.... .,,-::;*,. .. .o  :...'_..-..,-... .,:..-*.....:'..,... **.... 2....

,'::,!*','"'..:s::.v I .- .... . .." . '.-*',,,.y'.:"

• VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0 LRA LR Related Amend. Audit LRA Submittal Commitment" No. Item No. Section No. Description I Topic. NRC Accession No. Date (Yes I No) 350 B.1.27.3 1) LRPD-02 Section 4.21.3.B. "Program Description" will be NO revised to read; The Vernon dam Issubject to the Federal Energy Regulatory Commission (FERC) inspection program. This program consists of visual Inspections in accordance with FERC guidelines and complies with Title 18 of the Code of Federal Regulations, Conservation of Power and Water Resources, Part 12 (Safety of Water Power Projects and Project Works) and Division of Dam Safety and Inspections Operating Manual. The operation Inspection frequency for licensed and exempt low hazard potential dams Is biennially. NRC has found that mandated FERC Inspection programs are acceptable for aging management.

LRPD-02 Section 4.21.3.C- "Summary" will be revised to read:

The Vernon Dam FERC Inspection (performed biennially) has been effective at managing aging effects..."

2) LRA Section A.2.1.31 Structures Monitoring-Vernon Dam FERC Program will be revised to read:

The Vernon dam is subject to the Federal Energy Regulatory Commission (FERC) inspection program. This program consists of visual inspections in accordance with FERC guidelines and complies with Title 18 of the Code of Federal Regulations, Conservation of Power and Water Resources, Part 12 (Safety of Water Power Projects and Project Works) and Division of Dam Safety and Inspections Operating Manual. The operation inspection frequency for licensed and exempt low hazard potential dams is biennially. As Indicated in NUREG-1801 for water control structures, NRC has found that FERC / US Army Corp of Engineers dam inspections and maintenance programs are acceptable for aging management.

Page 25 of 26 06/21/2006.

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION AMENDMENT LIST REVISION 0

,f (

LRA LR Related Amend. Audit LRA. Submittal Commitment, No. Item No. Section No. Descrition I Tonle NRC Accession No. Date (Yes I No*

354 4.7.2.5 The CUFs in Section 4.7.2.5 (Vessel ID attachment welds) NO 4.7.2.6 and Section 4.7.2.6 (instrument penetrations) are generic analyses performed in the BWRVIP documents. These are not VYNPS specific calculations. As such, these should not be considered TLAA for VY.. This requires an amendment to the LRA to delete Sections 4.7.2.5 and 4.7.2.6.

359 3.1.1 To provide further clarification, the effectiveness of the Water NO 3.2.1 Chemistry Control - Auxiliary Systems, BWR, and Closed 3.3.1 Cooling Water programs Is confirmed by the One-Time

• Inspection program. This requires an amendment to the 3.4.1 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.

369 3.2.2 The One-Time Inspection program will be revised to Include NO activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.

37.1 4.3-2 The LRA will be amended to include the following discussion NO

'of the VYNPS transient monitoring program:

The VYNPS Fatigue Monitoring Program includes counting of the cycles incurred by the plant. Five transients are monitored by plant operations and recorded as they occur. It is projected that less than 60% of the design cycles for these five transients will be used through the first 60 years of operation, including the PEO. The remaining transients are monitored by plant engineering based on review of operating data at the end of each fuel cycle. These remaining transients are summarized in the Fatigue Monitoring Program as the sixth transient (Reactor Startups and Shutdowns). .Engineering evaluates these transients and advises operations ifthe number of design cycles is being approached Page 26 of 26 06/21/2006