ML062850142

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Email: (PA) VY License Renewal Application Amendments 14 and 15
ML062850142
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 09/20/2006
From: Hamer M
Entergy Nuclear Vermont Yankee
To: Rowley J
NRC/NRR/ADRO
References
%dam200611, TAC MD2297
Download: ML062850142 (41)
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Text

Ricnarýd Emch -VY License Renewal Application Amendments 14 and 15 Page 1!

From:

"Hamer, Mike" <mhamer@entergy.com>

To:

"Jonathan Rowley" <JGR@nrc.gov>

Date:

Wed, Sep 20, 2006 11:21 AM

Subject:

VY License Renewal Application Amendments 14 and 15 The VY Letters listed below are attached to provide Vermont Yankee's responses to various License Renewal RAIs listed below and to provide Revision 2 of the License Renewal Commitment List.

1.

BVY 06-088, LRA Amendment 14 RAI Responses for Fire Protection - Water RAI Responses for Fire Protection - C02 RAI Responses for CRD Return Line Nozzle RAI Responses for Reactor Vessel Surveillance License Renewal Commitment List, Rev. 2

2.

BVY 06-090, LRA Amendment 15 RAI Responses for Plant Level Scoping RAI Responses for Auxiliary Systems

<<BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDF>> <<BVY 06-090 - LR Am. 15 - RAI Responses - Scoping.PDF>>

Please contact me if you have any questions.

Mike Hamer Licensing Specialist Entergy Nuclear Vermont Yankee (802) 258-4226 mhamer@entergy.com CC:

"Dreyfuss, John" <jdreyfu@entergy.com>, "Mannai, David" <dmannai@entergy.com>,

"Devincentis, Jim" <jdevinc@entergy.com>, "YOUNG, GARRY G" <GYOUNG4@entergy.com>, "Lach, David J" <DLach@entergy.com>, "COX, ALAN B" <ACOX@entergy.com>, "POTTS, LORI"

<LPOTT90@entergy.com>, "McCann, John (ENNE Licensing Director)" <jmccanl @entergy.com>,

"Faison, Charlene D" <CFaison@entergy.com>, "Gill, Jeanne" <jgill2@entergy.com>, "Metell, Mike"

<hmetell @ entergy.com>

Mail Envelope Properties (45115C84.C13: 16: 19475)

Page 1Ii1

Subject:

Creation Date From:

Created By:

VY License Renewal Application Amendments 14 and 15 Wed, Sep 20, 2006 11:20 AM "Hamer, Mike" <mhamer@entergy.com>

mhamer@entergy.com Recipients nrc.gov TWGWPO03.HQGWDO01 JGR (Jonathan Rowley) entergy.com hmetell CC (Mike Metell) jgill2 CC (Jeanne Gill)

CFaison CC (Charlene D Faison) jmccanl CC (John (ENNE Licensing Director) McCann)

LPOTr90 CC (LORI POTTS)

ACOX CC (ALAN B COX)

DLach CC (David J Lach)

GYOUNG4 CC (GARRY G YOUNG) jdevinc CC (Jim Devincentis) dmannai CC (David Mannai) jdreyfu CC (John Dreyfuss)

Post Office TWGWPO03.HQGWDO01 Route nrc.gov entergy.com Files Size Date & Time MESSAGE 967 Wednesday, September 20, 2006 11:20 AM TEXT.htm 6845 BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDF 1594052 BVY 06-090 - LR Am. 15 - RAI Responses - Scoping.PDF 794812 Mime.822 1

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I, Richa*d Emci - BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDF Page 1I Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500 185 Old Ferry Road EntBrattleboro, VT 05302-0500 Tel 802 257 5271 September 20,2006 Docket No. 50-271 BVY 06-088

Reference:

1.

Letter, Entergy to USNRC, 'Vermont Yankee Nuclear Power Station, License No. DPR-28, License Renewal Application," BVY 06-009, dated January 25, 2006.

2.

Letter, USNRC to VYNPS, 'Requests for Additional Information for the Review of Vermont Yankee Nuclear Power Station License Renewal Application", NVY 06-114, dated August 15, 2006.

3.

Letter, USNRC to VYNPS, "Requests for Additional Information for the Review of Vermont Yankee Nuclear Power Station Ucense Renewal Application", NVY 06-115, dated August 16, 2006.

Subject:

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

License Renewal Application. Amendment 14 On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the Ucense Renewal Application (LRA) for the Vermont Yankee Nuclear Power Station (VYNPS) as Indicated by Reference 1. Attachments 1 and 2 provide responses to References 2 and 3 respectively.

NRC Commitments 37 and 38 have been Included in Revision 2 of the License Renewal Commitment List enclosed as Attachment S.

Should you have any questions concerning this letter, please contact Mr. James DeVincentis at (802) 258-4236.

I declare under penalty of perjury that the foregoing is true and correct, executed on September 20, 2006.

Sincerely, 2

Site Vice President Vermont Yankee Nuclear Power Station Attachments 1,2 and 3 cc: See next page

I Richar*i Emch - BVY 06-088 - LR AIm. 14"- RAI Responses FP, CRD Rx and LR Com_ mmitment List R2.PDFPe Page ý11 BVY 06-088 Docket No. 50-271 Page 2 of 2 cc:

Mr. James Dyer, Director U.S. Nuclear Regulatory Commission Office 05E7 Washington, DC 20555-00001 Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Jack Strosnider, Director U.S. Nuclear Regulatory Commission Office T8A23 Washington, DC 20555-00001 Mr. Jonathan Rowley, Senior Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike MS-O-1 1 F1 Rockville, MD 20853 Mr. James J. Shea, Project Manager U.S. Nuclear Regulatory Commission Mail Stop O8G9A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 (for mail delivery)

Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601 Diane Curran, Esq.

Harmon, Curran, Splelberg & Elsenberg, LLP 1726 M Street, N.W., Suite 600 Washington, D.C. 20036

IRicharEmch - BVY06-088 - LR Am. 14 -RAI Responses FP, OCRD Rx and LR Commitment List R2.PDF BVY 06-088 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 14 Section 2.3.3.8, Fire Protection -Water Section 2.3.3.9, Fire Protection - Carbon Dioxide RAI Responses RAI 2.3.3.8-1 to 2.3.3.8-11 RAI 2.3.3.9-1 to 2.3.3.9-3

Richard Emch - BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDF Page 4 i S

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 1 RAI 2.3.3.8-1 License renewal application (LRA) drawing LRA-G-191163-SH-01-0, "Fire Protection System Inner Loop," shows the yard fire hydrants as out of scope (i.e., not colored In purple). Verify whether the yard fire hydrants are In scope of license renewal In accordance with Title 10 Code of Federal Regulations Part 54.4(a) (10 CFR 54.4(a)) and subject to an aging management review (AMR) In accordance with 10 CFR 5421(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

RAI 2.3.3.8-1 Response LRA drawing LRA-G-1 91163-SH-02-0, "Fire Protection System Outer Loop" shows that the yard fire hydrants are not subject to aging management review since they are not highlighted.

As described In Section 2.3.3.8 of the LRA, The FP-water system has no Intended functions for 10 CFR 54.4(a)(1).

The FP-water system has the following Intended function for 10 CFR 54.4(a)(2).

Maintain Integrity of nonsafety-related components such that no physical Interaction with safety-related components could prevent satisfactory accomplishment of a safety function.

The FP-water system has the following intended functions for 10 CFR 54.4(a)(3).

Provide the capability to extinguish fires in vital areas of the plant (10 CFR 50.48).

Therefore, the fire protection system Is In scope for license renewal.

The piping In the outer loop performs a component pressure boundary Intended function that supports the ability of the fire protection system to extinguish fires In vital areas of the plant serviced by the Inner loop. If the outer loop failed, piping that provides water to fire systems in vital areas of the plant may not perform its Intended function. The yard fire hydrants are isolable from the outer loop such that their failure would not Impact the support of vital areas. Yard fire hydrants are not required to extinguish fires in vital areas of the plant and their failure cannot Impact safety-related components. Therefore, the yard fire hydrants perform no Intended function In support of the system intended functions and are not subject to aging management review.

RAI 2.3.3.8-2 LRA drawing LRA-G-1 91163-SH-02-0, 0Fire Protection System Outer Loop," shows the recirculation pump motor generator set foam system colored In purple (i.e., in scope). This drawing does not show the 150 gallon foam concentrate tank and Its components (piping and valves). Verify whether the 150 gallon foam concentrate tank and its components are in scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR In accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

Page 1 of 10 BVY 06-088 Docket 50-271

[ Richard Ernch - BVY 06.088-LR Am 14 - RAI Responses FP, CRD RX and L.R Commitment List.R2.PDIFa

...... Page.5.1t VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION '

RESPONSES TO REQUESTS FOR ADDmONAL INFORMATION (RAIs)

ATTACHMENT 1 RAI 2.3.3.8-2 Response LRA drawing LRA-G-191163-SH-01-0, "Fire Protection System Inner Loop" shows the recirculation pump motor generatorset foam system colored in purple (i.e., subject to aging management review) at coordinates I/J-2. The associated 150 gallon foam concentrate tank (TK76-1 B) and Its components are In scope and subject to aging management review as shown on the same drawing at coordinates B-8. LRA Table 3.3.2.8 includes line items for the tank and associated piping, valves, and flow nozzles with fire protection foam as the internal environment.

RAI 2.3.3.8-3 Section 3.2.2 of the January 17, 1978, U.S. Nuclear Regulatory Commission safety evaluation (the SE), approving the Vermont Yankee Nuclear Power Station fire protection program, discusses the use of flame retardant coating to protect electrical cables In trays and risers In the swItchgear room to meet the requirements of 10 CFR 50.48. The LRA does not list flame retardant coating for cables. Verify whether the flame retardant coating is in scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR In accordance with 10 CFR 54.21 (a)(1). If flame retardant coating is excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

RAI 2.3.3.8-3 Response Flame retardant (flamemastic) coatings are in scope and subject to aging management review and are Included in the line item "Fire wrap" in LRA Tables 2.4-6 and 3.5.2-6. Flamemastic was inadvertently omitted from the list of materials for the line item "Fire wrap" In LRA Table 3.5.2-6.

RAI 2.3.3.8-4 Section 4.3.1 (f) of the SE discusses a manually-operated foam maker with a permanent storage tank with fire suppression functions In the event of a fire affecting the 75,000 gallon outdoor fuel oil storage tank, the diesel generator day tanks, or the diesel generator room located on the ground floor of the turbine building. The LRA does not list this foam maker and its associated storage tank systems and components. Verify whether the foam maker and storage tank system and components (piping and valves) are In scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR In accordance with 10 CFR 54.21 (a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

RAI 2.3.3.8-4 Response As discussed in LRA Section 2.3.3.8, In the turbine building, in addition to hose stations and deluge systems, a foam fire protection agent is available that can be used to combat fires at the fuel oil storage tank, turbine lube oil storage tank, main and auxiliary transformers, house heating boilers, and the emergency diesel generators.

The turbine building foam tank (TK76-1A) and associated piping and valves are In scope and subject to aging management review as shown on LRA drawing LRA-G-1 91163-SH-01 -0, "Fire Protection System Inner Loop" at coordinates E-8. This manual foam system is used by attaching a fire hose to the outlet and opening valves to enable water from the fire protection Page 2 of 10 BVY 06-088 Docket 50-271

Richard Ernch - BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDF Page 6 1l VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RA1s)

ATTACHMENT 1 header to mix with the foam concentrate from the storage tank and flow through the hose. LRA Table 3.3.2.8 Includes line Items for the tank and associated piping and valves with fire protection foam as the Internal environment.

Fre hoses are periodically replaced and managed by the existing fire protection program, and therefore are not subject to aging management review.

RAI 2.3.3.8-5 Section 4.5 of the SE discusses floor drains provided In all plant areas protected with fixed water fire suppression. Are they In the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR In accordance with 10 CFR 54.21(a)(1)? If they are excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

RAI 2.3.3.8-5 Response Water-filled components In the radioactive waste system (which includes the floor drain system) that could affect safety-related equipment are In scope and require aging management review per 10 CFR 54.4(a)(2) due to potential spatial Interaction. These components are subject to aging management review and are addressed In LRA Table 3.3.2-13-32.

.RAI 2.3.3.8-6 Section 3.3 of the SE supplement dated February 20, 1980, discusses the fire protection features for the primary containment (e.g., fixed suppression systems, standpipe and hose stations, and oil collection system). Determine whether fire protection systems and features for primary containment should be Included as systems and components in scope for license renewal and subject to an AMR. If not, please explain the basis.

RAI 2.3.3.8-6 Response Section 3.3 of the SE supplement dated February 20, 1980, discusses potential fire protection features for the primary containment In the event the containment is not inerted. As noted in LRA Section 3.3.2.2.7, VYNPS is a BWR with an Inert containment atmosphere. Therefore, the primary containment does not have a fixed suppression system or a reactor recirculation pump oil collection system.

As shown on LRA drawing LRA-G-191163-SH-01-0, 'Fire Protection System Inner Loop," hose stations in the reactor building, that may be used for fire suppression in primary containment during non-inerted outage periods are In scope and subject to aging management review.

RAI 2A3.3.8-7 Section 3.3 of the SE supplement dated October 24, 1980, discusses the deluge system to protect the turbine building lay-down area. Determine whether the turbine building lay-down deluge system and Its components should be Included as systems and components In scope for license renewal and subject to an AMR. If not, please explain the basis.

Page 3 of 10 BVY 06-088 Docket 50-271

IRichardEmch

- BVY06-088-L LRAm. 14.- RAIResponsesI FP, CRD Rxx and LR Commitment List R2.PDF Page 71 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 1 RAI 2.3.3.8-7 Response The turbine building loading bay is the area referred to in the SE supplement as the turbine building lay-down area. The sprinkler system for this area Is In scope and subject to aging management review as shown on LRA drawing LRA-G-1 91163-SH-01 -0, 'Fire Protection System Inner Loop" at coordinate G-9.

RAI 2.3.3.8-8 Section 4.3.1(e) of the SE discusses the automatic sprinkler systems for various areas including the outdoor transformer. The LRA does not list the sprinkler systems or associated components to protect the outdoor transformer. Verify whether the sprinkler system and associated components are In scope of license renewal In accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

RAI 2.3.3.8-8 Response As described In LRA Section 2.3.3.8, the fire protection system is In thd scope of license renewal for 10 CFR 54.4(a)(3) because it Is credited In the Appendix R safe shutdown analysis (1 OCFR50.48).

The main transformer and auxiliary transformer sprinkler fire protection subsystems do not mitigate fires In areas containing equipment Important to safe operation of the plant, nor are they credited with achieving safe shutdown In the event of a fire. These subsystems are only required to meet state, municipal, or insurance requirements. Therefore, these subsystems have no Intended function and are not included in the aging management review summarized in LRA Table 3.3.2-8.

Since they are outdoors away from safety-related equipment, the main transformer and auxiliary transformer sprinkler subsystems cannot affect safety-related equipment by spatial interaction and therefore, have no Intended function associated with 10 CFR 54.4(a)(2). Therefore, these subsystems are not Included In the aging management review summarized In LRA Table 3.3.2-13-15.

RAI 2.3.3.8-9 Section 5.12.6 of the SE discusses the use of a three-hour rated fire protection coating to protect the structural steel supporting the wall and ceiling of diesel generator rooms. The LRA does not list three-hour rated fire protection coating for structural steel. Verify whether the fire protection coating for structural steel Is in scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21 (a)(1). If fire protection coating is excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

RAI 2.3.3.8-9 Response Subsequent to the January 17, 1978, NRC Safety Evaluation (the SE), VYNPS notified the NRC (in letter WVY 78-85) that a protective coating with a 'fire resistant rating of approximately 1-hour", would be utilized for the structural steel supporting the roof and ceiling. This is based on Page 4 of 10 BVY 06-088 Docket 50-271

Rickhard Emch - BVY 06-088 - LR Am. 14'- RAI Responses FP, CRD Rx and LR Co mmitment List R2.PDFe Page 8 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAis)

ATTACHMENT 1 the conclusion that a fire in one diesel generator room will not result In structural damage that could result in fire spread to the other room. The fire retardant coatings are In scope and subject to aging management review and are included In the line item "Fire proofing" In LRA Tables 2.4-6 and 3.5.2-6.

RAI 2.3.3.8-10 LRA Table 2.3.3-8 excludes several types of fire protection components that appears in the SE and its supplements and/or updated final safety analysis report (UFSAR), and which appear In the LRA drawings colored in purple. These components are listed below.

hose stations hose connections hose racks pipe fittings pipe supports couplings threaded connections flexible hoses restricting orifices Interface flanges chamber housings heat-actuated devices gauge snubbers tank heaters thermowells water motor alarms fire hydrants (casing) sprinkler heads dikes (contain oil spill) flame retardant coating for cables fire barrier penetration seals fire barrier walls, ceilings, floors, and slabs fire doors fire rated enclosures fire retardant coating for structural steel supporting walls and ceilings For each, determine whether the component should be Included In Table 2.3.3.8, and If not, please justify the exclusion.

RAI 2.3.3.8-10 Response hose stations - Since they support criterion (a)(3) equipment, hose stations are included In the structural aging management review. They are included in the "Fire hose reels" line item in LRA Table 2.4-6.

  • hose connections - Hose connections are Included In the "Piping" line item in LRA Table 2.3.3-8.

Page 5 of 10 BVY 06-088 Docket 50-271

Richard Emch-BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDF Page 91t VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT I

" hose racks - Since they support criterion (a)(3) equipment, hose racks are included in the structural aging management review. They are Included In the "Fire hose reels" line item In LRA Table 2.4-6.

" pipe fittings - As stated In LRA section 2.0, the term "piping" In component lists may include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells.

Pipe fittings are Included in the "Piping" line item in LRA Table 2.3.3-8.

" pipe supports - Since they support criterion (a)(3) equipment, piping supports are Included in the structural aging management review. They are Included In the "Component and piping supports" line item In LRA Table 2.4-6.

" couplings - As stated In LRA section 2.0, the term "piping" in component lists may Include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells.

Couplings are pipe fittings included in the OPiping" line item in LRA Table 2.3.3-8.

" threaded connections - As stated in LRA section 2.0, the term "piping" In component lists may include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells. Threaded connections are pipe fittings Included In the "Piping" line Item in LRA Table 2.3.3-8.

flexible hoses - Hoses are replaced on a specified periodicity and therefore, are not subject to aging management review per 10CFR54.21(a)(1)(ii).

" restricting orifices - As stated In LRA section 2.0, the term "piping" in component lists may include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells. Restricting orifices are included In the "Piping" line item in LRA Table 2.3.3-8.

" interface flanges - As stated In LRA section 2.0, the term "piping" in component lists may Include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells. Interface flanges are pipe fittings Included In the "Piping" line item in LRA Table 2.3.3-8.

" chamber housings - As shown on LRA drawing LRA-G-1 91163-SH-01 -0, the turbine building lube oil room sprinkler system Includes a retard chamber, piping, and valves whose purpose Is to prevent false alarms due to system pressure surges and to provide a flow path to the water gong alarm during system actuation. Since failure of these components downstream of valve DV-76-200D would not prevent fire suppression capability for the lube oil room sprinkler system, they are not subject to aging management review.

heat-actuated devices - As stated In Section 10.11.3 of the UFSAR, the pre-action fire protection subsystems for the hydrogen seal oil area and the turbine building condenser and heater bay area have heat-actuated devices to Initiate opening of the deluge valves. Heat-actuated devices are active components; not subject to aging management review.

gauge snubbers - Gauge snubbers are integral parts of tubing runs that protect Instrumentation from pressure surges. Gauge snubbers in tubing runs to instruments are included In the "tubing" line item In LRA Table 2.3.3-8.

Page 6 of 10 BVY 06-088 Docket 50-271

Ric harct -Emh-BVY 06-088-LR Am. 14-RA Resp onses FP, CRD Rx and LR Commitment List R2.PDF.

Page 10]

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDmONAL INFORMATION (RAIs)

ATTACHMENT 1 tank heaters - Neither the SE and Its supplements nor the UFSAR discuss tank heaters.

Tank heaters do not appear on the LRA drawings colored in purple. VYNPS does not have fire water storage tanks and the foam concentrate tanks do not have heaters. Therefore, the fire protection - water system does not have tank heaters.

9 thermowells - As stated in LRA section 2.0, the term "piping" In component lists may Include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells.

Thermowells are Included In the "Piping" line Item In LRA Table 2.3.3-8.

0 water motor alarms - This response assumes that reviewer means water flow alarms which are provided In critical locations and annunciate In the control room to provide positive indication of fire water system operation. Water flow alarms are active components; not subject to aging management review.

0 fire hydrants (casing) - As described In response to RAI 2.3.3.8-1, the yard fire hydrants are not subject to aging management review.

0 sprinkler heads - Sprinkler heads are Included In the "Flow nozzle" line Item In LRA Table 2.3.3-8.

dikes (contain oil spill) - Dikes are Included In the structural aging management review.

They are included in the "Flood curb" line items in LRA Table 2.4-6.

o flame retardant coating for cables - As described in response to RAI 2.3.3.8-3, flame retardant (flamemastic) coatings are subject to aging management review and are included In the line Item "Fire wrap" In LRA Table 2.4-6. Flamemastic was inadvertently omitted from the list of materials for the line Item "Fire wrap" in LRA Table 3.5.2-6.

o fire barrier penetration seals - Fire barrier penetration seals are Included in the structural aging management review. They are Included In the "Penetration sealant (fire, flood, radiation)" line item in Table 2.4-6.

o fire barrier walls, ceilings, floor, and slabs - Fire barrier walls, ceilings, floor, and slabs are included in the structural aging management review. They are Included In the concrete line items In Tables 2.4-2 through 2.4-4.

0 fire doors - Fire doors are Included In the structural aging management review. They are included in the "Fire doors" line Item in Table 2.4-6.

fire rated enclosures - As stated In section 5.17.1 of the SE, the diesel day tank for the fire pump Is located In a separate three-hour fire rated enclosure. This enclosure consists of concrete block walls In the Intake structure and Is Included in the structural aging management review. It is included in the "Masonry walls" line item in Table 2.4-3.

a fire retardant coating for structural steel supporting wall and ceiling - As described in response to RAI 2.3.3.8-9, fire retardant (flamemastic) coatings are subject to aging management review and are included In the line item "Fire wrap" In LRA Table 2.4-6.

Flamemastic was inadvertently omitted from the list of materials for the line item "Fire wrap" In LRA Table 3.5.2-6.

Page 7 of 10 BVY 06-088 Docket 50-271

.Rich*dEmch -BVY 06-088-LRAm.- 14 -RAIResponses FP, CRD Rx and LR Commitment List R2.PDF page i! I S

A VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT I RAI 2.3.3.8-11 LRA Table 2.3.3-8 listed flow nozzles (flow control) as within scope and subject to an AMR, but does not list spray nozzles (water). Please explain why the water spray nozzles are not subject to an AMR.

RAI 2.3.3.8-11 Response Water spray nozzles are In scope and subject to aging management review. They are included In the line Item Flow nozzles* In LRA Table 2.3.3-8.

RAI 2.3.3.9-1 Sections 3.1.5 and 4.3.2 of the SE discusses a total flooding carbon dioxide (CO2) system for the cable spreading area, battery room, and diesel driven fire water pump tank room. The LRA does not list the CO2 system for the cable spreading area, battery room, and diesel driven fire water pump tank room. Verify whether the C02 system and its components are in scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR In accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

RAI 2.3.3.9-1 Response

'As described in Section 2.3.3.9 of the LRA, the cable vault and switchgear rooms are protected by fully automatic total flooding carbon dioxide suppression systems initiated by Ionization detectors. Bottles located In the west switchgear room may also provide a backup or second shot to the cable vault if desired. The diesel fire pump fuel oil storage tank room is protected by a total flooding carbon dioxide suppression system initiated by heat detectors.

As further described in LRA Section 2.3.3.9, The FP-CO2 system Is within the scope of license renewal and has the following intended function for.10 CFR 54.4(a)(3).

Provide the capability to extinguish fires In vital areas of the plant (10 CFR 50A8).

The cable vault Is the area referred to in the SE as the cable spreading area and battery room.

Therefore, the C02 systems for the cable spreading area, battery room, and diesel driven fire water pump tank room are in scope and subject to aging management review.

RAI 2.3.3.9-2 LRA Table 2.3.3-9 excludes several types of C02 fire suppression system components that appear In the SE and its supplements and/or UFSAR, and which also appear In the LRA drawings colored In purple. These components are listed below.

strainer housings Page 8 of 10 BVY O6-O88 Docket 50-271

[Richard Emch - BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment -List R2.PDF

-Pagei12ý1 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDmONAL INFORMATION (RAI$)

ATTACHMENT I pipe fittings pipe supports couplings odorizer threaded connections flexible hose latch door pull box pneumatic actuators CO2 bottles (CO2 storage cylinders)

For each, determine whether the component should be Included In Table 2.3.3.9, and if not, please justify the exclusion.

RAI 2.3.3.9-2 ResPons$

" strainer housings - The CO2 fire protection storage tank (TK-1 15-1) reclrculation heater pump suction strainer (S-76-3) shown on LRA drawing LRA-G-191163-SH-03-0 has both filtration and pressure boundary functions. The strainer and its housing are both Included In the 'Strainer" line Item In LRA Table 2.3.3-9.

pipe fittings - As stated in LRA section 2.0, the term "piping" In component lists may Include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells.

Pipe fittings are Included In the "Piping" line item in LRA Table 2.3.3-9.

" pipe supports - Since they support criterion (a)(3) equipment, piping supports are Included in the structural aging management review. They are Included In the 'Component and piping supports" line item in LRA Table 2.4-6.

" couplings - As stated In LRA section 2.0, the term mpiping" in component lists may include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells.

Couplings are pipe fittings Included In the "Piping" line Item in LRA Table 2.3.3-9.

" ododzer - Ododzer cylinders (OC-700, 701, 702, and 703) on switchgear room discharge lines are shown on LRA drawing LRA-G-1 91163-SH-03-0. The odorizer cylinders are Included In the "Tank" line Item In LRA Table 2.3.3-9.

" threaded connections - As stated in LRA section 2.0, the term "piping" in component lists may include pipe, pipe fittings (such as elbows and reducers), flow elements, orifices, and thermowells. Threaded connections are pipe fittings Included in the 'Piping" line Item in LRA Table 2.3.3-9.

flexible hose - Hoses are replaced on a specified schedule and therefore, are not subject to aging management review per IOCFR54.21 (a)(1)(li).

Page 9 of 10 BVY 06-088 Docket 50-271

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPUCAT1ON RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 1

" latch door pull box - This response assumes the reviewer means emergency manual release stations to Initiate CO2 flow. Manual release stations are active components; not subject to aging management review.

pneumatic actuators - Pneumatic actuators (discharge delay timers) on deluge valves for the switchgear rooms are shown on LRA drawing LRA-G-191163-SH-03-0. Since the actuator subcomponents have a pressure boundary function, they are Included In the line Items for "Tank", "Valve body', and "Tubing" in Table 2.3.3-9.

C02 bottles (P02 storage cylinders) - The CO2 bottles, or storage cylinders, are included in the line Item "Tank" In Table 2.3.3-9.

RAI 2.3.3.9-3 LRA Table 2.3.3-9 listed nozzles with an Intended function of flow control as within scope and subject to an AMR. Nozzles with Intended functions of total flood, vent, and S nozzles are not listed. Please explain why these nozzles are not subject to an AMR.

RAI 2.3.3.9-3 Response The total flood nozzles In the C02 system are subject to aging management review, as indicated on drawings LRA-G-1 91163-SH-03-0 and LRA-G-1 91163-SH-04-0. They are included in the "Nozzle" line Item In Table 2.3.3-9. As shown on the LRA drawings the CO 2 system does not have vent or S nozzles.

Page 10 of 10 BVY 06-088 Docket 50-271

Richard Emch BVY 06-088 -LR Am. 14-RA! Responses FP, CRD Rx and LR Commitment List R2.PDF Page 141 BVY 06-088 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 14 Section B.1.2, BWR CRD Return Line Nozzle Section B.1.24, Reactor Vessel Surveillance RAI Responses RAI B.1.24-1 RAI B.1.24-2 RAI B.1.2-1 RAI B.1.2-2 RAI 4.2-1

Richald Emch - BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDFae Page 15 ]

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 2 RAI B,1.24-1 The applicant, In the updated final safety analysis report (UFSAR) supplement A.2.1.26,

'Reactor Vessel Surveillance Program,* and In the aging management program (AMP) B.1.24, "Reactor Vessel Surveillance," states that It will implement the Boiling Water Reactor Vessel and Intemals Project (BWRVIP) Integrated Surveillance Program (ISP) at the Vermont Yankee Nuclear Power Station (VYNPS) as specified In the BWRVIP-1 16 report, 'BWR Vessel and Intemals Project Integrated Surveillance Program Implementation for License Renewal." By letter dated March 1,2006, the staff Issued the final safety evaluation (SE) for the BWRVIP-1 16 report and therefore, the staff requests that the applicant include the following commitment (shown In bold underlined font) In UFSAR supplement Section A.2.1.26 and In AMP B.1.24 of the license renewal application (LRA).

The BWRVIP-1 16 report which was approved by the staff will be Implemented at VYNPS with the conditions documented in Sections 3 and 4 of the staff's final SE dated March 1 2006. for the BWRVIP-1 16 report.

RAI B.1.24-1 Response VYNPS makes the following commitment with the expectation that the BWR Owners Group (BWROG) will implement the conditions documented In the Staff's SER for BWRVIP-1 16 into the BWRVIP Integrated Surveillance Program. This commitment will need to be re-evaluated should the BWROG take exception to the conditions documented in the Staffs SER for BWRVIP-1 16.

The following statement is added to LRA Sections A.2.1.26, "Reactor Vessel Surveillance Program," and B.1.24, 'Reactor Vessel Surveillance.'

'The BWRVIP-1 16 report which was approved by the Staff will be implemented at VYNPS with the conditions documented In Sections 3 and 4 of the Staff's final SE dated March 1,2006, for the BWRVIP-116 report.'

RAI B.1.24-2 Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H requires that an ISP used as a basis for a licensee Implemented reactor vessel surveillance program be reviewed and approved by the U. S. Nuclear Regulatory Commission staff. The ISP to be used by the applicant Is a program that was developed by the BWRVIP. The applicant will apply the BWRVIP ISP as the method by which the VYNPS will comply with the requirements of 10 CFR Part 50, Appendix H. The BWRVIP ISP identifies capsules that must be tested to monitor neutron radiation embrittlement for all licensees participating in the ISP and identifies capsules that need not be tested (standby capsules). Table 3-3 of the BWRVIP-1 16 report Indicates that the standby capsule from the VYNPS unit Is not to be tested. This untested capsule was originally part of the applicants plant-specific surveillance program and has received significant amounts of neutron radiation.

The staff requests that the applicant Include the following commitment (shown In bold underlined font) In the UFSAR supplement Section A.2.1.26 and in AMP B.1.24 of the LRA.

Page 1 of 5 BVY 06-088 Docket 50-271

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 2 If the VYNPS standby capsule Is removed from the RPV without the Intent to test It, the capsule will be stored In a manner which maintains it In a condition which would permit Its future use. Including during the period of extended operation. If necessary.

RAI B.1.24-2 Response The following statement Is added to LRA Section A.2.1.26, "Reactor Vessel Surveillance Program."

"If the VYNPS standby capsule is removed from the reactor vessel without the Intent to test it, the capsule will be stored In a manner which maintains it In a condition which would permit its future use, Including during the period of extended operation, if necessary."

RAI B.1.2-1 The applicant states that the Control Rod Drive (CRD) return line nozzle has been capped at VYNPS. The staff requests that the applicant provide the following Information regarding the cap and the weld.

(1)

Describe the configuration, location and material of construction of the capped nozzle.

This should Include the existing base material for the nozzle, piping (if piping remnants exist) and cap material, and any welds.

(2)

Describe how the aging effects for this weld and the cap are managed in accordance with the guidelines of BWRVIP-75, "BWR Vessel and Internals Project (BWRVIP),

Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedule."

(3)

Discuss whether the event at Pilgrim (leaking weld at capped nozzle, September 30, 2003) is applicable to VYNPS. The staff issued Information Notice 2004-08, "Reactor Coolant Pressure Boundary Leakage Attributable to Propagation of Cracking in Reactor Vessel Nozzle Welds," dated April 22, 2004, which states that the cracking occurred in an Alloy 182 weld that was previously repaired extensively. Discuss experience with previous leakage at the VYNPS capped nozzle, if any. Include in your discussion the past Inspection techniques applied, the results obtained, and mitigative strategies Imposed.

Provide Information as to how the plant-specific experience related to this aging effect Impacts the attributes specified in AMP B.1.2, "BWR CRD Return line Nozzles."

RAI B.1.2-1 Response (1)

VYNPS removed the piping and thermal sleeve; no portion of the piping remains. A cap made of SA1 82 Grade 316L (FSAR Table 4.2-1) was full penetration welded to the nozzle safe end. The weld filler material is ER 316L and the nozzle side buttering Is ER 308L. The weld material used on the N9-SE nozzle weld is low carbon, non-IGSCC susceptible material. Also, the stainless steel cap with 308L ID weld buttering was solution heat treated after application of the buttering. The nozzle base material Is low alloy steel (SA 508 Class 2).

(2)

The aging effects for this weld and the cap are managed by the BWR CRD Return Une Page 2 of 5 BVY 06-088 Docket 50-271

Richarid Ernlch - BVY 06-088 - LR Am. 14-L RAI. Responses FP, CR0 Rx andR Commitment List R2.PDF Page 1 j VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 2 Nozzle Program, comparable to NUREG-1 801 Program XI.M6. As all piping has been removed from this nozzle, it is no longer governed by BWRVIP-75 and or Generic Letter 88-01, both of which pertain to stainless steel piping.

(3)

Evaluation of the applicability to VYNPS of the event at Pilgrim (leaking weld at capped nozzle, September 30, 2003, Information Notice 2004-08) revealed that the likelihood of cracking initiating in Vermont Yankee's N9-SE, in the same manner as the cracking at Pilgrim Station, is negligible. This is due to the non-susceptible material, the mitigation techniques employed, and the absence of repair activity which would have allowed an incipient crack or crevice condition to remain In the weld after repair welding was performed.

The cap to nozzle safe end weld was examined (visual, surface, and volumetric) during and after installation in 1979, this included a 1/3 RT of the weld during Installation and RT of the final weld. Inservice Inspection has been performed on the line as follows: UT and VT In 1979, PT In 1989, UT and PT In 2002. None of the examinations found any flaws and no repairs were performed during or after Installation.

Mitigative actions Include the use of non-IGSCC susceptible material for the weld and solution heat treating of the cap as discussed in item (1) above. Other crack mitigation techniques employed at Vermont Yankee are noble metal chemical addition (NMCA) and hydrogen water chemistry (HWC).

Plant-specific experience has not impacted the attributes specified in AMP B.1.2, "BWR CRD Return line Nozzles." Plant-specific experience has not identified any aging effects that were not already identified and considered when NUREG-1 801 Section XI.M6 was written.

RAI B.1.2-2 Section 4 of the Generic Aging Lessens Learned Report (GALL) AMP XI.M6, "BWR Control Rod Drive (CRD) Return Line Nozzle," recommends that the aging degradation in the CRD return line nozzles should be monitored per the Inspection recommendations specified In NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking." Section 8.2(2) of NUREG-0619 recommends that ultrasonic testing (UT) should be performed on the welded connection joining the rerouted CRD return line to the system which then returns the flow to the reactor vessel during each refueling outage.

In a letter dated January 15, 1982, the applicant made a commitment to the staff indicating that it will perform UT examination of the CRD to the reactor water cleanup (RWCU) weld joint as discussed In NUREG-0619 for three consecutive refuel outages. The applicant further stated that upon the completion of these inspections, the Inspection frequency will be reassessed based on the Inspection results. In AMP B.1.2, "BWR CRD Return Line Nozzle," the applicant stated that it Inspected the CRD return line to the RWCU weld joint using UT methods for three consecutive refuel outages and found no indications. Since no Indications were found, the applicant intends to take exception to GALL AMP XI.M6, in which the applicant proposes not to inspect the aforementioned weld joint during the extended period of operation. The staff determined that the following information regarding the subject weld Is required to complete its review.

Page 3 of 5 BVY 06-088 Docket 50-271

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ATTACHMENT 2 (1)

The applicant should provide technical justification for not performing the UT examination of the subject weld as recommended by the GALL AMP XI.M6 and NUREG-0619 during the extended period of operation.

(2)

The applicant should confirm that the CRD return lines that are connected to RWCU piping system that fall under the jurisdiction of the ASME Code,Section XI boundary will be inspected per the ASME Section XI Code.

RAI B.1.2-2 Resoonse (1) The recommendations of NUREGs 0619 and 1801 are based on the assumption that this weld has an intended function. NUREG-1801,Section XI.M6.4 states "The Intent and schedule of inspection, as delineated in NUREG 0619, assures detection of cracks before loss of Intended function... ".

Drawings LRA-G-191170 and LRA-G-1 91178 clearly show that neither the CRD return line from the CRD hydraulic system nor the portion of the RWCU piping to which the CRD return line connects are subject to aging management review. They are not subject to aging management review because they are not part of the reactor coolant system pressure boundary and have no license renewal Intended function. Because they have no Intended function, they do not require volumetric Inspection to detect cracks that might cause loss of intended function.

(2) License renewal drawing LRA-G-1 91170 coordinate H21 shows that the CRD return line (line

  1. 2 1Y CRD-9) Is a non-safety related line (Class 0). Therefore, none of the CRD return line receives inspections per the ASME Code,Section XI ISI program.

License renewal drawing LRA-G-191178 shows the CRD return line (line # 2 W" CRD-9) at coordinates A5-B5, with the connection to the RWCU piping at coordinate B5. This drawing also confirms the connection Is Class 0. The connection Is well outside the Class 1 piping boundary, which is shown at coordinate C3 of the same drawing. Therefore, consistent with requirements of the ASME Code,Section XI IS[ program, the weld of the return line to the RWCU does not receive Inspections.

RAI 4.2-1 In Section 4.2.1 of the VYNPS LRA It Is stated that "...the reactor fluence....has been projected to the end of the period of extended operation." In Sections 4.2.1 and 4.2.2 of the LRA there Is no discussion of how this extrapolation was performed. Vermont Yankee has been approved for operation at an extended power uprate. In general, power uprates are based on revised axial power profiles with higher axial peaks at a lower axial location. Therefore, extrapolation of the existing axial profile may not provide an accurate projection.

In view of the above, please respond to the following:

(1)

Compare the axial power profiles (at the peak power azimuthal location) and confirm that the extrapolation remains valid.

Page 4 of 5 BVY 06-088 Docket 50-271

I Richard Emch -BVY 06-088 - LR Am. 14 - RAI Responses FP, CRD Rx and LR Commitment List R2.PDF Page 19

ATTACHMENT 2 (2)

Confirm that the projected operating plan will support the assumed axial power profile to the end of the period of extended operation.

RAI 4.2-1 Response (1)

VYNPS originally performed the fluence extrapolation using a 32 EFPY axial fluence profile provided In GE-NE-0000-2342-R1 -NP dated July 2003. The results of this extrapolation were provided in response to RAI 3.1.1-17-P-01.

A 60-year (51.6 EFPY) axial fluence profile is available In GE-NE-0000-0014-0292-01 dated May 2003. Both of these profiles were produced by GE as part of the extended power uprate and both are based on the expected plant operating history including the power uprate. The 60-year curve does show the peak fluence lower in the core (75 inches above the bottom of the active fuel (BAF) versus 85 inches), and consequently the 60-year curve has slightly higher fluence below the active fuel in the area of the recirculation Inlet nozzles. VYNPS repeated the extrapolation to 54 EFPY for the 32 EFPY curve and extrapolated the 60 year curve from 51.6 to 54 EFPY with the following results.

1/4 T fluence, n/cm 2 (E>I Mev)

Original Revised Extrapolation Extrapolation Extrapolation Location from 32 from 32 from 60-year EFPY curve curve curve BAF 9.8E+16 9.8E+16 1.0E+17 BAF + 19%

1.2E+17 1.2E+17 1.2E+17 nozzle 6.7E+16 6.4E+16 7.5E+1 6 nozzle + 19%

7.9E+16 7.6E+16 9.0E+1 6 As indicated In this table, the projected fluence at the nozzle Is still less than lx1 017 n/cm2 (E>1 Mev). Even when 19% is added to the extrapolated value to account for possible error In the calculation as suggested by RAI 3.1.1-17-P-01, all values remain below lx1017 n/cm 2

(2)

The projected axial fluence profile was based on the projected operating plan, including the extended power uprate; therefore the projected operating plan supports the assumed power distribution to the end of the period of extended operation.

1Letter, Entergy to USNRC, 'Vermont Yankee Nuclear Power Station, License No. DPR-28, License Renewal Application, Amendment 12," BVY 06-083, dated September 5,2006.

Page 5 of 5 BVY 06-088 Docket 50-2711

Richard Emch-BVY 06-088 --LR Am.14-Responses FP,1C Rxand LR Commitment List R2.PDF Page20 II BVY 06-088 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 14 License Renewal Commitment List Revision 2

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 2 During the development and review of the Vermont Yankee Nuclear Power Station Ucense Renewal Application, Entergy made commitments to provide aging management programs to manage the effects of aging on structures and components during the extended period of operation. The following table lists these license renewal commitments, along with the implementation schedule and the source of the commitment.

ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 1

Guidance for performing examinations of buried piping will be enhanced to March 21, 2012 BVY 06-009 B.1.1/Audit specify that coating degradation and corrosion are attributes to be Items 5 & 130 evaluated.

2 Fifteen (15) percent of the top guide locations will be Inspected using As stated in the BVY 06-009 B.1.7/Audit enhanced visual inspection technique, EVT-1, within the first 18 years of commitment Item 14 the period of extended operation, with at least one-third of the inspections to be completed within the first 6 years and at least two-thirds within the first 12 years of the period of extended operation. Locations selected for examination will be areas that have exceeded the neutron fluence threshold.

.3 The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonic March 21, 2012 BVY 06-009 B.1.9 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 UT March 21,2012 BVY 06-009 B.1.9 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 periodic update March 21, 2012 BVY 06-009 B.1.11 of cumulative fatigue usage factors (CUFs), or to require update of CUFs if the number of accumulated cycles approaches the number assumed In the design calculation.

6 A computerized monitoring program (e.g., FatiguePro)-will be used to March 21, 2012 BVY 06-009 B.1.11 directly determine cumulative fatigue usage factors (CUFs) for locations of interest.

7 The allowable number of effective transients will be established for March 21, 2012 BVY 06-009 B.1.11 monitored transients. This will allow quantitative projection of future margin.

Page I of 6

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 2 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 8

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

152, 153 and 159 9

Procedures will be enhanced to state that the diesel engine sub-systems March 21,2012 BVY 06-009 B.1.12.1/Audit (including the fuel supply line) will be observed while the pump Is running.

Items 33, 150 Acceptance criteria will be enhanced to verify that the diesel engine did not

& 155 exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.

10 Fire Water System Program procedures will be enhanced to specify that In March 21, 2012 BVY 06-009 B.1.12.2 accordance with NFPA 25 (2002 edition), Section 5.3.1.1.1, when sprinklers have been in place for 50 years a representative sample of sprinkler heads will be submitted to a recognized testing laboratory for field service testing.

This sampling will be repeated every 10 years.

11 The Fire Water System Program will be enhanced to specify that wall March 21, 2012 BVY 06-009 B.1.12.2/Audit thickness evaluations of fire protection piping will be performed on system Items 37 & 41 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 during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

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

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

_ described in LRA Section B.1.17.

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

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

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 2 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 16 Implement the One-Time Inspection Program as described in LRA Section March 21, 2012 BVY 06-009 B.1.21 B.1.21. Include destructive or non-destructive examination of one (1)

Audit Items socket welded connection using techniques proven by past Industry 239, 240, 330, experience to be effective for the identification of cracking in small bore 331 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 I the period of extended operation.

17 Enhance the Periodic Surveillance and Preventive Maintenance Program to March 21, 2012 BVY 06-009 B.1.22 assure that the effects of aging will be managed as described in LRA Audit Item 377 Section B.1.22.

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

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

20 Enhance the Structures Monitoring Program to specify that process facility March 21, 2012 BVY 06-009 B.1.27.2 crane rails and girders, condensate storage tank (CST) enclosure, C02 Audit Item 377 tank enclosure, N2 tank enclosure and restraining wall, CST pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man-way seals and gaskets, and hatch seals and gaskets are included In the program.

21 Guidance for performIng structural examinations of wood to identify loss of March 21, 2012 BVY 06-009 6.1.27.2 material, cracking, and change in material properties will be added to the Structures Monitoring Program.

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

23 Guidance for performing structural examinations of PVC cooling tower fill to March 21, 2012 3VY 06-009 1.1.27.2 identify cracking and change in material properties will be added to the S tru ctu re s M o n ito rin g P rog ra m p ro ce d u re.

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 2 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 24 System walkdown guidance documents will be enhanced to perform March 21, 2012 BVY 06-009 B.1.28 periodic system engineer inspections of systems in scope and subject to Audit Items aging management review for license renewal in accordance with 10 CFR 187, 188 & 190 54.4 (a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impactthe subject system will include SSCs that are in scope and subject to aging management review for license renewal I in accordance with 10 CFR 54.4 (a)(2).

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

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

& 164 27 For each location that may exceed a CUF of 1.0 when considering March 21,2012 BVY-06-058 4.3.3 environmental effects, VYNPS will implement one or more of the following:

Audit Items 29, (1) further refinement of the fatigue analyses to lower the predicted CUFs to March 21,2010 for 107 & 318 less than 1.0; performing a fatigue (2) management of fatigue at the affected locations by an inspection analysis that program that has been reviewed and approved by the NRC (e.g., periodic addresses the effects non-destructive examination of the affected locations at inspection intervals of reactor coolant to be determined by a method acceptable to the NRC);

environment on (3) repair or replacement of the affected locations, fatigue (in accordance with an NRC Should VYNPS select the option to manage environmental-assisted fatigue approved version of during the period of extended operation, details of the aging management the ASME Code) program such as scope, qualification, method, and frequency will be provided to the NRC two years prior to the period of extended operation for review and approval.

28 Revise program procedures to indicate that the Instrument Air Program will March 21, 2012 BVY 06-009 B.1.16 maintain instrument air quality in accordance with ISA S7.3 Audit Item 47 Page 4 of 6

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 2 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 29 VYNPS will perform one of the following:

March 21,2012 BVY 06-009 B.1.7/Audit

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

30 Revise System Walkdown Program to specify C02 system Inspections March 21, 2012 BVY 06-009 B.1.28 every 6 months.

Audit Items 30, 141, 146 & 298 31 Revise Fire Water System Program to specify annual fire hydrant gasket March 21, 2012 BVY 06-009 B.1.12.2 Inspections and flow tests.

Audit Items 39

&40 32 Implement the Metal Enclosed Bus Program.

March 21,2012 BVY 06-058 Audit Item 97 (Details to be provided in a LRA Amendment) 33 Include within the Structures Monitoring Program provisions that will ensure March 21,2012 BVY 06-009 B.1.27 an engineering evaluation Is made on a periodic basis of groundwater Audit Item 77 samples to assess aggressiveness of groundwater to concrete.

34 Implement the Bolting Integrity Program.

March 21,2012 BVY 06-058 Audit Items Details to be provided In a LRA Amendment with specific locations in the 198,216, 218, LRA referenced.

237, 331 & 333 35 Provide within the System Walkdown Training Program a process to March 21, 2012 BVY 06-058 Audit Item document biennial refresher training of Engineers to demonstrate inclusion 384 of the methodology for aging management of plant equipment as described in EPRI Aging Assessment Field Guide or comparable instructional gulde.

36 If technology to Inspect the hidden Jet pump thermal sleeve and core spray March 21, 2010 BVY06-058 Audit Item 12 thermal sleeve welds has not been developed and approved by the NRC at least two years prior to the period of extended operation, VYNPS will initiate plant-specific action to resolve this Issue. That plant specific action may be justification that the welds do not require Inspection.

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 2 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 37 Continue inspections in accordance with the Steam Dryer Monitoring March 21, 2010 BVY 06-079 Audit Item 204 Program, Revision 3 in the event that the BWRVIP-139 is not approved prior to the period of extended operation.

38 The BWRVIP-116 report which was approved by the Staff will be March 21, 2012 BVY 06-088 Response to Implemented at VYNPS with the conditions documented in Sections 3 and RAI B.1.24-1 4 of the Staffs final SE dated March 1, 2006, for the BWRVIP-116 report."

39

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

Page 6 of 6

.ýRi6hwd-E ch-BVY06-090--LR-Am.15-hAlResýonses-Scopi6g.PC Pame -1 Richard Emch - BVY 06-090 - LR Am. 15 - RAI Responses - Scoping.PDF Prinn I Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500

  • Brattloboro, VT 05302-0500 Tel 802 257 5271 September 20, 2006 Docket No. 50-271 BVY 06-090 TAC No. MC 9668 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

1.

Letter, Entergy to USNRC, Vermont Yankee Nuclear Power Station, License No. DPR-28, License Renewal Application," BVY 06-009, dated January 25, 2006.

2.

Letter, USNRC to VYNPS, "Requests for Additional Information for the Review of Vermont Yankee Nuclear Power Station Ucense Renewal Application', NVY 06-116, dated August 16, 2006.

Subject:

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

License Renewal Application, Amendment 15 On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the License Renewal Application (LRA) for the Vermont Yankee Nuclear Power Station (VYNPS) as Indicated by Reference 1. Attachment 1 contains responses to the Requests for Additional Information provided In Reference 2.

This submittal does not contain new regulatory commitments.

Should you have any questions concerning this letter, please contact Mr. James DeVincentis at (802) 258-4236.

I declare under penalty of perjury that the foregoing is true and correct, executed on September 20, 2006.

Sincerely, Ted A. Sullivan Site Vice President Vermont Yankee Nuclear Power Station cc: See next page

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Mr. James Dyer, Director U.S. Nuclear Regulatory Commission Office 05E7 Washington, DC 20555-00001 Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Jack Strosnider, Director U.S. Nuclear Regulatory Commission Office T8A23 Washington, DC 20555-00001 Mr. Jonathan Rowley, Senior Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike MS-O-1 1 F1 Rockville, MD 20853 Mr. James J. Shea, Project Manager U.S. Nuclear Regulatory Commission Mall Stop 08G9A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 (for mal delivery)

Vemon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street-Drawer 20 Montpelier, Vermont 05620-2601 Diane Curran, Esq.

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

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ATTACHMENT 1 RAI 2.2-1 Table 2.2-4 of the license renewal application (LRA) identifies "Structures Not within the Scope of License Renewal." This table identifies the "Office Building (administration and service buildings)" as not within the scope of license renewal (See page 2.2-10 of the LRA). The table identifies two updated final safety analysis report (UFSAR) sections as references for the office building. UFSAR Section 12.2.1.1.3 Is an appropriate reference that identifies the administration building as a seismic Class II structure. However, the second UFSAR Section 12.2.3 Is actually for the turbine building and not the administration or service building. Clarify and correct the reference to Section 12.2.3 In Table 2.2-4.

RAI 2.2-1 Response The office building is called by various names in VY documents: the office building or area, the service building or area, and the administration building. It is sometimes considered part of the turbine building and In other contexts described as a separate building. In UFSAR Section 12.2.3, this area Is listed as the "service area" that Is part of the turbine building. Although the reference to UFSAR Section 12.2.3 Is correct, this reference could have been omitted since Section 12.2.3 only lists the service area and provides no description or further information about the service area.

RAI 2.2-3 The pressure regulator and turbine generator control system Is described in USFAR Section 7.11. The purpose of the turbine generator control system is to control steam flow and pressure to the turbine and to protect the turbine from overpressure or excessive speed. The turbine generator controls work In conjunction with the "nuclear steam system" controls to maintain essentially constant reactor pressure and limit reactor transients during load variations. The LRA does not address the nuclear steam system, nor does it appear to refer to UFSAR Section 7.11 In the text. Clarify whether the nuclear steam system is Included in the scope of license renewal, or explain the basis for Its exclusion.

RAI 2.2-3 Response The pressure regulator and turbine generator control system as described in UFSAR Section 7.11 Is an EIC portion of the main turbine generator (TG) system listed In Table 2.2-2. The TG system "provides automatic and manual controls to maintain essentially constant reactor pressure and limit reactor transients during load variations. Components In the system control steam flow and pressure to protect the turbine from overpressure or excessive speed."

As discussed In the Introduction to Table 2.2-1 b, "EIC Systems within the Scope of License Renewal (Bounding Approach)," all electrical and I&C commodities contained in electrical and mechanical systems are In scope by default. Table 2.2-1b provides the list of electrical systems that do not include mechanical components that meet the scoping criteria of 10 CFR 54.4.

Systems (such as the TG system) with mechanical components that meet the scoplng criteria of 10 CFR 54.4 are listed In Table 2.2-1a. The pressure regulator and turbine generator control system as described in UFSAR Section 7.11 Is not considered a separate system and therefore Is not listed In Table 2.2-1a. However, the components that perform this function are in scope as EIC components.

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igPF-Pg VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAls)

ATTACHMENT 1 RAI 2.3.3.2a-1 License renewal drawing LRA-G-191159-SH-01-0, at location H-12, depicts pipe section 2"-SW-566C within the scope of license renewal. Upstream from where 2"-SW-5660 enters the reactor building from the outside, there is no drawing continuation to depict the license renewal boundary. Provide Information for the continuation of 2"-SW-566C to the license renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.2a-1 Response Pipe section 2"-SW-566C contains vacuum breakers to prevent water hammer In the nonsafety-related portion of the SW system. The portion of this piping outside of the reactor building wall ends at this point. There Is no continuation of this portion of the piping. The boundary at the other end of this piping segment Is where the piping becomes nonsafety-refated. The LRA

' drawings only show the portions of the system with Intended functions that meet 10 CFR 54.4(a)(1) or (a)(3). As described in LRA Section 2.1.2.1.3, portions of systems included for 54.4(a)(2) are not shown on LRA drawings. The portion of the system included for 54.4(a)(2) is described in LRA Table 2.3.3.13-B.

RAI 2.3.3.2a-2 License renewal drawing LRA-G-191159-SH-01-0, at location H-11, drawing note 16 Indicates pipe section 4"-SW-567 and its supports on the reactor building alternate cooling supply piping (where the vacuum breakers tie In) are seismic Class II for structural Integrity. This pipe section from valve 23D through valves RBAC-1A, 1B, 1C and 1D is not shown within the scope of license renewal. Failure of this pipe section could have an adverse effect on the Intended pressure boundary function for the service water piping. Provide additional Information about why this section of pipe and components are not shown within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.2a-2 Response This portion of piping is Included for 10 CFR 54.4(a)(2) since It provides structural support for the safety-related portion of the system. As described in LRA Section 2.1.2.1.3, portions of systems included for 10 CFR 54.4(a)(2) are not shown on LRA drawings. However as discussed In LRA Table 2.3.3.13-B for the service water system, the components outside the safety class pressure boundary, yet relied upon to provide structural/seismic support for the pressure boundary are in scope and subject to aging management review. This Includes the portion of line 4"-SW-567 required to provide structural support for the vacuum breakers. In addition, this piping and associated valves are Included for 10 CFR 54.4(a)(2) due to spatial interaction from spray or leakage since the line Is in the reactor building.

RAI 2.3.3.2a-3 License renewal drawing LRA-G-1 91159-SH-01-0, at location D-5, depicts the license renewal boundary on the downstream side of flow control valve (FCV)-104-17A. The pipe section from FCV-104-17A to the safety class boundary designation flag located at valve 171A and to the intake screens is shown not within the scope of license renewal. Similarly, the pipe section from Page 2 of 9 BVY 06-090 Docket 50-271

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 1 FCV-104-17 B, C, D, and E to valves 17B, C, D and E and to the Intake screens is also shown not within the scope of license renewal. Failure of these sections of pipe could have an adverse effect on the Intended pressure boundary function for the service water piping. Provide additional Information about why these sections of pipe and components are not shown within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.2a-3 Response The LRA drawings only show the portions of the system with Intended functions that meet 10 CFR 54.4(a)(1) or (a)(3). As described In LRA Section 2.1.2.1.3, portions of systems Included for 10 CFR 54.4(a)(2) are not shown on LRA drawings. Valves FCV-104-17ANB/C/D and E are normally closed valves that are only open when the traveling screens are being washed.

Providing water to clean the screens Is not a function that meets 10 CFR 54.4(a)(1) or (a)(3).

These valves fail to a closed position such that failure of the piping downstream of these valves would not affect the ability of the SW system to perform Its functions required for 10 CFR 54.4(a)(1) or (a)(3). However, as described in LRA Table 2.3.3.13-B, the portion of the service water system in the Intake structure near the SW pumps and the components outside the safety class pressure boundary, yet relied upon to provide structuraVselsmlc support for the pressure boundary are in scope and subject to aging management review for 10 CFR 54.4(a)(2). This includes the portion of lines downstream of FCV-104-17AIB/C/D and E that provide structural support.

RAI 2.3.3.2a-4 License renewal drawing LRA-G-1 911 59-SH-02-0, at location G-6, depicts a license renewal boundary flag at the tee of pipe sections 2"-SW-566D and 8"-SW-34. There are no highlighted pipes or components on 2"-SW-566D or 8-SW-34. Clarify which portions of pipe and components are and are not bounded by the aforementioned boundary flag and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.2a-4 Response The LRA drawings only show the portions of the system with intended functions that meet 10 CFR 54.4(a)(1) or (a)(3). As described in LRA Section 2.1.2.1.3, portions of systems Included for 10 CFR 54.4(a)(2) are not shown on LRA drawings. The piping and valves on line 2"-SW-566D are safety-related since they have a safety function to break vacuum and prevent water hammer In the service water system. As a result, a system Intended function boundary flag Is provided that points towards and Includes all the components on line 2"-SW-566D. The reason these components are not highlighted as subject to aging management review Is that they perform their system intended function though the active function of the valves opening and breaking vacuum. In accordance with 10 CFR 54.21 (a)(1)(i), components that perform their Intended functions with moving parts or a change In configuration are not subject to aging management review. These components do not have a passive intended function of pressure boundary for 10 CFR 54.4(a)(1) or (a)(3) since this portion of the system Is isolated when aligned to the ultimate heat sink.

However, as described In LRA Table 2.3.3.13-B, the portion of the service water system Inside the reactor building and the components outside the safety class pressure boundary, yet relied upon to provide structural/seismic support for the pressure boundary are In scope and subject to aging management review for 10 CFR 54.4(a)(2). This Page 3 of 9 BVY 06-090 Docket 50-271

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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAls)

ATTACHMENT 1 Includes line 2"-SW-566D and portions of lines connected to this line that provide structural support and have the potential to affect safety-related components due to spray or leakage.

RAI 2.3.3.3-1 License renewal drawing LRA-G-191159-SH-03-0, at location P-10 at valve 29 shows a section of pipe within the scope of license renewal. This section of pipe is the reactor building closed cooling water (RBCCW) return to the alternate cooling system. However, a drawing continuation Is not provided. Provide Information for the continuation of this pipe section to the licens6 renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.3-1 Response The reactor building closed cooling water (RBCCW) return to the alternate cooling system (ACS) shown on license renewal drawing LRA-G-191159-SH-03-0, at location P-10 at valve 29 continues on license renewal drawing LRA-G-1 91159-SH-02-0, at location E-2.

As described in UFSAR Section 10.7, the RHRSW system provides a dynamic heat sink for the RHR system during accident conditions. One of its safety functions Is to provide service water to support the ACS should all service water pumps become Inoperable. The RBCCW system piping that supports RHR pump seal cooling by ACS supports this safety function. Therefore, these components are within the scope of license renewal per 10 CFR 54.4(a)(1). The ACS and RBCCW system piping that supports RHR pump seal cooling by ACS also perform a function that demonstrates compliance with the Commission's regulations for fire protection (1 OCFR50.48) and are therefore within the scope of license renewal per 10 CFR 54.4(a)(3).

RAI 2.3.3.5a-1 License renewal drawing G-1 91173, Sheet 1, at location H-5 shows a section of pipe within the scope of license renewal. The section of pipe includes check valve V-30 and a "penetration at concrete wall,' with changes In seismic classifications at each end. The section of pipe is Isolated from all other In-scope piping and Is not in an in-scope flow path. The piping upstream of V-30 (8"-FPC-24, 6"FPC-24, and 8*FPC-34) contains two normally closed valves (V-28 and V-

53) and Is not shown within the scope of license renewal. Piping downstream of V-30 (40-FPC-24 and 4"-FPC-25) Is also not shown within the scope of license renewal. Failure of these sections of piping could have an adverse effect on the intended pressure boundary function for the fuel pool cooling piping. Provide information to justify exclusion from the scope of license renewal the piping from valves V-28 and V-53 to valve V-30 and from the reactor well diffusers to the current license renewal boundary at the penetration upstream of valve V-30.

RAI 2.3.3.5a-1 Response The LRA drawings only show the portions of the system with Intended functions that meet 10 CFR 54.4(a)(1) or (a)(3). As described in LRA Section 2.1.2.1.3, portions of systems included for 10 CFR 54.4(a)(2) are not shown on LRA drawings. The piping from valves V-28 and V-53 to valve V-30 and from the reactor well diffusers to the license renewal boundary at the penetration upstream of valve V-30 are Included in scope and subject to aging management review for 10 CFR 54.4(a)(2) as described In LRA Table 2.3.3.13-B for the FPC system. The description Page 4 of 9 BVY 06-090 Docket 50-271

Richard-E Mich - BVY 06-090 - LR Am-'. 15 - RAI Repiý'-qise's -_Sc6ýi9g.PDF rRichariiErnch - BVY 06-090 - LR Am. 15 - RAI Responses -Scoping.PDF P~nc~ s~ II VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPUCATION RESPONSE TO REQUESTS FOR ADDmONAL INFORMATION (RAis)

ATrACHMENT 1 Includes portions of the system In the primary containment building and reactor building and components outside the safety class pressure boundary, yet relied upon to provide structuraVseismic support for the pressure boundary. The piping In question is inside the reactor building and attached to safety-related components so It Is In scope and subject to aging management review.

RAI 2.3.3.6-1 License renewal drawing, LRA-G-191162, Sheet 2, provides information about the emergency diesel generators, diesel-driven fire pump, and house heating boiler systems, supported by the fuel oil (FO) system. However, the drawing does not provide sufficient Information about the John Deere diesel system, also supported by the FO system. For example, more information is required regarding the transfer system between the 75,000-gallon fuel oil storage tank and the day tanks for the two John Deere diesels and single fire pump diesel, which are required to provide an Intended function for 10 CFR 54A (a)(3) in support of the fire protection regulation (10 CFR 50.48). The LRA text states only that a 500-gallon portable tank is used to transport fuel oil to the diesel day tanks. Typical components subject to aging management review (AMR) for diesels like the day tank, strainer, etc., for the John Deere diesel are not covered. Provide the FO system drawings and describe the John Deere diesel system. Explain the relationship between the John Deere diesel and the FO systems and clarify what the AMR tables should Include in both Sections 2.3.3.6 and 2.3.3.12. Also, provide information for the license renewal boundary that justifies its location with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.6-1 Response The 350 gallon diesel fire pump fuel oil day tank and 550-gal fiberglass underground storage tank for the John Deere diesel are filled with fuel oil from the fuel oil storage tank. The fuel oil is pumped from the fuel oil storage tank drain line into a portable 500-gallon tank. The portable tank Is then moved to the Intake structure or John Deere diesel building by a fork lift. A 12VDC pump on the portable tank then pumps the fuel oil into the diesel fire pump fuel oil day tank or the fiberglass underground storage tank for the John Deere diesel. Since the portable tank and pump are not part of the fuel oil system pressure boundary and since levels In the diesel fire pump fuel oil day tank and underground storage tank for the John Deere diesel are maintained, the portable tank and pump do not perform a component intended function and are not subject to aging management review.

A dedicated 550-gal fiberglass underground storage tank provides fuel to the John Deere diesel engine. As the John Deere diesel is required for compliance with the Commission's regulations concerning fire protection (1 0CFR50.48), providing fuel oil for the engine Is an intended function of the fuel oil system in accordance with 10 CFR 54.4 (a)(3). Therefore, the storage tank and associated piping and components that supply fuel oil to the diesel engine Injectors are in scope and subject to aging management review. John Deere diesel fuel oil components are included in the Injector housing, Piping, Pump casing, Strainer housing, and Tank line items in LRA Tables 2.3.3.6 and 3.3.2-6.

As the John Deere diesel is required for compliance with the Commission's regulations concerning fire protection (10CFR50.48), it is In scope and subject to aging management review in accordance with 10 CFR 54.4 (a)(3). The John Deere diesel is a nonsafety-related skid-mounted engine powering a generator that supplies back up electric power to plant lighting. It is Pago 5 of 9 BVY 06-090 Docket 50-271

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A1TACHMENT I located in a separate structure identified as the John Deere diesel building. The diesel Is electrically started utilizing batteries and does not require cooling water from other plant systems. Flow diagrams are not available for this skid-mounted diesel, or its fuel oil system, and only a few components are represented In the equipment database. However, the passive mechanical components of the diesel subject to aging management review that were verified by walkdown are Included in LRA Tables 2.3.3-12 and 3.3.2-12.

RAI 2.3.3.11-1 License renewal drawing LRA-VY-E-75-002-0, at location K-13, penetration X209D to the H2/02 analyzers, shows a section of pipe within the scope of license renewal. However, this same section of pipe on drawing LRA-G-1 91165-0, at location E-1 6 from penetration X209D through the continuation to drawing LRA-VY-E-75-002-0, is not shown within the scope of license renewal. Confirm whether this section of pipe Is within the scope of license renewal, or If not, Justify its exclusion.

RAI 2.3.3.11-1 Response The section of pipe shown on license renewal drawing LRA-VY-E-75-002-0, at location K-1 3 at penetration X209D to the H2/O2 analyzers and on drawing LRA-G-191165-0, at location E-16 from penetration X209D through the continuation to drawing LRA-VY-E-75-002-0 is within the scope of license renewal and subject to aging management review. Dashed lines (or phantom lines) on the drawings indicate that the actual line Is shown on its primary system drawing.

Phantom lines are not highlighted on the license renewal drawings.

RAI 2.3.3.11-2 Ucense renewal drawing LRA-VY-E-75-002-0, at location J-9 shows a pipe section, Including valve NG-1 6 to pipe section 20"-AC-1 3 within the scope of license renewal. However, this same section of pipe on drawing LRA-G-191175-SH-01-0, at location K-10 Is not shown within the scope of license renewal. Confirm whether this section of pipe Is within the scope of license renewal, or If not, justify its exclusion.

RAI 2.3.3,11-2 Response The section of pipe shown on license renewal drawing LRA-VY-E-75-002-0, at location J-9, including valve NG-16 to pipe section 20"-AC-13 and on drawing LRA-G-191175-SH-01-0, at location K-10 Is within the scope of license renewal and subject to aging management review.

Dashed lines (or phantom lines) on the drawings indicate that the actual line is shown on Its primary system drawing. Phantom lines are not highlighted on the license renewal drawings.

RAI 2.3.3.11-3 License renewal drawing LRA-VY-E-75-002-0, at location G-7 provides a continuation from valve VG-77 to drawing LRA-G-1 91165-0 (at location B-1 7) that is within the scope of license renewal.

However, the license renewal boundary could not be located on drawing LRA-G-1 91165-0 (at location B-1 7). Provide additional information for the continuation of this pipe section to the license renewal boundary and Justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

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ATTACHMENT 1 RAI 2.3.3.11-3 Response License renewal drawing LRA-VY-E-75-002-0, at location G-17 provides a continuation from valve VG-77 to drawing LRA-G-1 91165-0 that Is within the scope of license renewal. The drawing references location B-17 on drawing LRA-G-191165-0. The hydrogen/oxygen analyzers are shown at location H-14 on drawing LRA-G-191165-0. Therefore, the appropriate reference location for the continuation on drawing LRA-G-1 91165-0 Is H-1 4. An engineering request was submitted to correct the discrepancy on drawing LRA-VY-E-75-002-0. The piping to VG-77 Is connected to 3/" pipe VG-1 09-Ti prior to valve VG-20. As shown on the drawings, all of the piping and components from the primary containment air space to the analyzers and from the analyzers to the torus are within the scope of license renewal and subject to aging management review.

RAI 2.3.3.11-4 License renewal drawing LRA-VY-E-75-002-0, at location J-8 shows a pipe section downstream of valve VG-30A within the scope of license renewal. A drawing continuation to the license renewal boundary is not provided. Provide additional information for the continuation of this pipe section to the license renewal boundary and justify theboundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.11-4 Response Ucense renewal drawing LRA-VY-E-75-002-0 shows hydrogen/oxygen analyzer panel SI within a dotted rectangular box at locations H-17 through J-18. Above the box, at location G-18, VG-29A is shown going to hydrogen/oxygen analyzer panel SI, which Is not shown but is the same as the SII panel. Valve VG-30A, below the box at location J-1 8, is coming back from the SI panel. As shown on the drawing, all of the piping and components from the analyzer panels to the torus are within the scope of license renewal and subject to aging management review.

RAI 2.3.3.11-5 License renewal drawing LRA-VY-1 91165-0, at location 1-15 provides a continuation of a pipe section from the 1-12/02 analyzers to drawing LRA-VY-E-75-002-0 that is within the scope of license renewal. However, the license renewal boundary could not be located on drawing LRA-VY-E-75-002-0. Provide additional information for the continuation of this pipe section to the license renewal boundary and Justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.11-5 Response See RAI 2.3.3.11-3 response.

RAI 2.3,3.11-6 License renewal drawing LRA-VY-1 91165-0, at location C-12 provides continuations to drawing LRA-G-1 91267 (at locations H-1 2 and H-5) for two pipe lines from the post accident sampling panel that are within the scope of license renewal. The license renewal boundary could not be located on LRA-G-191267-SH-01-0. Provide additional information for the continuation of these Page 7 of 9 BVY 06-090 Docket 50-271

-Ruc-hard E-m-cfi -- BVY 06-.090 - L I R.- A m--'. i 5 - 1ý11ý.1,.'Respomses --Scoping.PD -F Pan'e i 1 *11 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

ATTACHMENT 1 pipe sections to the license renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).

RAI 2.3.3.11-6 Response The two pipe lines from the post accident sampling panel shown on license renewal drawing LRA-VY-1 91165-0, at location C-1 2 come from drawing LRA-G-1 91267 (at locations H-1 2 and H-5). However, the interface is difficult to understand as presented on the drawings due to the use of typicar representations on the drawings.

As shown in the table on drawing LRA-G-191267-SH-02-0 at location A-16, jet pump 1 has a high pressure (lower) Instrument connection with root valve 20B (root valve 20A for jet pump 6 is shown on LRA-G-191267-SH-01-0 at H-6 with typical instrumentation shown at H-5). As shown on LRA-G-191267-SH-01-0, the piping and components from the jet pump to the instruments are In scope and subject to aging management review as part of the RCS pressure boundary (LRA Section 2.3.1.3). Although not shown on LRA-G-191267-SH-01-0, a sample line from the high pressure instrument line extends to PASS system valves 102 and 101. This Is the line shown on drawing LRA-G-191165-0 going from jet pump Instrument root valve V-20B to PASS valves 102 and 101. As indicated on the drawing, components In the sample line are in scope and subject to aging management review as part of the primary containment atmosphere control and atmosphere dilution system (LRA Section 2.3.3.11).

Similarly, as shown In the table on drawing LRA-G-1 91267-SH-02-0 at location A-1 6, jet pump 11 has a high pressure (lower) instrument connection with root valve 20D (root valve 20C for Jet pump 16 Is shown on LRA-G-191267-SH-01-0 at H-1I with typical Instrumentation shown at H-12). As shown on LRA-G-191267-SH-01-0, the piping and components from the jet pump to the Instruments are in scope and subject to aging management review as part of the RCS pressure boundary (LRA Section 2.3.1.3). Although not shown on LRA-G-191267-SH-01-1, a sample line from the high pressure Instrument line extends to PASS system valves 104 and 103. This is the line shown on drawing LRA-G-1 91165-0 going from jet pump Instrument root valve V-20D to PASS valves 104 and 103. As Indicated on the drawing, components In the sample line are in scope and subject to aging management review as part of the primary containment atmosphere control and atmosphere dilution system (LRA Section 2.3.3.11).

Therefore, In accordance with 10 CFR 54.4(a)(1), the entire reactor coolant pressure boundary out to the second Isolation valve on the PASS sample lines is In scope and subject to aging management review.

RAI 2.3.3.13k-1 License renewal drawing LRA-G-191178-SH-01-0, at location D-4, shows the common elbow differential flow element upstream piping and high side instrument lines connected to flow transmitters FT-1 2-1A and FT-12-1B not In the scope of license renewal. A failure of the flow element upstream reactor water cleanup (RWCU) piping or common high side Instrument line could prevent the flow transmitters from detecting a high flow condition and the subsequent auto Isolation of the RWCU Isolation valves. The UFSAR states that the high flow auto closure of the RWCU isolation values prevents excessive loss of reactor coolant and reduces the amount of radioactive material released from the nuclear system caused by an RWCU line break. This line break Isolation feature Is necessary to support equipment qualification for high energy line break Page 8 of 9 BVY 06-090 Docket 50-271 I

_!ý(qýarqEmch - IM Ob-090-- Lk Am'. 15'- RAi 1ý4sýýqs_-_Sqopýng.PCO' IDA Richard Emch - BVY 06-090 - LR Am. 15 - RAI Responses-Scoping.PDF P~ri~ 19dI VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION:

RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (RAls)

ATTACHMENT 1 analyses. Confirm whether the RWCU high flow auto Isolation will occur when negative differential pressure is caused by either failure of the flow element upstream piping or the common high side instrument line. If not, explain why the flow element upstream piping and the common high side instrument lines are not shown in the scope of license renewal on the above drawing.

RAI 2.3.3.13k-1 Response The flow element upstream piping and the common high side Instrument lines are within the scope of license renewal based on the criterion of 10 CFR 54.4(a)(2) and thus are not shown as highlighted on the drawing. As stated In LRA Table 2.3.3.13-B, "Description of Nonsafety-Related System Components Subject to Aging Management Review Based on 10 CFR 54.4(a)(2) for Physical Interactions," the nonsafety-related portion of the RWCU system located inside the reactor building is within the scope of license renewal and subject to aging management review. The common elbow differential flow element upstream piping and high side Instrument lines connected to flow transmitters FT-1 2-1A and FT-12-1 B are located Inside the reactor building and are included In Table 2.3.3-13-36, "Reactor Water Clean-Up (RWCU)

System Nonsafety-Related Systems and Components Affecting Safety-Related Systems Components Subject to Aging Management Review." They are listed as component types of piping, tubing and valve body. As discussed In LRA Section 2.1.2.1.3, "Mechanical System Drawings," in-scope (a)(2) components are not highlighted on the drawings.

Page 9 of 9 BVY 06-090 Docket 50-271

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