ML062850253

Email: (PA) VY Lr D-Base Rev. 4 - Part 1 of 2

ML062850253
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	09/18/2006
From:	Hamer M Entergy Nuclear Vermont Yankee
To:	Rowley J NRC/NRR/ADRO
References
%dam200611, TAC MD2297
Download: ML062850253 (77)

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Rir' rdEmch - WY LR D-BaseRev. 4 - Part 1 of 2Paeij From:

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

To:

"Jonathan Rowley" <JG R @ nrc.gov>

Date:

Mon, Sep 18, 2006 4:47 PM

Subject:

VY LR D-Base Rev. 4 - Part 1 of 2

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VY LR D-Base Rev. 4 - Part 1 of 2 Mon, Sep 18, 2006 4:45 PM "Hamer, Mike" <mhamer@entergy.com>

mhamer@entergv.com Recipients nrc.gov TWGWPO03.HQGWDOO1 JGR (Jonathan Rowley)

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A-K-01 Please explain where the commitments for the various AMP enhancements to bring the particular AMP In conformance to the GALL Report recornmendations are made? How are these commitments tracked to closure?

2 B.I.1-L-01 Program Description Item -The GALL states, 'Gray cast Iron, which Is Included under the definition of steel, Is also subject to a loss of material due to selectie leaching, which Is an aging effect managed under Chapter XI.M33, 'Selective Leaching of Materials%* The LRA states, 'This program includes (a) preventive measures to mitigate corrosion and (b) Inspections to manage effects of corrosion on the pressure-retaining capability of burled carbon steel, stainless steel, and gray cast Iron components.' Are gray cast Iron components Included In the VYNPS selective leaching program?

3 B.1.1-L-02 Program Description Item - The LRA states, *A focused Inspection will be performed within the first 10 years of the period of extended operation....

Wtat Is fth extent of the focused Inspection at the start of the period of extended operation?

Modified Question: Program Description Item -The IRA states, 'A focused Inspection will be performed within the first 10 years of extended operation...

On what areas will the 'focused Inspection" be focused?

4 B.1.1-L-03 Scope of Program Element -The GALL Report stales, The program relies on preventrve measures such as coating, wrapping and periodic Inspection for loss of material caused by corrosion of the external surface of buriled steel piping and tanks., The IRA states, "The VYNPS program does not Inspect tanks. There are no buried steel tanks subject to aging management review.'

What Is the basis for Including piping but excluding tanks?

The LRA. Appendix B identifies the commitments for AMP enhancements.

Closed Consistent with how other NRC commitments we tracked, VY will enter the commitments associated with License Renewal Into PCRS corrective action database as Work Tracking (W7) Re ms. We win do this when requested by the LR Project Manager who has a tracking Item to define how all planned actions are tracked.

Yes, gray cast Iron components subject to aging management review are Included In the VYNPS selective leaching program. Reference IRA Section 8.1.25 and Table 3.32-8.

If a focused Inspection Is required during the first 10 years of the period of extended operation, It will be conducted In accordance with the criteria of NUREG-1 801,Section XI.M34, Burled Piping and Tanks Inspection.

In section 4 of XI.M34 It states that any credited Inspection should be performed In areas with the highest likelihood of corrosion problems, and In areas with a history of corrosion problems. This defines the focused Inspection that will be performed at VYNPS which will also Include burled piping that has experienced external corrosion problems and areas that have conditions such as exposure to groundwater that could increase the likelihood of corrosion of buried piping.

The basis for exclusion of tanks from the Burled Piping Inspection Program Is that none of the metal tanks subject to aging management review are burled.

Therefore, aging of tanks Is managed by other programs. Reference IRA Sections 3.2.2.2.9 and 3.4.2.2.5, and Section 3.3 Tables (The only buried tank In the auxiliary systems Is fiberglass.) [LAP 4/12/06]

These were discussed In Interview and the responses were subsequently written.

Closed Closed Closed

5 B.1.1-L-04 Parameters Monitored/inspected Element -The GALL Report states.

'Coatings and wrappings are Inspected by visual techniques." The LRA states,

'Guidance lot performing examinations of buried piping wilt be enhanced to specify that coating degradation and corrosion are attributes to be evaluated.*

What Is the VYNPS commitment number associated with this enhancement?

Burled piping Is visually examined for evidence of corrosion damage or coating defects.* A review of PP 7030, Section 4.3, does not identf the parameters that pertain to corrosion damage or coating defects. Is this the guidance that VY intends to enhaince?

6 8.1.1-1-05 Detection of Aging Effects Element -The GALL Report states, "Inspections substituted for inspections requiring excavation solely for the purpose of inspection. Methods such as phased array UT technology provide indication of wall thickness for buried piping without excavation. Use of such methods to identify the effects of aging Is preferable to excavation for visual Inspection, which could result In damage to coatings or wrappings.' How are buried components that cannot be examined by UT, due to, e.g.. either material or size, examined?

7 9.12-P-1 Exceptions granted under the current license are not assumned to apply to period of extended operation. Please confirn that the excepted weld Is outside the scope of license renewal. Also, explain why it need not be Inspected at least once In each Inspection interval.

a B.1.7-l-01 BWRVIP utilities have made a commitment that the NRC will be notified by a BWRViP licensee of their decision to not fully Implement a BWRVIP report, as approved by the NRC staff, within 45 days of the reports approval. Please clarify to exceptions for not fully Implementing BWRVIP report by VYNPS.

Did VYNPS define any new cases of not flly Implementing BWRVIP in the VYNPS LRA?

License Renewal Commitment #1 Vermont Yankee will enhance PP 7030. Structures Monitoring Program Procedure, to provide additional guidelines for inspections of buried pipe and underground structures. Attributes to be considered will Include:

1. improved definition of the scope of underground piping inspections

2. define the condition of coatings to be inspected, including adhesion and discontinuities.

3. define the need to Inspect piping underneath failed coatings

4. provide acceptance criteria, Including removal of rust and an evaluation of remaining wall thickness against the minimum wall thic"kness requirements

5. provide instructions to notify Engineering for an inspection of any underground structures unearthed diving excavation of piping.

Buried components are Inspected when excavated during maintenance. The exception merely states that alternate methods may be used to Inspect buried components. Reference LRA Section B.1.1.

As indicated in IRA Tables 3.3.2-13-5 and 3.3.2-13-36, the excepted welded connection Is subject to aging management review for potential spatial Interaction In accordance with 10 CFR 50.54 (a)(2). As stated In LRA Section 8.1.2, exception Note 1, the welded connection need not be inspected because It Is in a section of piping that Is Safety Class 0 and has no license renewal function in accordance with 10 CFR 54.4 (a)(1) or (a)(3).

The BWR Vessel Internals Program Includes provisions to notify the NRC If VYNPS does not Implement a BWRVIP recommendation. Exceptions to the NUREG-1 801 programs that Invoke specific BWRVIP reports are identified In Appendix B of the IRA. Reference IRA Section B.1.7 and LRPD-02 (AMPER) Section 4.7 The IVVI program procedure is ENN-DC-135, and the cuLrret revision Includes the requirements of BWRVIP 94 Revision 1. VY has prepared a technical Justification to defer the Jet pump beam examinations to align with the refueling outage schedule as allowed by BWRVIP-94 (Revision in place at time of deviation). The BWRV1P requirements are based on 24 month cycles while VY is on a 18 month cycle. The UT examinations of the Jet Pump beams are scheduled for the next refueling outage RFO 26 (2007).

BWRVIP 94 Revision 1, Section 3.5 provides guidance on the reporting requirements. A BWRV1P letter dated 12/20/2005 requires Implementation by 8/1/2006. This Is also addressed In the latest revision of ENN-DC-135.

Accepted Closed Closed Closed

.1 9

8.1.74H-02 In the VYNPS LIRA. pages B-28 & C-5, an exception to BWRVIP-25 Is taken.

UT & Enhanced VT-1 examinations are used to detect cracking and verify the Integrity of a critical number of rim hold-down bolts. VT.3 examination Is used to detect general conditton. Please provide further Justification for the aging management of the cracking, since VT-3 cannot detect cracking. If EVT-1 cannot be performed, please provide alternative for review and approval.

License Renewal Commitment # 29.

Closed RAI 9.1.7-H-02 This exception came from TJ-2004-0t In PP 7027. The BWR Core Plate Inspection and Flaw Evaluation Guideline (BWRVIP-25) recommended a LIT or EVT-1 examinations of core plate rim hold-down bolts for all plants that have not Installed core plate wedges. These bolts are the only location in the core plate requiring Inspection. Utilities have determined the EVT.1 examinations are extremely difficult to perform and are of limited value. The Inspection commlttee of the BWRVIP has attempted to develop a UT technique, and has had limited success. However, the LIT examination can only be performed on a limited number of existing bolt configurations and delivery hardware for the Inspection equipment has not been developed.

VY w*Ill either Install core plate wedges or complete an analysis, Including TLAA. to support continued inspection In accordance with BWRVIP-25.

CLOSED TO RAI 9.1.7-H-02 10 B.1.7-H-03 In the VYNPS IRA. page B-29, the applicant idenrifted a VT-3 examination as a baseline. The baseline Inspection described In BWRVIP Is the first Inspection that satisfies the guidelines In BWRVIP. Since VT-3 does not satisfy the BWRVIP guidelines, the inspection cited does not provide a baseline. Please explain how the BWRVMP guideline will be meel 11 B.1.7-11-04 In the VYNPS IRA, page B-27, (BWRVlP.76) Recent industry experience Indicates that partial through-wall cracks from the Inside dlameter are possible. (Mhey have been detected at Plant Hatch.) How will cracking initiated from the Inside surface of VYNPSs core shroud welds HI, H2. and H3 be managed?

Continuous question: Does applicant plan to revise LRA? If yes, Please provide the exact wording for LRA supplement.

The response to this question Is the same as above (e.g. Question 9). I.e. the LIT Inspection Is challenging and the BWRVIP Is working developing an inspection method.

LRA Amendment Accessible regions of the core shroud welds H1,H2 & H3 are UT examined LAW BWRVIP-76. Portions of the total accessible regions of H,.H2 & H3 are characterized as design reliant analysis performed by the shroud repair designer determined the minimum design reliant weld lengths.

LRA Section B.1.7 will be changed as follows:

1. The exception to the BWR vessel Intemals program related to the core shroud (page 9-27) will be deleted.

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

Closed Accepted

-p Ucense Renewal Commitment #36 Accepted 12 B.1.7.H-05 In the WNPS LRA, page B-28 (BWRVIP-18 and BWRVIP.41) BWRVIP.18 states that Inspection technique development needed for the thermal sleeve welds Is being addressed by the BWRVIP inspection committee as a high priority iam (since 1996). The Final License Renewal SER for BWRVI P41 states that aging management review of the nozzle thermal sleeve (et pump Inaccessible welds) will be provided by Idividual applicants. Please provide plant-specific justificationVconmmflent to demonstrate that these inaccessible welds (BWRVIP-1 8o4) will be adequately managed during the period of extended operation.

10 r3 ti CD1 VYNPS wil Inspect the hidden let pump thermal sleeve and core spray thermal sleeve welds In accordance with BWRVlP-18 and 41 once the technology Is developed and approved by the NRC.

If technology 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 by expanding the discussions summarized below.

The VYNPS hidden let pump welds (TS-1&2) are far enough Into the nozzle that failure at these welds would not result In the thermal sleeve disengaging from the nozzle. With the thermal sleeve still engaged. structural Integrity of the rest of the Jet pump Is maintained. If the VYNPS Jet pump thermal sleeve or riser piping severed, It would be detected through Jet pump monitoring, and the unit would be shut down to effect a repar of the break. The effects of short operation on the affected Jet pump nozzle would be evaluated.

The VYNPS hidden core spray welds (CSTS-1,2&3) are far enough Into the nozzle that failure at these welds would not result in the thermal sleeve disengaging from the nozzle. With the thermal sleeve still engaged.

structural Integrity of the rest of the core spray rng header Is maintained. If the VYNPS core spray thermal sleeve or ring header piping Is severed, It would be detected through the core spray sparger break detection monitoring system. The unit would be shutdown to effect repair of the break, If the core spray system Is operated during this time, the affect of that operation on the affected core spray nozzle would be evaluated.

The VYNPS hidden core spray welds (CSTS.1,2&3) are far enough Into the nozzle that failure at these welds would not result in the thermal sleeve disengaging from the nozzle. With the thermal sleeve still engaged, structural Integrity of the rest of the core spray ring header Is maintained. If the VYNPS core spray thermal sleeve or ring header piping Is severed, It would be detected through the core spray sparger break detection monitoring system. Once the technology is developed VY will Inspect these welds lAW BWRVIP-18.

If technology has not been developed and approved by the NRC at least two years prior to the period of extended operation. VYNPS will Inilate plant-specific action to resolve this Issue. That plant specific action may be Justification that the welds do not require Inspection by expanding the discussions summarized below.

The VYNPS hidden Jet pump welds (TS-I &2) are far enough into the nozzl that failure at these welds would not result in the thermal sleeve disengaging from the nozzle. With the thermal sleeve still engaged, structural Integrity of the rest of the Jet pump is maintained. If the VYNPS let pump thermal sleeve or riser piping severed, It would be detected through Jet pump monitoring, and the unit would be shut down to effect a repair of the break. The effects of short operation on the affected jet pump nozzle would be evaluated.

... -.. ; I..

.9 13 B.1.7-H-06 In the VYNPS LRA, page B-28 (BWRVIP-41) The VYNPS LRA states that flaws were identified through UT examinations. Please provide detailed.

Inspection evaluation, scope expansion and corrective action Information for the staffs review.

14 B.1.7-H-07 In the VYNPS LRA, page B-31 (BWRVIP-26) The VYNPS LRA states that an inspection will be performed for the first 12 years of the period of extended operation (PEO). Please clarify what Inspections (Hf any) will be performed for the remaining PEO.

Need commitment for the re-Inspection. Need word.

The VYNPS hidden core spray welds (CSTS-1,2&3) are far enough into the nozzle that failure at these welds would not result In the thermal sleeve disengaging from the nozzle. With the thermal sleeve still engaged, structural Integrity of the rest of the core spray ring header is maintained. If the WNPS core spray thermal sleeve or ring header piping Is severed, It would be detected through the core spray sparger break detection monitoring system. The unit would be shutdown to effect repair of the break. If the core spray system Is operated during this time, the effect of that operation on the affected core spray nozzle would be evaluated.

The VYNPS hidden core spray welds (CSTS-1,2&3) are far enough Into the nozzle that failure at these welds would not result In the thermal sleeve disengaging from the nozzle. With the thermal sleeve still engaged.

structural Integrity of the rest of the core spray ring header Is mairtained. If the VYNPS core spray thermal sleeve or ring header piping Is severed, It would be detected through the core spray sparger break detection monitoring system. Once the technology Is developed VY will inspect these welds lAW BWRVIP-18.

TE-2003-0021 from Appendix C of PP 7027 will be provided during on-site audit. References used to prepare TE-2003-0021 will be available for on-site review upon request Flaw evaluations were performed for the jet pump (JP) diffuser welds. JP riser welds, and the core spray collar welds. The JP riser flaw evaluation calculation number Is VYC-2400. The core spray collar weld flaw evaluation report number Is VY-RPT-05-00015. 100% of the JP diffuser welds were inspected by UT In RFO 21 (1999). The flawed diffuser welds were re-Inspected by UT In RFO 23 (2002) wth littie change In flaw sizes. 26 of 30 JP riser welds were UT inspected in RFO 20 (1998) and 4 welds were Inspected by VT-I with cleaning. The flawed riser welds were re-Inspected by UT in RFO 22 (2001) with no crack growth on 2 welds and two previous Indications were determlned to be due to UT ransducer lift-off. 100 % of the core spray collar welds were examined by UT In 1996. The flawed collar welds were re-Inspected by UT In RFO 22 (2001) with no change In flaw sizes. The flawed J P diffuser/riser welds and the Core Spray collar welds are scheduled to be Inspected by UT during RFO 26 (2007). Future re-Inspections will be performed In accordance with BWRVIP requirements.

License Renewal Commitment #2 NUREG-1 801 requires Inspection of 5% of the Top Guide during the first six years of the period of extended operation, and inspection of an additional 5%

during the second 6 years of the period of extended operation. VYNPS has committed to these examinations In the current LRA.

In response to the discussions relative to this question, VYNPS will Inspect an additional 5% of the Top Guide during the third 6 years of the period of extended operation. (Commitment #2)

Closed Accepted

• 0~

15 5.1.8-L-01 Operating Experience Element -The LRA states, 'A QA audit in 2001 revealed latent non-compliance with station administrative and Appendix J implementing procedures." Please clarify the meaning of latent! In this context.

Added:Scope of Program Item. Are any other examinationslests performed. In addition to the Integrated leakage rate and t*e local leakage rate tests?

No additional tests or examinations are performed under the Containment Closed Leak Rate Testing Program.

The term latent in this context means: not currently affecting program effectiveness, but with the potential for affecting program effictiveness If not corrected. While technical details were followed, admiistrative processes, associated with test record retention, were Implemented outside the established requirements. This procedural non-compliance. If not corrected, could have dImInished the effectiveness of the program. Reference VYNPS Audit Report VT-2001-26.

16 B.1.9-K-01 Please demonstrate that the guidelines provided in D2278 are consistent with or more stringent than the gulderines provided In D6217 to Justify the use of D2276 only.

17 B.1.9-K-02 Are the guidelines provided In D4057 addressed In this program? If not.

please Justify excluding this standard as an exception to the GALL Report recommendations.

18 B.1.9-K-03 Please Indicate what additives, If any, are provided by the fuel oil supplier.

Please provide a copy of a recent fuel oil procurement specification or supplier declaration which indicates what fuel oil addlitves are Included as well as any tests that may have been performed by the fuel oil supplier or by VYNPS.

ASTM D2276 provides guidance on determining particulate contamination using a field monitor. It provides for rapid assessment of changes in contamination level without the time delay required for rigorous laboratory procedures. It also provides a laboratory filtration method using a 0.8 micron filter. ASTM D6217 provides guidance on determining particulate contamination by sample filtration at an off-site laboratory. Neither method contains acceptance criteria or is more stringent than the other. Thus, there is no reason to use both methods. Since ASTM D2276 Is an accepted method of determining particulates and Is a method recommended by ASTM D975. to which VYNPS is committed by Technical Specifications, the D2276 method Is used at VYNPS.

As stated in the program description In IRA Section 8.1.9, sampling and analysis activities are In accordance with techniical specifications on fuel oil purity and the guidelines of ASTM standards D4057-88 and D975-02 (or later revisions of these standards). Reference LRA Section B.1.9. Program Description.

Vermont Yankee purchases un-dyed, low sulfur #2 diesel fuel for use In safety-related systems. Additives are not used by Vermont Yankee or the fuel supplier. The diesel fuel currently comes from Ultramar (a Canadian refinery) to a local supplier. The refinery blends fuel to meet a given specification and may use some additives such as cetane enhancers.

Refinery use of additives is not described in their specification and Is outside the control of the end user. Blocldes have never been added to the onsite fuel supply.

Closed Closed Closed

19-,

B.1.9-K-04 Please provide the technrical Justific.ation for not adding fuel oil additives.

As stated In LRA Section B.1.9, exception note 2, plant operating experience has not Indicated a need for additives. Reference LRA Section B.1.9, exception note 2.

Fuel additives are generally required for three reasons. These are to maintain the stability of the fuel oil, change the properties of the fuel oil (e.g. Increase the Ignition quality) or to prevent bacterial or mold growth in the fuel oil. The addition of blocides may degrade some of the other fuel oil properties such as Increasing the filterable solids loading.

For the past 10 years, VYNPS has been buying high quality fuel oil from Ultramar in Canada. Our deliveries are Umed to the arrival of new rail cars In Vermont from this refinery. We specify very high quality fuel oil and ensure that It and the delivery trucks do not contain any contaminarnts. Monthly analyses of diesel fuel oil from the top, middle and bottom of the Main Fuel Oil Storage Tank have not produced any Indications of fuel oil deterioration or the presence of water or sediment. Since mold and bacteria grow In the water fuel ofl interface, we have no need for blocides.

Diesel generator performance associated with the quality of the diesel fuel oil has been excellent. Thus, there Is no need for fuel oil additives.

The Diesel Fuel Monitoring Program monitors fuel quality and levels of water In the fuel oil. ASTM D4057-88 (or a later revision of this standard), Standard Practice for Manual Sampling of Petroleurm and Petroleum Products, is used for guidance on on sampling. Safety-related diesel fuel oil is analyzed according to ASTM D975-02 (or a later revision of this standard). ASTM D1796 Is used to check for water and sediment. Determination of particulates is according to ASTM Standard D2276. Reference LRPD-02 (AMPER) Section 4.9. Exceptions to NUREG-1 801 Section XI.M30 parameters monitored/inspected are described In LRA Section B.1.9.

Procedure OP-4613 Is available for on-site review In the program basis document.

As stated In LRA Section B.1.9. the Diesel Fuel Monitoring Program Is consistent with NUREG-1 801,Section XI.M30 for the detection of aging effects attribute. As described in NUREG-1801, periodic multi-level sampling Is used to provide assurance that fuel Oll contaminants are below unacceptable levels. Reference LRA Section B.1.9 and LSPD-02 (AMPER)

Section 4.9.

Closed 20 8.1.9-K-05 Please describe what parameters are monitored or Inspected and Indicate what guidance is used for fuel oil sampling. Please provide a copy of a representative plant procedure for fuel oil sampling.

21 B.1.9-K-06 Is mti-eve sampTing used to detect the presence of contaminants in the fuel oil and, if not, please provide the technical Justification for the approach used at the plant?

Closed Closed

22 B.1.9-K-07 Are the interior surfaces of the fuel oil tanks visually inspected and, If so.

provide a copy of a representative plant procedure used for the tank Inspection?

As stated In LRA Section B.1.9, the Diesel Fuel Monitoring Program is Closed consistent with NUREG-1 l01.Section XI.M30 for the detection of aging effects attribute. As described in NUREG-1 801, the fuel oil storage tank Is periodically drained, cleaned and visually Inspected to detect potential degradation. Reference LRA Section B.1.9 and LRPD-02 (AMPER) Section 4.9. PM Activity 3 of PM Basis M 18 Is available for on-site review In the program basis document.

The diesel day tanks are 800 gallon tanks located above ground and adjacent to the emergency diesels In separate rooms. The design of the tanks does not provide access for cleaning. The fuel oil lor these tanks Is supplied from the Main Fuel Oil Storage Tank. The suction for the transfer pumps is located 4" off of the bottom of the tank. Chemisty samples both the Main Tank and the Day Tanks from the bottom of the tanks. Water and/or sediment In the Main Storage Tank would be detected prior to it being transferred to the Day Tanks.

Each of the Emergency Diesel Generators Is run for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> monthly with each diesel using approximately 200 gallons of fuel oil per hour. This ensures that the fuel oil is turned over every month and that there are no stability Issues. There have been no Indications of water and sediment In the quarterly analyses from these tanks. Since VYNPS Is sampling from the bottom of these tanks and has not detected problems with the fuel oil, there Is no reason to drain and clean the tanks.

The John Deere Diesel Generator (JODG) Is run under load monthly for I hour. This diesel uses 10 gallons per hour and the survellance requires verification of auto feed. The fire pump diesel Is operated during monthly and quarterly surveillance tests. Thus, the fuel In the metal tanks associated with the JDDG end fire pump diesels Is turned over frequently.

23 9.1.9-K-08 Are UT measurements conducted on the fuel oil tank bottoms? How often are these measurements taken and provide a copy of a representative plant procedure which governs these measurements?

24 B.1.9-K-09 How often are the fuel oil In the tanks sampled? Is this data trended and what criteria Is used to Inmate corrective actions?

25 B.1.9-K-IO Have there been any component failures related to the qualty of the fuel oil which led to the loss of Intended function?

A 1996 ultrasonic thickness measurement of the fuel oil storage tank bottom surface revealed no significant degradation. The Diesel Fuel Monitoring Program Includes an enhancement to perform UT measurements of the fuel oi storage tank bottom surface every 10 years during the period of extended operation. Reference LRA Section B.1.9. WO 94-08951, with the results of the 1996 UT measurement, Is avaitable for on-site review In the program basis document.

The Diesel Fuel Monitoring Program Is consistent with NUREG°1 801,Section XI.M30 for the monitoring and trending attrbute. As described in NUREG-1801, monitoring (sampling) and trending occurs at least quarterly, and In accordance with VYNPS Technical Specifications (monthly). Reference LRA Section B.1.9 and Technical Specification 4.10.C2. Flterable solids acceptance criterion Is. 10 mg1L Water and sediment acceptance criterion Is = 0.05%, UT acceptance criterion will be = 60% nominal thickness.

Reference LRA Section B.1.9 and LRPD-02 (AMPER) Section 4.9.

The review of plant operating experience did not reveal any component failures retated to the quality of the fuel oil that led to the loss of intended function. Reference LRA Section B.1.9 and LRPD-05 (OE Report).

Closed Closed Closed

26 B.1.10-N-01 The results of the EQ of electrical equipment in LRA Section 4.4. Indicate equipment Identified in the TILAA. The important attributes of a re-ana"ysis are the analytical methods, the data collection, the reduction methods, the underlying assrrptions, the acceptance criteria, and corrective actions.

Provide Information on these Important attributes of re-analysis of an aging evaluation of electrical equipment Identified in the TLAA to extend the qualification under 10 CFR 50.49(e).

LRA Amendment VYNPS may perforn re-analysts of an aging evaluation In order to extend the qualliflcation of electrical components under 10 CFR 50.49 on a routine basis as part of the plants EQ program. Important attributes for the re-analysis of an aging evaluation Include analytical methods, data collection and reduction methods. underlying assumptions, acceptance criteria, and corrective actions.

VYNPS may apply this re-analysis program to EQ components now qualified for the current operating term. A re-analysis program that meets the conditions defined In the GALL report for Important attnblutes,is an acceptable AMP for license renewal under option 10 CFR 54.21(c)(l)(gi).

LRA Appendix B.1.10 will be revised to add the following:

EQ Component Re-analysis Attributes The re-analysis of an aging evaluation Is normally performed to extend the qualification by reducing excess conservatism Incorporated In the prior evaluation. Reanalysis of an aging evaluation to extend the qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) as part of an EQ program. While a component life limiting condition may be due to thermal, radiation, or cyclical aging, the vast majority of component aging limits are based on thermal conditions. Conservatism may exist In aging evaluation parameters, such as the assumed ambient temperature of the component, an unrealistically low activation energy, or In the application of a component (de-enargized versus energized). The re-analysis of an aging evaluation is documented according to the station's quality assurance program requirements that require the verification of assumptions and conclusions. As already noted, important attributes of a re-analysis include analytical methods, data collection and reduction methods, nderlying assumptions, acceptance criteria, and corrective actions (If acceptance criteria are not met). These attributes are discussed below.

Analytical Methods:

The analytical models used In the re-analysts of an aging evaluation are the same as those previously applied during the prior evaluation. The Arrhenlus methodology Is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation Is to demonstrate qualification for the total Integrated dose (that Is, normal radiation dose for the projected Installed life plus accident radiation dose).

For license renewal, one acceptable method of establishing the 60-year normal radiation dose Is to multiply the 40-year normal radiation dose by 1.5 (that Is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by.

case basis.

Data Collection and Reduction Methods:

Reducing excess conservatism in the component service conditions (for example, temperature, radiation, cycles) used in the prior aging evaluation is the chief method used for a re-analysis. Temperature data used in an aging Accepted

evaluation Is to be conservative and based on plant design temperatures or on actual plant temperature data. When used, plant temperature data can be obtained in several ways, Including monitors used for Technical Specification compliance, other Installed monitors. measurements made by plant operators during rounds, ard temperature sensors on large motors (while the motor Is not running). A representative number of temperature measurements are conservatively evaluated to establish the temperatures used in an aging evaluation. Plant temperature data may be used in an aging evaluation In different ways, such as (a) directly applying the plant temperature data In the evaluatlon or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation. Any changes to material activation energy values as part of a re-analysts are to be Justified on a plant-specific basis. Similar methods of reducing excess conservatism In the component service conditions used In prior aging evaluations can be used for radiation and cyclical aging.

Underlying Assumptions:

EQ component aging evaluations contain sufficient conservatism to account for most environmental changes occurring due to plant modifications and events. When unexpected adverse conditions are Identified during operational or maintenance activities that affect the normal operating environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken that may Include changes to the qualification bases and conclusions.

Acceptance Criteria and Corrective Actions:

The re-analysis of an aging evaluation could extend the qualification of the component. If the qualification cannot be extended by re-analysis, the component is to be refurbished. replaced, or re-qualified prior to exceeding the period for which the current qualification remains valid. A re-analysis Is to be performed In a timely manner (that is, sufficient time is available to refurbish, replace, or re-qusarfy the component i the re-analys Is unsuccessful).

0.

0 CO, 0

27 0..10-N-02 GALL X.EI, Environment Qualification (EO) of Electric Components, under

'Parameter Monitoredflnspected" states that EQ component qualified life Is not based on condition or performance monitoring. However, pursuant to Regulatory Guide 1.8g, Rev. 1, such monioring programs are an acceptable basis to modify a qualified life through analysis. Monitoring or Inspection of certain environmental conditions or component parameters may be used to ensure that the component Is within the bounds of its qualified basis, or as a means to modify the qualified life. Provide a detailed description of a monitoring program to modify the qualified tIe of EQ components through re-analysis and how the actual operating environment is determined.

The EQ program (10 CFR 50.49) does not require environmental monitoring, because the EQ components are qualified based on conservative bounding plant environments. The VYNPS EQ program, consistent with GALL X.E1, ensures that the components covered by the program are replaced at the end of the qualified lile or the qualified life Is modified by analysis In accordance with the applicable regulations governing the program.

Closed

28 B.1.10-N-03 The EQ program Is a qualification program that assures SSCs are replaced Closed Discuss operating experience of the existing EQ program. Show where an prior to exceeding qualified life beyond that date when unacceptable aging existing program has succeeded and where It has failed in identifying aging degradation may occur. The review of OE Identified no conditions in which degradation In a timely manner, the program failed to identify unacceptable aging degradation. License Event Report (LER) 97-20 notified the NRC staff of program deficiencies Including non-conservative analytical methods. Supplementary and confirmatory analyses were completed because conditions In the EQ analyses were determined to be non-conservative. This OE demonstrates that the corrective action process Is used to doctument program deficitncies and track corrective actions when necessary.

QA audt In 2000 and 2002 Identified deficiencies related to maintenance and content of program documentation. A 2004 QA audit and engineering program health report determined the program Is effective and being administered and maintained In a manner that meets regulatory requirements and commitments.

29 B.1.11-P-t Please clarify the basis for excluding the Impact of environmental factors for critical locations during the period of extended operation.

License Renewal Commitment # 27 The impact of environmental factors on fatigue at critical locations during the period of extended operation will be addressed as stated In the following commitment Prior to entering the period of extended operation, for each of the seven locations that may exceed a CUF of 1.0 wten considering environmental effects, VYNPS will Implement one or more of the folowing: (1) further refinement of the fatigue analyses to lower the predicted CUFs to less than 1.0; (2) management of fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at Inspection Intervals to be determined by a method acceptable to the NRC); (3) repair or replacement of the affected locations. Should VYNPS select the option to manage environmental-assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be provided to the NRC prior to the period of extended operation. Reference IRA Section 4.3.

License Renewal Commitment #30.

IRA Amendment The Halon 1301 suppression system proVides fire suppression only for the computer room. There are no Appendix A. SER commitments or Appendix R commitments requiring the Haion 1301 suppression system. Therefore, it is not subject to aging management review. Aging effects for components In the C02 system are managed by the System Wailtown Program.

Reference LRA Section B.1.12.1, exception note 1; IRA Table 3.32-9; and AMRM-17 (Aging Management Review of the Rre Protection-Water System).

VY will perform C02 system walkfowns every 6 months starting no later than the beginning of the period of extended operation. (LR Commitment #30)

Accepted 30 B.I.12.1-L-01 Program Description Item - The GALL states. 'The AMP also Includes periodic Inspection and testing of the halon/carbon dioxide (CO2) fire suppression system.' The LRA does not address the halen/carbon dioxide (CO2) fire suppression system. On what basis does the IRA not address the halonr/carbon dioxide (CO2) fire suppression system?

Accepted

31 B.1.12.1-L-02 Scope of Program Element - The GALL states, 'The AMP also Includes management of the aging effects on the intended function of the halorCO2 fire suppression system.' The LRA states, This program Is not necessary to manage aging effects for halon fire protection system components.' What program will manage aging effects on halon system components?

32 B.1.12.1-L-03 The IRA states 'the t-slon 1301 suppression system Is not subject to aging management review. Aging effects for components In the C02 system are managed by the System Wakdown Program.' Explain rational for why the Haleri 1301 suppression system Is not subject to review.

33 B.1.12.1-L-04.

Parameters Monitoredhnspected Element. The GALL Report states, "The diesel-driven fire pump Is under observation during performance tests such as flow and discharge tests. sequential stalring capability tests, and controller function tests for detection of any degradaton of the fuel supply line.' The LRA states, 'Procedures will be enhanced to state that the diesel engine sub-systems (Inctufding the fuel supply line) shall be observed while the pump Is nmNng." Is there a VYNPS commitment number associated with this enhancement?

34 B.1.12.1-L-05 Detection of Aging Effects Element - The GALL Report states, *Visual Inspection by fire protection qualified Inspectors of approximately 10% of each type of seal In walkdowns Is performed at least once every refueling cycle.'

The LRA states, 'The NUREG-1801 program states that 10% of each type of penetration seal should be visually inspected at least once every refueling outage. The VYNPS program specifies inspection of approximately 25% of the seals (regardless of seal type) each operating cycle, with as accessible fire barrier penetration seals being inspected at least once every four (4) operating cycles. Since aging effects are typically manifested over several years, this variation In Inspection frequency Is Insignificant." How are inaccessible seals addressed?

35 8.1.12.11..06 Acceptance Criteria Element -The GALL states. 'Inspection results are acceptable if there are no visual indicatiros (outside those allowed by approved penetration seal configurations) of cracidng, separation of seals from walls and components, separation of layers of material, or ruptures or punctures of seals; no visual Indications of concrete cracidng. spalling and loss of material of fire barrier walls, ceilings, and floors; no visual Indications of missing parts, holes, and wear and no defidencies In the functional tests of fire doors., The LRA states. 'Acceptance criteria will be enhanced to verify no significant corrosion.' How much corrosion Is considered 'sIgnificant?' What actions are taken, either with or without "significant corrosion'? Is there a VYNPS commitment number associated with this enhancement?

The computer room fire suppression Is provided by a Halon 1301 suppression system. There are no Appendix A. SER commitments or Appendix R commitments requiring the Halon 1301 suppression system.

Therefore, it Is not subject to aging management review. Reference AMRM-17 (Aging Management Review of the Fire Protection - Water System).

The computer room fire suppression Is provided by a Haton 1301 suppression system. There are no Appendix A, SER commiltments or Appendix R commitments requiring the Halon 1301 suppression system.

Therefore, It Is not subject to aging management review. Reference AMRM-17 (Aging Management Review of the Fire Protection - Water System).

License Renewal Commitment #9 Yes - License Renewal Commitment #9 addresses this enhancement The environment to which Inaccessible seals are exposed Is very similar, If not the same, as the environment for accessible seals such that the condition of accessible seals Is representative of the condition of inaccessible seals.

License Renewal Commitmrent #8 License Renewal Commitment #8 addresses the need to revise these acceptance criteria.

Any recordable Indication is entered Into the Corrective Action Program for evaluation.

Closed Closed Accepted Closed Accepted

36 B.1.12.2-L-01 Program Deacription Item - The GALL states. 'This aging management program (AMP) applies to water-based fire protection systems that consist of sprinklers, nozzles. fittings, valves, hydrants, hose stations, standpipes, water storage tanks. and aboveground and underground piping and components that are tested In accordance with the applicable National Fire Protection Association (NFPA) codes and standards.' The LRA states. 'This aging management program applies to water-based fire protection systems that consist of sprinklers, nozzles, rfings, valves, hydrants, hose stations, standpipes, and aboveground and underground piping and components that are tested In accordance with applicable National Fire Protection Association (NFPA) codes and standards.- Does VYNPS have fire water storage tanks?

37 B.1.12.2-L-02 Program Description Item - The GALL states, "The fire protection system piping Is to be sublected to required flow testIng In accordance with guidance In NFPA 25 to verify design pressure or evaluated for wag thickness (e.g., non-intruslve volumetric testing or plant maintenance visual Inspections) to ensure that aging effects are managed and that wall thickness Is within acceptable limis. These Inspections are performed before the end of the current operating term and at plant-specific Intervals thereafter during the period of extended operation. The plant-specific Inspection Intervals are to be determined by engineering evaluation of the lire protection piping to ensure that degradation wil be detected before the loss of Intended function. The purpose of the full flow testing and wall thickness evaluations Is to ensure that corrosion. MIC, or bio-foullng Is managed such that the system function Is maintained." The IRA does not address this Item. How does VYNPS Intend to address these NFPA and GALL recommendations?

38 B.l.12.2-L-03 Detection of Aging Effects Element -The GALL Report states. 'Fire hydrant hose hydrostatic tests, gasket Inspections, and fire hydrant flow tests, performed annually, ensure that fire hydrants can perform their Intended function and provide opportunities for degradation to be detected before a loss of Intended function can occur.' The LRA states. 'NUREG -1801 specifies annual fire hydrant hose hydrostatic tests. Under the VYNPS program, hydrostatic test of outside hoses occurs once per 24 months: and hydrostatic test of inside hoses occurs once per 3 years' Provide justification for relaxing the test frequency.

No, VYNPS does not have fire water storage tanks. Reference UFSAR Section 10.11.

Closed Ucense Renewal Commitment I 11 This paragraph comes from NUREG-1 801, Section XLM27 program description. The recommendation for flow testing is included In the NUREG-1801 lechnical basis for the parameters mon1toredlirrspected attribute. As stated In LRA Section B.1.12.2. the VYNPS Fire Water System Program Is consistent with this attribute. Every fire main segment Is full flow tested using the guidelines of NFPA 25 at least once every 3 years. Reference LRPD-02 (AMPER) Section 4.12Z The recommendation for wall thinning monitoring Is Included In the NUREG-1801 technical basis for the detection of aging effects attribute. As Indicated in LRA Section B.1.12.2, the Fire Water System program Includes an enhancement to this attribute to perform wall thickness evaluations of fire protection piping using non-Intrustve techniques (e.g.. volumetrfc testing) to Identify evidence of lose of material due to corrosion. These Inspections will be performed before the end of the current operating term and at Intervals thereafter. Results of the Initial evaluations will be used to determine the appropriate inspection Interval.

Per NUREG-1800, Table 2.1-3, fire hoses are consumables not subject to aging management review. Therefore, the exception to the Fire Water System program related to fire hydrant hose hydrostatic tests Is not necessary. (An aging management program Is not required to address components that are not subject to aging management review.)

Accepted Closed

39 B.1.12.2-L-04 Detection of Aging Effects Element -The GALL states, 'Fre hydrant hose hydrostatic tests, gasket Inspections, and firs hydrant flow tests, performed annually, ensure that fire hydrants can perform their Intended function and provide opportunilies for degradation to be detected before a loss of Intended furnctlon can occur.' The LRA states, "NUIEG-1801 specifies annual gasket Inspections. Under the VYNPS program, visual Inspection. re-racking and replacement of gaskets In couplings Is to occur at least once per 18 months."

Provide justification for relaxing the test frequency.

40 B.1.12.2-L-05 Detection of Aging Effects Element - The GALL states. 'Fire hydrant hose hydrostatic tests, gasket Inspections, and ire hydrant flow tests, performed annually, ensure that fire hydrants can perform their Intended function and provide opportunities for degradation to be detected before a loss of Intended function can occur.' The LRA states, "NUREQ-1 801 specifies annual fire hydrant flow tests. Under the VYNPS program, verification of operability and no flow blockage occurs at least once every 3 years.' Provide Justification for relaxing the test frequency.

41 B.1.12.2-L-06 Detection of Aging Effects Element. The GALL Report states, 'Fire protection system testing Is performed to assure that the system functions by maintaining required operating pressures. Wall thickness evaluations of fire protection piping are performed on system components using non-intrusive techniques (e.g., volumstric testing) to Identify evidence of loss of material due to corrosion. These Inspections are performed before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation.' The VYNPS IRA identified the following enhancement, 'Wall thickness evaluations of fire protection piping wtll be performed on system components using non-intrusive techniques (e.g.,

volumetric testing) to Identify evidence of loss of material due to corrosion.

These Inspections will be performed before the end of the current operating term and at Intervals thereafter during the period of extended operation.

Results of the Initial evaluations will be used to determine the appropriate Inspection Interval to ensure aging effects are Identified prior to loss of nended function.' What Is the VYNPS commitment number associated with this enhancement?

Lcense Renewal Commitment #31 IRA Amendment Since aging effects are typically manifested over several years, differences In Inspection and testing frequencies are insignificant. The review of operating experience did not reveal age-related failures of fire water system components that led to loss of Intended function. Reference LRA Section B.1.12.2, exception note 1 and LRPO-05 (OE Report). Ucense Renewal Commitment 31 agrees to examine these components annually.

License Renewal Commitment #31 LRA Amendment As stated In IRA Section B.1.122, exception note 1, since aging effects are typically manifested over several years, differences in Inspection and testing frequencies are Inslgnlflcant. The review of operating experience did not reveal age-related failures of fire water system components that led to loss of Intended function. Reference LRPD-05 (OE Report).

License Renewal Commitment 31 agrees to examine these components annually.

License Renewal Commitment #11 License Renewal Commitment #11 Is the commitment associated with this enhancement.

Accepted Accepted Accepted

42 B.1.1.1-W-01 Provide drawings for the sand pocket region of the Drywael. Provide drawings for the refueling bellows detailing how they are stored, installed. connected and sealed. Provide procedures for how the refueling bellows are used.

Provide drawings of the Drywelg showing the gap and fill material between te secondary concrete shield wall from the refueling beflows/cavity seal connection down to the sand pocket region. Provide the VYNPS response to Generic Letter 87-05.

Portions of drawings G-191150, 0-191277. & 0.191481 have been provided Closed to the NRC for the Sand pocket region of the Drywell; Refueling Bellows assemblies. and the General Arrangement of the Reactor Building Including the Primary Containment The Refueling Bellows (to RPV) and the Drywell to Reactor Cavity Seal assemblies are permanently installed by full penetrant welds. The bellows allow the Refueling Cavity to be flooded during refueling operations to allow for spent fuel transfer to the Spent Fuel Pool for storage. No procedures are required for the operation of the bellow assemblies since they are static.

Operation of the drain line Isolation valves are controlled by plant operating procedures used for flood-up and drain-down of the cavity.

There Is no fill material In the gap located between the Drywell Shell and the Secondary Concrete Shield.

VYNPS response to GL 87-05 has been provided to the NRC.

43 B.1.1S.1-W-02 It Is stated In the VYNPS UFSAR that all Interior and exterior drywell surfaces which are exposed to the atmosphere are protected from corrosion by application of a corrosion resistant coating mat6rfal. However. in the VYNPS LRA It Is stated that VYNPS does not rely on protective coating to manage the effects of aging. The VYNPS LRA Appentrix B does not have a Protective Coating Monitoring and Maintenance Program section. However, there is a GALL AMP XI.S8 called Protective Coating Monitoring and Maintenance Program which states the following: Proper maintenance of protective coatings Inside containment (defined as Service Level I) Is essential to ensure operability of post-accIdent safety systems that rely on water recycled through the containment sumprdraln system. Explain why VYNPS does not have a Service Level I Protective Coating Monitoring and Maintenance Program to prevent coating failure that could adversely affect the operation of post-accident fluid systems and thereby Impair safe shutdown. Provide a copy of the VYNPS response to GL 98-04 and discuss it VYNPS considers the maintenance programs described acceptable coatings AMPS for license renewalt.

WNPS has a Service Level I Coatings Program; however it Is not relied on for managing the aging effects for licensing renewal.

The WNPS UFSAR states: 'No material within primary containment will fall by decomposition or corrosion and affect vital systems." The examination of the coated surfaces Is performed as a part of the Containment Inservice Inspection Program (IWE) to assure that the paint and base metal has not degraded (IS Section 4.7.A). VY has an active end effective Service Level I Coatings Program to prevent degradation to the primary containment structure.

VYNPS response to GL 98-04 Includes our commitrnent to EPRI TR-109937

• Guideline on Nuclear Safety-Related Coatings (renumbered 1003102). The GL also discusses the Impact of debris loading on the ECCS strainers. These strainers were designed to accept 100% of the coatings within the LOCA zone of Influence. The approach velocity of materials entrained In the torus water Is extremely low due to the sizing of the ECCS strainers,. Conservative design assumptions ensures VYNPS compliance with 10CFR50.46(b)(5).

A copy of VYNPS response to OL 98-04 has been provided.

Closed

44 B.1.15.1-W-03 Explain why the Containment Inservice Inspection Program Is a plant-specific program Instead of an ASME Section XI, subsection IWE program with exceptions. Explain why the scope of the Containment Inservice Inspection Program does not Include containment seals, gaskets and pressure retaining bolts. Explain under what WNPS AMPs the inspection of these components are performed. It Is stated In the VYNPS IRA that the Containment Inservice Inspection Program Is an ewtsting program. Explain If this program has been in compliance with ASME Section XI, subsection [WE since the final rulemaking to require IWE Inspections was made by the NRC In 1996.

Provide a copy of the VYNPS notification of commitment to IWE Inspections.

Entergy chose to descnrbe the Inservice Inspection and Containment Inservlce Inspection Programs as plant-specific programs rather than comparing to the corresponding NUREG-1801 programs because the NUREG.1 801 programs contain many ASME Section XI table and section numbers that change with different verslons of the code. Because of this, comparison with the NUREG-1801 programs generates many exceptions and explanations that detract from the objective of the comparison. VYNPS follows the version of ASME Section XI that is approved for use at VYNPS and accepted by 10CFR50.55(a). As this Is the case, the tnservice Inspection and Containment Inservtce Inspection Programs are presented as plant-specific programs so they can be judged on their own merit without the distraction of numerous explanations of code revision.

The Containment Inservice Inspection Program does not Include containment seals or gaskets because they have been removed from the scope of Subsection IWE In the 1998 Edition of ASME Section XI with 2000 Addenda.

These components are Inspected under the Structures Monitoring Program as Indicated In Table 3.5.2.1 of the LRA. Pressure retaining bolts are considered and Included as Integral part of the structural components.

The Containment Inspection Program does not Include contInment seals or gaskets because they have been removed from the scope of Subsection IWE In the 1998 Edition of ASME Section XI with 2000 Addenda. These components are seal tested under the Containment Leak Rate Program.

Pressure retaining bolts are considered and Included as Containment Inservice Inspection Program.

vY has been In compliance wt!OCFRS0.5Sa (b)(2)Mv) and ()(2)mx) since at least September 9, 2001. No notification of commitment to the IWE examinations was required byl 0CFRSO.55a. In 2003. VY submitted a notification of the Intent to use ASME Section Xl-1998 Edition with 2000 Addenda as the Code of Recor for all ISI programs. A copy of the submittal has been provided.

Closed

45 BA.15.1-W-04 Explain how Inspections am performed in the tors suppression pool above and below the waterline. Explain historically what Inspection findings have lead to the need for augmented Inspections. Explain If any augmented Inspections are currently being performed. The LRA states that VYNPS uses Inspection program B for containment Inservice Inspection. Provide the Inspection Interval dates through the current license and also through a possible license extension period.

46 B.1.15.1-W-06 VYNPS lists several Containment Inservce Inspection findings under operating experience forAMP B.1.15.1 In the LRA. Explain why the operating experience discusses the drywell moisture banrer when the Inspection of it does not appear to be In the scope of the VYNPS Containment Inservice Inspection Program. Provide the documertatlon for any containment inspection findings from the most recent RFO if beyond 24. Explain if water leakage has ever been discovered between the drywall and concrete secondary shield wall or in the sand pocket area. Explain what VYNPS does to Inspect for water leakage in these two areas or to verify that loss of material Is not occurring on the backside of the Drywell. Provide the docurmentation for the RFO 24 Issues identified by OA surveillance that are discussed In the operating experience. Provide the latest engineering system health report for the containment in-service Inspection program.

47 B.1.18-P-1 Please Identify the standard(s) to which Instrument air Is maintained, and document this commitment In Appendix A If appropriate.

Examinations are performed in accordance with the Code of Record that requires the examination of all accessible Interior and exterior surfaces. In 1998, the Interior surface, slightly above and fuliy below the water Oine, was stripped and coated. During RFO-24 (2004). the Suppression Pool exterior surface was General Visual examined. Though normaly inaccessible, the Suppression Pool interior was made accessible and the surface above the water-line was General Visual examined. During the General Visual examination of the Interior surface, the water clarity permitted observation of nearly 1 0% of the submerged surface area. Three small areas (at the water line) in BAY 3 were Identified to have a loss of coating and primer. These areas ware UT (uhreasonio tested) from the exterior, In 2 gridded areas. No result approached the minimum wall thickneess of 0.5=33 with the lowest reading being 0.597." Based on the results, these areas were excluded from augmented examination. In RFO-27 (2008). the VT-3 of the wetted areas Is presently planned to be executed by divers without dewatering the Suppression Pool. The current examination schedule Is contained In Program Bases Document (4.14.2) in the PP 7024 tables. The projected schedule through the possibie license extension period will be developed In accordance with the Code in effect but should be 6 Inspection periods in 20 years.

Drywall moisture barrier Is examined under the Containment InservIce Inspection Program. Table IWE-2500-1 Item E1.30 of ASME Section Xl-1998 Edition with 2000 Addenda Is contained In the Program Bases Document (4.14.2) In the PP 7024 tables. The Program Based Document (4.142) In Section B.1.15.1.10. describes the area examined and replaced during RFO-21 (2001). LRA Table 3.52.6 shows the drywel moisture barrer to be Inspected under the structural monitoring program; this will be changed to the Containment Inservice Inspection Program. IWE examinations during RFO-25 (2005) produced no findings.

In 1991, an Auxiliary Operator (AD) observed water running from a crack In the Drywall pedestal concrete onto the Torus Room floor. The Investigation revealed leakage from a steam valve was condensing on and traveilng along the Primary Containment Air Conditioning piping to the Drywall shell. From the Drywell shell, the water found a crack or cold-joint that directed it to the Torus Room floor. To ensure the Drywell shell Integrity. the sand-cushion drains were examined and found to be functional; the exterior drywall shell was Inspected and determined to be non-corroded; and the sand-cushion was observed to be dry, compacted, with adequate ventilation to assure the sand would remain dry.

License Renewal Commitmnent # 28 License Renewal Commitment # 28 ensures that Instrument air Is maintained in accordance with ISA S7.3.

Closed Closed Accepted

48 B.1.17-N-01 GALL XI.E3 under 'Detection of Aging Effects' recommends that the inspection for water collection should be performed based on actual plant experience with water accumulation In the manhole. However, the inspection frequency should be at least once every two years. VYNPS AMP B.1.17 under the same attribute requires Inspectio for water collection In cable manholes and conduit occurs at least once every two years. Explain how actual plant experience Is considered in the manhole Inspection frequency to be consistent with GALLs XU.E3.

49 8.1.17-N-02 In AMP B.1.17 under the 'Operating Experience' element, you have stated that the 'Non-EQ Inaccessible Mediumn-Voltage Cable Program* at VYNPS is a new program for which there Is no operating experience. GALL XI.E3 under the same element states that operating experience has shown that cross linked polyethylene (XLPE) or high molecular weight polyethylene (HMWPE)

Insulation materials are most susceptible to water tree formation. The formation and growth of water trees varies directly with operating voltage.

Water treeing Is much less prevalent In 4kV cables than those operated at 13 or 33kV. Also, minimizing expsure to moisture minimizes the potential for the development of water treeing. As additional operating experience Is obtained. lessons learned can be used to acjust the program, as needed.

NUREG-1 800. Rev. 1, Appendix A, Branch Technical Position RLSB-1 states that an applicant may have to commit to providing operating experience In the future for new programs to confirm their effectiveness. Describe how operating experience Is captured at VYNPS to confirm program effectiveness or how it Is to be used to adjust the program as needed.

50 8.1.17-N-03 As stated In FSAR Section 8.3.3 (Page 8.3-5 of 8), the underground power ines - that run from the adjacent Vernon Hydroelectric Station to station switchgear -have been designated as the Station Blackout alternate AC source. Thus; they are used to meet Station Blackout requirements 10 CFR 50.63. Are these cables Included In the scope of AMP B.1.17? If not, provide an explanation.

51 B.I.18-N-01 In AMP B.1.18, you have stated that for neutron flux monitoring system cables that are disconnected during instrument calibration, testing Is performed at least once every 10 years. GALL XI.E2 recommends that the test frequency shall be determined by the applicant based on engineering evaluation, but the test frequency shall beat least once every ten years. Explain how engineering evaluation Is considered In the test frequency, In order to be consistent with GALL XLE2.

LRA Amendment LRA Appendix 8.1.17 wil be revised to include the following:

VYNPS Inspection for water accumulation in manholes Is conducted by a plant procedure. An engineering evaluation will be used per EN-U-102 to document and determine the plant experience that is considered in manhole inspection frequency.

Operating Experience at VYNPS Is controlled by procedure EN-OP.100.

Operating Experience Program. The program Includes the following components:

Operating Experience - Information received from various industry sources that describe events. Issues, equipment failures that may represent opportunities to apply lessons learned to avoid negative consequences or to recreate positive experiences as applicable.

Internal Operating Experience - Operating Experience that originates as a condition report or request from plant personnel that warrants consideration for possible Entergy-wide distribution. Internal OE can originate from any Entergy plant or headquarters.

Impact Evaluation - Analysis of an OE event or problem that requires additional Information and research to determine Impact or potential Impact, as it relates to plant condition andfor configuration. Impact evaluations are typically documented with a Condition Report.

Condition Report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed.

Yes, the underground power lines that run from Vernon Dam Switchyard to VYNPS safety buses, are Included in program B.1.17.

CLOSED TO RAI 3.6.2.2.N-08 LRA Amendment LRA Appendix 8.1.18 will be revised as follows:

The first test of neutron monitoring system cables that are disconnected during instrument calibrations shall be completed before the period of extended operation and subsequent tests wlil occur at least every 10 years.

In accordance with the Corrective Action Program. an engineering evaluation will be performed when test acceptance criteria are not met and corrective actions, including modified Inspection frequency will be Implemented to ensure that the intended functions of the cables can be maintained consistent with the current licensing basis for the period of extended operation.

Yes, the 6.1.18 program Includes both cables and connections for the instnrnent circuits that are In scope for license renewal.

Accepted Closed Closed Accepted 52 B.1.18-N-02 Confirm that the test Includes both cables and connections.

Closed

53 9.1.19-N-01 In AMP B.1.19 you have stated that the a representative sample of accessible Insulated cables and connections, within the scope of license renewal, will be visually inspected for cable and connection jacket surface anomalies such as embrdttfement, discoloration. cracking or surface contamination. The technical basis for sampling will be determined using EPRI document TR-109619,

• Guldeline for the Management of Adverse Localized Equipment Eromrents'. Explain the technical basis for cable sampllng.

54 BI.19-N-02 In AMP B.1.19 under the 'Operating Experience" element, you have stated that the Non-EQ Insulated Cables and Connection Program at VYNPS is a new program for which there Is no operating experience. GALL XI.EI under same element states that operating experience has shown that adverse localized evroronments caused by heat or radiaton for electrical cables and connections may exist next to or above (within three feet of) steam generators, pressurizers or hot process pipes, such as feedwater lines. These adverse localized environments have been found to cause degradation of the Insulating materials on electrical cables and connections that Is visually observable, such as color changes or surface cracking. NUREG-1 800, Rev.

1, Appendix A. Branch Technical Position RLSB-1 under operating experience states that an applicant may have to commit to provldlng operating experience In the future for a new program to confirm its effectiveness. Describe how operating experience will be captured by VYNPS.

LRA Amendment The LRA Appendix 0.1.19 program description will be changed to read as follows:

This program addresses cables and connections at plants whose configuration Is such that most cables and connections Installed In adverse localized environments are accessible. This program can be thought of as a sampflng program. Selected cables and connections from accessible areas will be inspected and represent, with reasonable assurance, all cables and connections In the adverse localized environments. If an unacceptable condition or situation is identified for a cable or connection In the Inspection sample, a determination will be made as to whether the same condition or situation is applicable to other accessible cables or connections. The sample size will be increased based on an evaluation per EN-U-102 - Corrective Action Process.

Operating Experience at WNPS Is controlled by procedure EN-OE.1 00, Operating Experience Program. The program includes the following components:

• Operating Experience - Information received from various Industry sources that describe events, Issues, equipment failures, that may represent opportunities to apply lessons learned to avoid negative consequences or to recreate positive experiences as applicable.

-Internal Operating Experience - Operating Experience that originates as a Condition Report or request from plant personnel that warrants consideration for Entergy-wide distribution. Internal OE can originate from any Entergy plant or headquarters.

-Impact Evaluation - Analysis of an OE event or problem that requires additional information and research to determine Impact or potential Impact.

as it relates to plant condition and/or configuration. Impact evaluations are typically documented within a Condition Report.

Condition Report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed.

Accepted Closed

55 B.120-K-01 For those components that do not have regular oil changes, please provide the basis for Note I (not determinik*g the flash point for the sampled oil).

As stated In IRA Section B.1.20. exception note 1, flash point is not determined for sampled oil because analyses of tilter residue or particle count, viscosity, total acidtbase (neutralization number), water content, and metals content provide sufficient Information to verily the on does not contain water or contaminants that would permit the onset of aging effects.

Added Response: Fuel dilution Is measured on EDG lube o11, rather than determiming the flash point.

In lieu of performing Rash point testing on the Emergency Diesel Generators, Diesel Driven Fire Pump and the John Deere Diesel Generator, a test for fuel and water by % of volume is performed. This test accomplishes the same goal as the flash point test but is more prescriptive then the flash point test.

There could be two factors that affect the flash point of the oil; the addition of fuel that would lower the flash point or the addition of water that would raise the flash point The worst case would be a combination of the two. By determining the % by volume of both fuel end water, the analysis can determine the cause of the change In flash point without having to conduct additional tests and corrective actions, If required, could be implemented on a timelier basis.

Additional tests to determine the *Heaith of the diesels are; total base number (TBN), viscosity, SAE Grade, Total Soot, and Spectrometals analysis (for wear metals and additives). The results of these analyses are trended to determine the total health of the diesel and the quality of its lubricating oil.

Diesel Lube Oil Analyses are performed on a quarterly basis.

As Indicated in LRA Section B.1.20. the Oil Analysis Program is consistent with NUREG-1 801,Section XI.M39 for the acceptance criteria attribute. As recommended In NUREG-1 801, action limits were established in accordance with industry standard ISO 4406 and manufactuer's recommendations. See DP 0213 (available for on-site review In the program basis document) for trending and critera of LRPD-02 (AMPER), which Is available for on-site review In the program basis document, is a table similar to the table provided In the GALL report. Attachment 2 Identifies the inspection method and parameters monitored for applicable aging effects. As indicated in LRA Section B.1.21, of LRPD-02 (AMPER) is consistent with the table provided in NUREG-I 801,Section XI.M32.

Closed 56 B.1.20-K-02 How are the alert levels or action limits esblaished? How Is the data trndeed and what criteria are used to determine if the trends are unusual?

57 B.1.21-K-Oi Please provide a table outlining the Inspection methods used for each aging effect and parameter monitored or Inspected. This should be consistent with the table provided in GALL Report AMP XI.M32. If not, provide a Justification for any exceptions to this table.

Closed Closed

58 8.1.21-K-02 The table provided hi the program description In section B.1.21 Indicates that the one-time Inspection activity will confirm that the loss of fracture toughness Is not occunring or is so Inslgntflcant that an aging management program Is not waranted. What Inspection method Is used to detect this aging effect and what parameter Is monitored?

Please address the main steam flow restrlctors In the response.

59 B.1.21-K-03 What Is Vermont Yankee's operating experience with Class I piping teas than 4 Inches NPS In terms of cracking?

60 B.1.22-M-01 As stated by the applicant. *...prlor to the period of extended operation, program activity Implementing documents will be enhanced as necessary to assure that the effects of aging will be managed.,.." The applicant is asked to provide a listing of which specific PSPM plant Implementing documents will be enhanced and why such an enhancement Is necessary for each Implementing document.

61 8.1.22-M-O2 In the statement for the 'operating experience" element of the AMP, the applicant, notes that...the material condilion of cranes was consistent with Inspection acceptance criteria..', and "...ECCS comer room recirculation units had no significant conrosloi...

By the appearance of these statements in the

'operating experience" of the PSPM, is the staff to understand that the-applicant Intends to use the applicant's PSPM AMP In Nleu of the GALL.

recommended programs. XI.M23, "Inspection of Overhead Heavy Load and Ught Load (Related to Refueling) Handling Systems'. and XLM38. 'Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components'- during the period of extended operation?

Combinations of non-desbtctive examinations Including visual, ultrasonic.

and surface techniques will monitor cracking of CASS valve bodies In piping

<4' NPS to confirm that reduction of fracture toughness Is not occurring or Is so Insignificant that an aging management program Is not warranted.

Reference Attachment 2 of LRPD.-02 (AMPER).

Main steam flow restrictors:

Thermal aging embrittlement results In Increased rates of crack growth that are evidenced by cracking In the material. The One-Time Inspection Program will be used to verify that reduction of fracture toughness has not progressed to the point that unacceptable cracking of the component has occurred.

The review of plant operating experience (1998 to 2005) did not reveal Instances of cracking of Class I piping less than 4'NPS. Site to confirm and address expedence prior to 1998.

In the early years of plant operation VYNPS experienced occurrences of Intergranular stress corrosion cracking (IGSCC) In some stainless steel piping systems. In the period of approximately 1980 through 1988 VYNPS embarked on a major IGSCC mitigation program, replacing the susceptble stainless steel piping with IGSOC resistant materials. Since then, there have been no instances of IGSCC or other pipe cracking events at VYNPS. See report 'YAEC-1247. Rev. 1V and Letter FVY 88-62.

This information Is Included In Attachment 3 of LRPD-02 (AMPER) that Is available for on-site review In the program basis document.

Yes. Reference LRA Table B-2 and Section B.1.22 Program Description.

Closed

.0 CL 0.

r-I

'CD

'3) 0

-n Closed Closed Closed

62 8.1.23-M-01 As noted In the GALL, [Section XI.M3, Element Number four (4)-

Detection of Aging Effects']; GALL-recommended programs use visual, surface, and volumetric examinations, to Indicate the presence of surface discontin0eafflaws and other disontinuitism/fleaw throughout the volume of material The appkint's proposed exception states that cracking Initates on the outside surfaces of the boltfstudsl, and by meeting acceptance standards of IWB-3515, this 'surface-type" examination will...provide at least the sensitivty of flaw detection that an end shot ultrasonic examination provides on boits/tuds...'. The applicant Is asked to provide further evidence that such a 'qualified surface examinatIon" provides the stated level of sensivity with the thoroughness of other GALL-recommended programs.

63 B.1.23-M-02 Some replacement stud bolts use a manganese phosphate surface treatment in combination MoS2 to prevent boit degradation due to corrosion or hydrogen embrittlement. The applicant's AMP notes that Vermont Yankees existing program Includes preventive measures, such as "appropriate materials', to mitigate cracidng and loss of material. GALL Section XLM3. [Element Number two (2) - "Preventive Actions') states that the use of this type of surface treatment is acceptable and effective. Does the applicant use similar bolting with a similar type of surface treatnent?

64 8.1.23-M-03 As noted In GALL,Section XI.M3, [Element Number ten (10) -'Operating Experience']; GALL-recommended programs should have provisions regarding Inspection techniques and evaluation. The applicant states, In Its explanation of their existing program, that '...recent (2002 and 2004) visual and ultrasonic Inspectlons...revealed no recordable Indications..'. The applicant is asked to compare examinatlons performed In 2002 and 2004 with the "exception-stated' examination technique proposed for future examinations and to provide to the staff the results of this comparison.

65 B.1.26-W-01 Provide examples of VYNPS plant procedures used to implement the requirements of GL 89-13/Service Water Integrity AMP for routine Inspection and maintenance of the service water systems. Include examples of actual visual and NOE testing. Explain any differences between the GL 89-13 program scope and the Service Water Integrity Program scope for license renewal 66 B.1.26-W-02 Provide the original (or current 9i pipe has been replaced) material and lining specification for the buried piping which Is part of the service water system, including the alternate cooling system.

VYNPS meets the 1998 edition through 2000 addenda of the ASME Section XI Code. Sub Section IWB 2500-1 Examination Category B -G-1.*Pressure Retaining Boiler Greater than 2' in Dlameter* Items B.20 and.30 that specifies a surface or volumetric examination method.

As stated In IRA Section B.1.23. the Reactor Head Closure Studs Program Is consistent with NUREG-1 801, XI.M3 for the preventive actions attribute. As described In NUREG-1 801, threaded surfaces of studs, nuts and washers have a phosphate coating to act as a rust inhibitor and lubricant. Also, a stable lubricant compatible with the bolting and vessel materials is applied to the stud threads, the mating surfaces of the washers and the nut threads during assembly. Reference LRPD-02 (AMPER) Section 4.18.

LRA Amendment The 2002 examinations Included visual and ultrasonic Inspections. The 2004 examinations were visual only as per the stated exception. Future examination will be visual only in accordance with ASME Code Case N-652.

Code Case N-652 has been endorsed by the NRC per Table 1 of Regulatory Guide 1.147. Revision 14.

Closed Closed Accepted Procedures OP 5265, Service Water Component Inspection and Acceptance Criteria; PP 7021, Service Water Program; and PP 7601, Service Water Chemical Treatment and Monitoring Program are available for on-site review in the program basis document.

As stated In LRA Section 5.1.26, the Service Water Integrity Program is consistent with NUREG-1801, XI.M20 for the scope of program attribute.

Therefore, there are no differences between the GL 89-13 program scope and the Servce Water integrity Program scope for rcense renewal.

Provided a copy of the original site piping specification 0C-10 that shows the piping for the Service Water and altemate cooling water systems piping is carbon steel material and are not coated.

Closed Closed

67 B1.26-W-03 VYNPS takes exception to GALL AMP XI.M20 element 2 by stating that not ali VYNPS service water system components are lined or coated. Components are lined or coated only where necessary to protect the underlying metal surfaces. Provide an itemized list of the piping in the service water system where it Is lined or coated to protect the underlying metal surfaces. Provide the type of lining or coating for each Item on the list 68 B.1.26-W-04 Fxplain if there any portions of the service water system that are infrequently used and ere periodilcally flushed. If so, describe these portions and how often they are flushed. Explain the criteria used to Initiate the flushing.

Explain It any other flushing of the system Is done and how the strainers are cleansed. Discuss the historic Inspection results of the gravity portion of the ACS piping coming from the deep water basin and If this has been a problem area with flow blockage.

69 B.1.26-W-O5 VYNPS takes exception to GALL AMP X>.M20 element 5 by stating that the VYNPS program requires tests and inspections each refueling outage, but not annually. Provide documentation that this frequency Is In agreement with the commitments made by VYNPS under GL 89-13. Provide the frequency of heat transfer testing for each heat exchanger In the service water system.

The appnlcant Is requested to state which WNPS group Is responsible for reviewing the test data and to provide through a plant procedure an example of how this process Is Implemented. Explain the type of heat transfer testing which Is done on the service water system heat exchangers.

Unings end coatings are not credited. Piping that is lined or coated will be inspected with the same techniques used for unlined piping. An Itemized listing of which piping Is lined or coated was not necessary for the aging management review.

In accordance with the piping specification QC-I0 there Is no coated piping In the Service Water system. The only coated components area few vale body Internals and heat exchanger heads that are currentiy and will continue to be Inspected as part of the Service Water program.

The only sections of the Service Water (SW) system that are flushed on a regular basis are the instrumnntation tubing lines (3/8V stainless steel tubing). A list of the specific lines has been provided. These lines are flushed on a 12 or 18 month basis as Identified in the Preventive Maintenance program. The SW strainers are self cleaning and are not opened and cleaned on a regular basis. The suction line from the deep basin to the,HRSW pumps Is opened and inspected every other outage (3 years). The results of the inspection have shown the line to be free of tuberflcation and slit. The line is treated with a blocide before being closed after Inspection. No Issues with flow blockage have been Identified in the past six years. The mhe was found to be fouled in the early 199O's and was subsequently deaned and the addition of blocide was started. This appears to be very successful based on the recent inspections.

PP7021 provides information related to VYNPSs compliance with GLM8-13 requrernents. A copy of this procedure was provided. GL 89-13 provides for the options of performing either thermal performance testing or periodic cleaning. VYNPS has chosen to perform cleaning for most of the SW supplied heat exchanger and coolers. The exceptions are the Stand-by Fuel Pool Cooling (SBFPC) Heat Exchangers, the Emergency Diesel Generator Coolers (3 each) and the Comer Room RRUIs #7 & 8. The SBFPC heat exchangers are thermal performance tested every 18 months. Based on the satisfactory results of the tests VYNPS Is preparing a change to perform cleaning Instead of testing. The coolers have been internally examined and found to be very dean and free for silt. sludge and tuberculation. The frequency of cleaning has yet to be determined but Is anticipated to be In the every 3 to 6 year range. The Emergency Diesel Generator Coolers are tested every month and the results are trended by System Engineering. No adverse trends have been identified. A copy of the trends for the B" Diesel has been provided. Copies of the test data sheets for the entire year 2004 have been provided.. The RRU's are tested quarterly by measuing the DP across the units. This winl detect any foutng which would decrease thermal performance.

No performance issues have been Identified. An performance data and Inspection results are monitored and trended by the System Engineering Department and the Service Water System Engineer.

Closed Closed Closed

70 B.1.26-W-06 Provide the NRC inspection report written in 2002 for the service water system. Characterize the 20 service water system leaks and how they were repaired under the VYNPS corrective action program. Provide the VYNPS self-assessment and Independent evaluation which was completed on 12/2at2002. Provide an example of the documents which provide the protocols for the use of biocides to mitigate MIC and any other procedure changes made after the self-assessment Provide a sampling of the different performance testing and inspection results for 2004 that are discussed In the LRA operating experience with acceptance criteria. If more recent performance testing and Inspection results are available, provide a sampling of them.

71 B.1.26-W-06 Provide the NRC Inspection report written In 2002 for the service water system. Characterize the 20 service water system leaks and how they were repaired under the VYNPS corrective action program. Provide the VYNPS self-assessment and Independent evaluation which was completed on 1212012002. Provide an example of the documents which provide the protocols for the use of blocides to mitigate MIC and any other procedure changes made after the self-assessment Provide a sampling of the different performance testing and Inspection results for 2004 that are discussed in the LRA operating experience with acceptance criteria. If more recent performance testing and Inspection results are available, provide a sampling of them.

72 B.1.27.1-W-01 Provide a masonry want Inspection report for an un-reinforced masonry wall.

73 B.1.27.1-W-02 Explain how often masonry walls are Inspected for crackig. Explain if the inspection frequency varies from wal to wall. If the frequency does vary.

explain the basis for the differences In frequency. Explain the qualification and training that Is required of the Inspection personnel. Explain Hf Inspectors use crack maps during the Inspections to help in the detection of changes.

A copy of NRC Report, NVY 02-61 and CR-VTY-2003-02344 was provided.

This CR documents the investigation Into the adverse trend created by approximately 20 through wall leaks in the SW system. The result of this Investigation Identified several causes. One of these being the use of carbon steel components which are susceptible to Microbiological Influenced Corrosion (MIC). Another cause was determined to be Ineffective chemical treatment of the system. The ineffectiveness of the chemical treatment was reinforced by a follow up assessment (DR Lutey Report). This assessment was also provided. Changes were made to the sampling program and chemical treatment process. New chemical addition pumps were installed and sampling was Implemented for SW components during Inspections. It should be noted that the plant is limited by the NPDES permit to no more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> a day of treatment to the SW system. This reduces the effectiveness of the treatments. VYNPS also began treatment of lines which are not normally Inservice, La. supply line to the Diesel Generator Cooler.

These Ones are treated when the diesels are run to ensure that the lines are full of treated water when they are secured. Copies of the Inspection database detalitng the results of Internal Inspections have been provided.

Duplicate entry. Close to # 70.

Inspection Report for Masonry wall G-1 91513-51 provided In Drawing B-191600 Sheet 96 for an un-reinforced masonry wall was provided.

Site procedure PP-7026 will be In the program basis document Additional Response:

Inspection of masonry walls, In scope of license renewal, are performed each refueling outage. Upon completion of six successive surveillance intervals during a ten year period, the sequence of the inspection Is reverted back to the Initial sequence interval. The inspections are performed by inspection team comprised of degreed engineers having understanding of structures, materials of masonry construction and masonry wall analysis techniques. The observed Instances of cracking are detailed on as-buit and considered In record analysis.

Closed Closed Closed Closed

74 B1.27.1-W-03 Explain if Masonry Wall crack changes are turned over to engineering for evaluation and documentation by procedure. Provide the procedure for performing the Masonry Walg crack Inspectios. What engineering procedures are used to control and evaluate the attachment of new components to masonry wa*ts evaluated under NRC IEB 80-11? Explain If there Is a masonry wall log book or data base to track new attachments to block walls and evaluate the effects on the existing evaluations performed under 80-11 ?

PP 7026 Rev 1 requires that If during the course of Inspection, a 'significant Closed flndlng" Is encountered a Condition Report shall be generated and the Civil Structural Supervisor Is notified (Section 4.4, PP 7026). PP 7026 Is provided for reference. The Engineering Request process Is used to control the plants configuration. Waits affected via planned modifications are Identified during the design process and the analysis of record and design drawings reflecting I. E. B. 80-11 are updated accordingly. Administrative controls require that proposed new attachments are reviewed by the Civil Strctural Department (Section 4.4.5, PP 7026). A log book Is maintained by the Civil Structural Department with a summary findings memo and surveillance walkdow" sheets (Form VYPPF 7026.01 and Section 4.4.7. PP 7026).

Attachments Include the Vermont Yankee Masonry Wall Routine Surveillance for RFO 25 In which three corrective updates were performed for observed discrepancies. The CR generated for correcting the drawings Is also attached along with a corrected drawing for example.

75 B.1.27.2-W-01 The program description In the LRA for the Structures Monitoring Program (B.1.27.2) makes no reference to GALL, Section XLS7, RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plants. GALL XI.S7 states that for plants not committed to RG 1.127. Revision 1, aging management of water-control structures may be Included In the Structures Monitoring Program. However, details pertaining to water-control structures are to Incorporate the attributes of GALL XI.S7. Explain If VYNPS Is committed to RG 1.127 Revision 1 for Inspection of its water control structures (such as Intake Structure). If WNPS Is not committed to RG 1.127 Revision 1, explain how the 10 element attributes of GALl XI.S7 are Incorporated Into the VYNPS Structures Monitoring Program.

' ~ ~

~ ~

The water-control structure at VYNPS Is the Intake structure. There are no Closed earthen water control structures at VYNPS. The attributes of the Water Control Structures. GALL Xl.S7 aging management program applicable to the intake structure are Incorporated In the VYNPS Structures Monitoring Program as described below. Attributes of the GALL XIS7 aging management program that are not Incorporated In the Structures Monitoring Program primarily apply to earthen structures.

1) Scope -The scope of the GALL X).S7 program applicable to VYNPS Is the Intake structure. The Intake structure is included In the scope of the Structures Monitoring Program as delineated In Table 3.5.2-3.

2) Preventive actions - The GALL XI.S7 program Inci*iles no preventive actions.

3) Parameters Monitored -The aging effect requiring management for concrete structural components of the Intake structure Is loss of material which Is consistent with GALL Volume 2 Item IL.A6-7. The parameters monitored from the GALL XLS7 program apprlable to loss of material are consistent with those monitored by the Structures Monitoring Program. The guidance for Inspections of concrete In Section C.2 of RG 1.127 Is consistent with the guidance In ACI 349.3 used In the Structures Monitoring Program.

4) Detection of Aging - GALL XI.S7 Identifies visual inspection methods as the primary method used to detect aging. The Sructures Monitoring similarly uses visual Inspection methods as the primary method used to detect aging In concrete structural components. GALL X.S7 Identifies Inspection Intervals of five years. The Struchres Monitoring Program identifies similar Inspection Intervals of three years for accessible areas, ten years for Inaccessible areas and opportunistic Inspections for buried components.

5) Monitoring and Trending - Monitoring Is by periodic Inspection for both the GALL XI.S7 and Structures Monitoring Programs.

6) Acceptance Criteria - Acceptance criteria Is not Identified In RG 1.127.

however appropriate guidance Is provided In the Structures Monitoring Program to ensure corrective measures are identified prior to loss of Intended function.

7-9) The corrective actions, confirmation process and administrative control attributes of the Structures Monitoring Program and the GALL XI.$7 program are consistent-

10) Operating Experience - The operating experience relevant to the effectiveness of the Structures Monitoring Program Is presented in Appendix 0 of the application and is consistent with the operating experience described in GALL XI.S?.

Therefore, the attributes of the NUREG-1801 XIS7. Water Control Structures, aging management program pertaining to the Intake structure are incorporated within the VYNPS Structures Monitoring Program.

76 B.1.27.2-W-02 Explain why the deryle floor iner seal and other components are not part of the ASME Section XI subsection IWE Inspection program. Justify this exclusion. Explain why the Inspection of crane rails and girders are not under an Inspection of Overhead Heavy Load and Ught Load Handling Systems AMP. Explain if all the structures and components being added to the Scope of Program for this AMP by enhancement are currently Inspected by another program, since the SMP Is an existing program.

IRA Amendment Accepted The drywa floor liner sal (moisture barried) Is examined under the Containment Inservice Inspectlon-IWE Program and will remain under the CII-IWE Program during the period of extended operation not the Structures Monitoring Program as shown In IRA Table 3.5.2-1. This approach will require the followIng.

1) Update LRPD-02. Section 4.14.2 Item B.4 by adding 'ihe CII Program manages cracldng and change In material properties for drywael shell to floor seal (molsturre barerl) elastomnre

2) Update LRPD 02, Section 4.21.1 Items B.1.a and b Enhancement! and Item 10.D. 'Summary' to delete "drywell floor finer sear from the discussion.

3) Update IRA Table Une Item "DryvwHl floor liner sear for Table Item 'AMP' change Structures Monitodng" to "CIHWE'. For clarification, change

'drywell floor liner sear to "drywell shell to floor seal (moisture bander)

The clarification of the terminology also applies to Table 2.4-1 and Section B.1.27.2. (This change requires an amendment letter to the LRA)

The Periodic Surveillance and Preventive Maintenance and Structures Monitoring Programs adequately manage aging effects for cranes and girders. Therefore, a separate program (i.e., Inspection of overhead heavy load and fight load handling system) Is not necessary. Not all the miscellaneous structures and components added by the enhancement to the SMP are currently inspected under another program.

License Renewal Commitment #33 LRA Amendment VNPS does not have porous concrete sub foundations or a site dewatering system. The Inspection team was provided with the results of the two most recent reported groundwater samples as submitted to the State of Vermont.

These samples are currently obtained twice yearly, primarily around the plant septic systems (some of the sampling wells are near plant structures). The results of these samples are provided to the State of Vermont In accordance with our Indirect Discharge Permit The Strictures Monitoring Program will be enhanced, (License Renewal Commitment #33) to ensure an engineering evaluation Is made on a periodic basis (at least once every five years) of groundwater samples to assess for evidence of groundwater being aggressive to concrete. Historically, VYNPS groundwater samples have shown some level of seasonality in that the wels adjacent to roadways have slightily higher levels of chlorides due to salt treatment.

Yes. VYNPS will and currently does take advantage of Inspecton opportunities for underground structures that become accessible by excavation. This Inspection Is already part of the program.

77 B.1.272.W-03 Explain If VYNPS has any porous concrete sub foundations and a site dewaterfng system. Explain If the Structures Monitoring Program requires periodic sampling and testing of groundwater to determine and confirm that that the below grade water chemistryfsoll Is non-aggresslve to concrete structures below grade. Provide the results for the two most recent tests and provide the scheduled frequency of groundwater monitoring. Explain If there Is any seasonal consideration for groundwater monitoring.

78 B.1.27.2-W-04 Will VYNPS take advantage of Inspection opportunities for struictures required for license renewal and Identified as inaccessible? As Inaccessible areas become accessible by such means as excavation or other reason, will additional Inspections of those areas be performed?

Accepted Closed

79 B.1.27.2-W-05 Explain how the frequency of Inspection for the structures. buildings and components within the scope of this program are affected when aging effects are discovered.

Vermont Yankee's current structures monitoring program Is performed by Closed Design Structural Engineers In accordance with PP 7030. Structures Monitoring Program Procedure. Our surveillance track"ng program ensures that this inspection is performed on a three year Interval.

Any adverse condition discovered during Inspections of buildings, structures and components would be entered Into Ertergyts Corrective Action Process through the Initiation of a Condition Report In the PCRS tracking system. The Corrective Action Program defines further responses to the discovered condition. Attributes considered through the corrective action win include, as applicable, apparent cause evaluation, root cause evaluation, extent of condition, consideration of Operating Experience, required corrective action and follow-up verification. Frequency of future inspections will also be considered through the Corrective Action Process.

80 9.1.27.2-W-06 Explain If the inspection acceptance critera for the Structures Monitoring Program Is based on ACI 349.3R-96, and Uf not, provide the Industr code standards and guldelines that the acceptance criteria is based on. Explai basis of the acceptance criteria for crane ral/girder Inspections and drywe floor finer seal.

LRA Amendment Accepted s,

The VYNPS Structures Monitoring Program Is controlled by PP 7030.

I the Structures Monitoring Program Procedure. The standards used to develop 11I and conduct the program are listed in Sect. 5.2 of the procedure. The specific standard used to develop inspection requirements for this procedure Is NEI 96-03, "Nuclear Energy Institute, Industry Guideline for Monttorlng the Condition of Structures at Nuclear Power Plante, Section 3.3 'Examination Guidance. Inspection requirements of commodities taken from NEI-96-03 are delineated In Section 4.3.3 of PP7030. A comparison of the relevant guidelines for concrete structural components In PP7030. with the guidelines of ACt 349.3 Chapter 5 "Evaluation Criteria Indicates general consistency.

1) Both documents specify visual Inspection methods for the examination of structures.

2) Both documents provide guidance for the Inspections for the following parameters and conditions:

Concrete components: spallng. cracking, delamination, honey combs, water in-leakage, chemical leaching, peeling paint, or discoloration Structure Settlement: excessive total or differential settlement Structural/seismic gap: insufficent space for structural movement during a seismic event (I.e., exclusion of foreign objects or debris); deteriorated elastomer type filler.

3) ACt 349.3R96 Chapter 5 provides acceptabre limits beyond which further evaluation Is required. PP7030 Section 4.8 conservatively requires evaluation of Identified degradation.

Based upon this comparison, the guidance for Inspections provded In PP7030 is consistent with the guidelines In ACt 349.3R96.

The acceptance criteria for crane rail/girder inspections are contained In the preventive maintenance tasks for the crane Inspection. Procedure OP 2200 provides the Inspection and acceptance criteria for crane ralllgIrders. The procedure criteria Is based on the following codes and standards ANSI B30.2.

83Property "ANSI code" (as page type) with input value "ANSI B30.2.</br></br>83" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 'Overhead and Gantry Cranes" and NUREG-0612, Control of Heavy Loads at Nuclear Power Plante.

The acceptance criteria for the drywall shell to floor liner seal (moisture barrier) is covered under 4.14.Z Containment Inspection Program. See the response to Item 76 for addtional discussion on this seal For additional discussion, see Item #243 response.

81 B.1.27.2-W-07 VYNPS lists the following structure Issues under operating experience for this AMP.

" Concrete pad above JD diesel generator day tank sinking and cracking

• Degradation of Cooling Tower structural column Provide the documentation for these Issues showing when, where and how they were discovered. Also, provide the documentation on how these Issues were evaluated and resolved with a discussion on the need for any follow-up Inspections.

Provide the most recent Inspection results for the reactor building overhead crane rails/girders, reactor building (a few examples of areas where aging has been discovered), cooling towers, and Intake structure (a few examples of areas where aging has been discovered). Provide the last three inspection reports for the drywell floor rier seal.

IRA Amendment Accepted Documentation of the operating experience with structural repairs was provided to the Inspection Team In the following formatb Concrete pad above the JD diesel generator day tank WO 99-1090-000 WO 99-9748-001 Degradation of cooling tower struntural columns WO 05-5158-000 WO 07-5357-004 WO 97-5327-00 WO 03-1243-009 Intake structure floor concrete repair WO 04-1745-000 The concrete pad above the JO diesel generator day tank Is in a high traffic area. Degradation was Identified by personnel transiting the area. The cracked concrete slab was replaced. This was essentially a design Issue, In that the original pad was not designed to bear the weight of the fuel oil delivery truck. The reference WO replaced the pad and added bollard columns to prevent vehicles from driving over the pad. No further follow-up Inspections are required.

Degradation of cooling tower structural columns was discovered during routine fall and spring structural Inspection PMs. These columns were replaced In kind. Follow-up inspections are performed during the routIne fall and spring structural Inspection PMs.

The most recent inspection and repair results for the Turbine Building overhead crane were provided to the Inspection Team. Included were reports of two different Inspections, repair information and monitoring plans. Both the Reactor and Turbine Building overhead cranes are In scope of the Maintenance Rule and are subject to the same Inspection and corrective action programs. Recent Reactor Building overhead crane Inspections have identified only mechanical and electrical deficiencies (I.e. trolley motors, brakes, etc.). The results for the Turbine Building overhead crane were provided in lieu of the Reactor Building overhead crane because the recent inspection results Involve structural elements and show the effectiveness of the Maintenance Rule crane inspection program. The Structures Monitoring Program will be enhanced (Project document revision) to describe how the program takes credit for the structural inspection program being performed through the Maintenance Rule crane Inspection program.

Examples of Inspections for cooling tower aging are Included In the referenced WOs above.

As stated in other responses, LRDP-02 will be revised to indicate that the drywall floor liner seal will be covered under the containment Inspection program, not the structures monitoring program. The seal was replaced two

refueling outages ago, and the seal Inspection report for last outage has already been provided to the Inspection team.

Degradation of Intake structure floor concrete was discovered during routine diver PM Inspections performed every refueling outage. The small washed out area was repaired with an underwater concrete repair product. Follow-up routine diver PM Inspections will be performed every refueling outage.

82 B.1.27.3-W-01 Explain which VYNPS individual is responsible for the coordination of Vernon Dam FERC Inspections. Explain the process of VYNPS Interfacing with FERC with respect to Vernon Dam and if there are any plant procedures for the interface. ft there are plant procedures for dealing with FERC, provide a current copy. Explain If VYNPS has any Influence on what and when repairs are made on Vernon Dam from a management or economic standpoint.

Provide the most recent Vernon Dam assessment performed by FERC.

Explain how VYNPS receives the report and If the report Is Independently reviewed by any VYNPS personnel such as In systems or design engineering.

RAI 3.6.2.2.N-08 There has not been any need for site to coordinate or Interface with Vernon Dam's Federal Energy Regulatory CommIssion (FERC) Inspection. VYNPS does not have an individual responsible for coordinating, Interfacing.

collecting and reviewing FERC Inspection report. There is no site procedure for dealing with FERC and obtaining a current copy. Reports are normally received on site after each inspection. VYNPS does not have any Influence on what and when repairs should be made from management or economics standpoint.

CLOSED TO RAI 3.6.2.2.N-08 Closed

83 B.1.27.3-W-02 The operating experience for this AMP states that daily inspections are made of Vernon Dam and periodic underwater Inspections are made on the Dam.

Explain what organization makes the daily Inspections and the underwater Inspections. Explain how often the underwater Inspections are performed and what determines the frequency. Explain If WNPS has ever Independently Inspected Vernon Dam. Explain If any flooding has occurred which required additional FERC Inspections beyond the normal 5 year. The operating experience states that areas of degradation were found on Vernon Dam during the 2002 FERC inspection and will continue to be monitored. Explain ff the continued montioring is by FERC on a five year cycle or by VYNPS personnel on a more frequent basis. Explain the type and number of staff that work at Vernon Dam on a daily basis to maintain it. Explain If and how any personnel at Vernon Darn have the ability to communicate Immediately with responsible Individuals at VYNPS should a problem develop at the Dam which could affect the availability of plant cooling water.

RAI 3.6.2.2.N-08 As stated In LRA section 2.4.5, Vernon Dam is not part of the site structues owned by VYNPS. Dam Inspections are regulated by the Federal Energy Regulatory Commission (FERC). which licenses the dam and associated power block-Daily inspections are performed by the dam owner's (e.g. Trans Canada, maintenance personnel. And. underwater inspections are performed by divers once every 5 years as required by FERC. No evidence of flooding to require additional FERC inspections beyond the normal 5 year. As stated in the inspection reports, maximum rise In stage cause by a breach will not exceed 1.7 feet under either 50 or 100 year flood condition. The areas of degradation. found on Vernon Dam during the 2002 FERC inspection, are monitored by FERC on a five year cycle. However, daily Inspection by the dam owner also supplements these inspections. Number and type of staff at Vernon Dam on daily basis Is not kn'own. Although not proceduralized, any significant problem with dam is expected to be communicated to the site.

In accordance with NEI 95-10, Rev. 6, Appendix C, Reference 4 (pages C-20 through C-25), License Renewal Issue No. 98-0100, Crediting FERC-Required Inspection and Maintenance Programs for Dam Aging Management,' FERC inspections may be credited for aging management activities. The Vemon Dam is under FERC Jurisdiction and that Its inspection end maintenance program Is in conformance with FERC requirements. The NRC guidance In the referenced section of NEI 95-10 states 'It is the staffs opinion that dam inspection and maintenance programs under the Jurisdiction of FERC or the Army Corps of Engineers, continued through the period of the license renewal, will be adequate for the purpose of aging management (page C-25)."

During the period of the onsite inspection Vermont Yankee Staff provided a copy of the most recent FERO inspection for the Vernon dam to the NRC Staff.

CLOSED TO RAI 3.6.2.2.N-08 License Renewal Commitment #26 No, as stated In LRA Section B.1.30.1, rather than sampling, procedures will be enhanced (License Renewal Commitment 26) to flush the John Deere diesel cooling water system and replace the coolant and coolant conditioner every three years.

Closed 84 B.1.30.1-M-01 Since the applicant Is currently and periodically sampling and analyzing the cooling water of the other systems 'controled' by VYNPSs existing program-the stator cooling water and plant heating boller systems--Is It also the intent of the applicant to periodically sample and analyze the John Deere Diesel cooling water system?

Accepted

85 B.1.30.2-M-01 Section)(].M2 of the GALL notes that a 'water chemIsty only' program may not be fully effective for verification of corrosion or SCC In slow flow or stagnant flow areas. The GALL further sugests that for some of these

'susceptible locations" a one-time Inspection verification program may be appropriate. Do you Intend to Implement a'one-time Inspection (or some other program) to verify existence of corrosion or SCC In these "susceptible locations'?

88 B.1.30.2-M-02 Section XI.M2 - Element Number four (4) - of the GALL notes that the staff considers a BWR water chemistry program as a "...mitlgation program and (that It) does not provide detection of any aging effects...'. The GALL further states that *...inspection of select components (should) be undertaken to verify the effectiveness of the program..." The applicant's AMP does not present any other program - other than the Indirect results of their existing water chemistry program - to verify effectiveness of the chemistry control program. Do you Intend to perform "other inspectlons, as suggested by the GALL, "...to ensure that significant degradation Is not occurring and that Intended functions of system components Alt be maintained during the extended period of operation...'?

LRA Amendment Yes, the one-time Inspection program described in LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs by confirming that unacceptable cracking, loss of material, end fouling Is not occurring.

To provide further cisrifIcation, the effectiveness of the Water Chemistry Control - Auxillary Systems. BWR. and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -Auxllary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities wIll confirm the effectiveness of these programs.

LRA Amendment Yes, the one-time Inspection program described In IRA Section B.1.21 includes Inspections to verify the effectiveness of the water chemistry control aging management programs by confirming that unacceptable cracking, loss of material, and fouling Is not occurring.

To provide further clarificaton, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A.

SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitiy state One-Time Inspection Program activiltes will confirm the effectiveness of these programs.

Accepted Accepted

87 B.1.S0.3-M-01 The applicant's exception for this AMP states that *...monitoring pump performance parameters is of little value In managing effects of aging on long.

lived, passive CCW system components.'. The associated GALL for this AMP (XI.M21; Element 4) states that *...control of water chemistry does not preclude corrosion or SOC at locations of stagnant flow conditions or crevices...'. How does this AMP ensure that a stagnant flow condition or crevice will not be periodically present In system piping during the period of extended operation?

LRA Amendment Accepted This AMP does not ensure that a stagnant flow condition or crevice will not be periodically present In system piping during the period of extended operation.

Preventing stagnant flow conditions is not a recommended preventive action in NUREG-1 801,Section XI.M21. As stated In LRA Section 8.1.20.3.

passive Intended functions of pumps, heat exchangers and other components will be adequately managed by the Water Chemistry Control. Closed Cooling Water Program through monitoring and control of water chemistry parameters. Also the one-time Inspection program described In LRA Section B.1.21 includes Inspections to verify the effectiveness of the water chemistry control aging management programs by confirming that unacceptable cracking, loss of material, and foutling Is not occuring.

To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is

,L.'ia*nurr y lire One-Time inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chem"st Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.

88 B.1.30.3-M02

[Original Question]

The applicants exception for this AMP also states that I....in most cases.

functional and performance testing verifies that the component active functions can be accomprished and as such would be Included as part of the maintenance rule...'. Does this AMP reference or refer to *maintenance rule actlvlties" as part of planned aging management actions; i.e.. actions which address GALL XI.M21 'parameters monitoredrinspected?

[Follow-up Question] Clarify commitment to performance monitoringltesting of HX (founlng) and pumps

".oM) managed using OCCW (SWI) and CCCW (WCC-Aux & WCC-CCW) AMPs.

[Original Response]

No, functional and performance testing are not aging management actions.

They are maintenance rule activities and not part of the Water Chemistry Control - Closed Cooling Water Program. As stated In LRA Section B.1.30.3, the Water Chemistry Control -Closed Cooling Water Program takes exception to this recommendation of NUREG 1801, Section Xl.M21.

[Follow-up Response]

As stated In Section 4.20 of LRPD-02, the Service Water Integrity Program, In accordance with NRC GL 89-13, Includes condition and performance monitoring activities. As these activities are already pad of the existing program, a separate commitment is not necessary.

As stated in the LRA and prior RAI responses, the Water Chemistry Control -

Auxiliary Systems and Water Chemistry Control - Closed Cooling Water programs do not Include performance or functional testing of heat exchangers or pumps. The programs are preventive programs which maintain the water chemistry within specified limits to minimize loss of material, cracking and fouling. Also, as described in LRA Section B.1.21. the One-Tine Inspection program will verify the effectiveness of the water chemistry control aging management programs by confirming that unacceptable cracking, loss of material, and fouling is not occurring. Therefore, the passive intended functions of pumps, heat exchangers, and other components will be adequately managed without condition or performance monitoring. [Condition and performance testing of heat exchangers and pumps is performed under the Maintenance Rule 1 OCFR50.65, but Is not considered part of these aging management programs.]

Closed

89 A-P-01 Please clarify the rationale for the unusual numbering system used for auxiliary systems after the first 12. (Note: This question Is arbitran'ly inked to the first Item of Table 3.3.1-13-1) 90 3.1.1-14-P-01

'Support* Is not listed as an Intended function Please clarify which IF (SNS.

SRE, and/or SSR) Is Intended.

Section 13 Includes all the systems that have Intended functions that meet 10 Closed CFR 54.4(a)(2) for physical interaction. The aging management review of these systems that have functions that met 10 CFR 54.4(a)(2) for physical Interaction was done separately from the review of systems with Intended functions that met 10 CFR 54.4 (a)(1) or (a)(3). The results of this review therefore needed to be presented separately so that they could be distinguished from the 10 CFR 54(a)(1) and (a)(3) review. Table 3.3.1-13 would be the next sequential table number after the remainder of the auxiliary system tables. To indicate Inrvdual systems included in the aging management review for (a)(2). Table 3.3.1-13 Is subdivided by system. For example, Table 3.3.1-13-1 Is for the augmented off gas system, a system which only has components Included for (a)(2). For the core spray system, Table 3.3.1-13-6 shows the components included for (a)(2) but since the system is also In scope for other reasons, Table 3.2.2-2 shows the components Included for 54.4(a)(1) and (a)(3). This numbering system was chosen so that these systems and the components that had Intended functions unique for 54.4(a)(2) could be uniquely Identified and reviewed separately. This allows a reviewer to clearly distinguish which component types in a system were Included for 10 CFR 54.4(a)(2) for physical Interaction. Since most of these systems are auxilary systems they were added as part of the auxiliary systems section.

This response assumes that the question Is referring to the tables in Section Closed 3.3.2-13 for components Included for 10 CFR 54.4(a)(2). This function Is described in Section 2.3.3.13 under "System Description (pg. 2.3-65) and In the definition In Table 2.0-1 for 'Pressure boundary.* As shown in the component type tables In Section 2.3.3-13, a footnote states 'For component types Included under 10 CFR54.4(a)(2), the Intended function of pressure boundary Includes providing sbucturaVseismlc support for components that are Included for non-safety-related SSCs directly connected to safety-ralated SSCs" when this function Is appropriate. Pressure boundary was only used because there is no difference In the aging management review regardless of whether the component Intended function Is pressure boundary or structural support, and If the pressure boundary Intended function of the component Is maintained the structural support function will be maintained. This defitIon of providing structuraVselsmio support would be equivalent to the intended function of SSR as defined In Table 2.0-1.

91 3.6.2.2-N-01 In LRA. Table 3.62-1, under Cable connections (metallic parts), you have stated that no aging effects requiring management and no AMP Is required.

Further. in LRA, Table 3.6.1 under discussion of cable connection metallic parts, you have stated that cable connections outside of active devices ar taped or sleeved for protection and operating experience with metallic parts of electrical cable connections at VYNPS lncfiated no aging effects requtring management. Electrical cable connections (metallic parts) are subject to the following aging stressors: thermal cycling, olvrnic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. NUREG-1801, Revision 1. AMP Xl.E6, "Electical Cable Connection not Sublct to 10 CFR 50.49 Environmental Qualification Requirments,* specifies that connections associated mwt cables whthin the scope ol license renewal are part of thil program, regardless of their association with active or passive components.

Also, refer to pages 107.256. and 257 of NUREG-1833, 'Technical Bases for Revision to the License Renewal Guidance Documents., for additional

!nua ezr.-1ALPXE.

P.-;d a -ss&craitlzd an, AMP with the ten elements for cable connections or provide a justification for wby an AMP Is not necessary.

RAI 3.6.22.N-01 Closed VYNPS electrical AMR AMRE-01 In section 4.1.4.4 states for cable connections (metallic parts)

• An evaluation of thermal cycling, ohmic heating, electrical transients.

vibration, chemical contamination, corrosion, and oxidation stressors for the metallic parts of electrical cable connecions identified no aging effects requiring managernentr

-Metallic parts of electrical cable connections potentially exposed to thermal cycling and ohmic heating are those carrying significant current In power supply circuits. Typically, power cables are In a continuous run from the supply to the load. Therefore, the connections are part of an active component that is controlled by Maintenance Rule and Is not subject to aging management review.

-The fast action of circuit protective devices at high currents mitlgates stresses associated with electrical faults and transients. In addition,

,sfeeaw*-,*Ai

%iiuss ussomiaied with eiectfica fauns is not a crescile aging mechanism because of the low frequency of occurrence for such faults.

Therefore, electrical transients are not applicable stressors.

-Metallic parts of electrical cable connections exposed to vibration are those associated with active components that cause vibration. Since active components are controlled by Maintenance Rule, they are not subject to aging management review.

• Corrosive chemicals are not stored In most areas of the plant. Routine releases of corrosive chemicals to areas Inside plant buildings do not occur during plant operation. Such a release, and Its effects, would be an event.

not an effect of aging. The location of electrical connections inside active components protects the metallic parts from contamination. Therefore, this stressor is not applicable.

-Oxidation and corrosion usually occur In the presence of moisture or contamination such as industrial pollutants and salt deposits. Enciosures or splice materials protect metal connections from moisture or contamination.

Therefore, oxidation and corrosion are not applicable stressors.

Based on the evaluations of the stressors above, there are no aging effects requiring management for metallic components of connections and no AMP is required CLOSED TO RAI 3.6.2.2.N-01

92 3.622-N-02 In LRA, Table 3.62-1. under switchyard bus (sWftchyard bus for S30) arv conectlions you have stated no aging effects requiring management and AMP Is required. NUREG 1800. Rev. 1, Standard Review Plan for Revle%

License Renwwal Application for Nuclear Power Plants, Section 3.6.2.2.3 Identifies loss of preload Is an aging affect for swktchyard bus connecOtns Torque relaxation for bolted connection is a concern for switchyard bus connections. An electrical connection must be designed to remain tight a maintain good conductilvty through a large temperature range. Meeting I design requirement is difficut if the material specified for the bolt and the conductor are different and have different rates of thermal expansion. Fo example, copper or aluminum bus/conductor materials expand faster thar most bolting materials. If thermal stress Is added to stresses Inherent at assembly, the Joint members or fasteners can yield. If plastic deformatior occurs during thermal loading (I.e.. heat-up) when t connection cools, II joint win be loose. EPR document TR-104213, "Bolted Joint Malntenanc, ovetating, signs of burning or discoloration, and indication of loose bok Provide a discussion why torque relaxation for bolted connections of switchyard bus Is not a concern for VYNPS.

VYNPS electrical AMR Section 4.3.4 of AMRE-01.

I Connection surface oxidation for alurnum swrtchyard bus Is not applicable no since all switchyard bus connections requiring AMR are welded connections.

w of No aging effects have been Identified for welded connections on switchyard bus for SBO.

Closed

93 3.6.22-N-03 Provide AMR line Item for transmission conductor connections In Table 3.6.2-

1. Address any aging effects requiring management.

IRA Amendment LRA Table 3.6.1 and section 3.6.2.2.3 will be revised as shown below-Table 3.6.1 Rtem # 12 -Transmission conductors and connections.

Aging Effects - Section 3.62.2.3 Transmission conductors are un-insulated, stranded electrical cables used outside buildings In high voltage applications. The transmission conductor commodity group includes the associated fastening hardware, but excludes the high-voltage insulators. Major active equipment assemblies Include their associated transmission conductor terminations.

Transmission conductors are subject to aging management review if they are.

necessary for recovery of oftite power following an SBO. At VYNPS, transmission conductors located between switchyard breakers K-I/K-186 and startup transformers T-3-1A/T-3-tB support recovery from an SBO event Other transmission conductors are not subject to aging management review since they do not perform a license renewal Intended function.

The aging effect for transmission conductors found In Industry reviews are loss of conductor strength and loss of material (wear).

The prevalent mechanism contributing to loss of conductor strength of an ACSR transmission conductor Is corrosion, which includes corrosion of the steel core and alumwnurn strand pitting. Corrosion In ACSR conductors Is a very slow acting mechanism. and the corrosion rates depend on air quality, which Includes suspended particles chemisry, S02 concentration In air, precipitation, fog chemistry and meteorological conditions. Air quality in rural areas generally contains low concentrations of suspended particles and SO2.

which keeps the corrosion rate to a minimum. Teats performed by Ontario Hydroelectric showed a 30% loss of composite conductor strength of an 80 year old ACSR conductor due to corrosion.

ACAR conductors are more resistant to loss of conductor strength since the core of the conductor Is an alloy of steel and corrosion resistant metals.

AMR conclusions regarding ACSR conductors conservatively bound ACAR conductors.

The National Electrical Safety Code (NESC) requires that tension on installed conductors be a maxmumn of 60% of the ultimate conductor strength. The NESC also sets the maximum tension a conductor must be designed to withstand under heavy load requirements, which Includes consideration of Ice, wind and temperature. These requirements are reviewed conceming the specific conductors included In scope at VYNPS.

The 4/0 ACSR conductors have the lowest initial design margin of any transmission conductors Included In the AMR. The Ontario Hydro test and the NESC requirements illustrate with reasonable assurance that transmission conductors wil have ample strength through the period of extended operation.

Therefore, loss of conductor strength due to corrosion of the transmission conductors In not an aging effect requiring management for the period of extended operation.

Accepted

94 3.6.2.2-N-04 In LRA, Table 3.6.2-1. Linder Transmission conductors, you have stated that no aging effects requiring management and no AMP Is required. NUREG 1800, Rev. 1, Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants, Section 3.6.2.2.3 Identifies loss of conductor strength due to corrosion Is the aging effect of high voltage transmission conductor. The most prevalent mechanism contributing to loss of conductor strength of aluminum core steel reinforce (ACSR) transmission conductor is corrosion which Includes corrosion of steel core and aluminum strand pitting. Degradation begins as a loss of zinc from the galvanized steel core wires. Corrosion rate depend largely on air quality. which Includes suspended particles chemistry. sulfur dioxide concentration In air, precipitation. fog chemistry and meteorological conditions. Expl*in why loss of conductor strength due to corrosion is not an aging effect requirement management for transmission conductors at VYNPS.

Loss of material due to mechanical wear can be an aging effect for strain and suspension Insulators that are subject to movement caused by transmission conductor vibration or sway from wind loading. Design and installation standards for transmission conductors consider sway caused by wind loading. Experience has shown that transmission conductors do not normally swing and that when they do swing because of substantial wind, they do not continue to swing for very long once the wind has subsided. Wear has not been Identified during routine inspection; therefore, loss of material due to wear In not an aging effect requiring management This report documents a review of Industry OE and NRC generic communications related to the aging of transmission conductors In order to ensure that no additional aging effects exist beyond those previously identified. This report also documents a review of plant-specific OF, which did not identify any unique aging effects for transmission conductors.

VYNPS electrical AMR Section 4.2 In AMRE-01.

The prevalent mechanism contributing to loss of conductor strength of an ACSR transmission conductor Is corrosion, which includes corrosion of the steel core and aluminum strand pitting. Corrosion in ACSR conductors is a very stow acting mechanism, and the corrosion rates depend on air quality.

which Includes suspended particles chemisltr, S02 concentration In air, precipitation, fog chemistry and meteorological conditions. Air quality in rural areas generally contains low concentrations of suspended particles and SO2, which keeps the corrosion rate to a mininmum.

Tests performed by Ontario Hydro showed a 30% loss of composite conductor strength of an 80-year old ACSR conductor due to corrosion.

The National Electrc Safety Code (NESC) requires that tension on Installed conductors be a maximum of 60% of the ultimate conductor strength. The acceptance criteria for VYNPS Is less than 40% loss of composite conductor strength per NESC.

Aluminum conductor alloy reinforced (ACAR) conductors are used at VYNPS as well as ACSR conductors.

ACAR conductors are more resistant to loss of conductor strength since the core of the conductor is an alloy of steel and corrosion resistant metals.

Conclusions for ACSR conductors conservatively bound ACAR conductors.

The National Electric Safety Code (NESC) requires that tension on Installed conductors be a maximum of 60% of the ultimate conductor strength. The acceptance criteria for VYNPS is less than 40% loss of composite conductor strength per NESC. Aluminum conductor alloy reinforced (ACAR) conductors are used at VYNPS as well as ACSR conductors.

ACAR conductors are more resistant to loss of conductor strength since the core of the conductor is an alloy of steel and corrosion resistant metals.

Conclusions for ACSR conductors conservatively bound ACAR conductors.

Therefore, corrosion of transmission conductors is not aging effect requiring management and an AMP is not required.

Closed

95 3.622-N-0S In LRA, Table 3.6.2-1, under high voltage Insulators, you have Indicated that no aging effects requiring management and no AMP Is required. In LRA, Section 3.6.2.2.2, you have also stated that at VYNPS surface contamination bui"d-up on Insulator Is not a concern. NUREQ 1800, Rev. 1, Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants. Section 3.6.22.3 Identifies surface contamination Is the agig effect of high voltage Insulators. Various airborne materials such as dust and industrial effluent can contaminate Insulator surfaces. The buildup of surface contamination Is gradual and In most areas such contamination Is washed away by rain: the glazed insulator surface aids this contamination removal.

However, a large buildup of contamination enables the conductor voltage to track along the surface more easily and can lead to insulator flashover.

Surface contamination can be a problem In areas where there are greater concentration of airborne particles such a near facilities that discharge soot Explain why surface contamination Is not a concern at VYNPS.

96 3.6.2.2-N-06 Are all electrical and I&C containment penetrations EQ? If not. provide AMRs and AMPs for non-EQ electrical and I&C containment penetrations. The AMRs should Include both organic (XLPE, XLPO, and SR internal conductor/plgtail Insulation, etc.,) as well as Inorganic material (such as cable filters, epoxes. potting compounds, connector pins, plugs, and facial grommets).

Per VYNPS electrical AMR Section 4.4 In AMRE-01:

Closed Various airborne materalss such as dust, salt and Industrial effluents can contaminate Insulator surfaces. The buildup of surface contamination Is gradual and in most areas. Such contamination Is washed away by rain; the glazed Insulator surface aids this contamination removal.

VYNPS Is not located near the seacoast where salt spray s prevalent, or near facilities that discharge soot.

At VYNPS, as In most areas of the New England transmission system.

contamination build up on Insulators Is not a problem. Therefore, surface contamination is not an applicablea aging mechanism for the Insulators at VYNPS.

Section 3.4.2 In AMRE-01 and rSAR Section 5.2.3.4.3 At VYNPS. electrical penetration assemblies are Included In the EQ program and are riot subled to aging management review.

Closed

97 3.6.2.2-N-07 In LRA, Table 3.6.1 under metal enclosed bus, you have stated that an evaluation of metal enclosed bus for VYNPS determined that VYNPS does not have any phase bus that support a license renewal function. 10 CFR 54A (a)(3) requires, In part, that all systems, structures, and components relied on In safety analyses or plant evahmtl*n to perform a fsnction that demonstrates compliance with the commission's regulations for station black out (10 CFR 50.63) are within the scope of license renewal. VYNPS FSAR Section 8.3.3 states that electric power supplied from the transmission network to the on-site electric distrfbutlon system by two Independent circuits, one immediate access and one delayed access. The Immediate access circuit Is supplied from the 345 kV transmission system through 345 kV/1 15 W auto-transformer. It feeds the on-site electric distribution system through the two 115 kV to 4160 V start up transformers and Is available Immediately following a loss of generating capabilty. The delay access circuit Is available by opening the generator no-load disconnect switch and establish a feed from the 345 kV switchyard through the main generator step-up transformer and unilt auxiliary transformer to the 4160 V safety buses. Answer the following questions and support them with a main one line diagram:

3.6.2.2-7(a). In regard to the above, are non-segregated phase buses used to connect the start up transformers (T-3A and T-38) (lower sides) to 4.16 kV safety buses?

3.62.2-7(b). In regard to the above, are Iso phase buses used to connect the delay access circuit from the 345 WV switchyard through the main generator step-up transformer and unit au)dliary transformer?

3.6.2.2-7(c). In regard to the above, are non-segregated phase buses used to conrect the unit auxiliary transformer (lower sides) to 4.16 kV safety buses?

If the answer to a, b, or c Is yes, explain why metal enclosed buses (iso phase and'or non-segregated phase buses) are not In scope of license renewal and not require an AMP.

License Renewal Commitment #32 LRA Amendment Resolution - The VY UFSAR Section 8.3.3 describes three offstta power sources. The immediate access circuit from the 345kV yard through the 345/115kV autotransformer to the startup transformers, the altemate Immediate access circuit from the 115kV yard (Keene Une) through the startup transformers. The delayed access circuit Is available by opening the generator no-load disconnect switch and establishing a feed from the 345W switchyard through the main and aux transformers.

3.62.2-N-07(a)

No. there are no non-segregated phase buses In the path from the startup transformers to the 4.16 safety buses.

3.6.2.2-N-07(b)

The delayed access circuit from the 345KV switchyard through the main generator step-up transformer and unit aux transformer uses the Iso-phase bus for connection and Is In scope for license renewal. The wNPS Metal-Enclosed Bus program will be consistent with GALL XI.E4. The VYNPS Metal-Enclosed Bus program will perform visual inspection of the Internal portions of the bus for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of water Intrusion. Internal bus supports will be Inspected for structural Integrity and signs of cracks. Enclosure assemblies will be inspected for evidence of loss of material and elastomera will be Inspected to manage cracking and change In material properties.

The first Inspection will be completed before the period of extended operation and every five years thereafter.

The Metal-Encased Bus Program will be added to the following LRA sections:

Section 2.5-Electrical and I&C Systems Section 3.8-Electrical and Instrumentation and Controls Table 3.6.1 Table 3.6.2-1 Appendix A Appendix B Accepted This requires an amendment to the LRA The Metal-Enclosed Bus Program wil be added to the following AMR and AMPER.

LRPD Aging Management Program Evaluation Results AMRE Electrical Screening and AMR This Is LR commitment #32.

3.6.22-N-07(c)

No, there are no non-segregated phase buses in the path from the Unit Aux Transformer to the 4.16 safety buses.

Summary The In-scope components required for recovery from a SBO do not include any non-segregated phase bus that requires aging management review.

98 3.6.2.2-N-08 10 CFR 54.4 (a)(3) requires, in part, that at systems, structures, and components (SSCs) relied on in safety analyses or plant evaluation to perform a function that demonstrates compliance with the commission's regulations for station black out (10 CFR 50.63) are within the scope of license renewal.

Vernon Hydroelectric Station has been designated as the Station Blackout (SBO) alternate ac (AAC) source and Is used to meet SBO requirements 10 CFR 50.63. Are all SSCs (including electrical components) associated with Vernon Hydroelectric Station Included In the scope of licensee renewal? If they ara not. explain why not. If they are, provide an AMR for long-lived, passive SSCs associated with the hydro station.

99 B.1.27.3-W-03 Are there any other license renewal intended functions other than SBO, associated with the Vernon Dam?

100 The NRC requested additional Information on licensing renewal, specificaty on how aging management applied to passive components In the Vernon Hydroelecrt Station.

101 9.1.30.3.M.04 GALL X1.M21 discusses pump and heat exchanger testing In the parameters monitored I Inspected attribute, Is this testing part of the Water Chemistry Control - Closed Coollng Water Program?

102 0.1.9-K-I1 Please provide a copy of QA Surveillance 99-010 and more recent CA surveillance of Diesel Fuel Monitoring Program.

103 B.1.9-K.12 Please Identify sample point locations on John Deere diesel and diesel fire pump olf storage tanks. (Diesel Fuel Montoring Program) 104 B.1.9-K-13 Please provide 2000 and 2003 sample results spreadsheet Also sample lab results for main storage tank and EDG day tanks are desired. (Diesel Fuel Monitoring Program) 105 B.1.30.3-M-05 Please provide a copy of recent third party assessment of the water chemistry control - closed cooling water program.

RAI 3.6.2.2.N-08 The longlived, passive components from the Vernon dam switchyard to the plant are in scope and sublect to AMR. The undergrourd cables and connections are Included in E2. The Vernon Dam Is regulated by FERC and inspected per FERC regulations.

Vernon Dam Is used for hydro-electric generation and Is the alternate AC source of power for VYNPS. The deep basin beneath the west cooling tower Is a safety-related, reinforced concrete structure constructed on bedrock. The basin acts as a reservoir to reptaci the evaporative and other losses occuring during alternate cooling system (ACS) operation, providing a one-week supply of makeup for the alternate cooling cell in the event of a loss of Vernon Dam. The Vernon Dam has no other Intended functions for (10CFR54.4(a)(1) or (a)(2). The Vernon Dam Is credited for station blackout (10CFR50.63). intended functlon IOCFR54.4(a)(3).

The NRC requested additional Information on underground cables, buried piping and support systems. The requested Information was provided to the NRC during the onsfte review. In additon a FERC Inspection report was provided for the dam and NPCC Document A-3, Emergency Operational

Criteria, LRA Section B.1.30.3 includes an exception to the performance and functional testing discussed in the detection of aging effects attribute. This exception and Its justificatlon are equally applicable to the parameters monitored / trended attribute.

Provided OA Surveillance 99-010, QA Audit Report QA-2-2005-VY-1 and CR-VTY-2005-001 96.

Provided Section 5 of OP2106 Rev. 18, App. D JD Diesel day tank sample location Is at the bottom of this tank. Fire pump diesel fuel supply & sample point are 2 Inches from the bottom of the diesel tire pump fuel tank.

This Information has been provided via spreadsheet of monthly analysis data for the Main Fuel Oil Storage Tank for 2000 and 2003. Also, provided example analysis results for samples from the Walpole NH supplier tank, the John Deere diesel storage tank, the diesel fire pump storage tank, and the EDO day tanks.

Third party assessment of 'Chemistry on May 6, 2003 provided for review.

Summary states that closed cooling water systems are mornitored and treated to provide a chemical environment that minlimzes corrosion rates.

Closed Closed Closed Closed Closed Closed Closed Closed

106 B.1.2.3-M-04 The Reactor Vessel Stud Program takes exception to GALL based on relief request ISI-03. The NRC does not believe this should be an exception.

Review the relief request and ASME code. If this is not an exception, revise the program document.

107 The commitment to manage locations CUF>1.0 should be on a nuimbered commitment list The commitment to analyze the limiting location for environmentally assisted fatigue should be on a ntumbered commitment list.

NOTE: The commitment is in section 4 (4.3.3.?) not In App. B 108 Identify the site specific calculations for core plate hold down bolt preloed.

109 Accurately state / describe the Information Idocumentation requested. Be as specific as possible. The NRC requested a copy of the Vernon hydro-drawing.

Not an NRC question. Close item.

110 The NRC Inspector had e one-line diagram and asked If bus duct was used for the immediate access source or the delayed access source. The Inspector was interested If an AMR applied to either source for segregated or non-segregated bus, if used.

Not an NRC question. Close item.

111 Please provide results of the last Inspecton of the welds between the rerouted CRD return fine and the RWCU system. (BWR CRD Return Line Nozzle Program) 112 Please provide documentation related to resolution of vessel clad cracking.

113 The BWR penetrations program second erception allows a smaller Inspection than the code (I /" vs. 1/2' vessel wal% thickness). What Is the basis for tis?

The existing examinations for the reactor vessel closure studs (Category B 2) are based on ASME Code Case N-e52. Code Case N-652 has been endorsed by the NRC per Table t of Regulatory Guide 1.147, Revision 14.

License Renewal Commitment #27 License renewal commitment #27 has been prepared, to address the above items.

No site specific calculation was found in the VYNPS current licensing basis for the number / preload of the core plate hold-down boits required to prevent lateral motion of the core plate.

This information was provided during the onshie review.

Immediate Access: The cables are used from the startup transformers to the 4 KV buses and overhead 115 KV bare cable Is used to supply the transformers with bus above the transformers.

Delayed Access: There is Isophase bus duct used on the back-feed for the 22 KV system and It connects to the awdliary transformer.

Provided results of 1985 Inspection Provided documentatlon as requested during NRC Interview.

The Inspection of the vessel penetrations to/2' versus 1/2T was approved via Relief Request ISI-09. This relief request Is In turn based on ASME Code Case N-613-1. Code case N-613-1 has been endorsed by the NRC per Table t of Regulatory Guide 1.147, Revision 14, August 2005.

This Is conservatively identified In the BWR Penetrations Program description as an exception to GALL because It required relief to the existing code requirements.

Closed Accepted Closed Closed Closed Closed Closed Closed

114 Do the VY penetration nozzles have a bored (cold worked) safe end extension?

If yes, they require additional Inspection.

Closed 115 Accurately state I describe the Information I documentation requested. Be as specific as possible.

LRPD-05 section 4.4.1 second paragraph states fat the BWR CRD Return Line Nozzle program provkds reasonable assurance. Should this have been the Buried Piping Inspection Program?

116 B.1.17-N-04 GALL X1.E3 under program description states. In part, that periodic actions such as Inspecting for water collection In cable manholes, and draining water.

as needed to prevent cables from being exposed to signIficant moisture. The above actions are not sufficient to assure water Is not trapped elsewhere in the raceways. In addition to the above periodic actons, In scope, medium voltage cables are tested to provide an indication of the condition of the conductor Insulation. VYNPS AMP B.1.17 under same element states that periodic actions will be taken to prevent cables from being exposed to significant moisture, such as Inspecting for water collection In cable manholes and draining water, as needed. In-scope medium-voltage exposed to significant moisture and voltage will be tested to provide an Indication of the condition of the conductor insulation. It is not clear to the NRC If you Intend to use these periodic actions to preclude cable testing. It this is the case, provide a technical Justification of why removing water In the cable manholes will provide assurance that water Is not present elsewhere In the condults or duct banks. If this is not the case, revise your AMP as appropriate to requires both testing and Inspecting water accumulVon in the manholes.

117 B.1.17-N-05 GALL XI.E3 recommends testing all In-scope Inaccessible mediumn-voltage cables. Are ell Inaccessible medium-voltage cables within the scope of ricense renewal tested?

This question was erroneously applied to the vessel Instrumentation nozzles.

BWRVIP.40-A requires no additional inspection requirements for cold worked safe ends for the Instrumentation nozzles.

The question should have been directed at the SLCtDP nozzle, for which the discussion of cold worked safe ends is found in the BWRViP-27-A i*nspection guideline 3.4.1. Per drawing 5920-52666 RO Implementing the Inspection guidelines of BWRVMP-27-A as applicable to VY, but that does not Include the entire safe end extension examination required of those plants with cold worked safe ends.

Yes, this Is a typographical error and It should have said that the Buried Piping Inspection Program provides reasonable assurance that the effects of aging will be managed such that the current licensing basis for the period of extended operation. This Item has been addressed through revision of LRPD-05.

The Intent of the VY AMP B.1.17 Is to Inspect for water In manholes and to test the in-scope medlum-voltage cables.

Yes, all of the in-scope medium-voltage cables will be subject to testing per the program requirements.

Closed Closed Closed

i" 118 B.1.17-N-06 GALL Xl.E3 under parameters monltored* spected states that the specific type of test performed will be determined prior to the Initial test and Is to be a proven test for detecting deterioration of the Insulation system due to wetting such as power factor, partial discharge test, or polarization Index, as described In EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test Is performed. VYNPS B.1.17 under the same attdrbe only states that the specific type of test performed will be determined prior to Initial test.

Revise your AMP to be consistent with GALL or explain how do you ensure that the test to be performed will be In accordance with Industrial guideline or that Is the state-of-the-art at the time the test-is performed.

119 B.1.17-N-07 Do you currently Inspect water In the man holes. Are there any existing procedures for Inspecting man holes. Provide a copy of these procedures.

120 B.1.17-N-08 GALL X1.E3 defines medcirn-voltage cable Is the voltage level from 2kV to 35kV VYNPS AMP B.1.17 defines medlum-voltage cable Is the voltage level from 2kV to 15kV. Revise the scope of the inaccessible medium - voltage level to be consistent with GALL or provide a technical Justification that why the water tree phenomenon Is not applicable to voltage level greater than 15kV. Are there any Inaccessible medium -voltage cables within the scope of licensee that are greater than I SkV.?

LRA Amendment LRA Appendix B.1.17 will be revised to state that the specific type of test to be performed will be determined prior to the Initial test and Is to be a proven test for detecting deterioration of the Insulation system due to wetting as described In EPRI TR-t 03834-P1-2, or other testing that Is state-of-the-art at the time the test Is performed.

Yes, the manholes are Inspected on an annual basts. An example was provided during the onsite inspection IRA Amendment VY does not have any medium-voltage cable in-scope that Is greater than 15KV. LRA Appendix B.1.17 will defie medium-voltage cable as voltage level from 2W to 35kV.

Accepted Closed Accepted

121 B.1.18-N-03 GALL Xl.E2 under corrective actions states that such an evaluation Is to consider the significance of the test results, the operability of the component, the reportabtifty of the event, the extend of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective actions required, and likelitood of recurrence In addition to 10 CFR Part 50, Appendix B. VYNPSB.l.18 under the same element only refers to 10 CFR Part 50 Appendix B to address corrective actions. Revise your AMP corrective actions to be consistent with GALL or provide a justification of why such specific corrective actions are not necessary.

122 B.1.1.8-N-04 Why is the high range radiation monitor cable Is not considered In scope of XIE2.

123 B.l.19-N-03 For an new AMP provide a commitnent nuirber and the Implementation period for this new program.

VYNPS B.1.18 AMP under corrective actions states that 'an engineering evaiuation will be perfohmed when the test acceptance criteria are not met In order to ensure that the Intended functions of the electrical cables can be maintained consistent with the current licensing basis. This evaluation Is performed In accordance With the Entergy corrective action process per procedure EN--I.1 02. This procedure provides the stated elements to consider including the extent of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective actions required, and likerlhood of recurrence. See procedure details below.

Adverse Condition - An event, defect, characteristic, state or activity that prohibits or detracts from safe, efficient nuclear plant operation or a condition that could credibly Impact nuclear safety, personnel safety, plant reliability or non-conformance with federal, state, or local regulations. Adverse conditions Include non-conformances, conditions adverse to quality and plant reliability concerns Operability Evaluation - A written evaluation of a Condition Report, to determine Impact of the Identified condition on the operability of structures, systems or components. The operability evaluation Includes a determination for reportablty.

Extent of Condition - An evalualion to Identify the total population of items that have or may have the same problem as Identified in the original CR problem statement The Intent of the Extent of Condition review focuses on a determination of any potential Impact to the operabtilty/functfonalty of similar components, equipment, systems, human performance traps/issues, or organizational processes/programs.

Root Cause - The most basic cause(s) for a failure or a condition that, If corrected or eliminated, wit preclude repetition of the event or condition.

Corrective Action - Corrective actions Include actions Intended to preclude repetition of significant conditions and those Intended to correct adverse conditions.

Corrective Actions to Preclude Repetition - A type of corrective action intended to correct the root cause of a condition and thereby preclude repetition.

A copy of EN-U-102 had been provided to the onsite review team.

VYNPS electrical AMR, AMRE-01, states that Cables and connections in the high-range reactor bulding area monitoring system, support a license renewal intended function. However, the entire length of these cables are EQ and do not require aging management since they are subject to replacement based on a qualified life.

CommItments numbers are being supplied In a table for all commitments.

Closed Closed Closed

124 B.I.19-N-04 GALL X1.E1 under scope of program states that this Inspection program applies to accessible electrical cables and connections within the scope of license renewal that are installed In adverse locaized environments caused by heat or radiation In the presence of oxygen, VYNPS AMP B.1.19 under the same element you have stated that this program will Include accessible Insulated cables and connections Installed In structures within the scope of license renewal and prone to adverse loce environments. Clarify If the scope of this program Include only Insulated cables and connections Installed In structures which (structures) are In scope of license renewal and prone to adverse localzed environments or nsulated cables and connectlins within the scope of license renewal that are Installed In adverse localized environments.

. Why are structures Included In the scope of the AMP. Modify the scope of the program as appropriate to remove the confusion.

125 B.1.19-N-05 Explain why the GALL X.E1, EO. Is included in the basic document for non-EQ insulated cables and connections program.

126 3.6.2.2-N-09 GALL XI.E5 states that the fuse holder (not part of a larger assembly) metallic portions are subject to fatigue due ohmic heating, thermal cycling, electrical transients, frequent manipulaion, vibration, chemical contamination, corrosion, and oxidation. In the LRA Table 3.&.1 Item 3.6.1-6, you have stated that NUREG-1i801 aging effect Is not applicable to VYPNS. In AMRE-01 Revision 0 Page 14 of 108, you have stated that WNPS employs two general types of fuse holders. The first type Is the boit-mount fuse holder that uses either a lug or cap-screw to secure the fuse between the clamps. The second type of fuse holder Is the metallic clamp fuse holder, which uses the spring tension. Installation data for cables and connections indicated that the only fuse holders installed at VYNPS that utilize metallic clamps to secure the fuse are either part of active assembly or are located In circuits that perform no license renewal indented functions. Are there any bolt-mount fuse holders In scope of licensee renewal that are not part an active assembly. If there are, explain why agig effects as Identified In the GALL are not applicable.

127 B.1.1-L-06 Program Description item. The IRA says *Burled components are Inspected when excavated during maintenance'. Is maintenance performed on an as needed basis or Is It on a scheduled frequency?

LRA Amendment

,In a struchtr' means inside the plant not outside. The VYNPS B.1.19 will be revised to state that the program applies to accessible electrical cables and connections within the scope of license renewal that are Installed In adverse localized environments caused by heat or radiation In the presence of oxygen.

A revised copy of GALL for XLE1 was provided.

No. the two types of fuse holders are all located In active devices.

The maintenance Inspections being credited are Inspections that are being performed on an as needed basis since there are no routine scheduled maintenance inspections of buried piping.

Accepted Closed Closed Closed

128 B.1.1.1--07 Program Description Item. The LRA says 'A focused inspection win be performed within the frst 10 years of the period of extended operation.... The LRA seems to address Inspections that occur both before and during the period of extended operation; the Appendix A reference does not clarify this confusion; When does VY plan to perform these focused inspections?

129 B.1.1-L-07 Program Description Item. Depending on the response to the above question.

please clarify the Appendix A reference, as needed.

130 B.1.1-L-08 Acceptance Criteria Item. The GALL Report says 'Any coating and wrapping degradations are reported and evaluated according to site corrective actions procedures.! The IRA says CoatIng and wrapping degradation, or loss of material due to corrosion, Is evaluated In accordance with the site corrective action program.' PP 7030, Section 4.8, Is very general, e.g., "signs of degradation." areas of degradation.! Does VY Intend to enhance this guidance, as well as that addressed in question 9.1.1-L-04?

131 B.1.1-L-09 Operating Experience hem.. Why does LRDP-05, Section 4.4.1 reference the BWR CRD Return Une Nozzle Program?

132 9.1.30.2-M-03 An exception to BWRVIP. 130 critera for feedwater copper was noted.

Please provide related Information. (Water Chemistry Control - BWR Program) 133 B.1.30.2-M-04 Please provide a copy of recent third party assessments of the Water Chemical Control - BWR Program.

134 B.1.8-L-02 Detection of Aging Effects Rem. PP 7006, Section 4.4.4, refers to a Type A Test, which will be developed. Please explain.

The focused inspection will be performed within the first 10 years of the period of extended operation, unless an opportristlc Inspection occurs within this ten-year period as stated in LRPD-02 section 4.1.B.4.b of the Buried Piping Inspection Program and In AppendSx B.1.1 of the LRA. The first sentence In the third paragraph of the program description in the IRA describes a review of operating experience (If available) for examinations of buried piping for relevant information and Is not a required Inspection.

Inspections of bu.sled carbon steel piping were performed in 2003 which Is within the 10 years prior to the period of extended operation. These inspections revealed no coating or piping degradation.

Appendix A Is correct as written. The focused inspection Is specified for the ten years Immediately after entering the period of extended operation. This Is consistent with the SER for Bnswick dated March 2006.

License Renewal Commitment #1 It was the intent of the enhancement specified In 8.1.1 to revise appropriate sections of procedure PP 7030 to Include attributes of coating damage and evidence of corroeion. This would include updating sections 4.3 & 4.8.

Yes, this Is a typographical error and it should have said that the Buried Piping Inspection Program provides reasonable assurance that the effects of aging wit be managed such that the current licensing basis for the period of extended operation. This Item was addressed in revision to LRPD-05.

Provided Revision I of Technical Justification for Continued Operation of Entergy Northeast Vermont Yankee (ENVY) with Feedwater Copper > 0.2 ppb.

Third party assessment of BWR Water Chemistry control from March 2001, May 2003 and April 2005 were provided for review.

Type A testing) and due to the expectations of VY on maintaining operating procedures current. OP 4029 (test procedure) was retired. By retiring the procedure that Is conducted once every 10 to 15 years, forces the test engineer to develop a Type A Test lAW Tech Specs 6.7.C & PP 7006, Section 4.4.4 that adopts the latest test equipment, processes, software programs, and testing philosophies Into the Infrequently conducted evolution (SOER 91-01). thereby ensuring that the complex Type A testing process Is thoroughly understood by the test engineer. With the inception of 10CFR50 Option B. containment integrity Is adequately monitored between Type A tests.

Closed Closed Accepted Closed Closed Closed Closed

135 B.1.8-L-03 Monitoring and Trending hem. The GALL Report says 'The frequency of these tests depends on which option (A or B) Is selected. With Option A, testing Is performed on a regular fixed time Interval as defined In 10 CFR Part 50.

Appendix J. The LRA says 'he first Type A test after the Aprl 1995 Type A test shall be performed no later than Aprtl 2010. This is a one-time extension of the NEI 94-01, 10 year Type A test Interval to 15 years. NRC approved Amendment 227 to Facility Operating License DPR-28 for VYNPS to extend the primary containment Integrated leak rate tesfing Interval from 10 years to no longer than 15 years on a one-time basis." Amendment 227 refers to ha being a one-time extension, so It would not appear to extend Into the period of extended operation. Please clarify.

136 B.1.8-L-04 Monitoring and Trending Hem. Does VY take any exception to the testing gukdance of RG 1.163 or NEI 94"1?

137 B.1.8-L-05 Acceptance Criteria Item. LRPD-02 Identifies the following as an exception that the IRA did not. The GALL Report says 'Acceptance criteria for leakage rates are defined In plant Technical Spectfications. These acceptance criteria meet the requirements In 10 CFR Part 50, Appendix J, and are part of each plants current licensing basis. The current licensing basis carries forward to the period of extended operation." The LRA says "VYNPS acceptance criteria are defined In plant technical specifications. Please expand on why the acceptance criteria are not consistent with the GALL Report.

138 B.1.8-L-06 Operating Experience Hem. Does VYNPS monitor Industry Issuestevents and assess these for applicability to Its own program?

Under currant regulations and NEI guidance, the one time change does not affect the Type A test interval or number of tests to be conducted during the period of extended operation.

At present, VY does not take direct exception to any provision In RG 1.163.

VY does take exception to NEI 94-01. Specifically, with the adoption of License Amendment 223 of the Alternative Source Term (AST), the Main Steam Une Pathways were determined to be separate radiological (consequences) release paths exclusive of the Primary-Secondary Containment System radiologlcal (consequences) release path. This pathway Is subject to the 1 OCFR50 Appendix J Type C testing methodologies but the calculation methods, leakage-rate summations, and acceptance criteria were determined to be Independent of the Primary Containment allowable leakage rate (La). NE 94-01 does not address the effects AST adoption on a primary containment leakage rate testing program; therefore, an exception to Lcense Amendment 223 for the VY current license and through the possible license extension period is required.

See B.1.8-L-04 exception basis for response.

VYNPS Incorporates, as necessary, lessons teamed Into the Containment Leak Rate Program from operating experiences Identified at VYNPS and industry operating experiences. The Incorporation of the lessons learned follows a process of an understanding of the operating experience, an assessment of the current program to determine applicability, and the document development to affect the change.

Closed Closed Closed Closed

139 B.1.14-K-01 Requested operating experience Information on a sample of the heat exchangers Included In the Heat Exchanger Monitoring Program If any Is available.

Operating History search was performed on the following componets:

Closed HPCI gland Seal condenser (E-1 8-1A)

HPCl Lube olf coolers (E-1 9-IA)

RCIC tube oft coolers (E-21-1A)

CST aluminum steam reheat coil (E-HB-1)

Drywell atmospheric cooling urits (RRU 1. 2, 3. 4)

Dfywell equipment drain cooler (E-ESC-1A)

Reactor Recirculatfml pump seal water coolers (P-t 8-TAB13 Hx-3)

Reactor Recirculation pump motor upper & lower bearings oll coolers (P-1 8-1IAB Hx-2)

Reactor Reclrculation pump motor air coolers (P-18-1/AB Hx-1)

Keywords used in PCRS:

Fouling Eddy Current Tube replacement Tube plugging Plugging Tube blockage No Information was found on the heat exchanger or coolers for any of the above components in PCRS.

EMPAC search on components:

WO 2001-5153 performed 10104/2002-E-18-1A HPCI Gland Seal condenser Cleaning and Inspection WO 1997-8128 performed 04/02/1998-E-19-1A Inspect lube oil side of HPCI lube oll cooler RRU-1 through 4 are Inspected and lubricated during refueling outages-External Inspections only Attachments provided to the NRC during the onsite review.

WO 2001.5153 WO 1997-8128 NRC has these attachments.

41

140 B.1.14-K-02 What is the proposed frequency of Inspection and basis of the frequency selected for the heat exdnges Included In the Heat Exchanger Monitoring Program.

The development of the non Service Water (SW) cooled heat exchanger inspection and monitoring plan would be similar to the process which was used for the SW heat exchangers.

The scope of this plan would include, but not be limited to, the following heat exchangers and coolers:

Drywell Coolers. RRU-1 through 4 HPCI Gland Seal Condenser. E-18-IA HPCI Lube Oil Cooler, E-19-IA RCIC Lube Oi Cooler, E-21-IA CST Reheat Coil, E-HB-1 Drywell Equipment Drain Cooler. E-ESC-1A Reactor Recirculation Pump Seal Water Coolers. P-18-lA HX-3 & P-18-1B HX-3 Recirculation Pump Motor Upper & Lower Bearing ON Coolers, P-1 8-1A HX-2

& P-1 8-1 B HX-2 Recirculatlon Pump Motor Air Coolers, P-18-1A HX-1 & P-I -1 HX-1 The following Is an example of the steps which would be used to develop the plan:

1. An Initial visual Inspection would be performed of the in scope heat exchangers. This inspection would document the "as-found" conditions.

Additional examination methods may be used 1 "as-found' conditions warrant. (I.e. utrasonic thlclkess measurements or radiography). The results of these inspections would be used to establish the frequency of future Inspections.

2. Where physically accessible, baseline eddy current data would be obtained. The number of tubes sampled would be determined based on Industry best practices and EPRI recommendations. The results of these tests would be used to determine the frequency of future Inspections and the number of tubes to be sampled.

3. Future Inspections and eddy current examinations would be scheduled via the Preventive Maintenance process.

4. Performance monitoring and trending would be performed in accordance with established fleet procedures.

Once developed the plan would be administered by the onsite engineering organization.

Closed

141 B.1.12.1-L-07 Scope of Program Item. The GALL Report has requirements in numerous program elements that are on a sx,-month frequency. The LRA states that these are on a refueling (tweny-onth) frequency. Please discuss and Justify the Inspection frequency differential for the C02.system.

142 B.1.18-N-04 Why Is high range radiation monitor cable not considered In scope of XI.E2?

143 B.1.18-N-05 GALL XL.E2 under parameter monltoredItnpected states that the parameter monitored are determined from the specific calibration, surveillance or testing performed and are based on the specific Instrumentation under surveillance or being calibrated, as documented In plant procedures. VY AMP 8.1.18 under same altribute states that results from the calibratlons or surveillance of components within the scope of rocese renewal will be reviewed. The parameters reviewed will be based on the specific intrumentation circuit under surveillance or being calibrated, as document In the plant calibration or surveillance procedures.

a Why does the review of calibration results belong to parameter monitoredlinspected attribute?

b. The parameter monitoredclnspected for cable testing was not mentioned.

What is the parameter for cable testing. Confirm that cable testing will be perform on cables h-scope of XI.E2 that are disconnected during Instrumentation calibration.

144 B.1.18-N-06 VY B.1.1 8 under acceptance criteria address the acceptance criteria for calibration. However, It silences on the acceptance criteria for cable testing.

What in the acceptance criteria for cable testing?

145 B.1.20-K-03 Please provide QA Surveillance and self-assessment referenced In operating experience for Oil Analysis Program.

License Renewal Commitment #30 LRA Amendment System walkdown every 6 months, starting prior to period of extended operations.

The VY AMP B.1.17 will state that the specific type of test to be performed will be determined prior to the Initial test and Is to be a proven test for detecting deterioration of the Insulation system due to wetting as described In EPRI TR-103834-P1-2. or other testing that Is state-of-the-art at tlýe time the test Is performed.

VYNPS Electrical AMP, AMRE-01 states that 'Cables and cornections In the hlgh-range reactor building area monitoring system, support a license renewal Intended function. However, the entire length of these cables are EQ and do not require aging management since they are subject to replacement based on a qualified lfe.

a) LRPD-02 will be revised under parameter monitored/inspected to state that the parameters monitored are determined from the specific calibration, surveillances or testing performed and are based on the specific Instrumentation circuit under surveilance or being calibrated, as documented In plant procedures.

LRPD-02, Rev 2 incorporated this change.

(b) LRPD-02 under parameter monitoredAnspected will state that the parameters monitored are determined from the specific calibration, surveillances or testing performed. The parameter for cable testing Is determined from the plant procedures. Cable testing Is performed by plant procedures on cables In-scope of XI.E2 that are disconnected during Instrument calibration.

Accepted Closed Closed LRPD-02 will be revised under acceptance criteria to state that calibration results or findings of surveillance and cable system testing results are to be within the acceptance criteria.

LRPD-02, Rev 2 incorporated this change.

QA Surveillance SRVY 2002-025 and 2003 self-assessment provided during the onslte audit.

Closed Closed

146 0.1.12.1-L-07 Scope of program Item. The GALL Report has requirements In numnerous program elements that are on a six-month frequency. The LRA states that these are on a refueling (twenty-month) frequency. Please discuss and ustilfy the Inspection frequency differential for the C02 system.

147 B.1.12.1-L-08 Preventive Actions hem. The GALL Report says "For operating plants, the fire hazard analysis assesses the fire potential and fire hazard In all plant areas.... The LRA says 'The NUREG-1801 Preventive Actions do not specify any measures for prenting aging effects of fire protection structures, systems or components.' Has VY performed a fire hazard analysis?

148 B.1.12.1-L-09 Parameters Monitored/Inspected Item. The GALL Report says 'Vlsual inspection of the fire barrier wails, ceilings, and floors examines any sign of degradation such as cracking. spalling. and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates." The ERA says

'Procedures will be enhanced to specify that fire damper frames In fire baniers shal be inspected for corrosion." What Is the material and envirorunent of the damper frames?

149 B.1.12.1-L-10 Parameters MonitoreMd/Inspectad Item. What examination technique will be used?

150 B.1.12.1-L-11 Parameters Monwtored/Inspected Item. The GALL Report says 'The diesel-driven fire pump Is under observation during performance tests such as flow and discharge tests, sequential starting capability tests, and controller function tests for detection of any degradation of the fuel supply fine! The LRA says "Procedures will be enhanced to state that the diesel engine sub-systems (Including the fuel supply ine) shall be observed while the pump Is running.' Is there a VYNPS commitment associated with this enhancement?

151 B.1.12.I-L-12 Acceptance Criteria item. The GALL Report says "Inspection results are acceptable if there are no visual Indications (outside those allowed by approved penetration seal configurations) of cracldng, separation of seals from walls and components, separation of layers of material, or ruptures or punctures of seals; no visual Indications of concrete cracking, spelin and loss of material of fire barrer walls. celling, and floors; no visual indications of missing parts, holes, and wear and no defidencles In the functional tests of fire doors.' The LRA says 'Acceptance criteria will be enhanced to verify no signficant corrosion" How much Is "sIgnIficant?"

License Renewal Commitment #30 LRA Amendment The TRM frequencies are based on those that were previously In the Technical Specifications. Entergy VT will re-examine the ability to performing these surveitances at a 6 month or higher frequency, provided that they can be safely performed Woline.

This effort wilt be started 6 months prior to the period of extended operation and Is tracked as License Renewal Commitment #30.

The VY Fire Hazards Analysis was provided during the onaste Inspection.

These dampers are In ventilation ducts; therefore, the conditions would be slmiar to other ambient conditions In the plant. The duct material Is carbon steel. The environment Is Indoor air.

Visual exam, consistent with ANSI 452-6 ticense Renewal Commitment #9 Yes. This Item is being tracked by Ucense Renewal Commitment #9.

License Renewal Commitment #8 This Item Is being addressed by Ucense Renewal Commltert #ft Accepted Closed Closed Closed Accepted Accepted

152 B.1.12.1-L-13 Acceptance Critera Item. What actions are taken. either with or without slgnimant corrosion?

153 B.1.12.1-L-14 Acceptance Criteria Item. Is there a WNPS commitment associated with this enhancement?

154 8.1.12.1-L-15 Acceptance Criteria item. The GALL Report says 'No corrosion is acceptable In the fuel supply line for the diesel-driven lre pump." The IRA says

'Acceptance criteria will be enhanced to verify that the diesel engine did not exoibit sIgns of degradation while it was nning: such as fuel oil, lube oil, coolart or exhaust gas leakage." Does the enhancement Include corrosion In the fuel supply line of the diesel-driven fire pump?

155 B.1.12.1-6-16 Acceptance Criteria item. Is there a WNPS commitment associated with this enhancement?

158 B.1.12.I-L-17 Operating Experience item. Has VY experienced any fire-protection-related operating experience? Please describe.

157 B.1.12.1.L-18 Operating Experience Item. Has VY reviewed and applied the industry operating experience that relates to fire protection?

158 B.1.12.1-6-19 Operating Experience Item. Is any VY plant-specific operating experience not bounded by industry operating experience?

159 B.1.12.1-L-20 Program Description item. Does VY Inspect the fire dampers?

160 B.1.12.1-L-21 Program Description Item. Does VY have an electric lire pump?

License Renewal Commitment #8 This Item Is being addressed by Ucense Renewal Commitment #8 License Renewal Commitment #8 This item Is being addressed by LUcense Renewal Commitment #8 Evidence of corrosion Inside the fuel line would appear as corrosion products In the fuel filter. Evidence of corrosion In the fuel filter would result in a Condition Report and an evaluation. Evidence of corrosion would be an Inspection criterion for fuel filters removed from service. In addition, the Internals of the fuel line are managed by the diesel fuel oil monitoring program.

License Renewal Commitment # 9 Yes. This item Is being tracked by License Renewal Commitment # 9 During the onsite Inspection, the OE Coordinator provided the requested Information.

VY routinely reviews Industry OE In accordance with fleet procedure, EN-OE-100. The VY OE coordinator routes OE to affected line organization groups, and enters action items Into the corrective action process to ensure that timely review Is completed and documented.

No IRA Amendment Yes. Surveillance Test #7134 Is the Operating Cycle Test of Fire Barrier Dampers, using procedure OP 4019. VY will add Fire Dampers to the program description, Yes. The pump end Is Identical to the diesel fire pump. It Is located in the Intake Structure. Component ID is P-40-1B. It Is Managed by Fire Water Program via Test Procedure If OP 4105.

Accepted Accepted Closed Accepted Closed Closed Closed Accepted Closed

161 B.1.12.1-L-22 Program Description Ram. How does VY inspect/ta equipment?

Test Procedures for Inspecting and testing Appendix R required equipment si Appendix R-required are:

PROC. # TITLE AP 0042 Plant Fire Prevention and Fire Protection OP 0048 Installation and Repair of Fire Banrers, Penetration Seals, Fire Breaks and Flood Seals.

OP 2186 Fire Suppression Systems OP 3020 Fire Emergency Response Procedure AP 3700 Fire Training OP 4001 Plant Fire Extinguisher Service and Issue OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems OP 4019 Surveillance of Plant Fire Barriers and Fire Rated Assemblies OP 4103 Fre Protection Equipment Surveillance OP 4104 Fire Hose Hydro Test Surveillance OP 4105 Fire Protection Systems Surveillance OP 4221 Surveillance of Gas Fire Extinguishing Systems OP 4339 Surveillance of Fire Protection Detectorsilnstruents OP 4392 Trip Test of Fire System Water Flow Alarms OP 4393 Test of the Cable Vault, Swftchgear Room, and Intake Structure C02 Systems OP 4395 Check of Computer/Heating Ventilation Air Conditioning (HVAC)

Shutdown Clrcuts I Computer Room Halon Act System OP 4602 Sampling of Fire Fighting Foam for Annual Anatysis OP 4800 General Safety Surveillance OP 5327 Calibration of Plant Fire Protection System Instruments AP 6024 Plant Housekeeping and Foreign Material Exclusion/Cleanliness Control PP 7011 Vermont Yankee Fire Protection and Appendix R Program At VY. the program Is being developed and will include training, acceptance says 'Visual Inspection by criteria, and qualification as a 'tire protection qualified Individual ANSI 45Z6 this consist, at VY?

The Injection program. EN-MA-102, will be used.

OP 4019 acceptance criteria will be revised to require that any recordable Inspection results are

'outside those allowed by approved penetration seal configurations' visual le those allowed by Indication be Identified and entered Into the corrective action process for ng,...." OP 4019, Appendix evaluation.

arriers, concrete block -

d smoke/gas seals.

The CA number to complete this action by 12/31/06 [a CR.VTY-2006-112. CA-02; CA-03.

Closed Closed Closed 162 B.l.12.1-L-23 Detection of Aging Effects item. The GALL Report fire protection qualified Inspectors....' Of what doe 163

.1.12.1-L-24 Acceptance Criteria item. The GALL Report says" acceptable if there are no visual Indications (outsid approved penetration seal configurations) of crack B. allows cracks In poured concrete barriers, fire b wails, drywall, plaster, silicone foam, pyrocrete, an

164 8.1.30.1-M-02 Is the Identified enhancement to AMP B.1.30, Water Chemistry Control -

Auxiliary Systems, necessary and appropriate for this program?

License Renewal Commitment #26 The Identified enhancement to AMP 8.1.30, Water Chemistry Control -

Auxiliary Systems is to enhance procedures to flush the John Deere diesel cooling water system and replace the coolant and coolant conditioner every three years.

A program Is necessary to manage loss of material and fouling of carbon steel and copper alloy components in the John Deere diesel cooling water system for the period of extended operation. Due to the size and configuration of the system, periodic sampling of the coolant was deemed unrealistic and the decision was made to flush the cooling water and replace the coolant and coolant conditioner every three years. While this task could have been Itukdxed In the Periodic Surveillance and Preventive Maintenance program, it was Included In the Water Chemistry Control - Auxiliary Systems program to be consistent with other components exposed to treated water, which are managed by water chemistry control programs.

As stated In LRA Section B.1.30.1. rather than sampling, procedures will be enhanced to flush the John Deere diesel cooling water system and replace the coolant and coolant conditioner every three years. (License Renewal Commitment 26)

Accepted

165 B.1.30.1-M-03 Confirm that there are no other In-scope systems that rely on this AMP for managing the effects of aging.

LRA Amendment The following LRA tables credit the Water Chemistry Control - Auxiliary Systems Program for managing the effects of aging.

3.2.2-5, Reactor Core Isolation Cooling (RCIC) System - Surnmary of Aging Management Evaluation 3.3.2-10, Heating, Ventilation and Air Conditioning (HVAC) Systems-Summary of Aging Management Evaluation 3.3.2-12, John Deere Diesel (JDD) - Summary of Aging Management Evaluation 3.3.2-13-18, House Heating Boiler (HB) System, Non Safety-Related Components Affecting Safety-Related Systems - Summary of Aging Management Evaluation 3.3.2-13-39, Stator Cooling (SC) System. Non Safety-Related Components Affecting Safely-Related Systems - Summary of Aging Management Evaluation The component in the RCIC system that credits this program is a steam heater which Is supplied by the house heating boiler system. Similarly, the components In the HVAC systems that credit this program are supplied by the house heating boiler system. Thus, there are no in-scope systems (other than the house heating botler, stator cooling, and John Deere diesel systems) that rely on this AMP for managing the effects of aging. All other tn-scope treated water systems rely on either the Water Chemistry Control - BWR program or the Water Chemist Control - Closed Cooling Water program for managing the effects of aging.

Items 3.3.1-50 and 3.3.1-51 In LRA Table 3.3.1 wig be updated to reflect that the de-mineralized water system Is managed by the Water Chemistry Control

- BWR Program, as indicated In LRA Table 3.3.2-13-12. aging of components.

LRA Amendment IRA Section 3 Table 1's discussions provide the link between the One-Time Inspection and Water Chemistry Control Program for these components.

To provide further clarification, the effectiveness of the Water Chemistry Control - Auxillary Systems, BWR, and Closed Cooling Water programs is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemisr Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Tune Inspection Program activities will confirm the effectiveness of these programs.

Inspection locations will be based on physical accessibility exposure levels, NDE techniques. and locations identified In NRC Information Notice 97-46.

Un-isolable Crack In High-Pressure Injection Piping. The Iitial population will Include all Class 1 small - bore piping.

Accepted Accepted Closed 0~

3 0

=-

CD 03 0

-n 168 B.1.21-K-04 LRA Section 3 Table 2's do not list the One-Time Inspection Program with the water chemisty control programs for components for which GALL recommends One-Time inspection to verify effectiveness of the Water Chemistry Control Program.

167 B.1.21.-K-05 Please provide sample selection criteria for the small -bore piping one-time inspection program.

168 B1.152-P-01 Please explain why the AMP for ISI (tWB, IWC, & I1Wf) is not consistent with the GALL AMP XIMi 169 B.1.15.2-P-02 The AMP for ISl (MWB, IWC, & IWD) makes no mention of any risk-informed program. Please confirm whether or not there are current or future plans for the Impiementation of rfsk-linformed ISI.

Entergy chose to describe the Inservice Inspection and Containment Closed Inservice Inspection Programs as plant-specific programs rather than comparing to the corresponding NUREG-1 801 programs because the NUREG-t 801 programs contain many ASME Section XI table and section numbers which change with different versions of the code. Because of this, comparison with the NUREG-1 801 programs generates many exceptions and explanations which detract from the objective of the comparison. What Is really needed is that WNPS follow the version of ASME Section XI that Is approved for use at VYNPS and accepted by iaw in 10CFR50.55(a). As this Is the case, the Inservice Inspection and Containment Inservice Inspection Programs are presented as plant-specific programs so they can be Judged on their own merit without the distraction of numerous explanations of code revision.

Rllsk-informed ISI Is being Implemented during the Fourth Ten-Year Interval Closed (9/11/2003 - 8W31/2013). Surface examination of ASME Section X), Class 1, Examination Categories B-F, C-F-1. and C-F-2 (4 NPS and larger) aye conducted In accordance with Code Case N-663. All areas of the subject welds identified as susceptible to outside surface attack shall be surface examined during the Fourth Ten-Year Interval In accordance with Code Case N-663. Code Case N-663 Incorporates lessons learned for rlisk-iniformed initiatives and Industry examination experience by requiring that an evaluation be conducted to Identify locations, if any, where a surface examination would be of benefit from a generic piping degradation perspective. The results of the evaluation Identify where O.D. degradation Is most likely to occur by reviewing piant-specific programs and practices, and operating experience. if the potential for degradation Is Identified, Code Case N-663 defines examination techniques, volumes, and frequencies. As such, Implementing Code Case N-663 Identifies appropriate locations for surface examination and eliminates unnecessary examinations.

VYNPS plans to continue surface examination of ASME Section )X, Class I, Examination Categories R-F, C-F-i, and C-F-2 (4" NPS and larger) In accordance with Code Case N-663 in subsequent Inspection Intervals. if Code Case N-663 Is not incorporated into the ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission In 10 CFR 50.55a for the subsequent Interval, a relief request will be submitted as was done for the Fourth Inspection Interval PP7027, Appendix B states clearly that these brackets are examined as if they are furnace sensitized, I A W VIP 48-A.

170 Provide the basis for determining the Inspections required for BWRVIP-48.

Particularly address whether VYNPS has any furnace sensitized material or Alloy 182 material that requires EV'I.

closed

171 B.1.27.1-W-04 Provide the last two Inspection reports for one un-reinforced Masonry Wail without bracing, one reinforced Masonry Wai without bracing and one steel braced Masonry Wail.

172 Please provide copies of OP4339 and EN.OE-1 00, procedures related to the Fire Water System Program.

173 In Section 2b Prvente actlons of LRPD-02 and it Is stated that there are no preventive actions. GALL says that monitoring of water chemistry to control pH and concentration of corrosive contaminants and treatment with hydrazine are effective In reducing selective leaching. Do any of the systems that have selective leaching as an AMP have a treated water environment that performs any of these treatments to control selective leaching?

174 What Is the flaw evaluation calculation for the Jet pump diffuser welds? Is this calculation considered a TLAA?

175 Win UT of the flawed let pump dilffuser welds continue?

Please Identify any change to the exception Identified In LRA.

If yes, please provide the exact wording In iRA supplement.

(Note: EV"-I does not provide flow propagation verification.)

The following Block Wall Inspection Reports and drawings were provlded during the onsite inspection:

-Masonry Wail Routine Surveillance Walkdown Sheet for Wall G-191145-9 dated IOft102 G

(ur-reinforced wall)

-Drawing B-191600 Sheet 8 Rev 0 (from walkdown)

-Attachment C VYP-007 RI Masonry Wall Routine Surveillance Waildowt Sheet for Wall 0.191145-9 dated 9/1/93 (un-reinforced wall)

-Drawing 5-191600 Sheet 8 Ray 0 (from walkdown)

-Attachment C VYP-007 R1 Masonry Wagl Routine Surveillance Walkdown Sheet for Wail G-191145-4 dated 9/2893 (steel braced wall)

• Attachment C VYP-007 RO Masonry Wall Routine Surveillance Walkdown Sheet for Wall 0-19114S-4 dated 9/10/87 (steel braced wai)

-Drawing B-191600 Sheet 7 Rev 1 (from 1993 walkdown)

-Masonry Wail Routine Surveillance Walkdown Sheet for Wall G-1 91627-4 dated 10,'16/02 (reinforced wall)

-Attachment C VYP-007 R1 Masonry Wan Routine Surveillance Waikdown Sheet for Wall G-1916274 dated 9/11/93 (reinforced masonry wail)

-Drawing B.191600 Sheet 105 Rev 0 (reinforced masonry wall. from walkdown)

-Drawing B-191600 Sheet 105 Rev I (reinforced masonry wall)

OP4339 and EN-OE-100 were provided during the onslte Inspection.

Yes. The Water Chemistry Control - Closed Cooling Water and BWR programs at VYNPS control PH and corrosive contaminants and could be effective In controlling selective leaching. Therefore any system and components with both the selective leaching and the water chemistry programs as aging management programs are included measures that could be effective In controlling the aging effect of selective leaching.

The iet pump diffuser welds calculations are contained In: GE-NE-B13-01935.

Rev. 2. Jet Pump Assembly Welds Flaw Evaluation Handbook for Vermont Yankee, July 1999.

This is not a TLAA.

These welds are scheduled for UT examination during RFO 26.

Following RFO -26. R there are no changes to the observed Indications, the Inspections will revert to EVT-I Inspections IAW BWRVIP-4.

Closed Closed Closed Closed Closed

176 Win VYNPS continue to Inspect 10% of CR0 guide tubes every 12 years?

Additional question: PP-1027 stated that 2Vr-3 Inspections were performed.

BWRVfP stated that 4 CR0 Guide tube weld locations were recommended to be inspected; 2 locations (Vr-3) 2 locations (EVT-1)

Please describe the inspection for all 4 locations. Does applicant Inspect all 4 welds or only 2 welds?

177 Wil VYNPS continue to inspect the top guide at the rate of 10% every 12 years?

178 What Is the exam history, results, schedule and currrent status of shroud I-I8 and H9 welds?

VYNPS Inspects guide tubes lAW BWRVIP-47-A and plans to continue to do so.

EVT-1 Inspections are conducted on CRGT-2 and CRGT-3.

VT-3 Inspections are conducted on CRGT-1 and FS?GT-APRIN-1 This question has been addressed In Cuestion I 14. The BWR Vessel Internals Program at WNPS Is consistent with the program described in NUREG.1801,Section XI.Mg. BWR Vessel Internals with the exceptions and enhancement noted In LRA Section B.1.7. As stated In NUREG-1 801, the extent of the examination and Ibs frequency will be based on a ten percent sample of the total population, which Includes all grid beam and beam-to-beam crevice slots.

In RFO 19 (1996) Vermont Yankee performed an Inspection of welds H8 and H9 which meets the requirements of BWRVIP-38 for a baseline examination.

The followig describes the rationale for this statement The baseline strategies for welds H8 and H9 are shown In Figures 3-4 and 3-5 of BWRVIP-

38. The load multiplier Is determined from Figes 5-1. In Vermont Yankee's case this Is a 0.41. The flaw tolerance Is determined from figures 5-1 (for H8) and 5-2 (for Hg) for plants with support legs. For both welds the flaw tolerance of 100 %. The minimum examination coverage for a flaw tolerance of 100% is 10% for both H8 and Hg. The coverage was 25% for weld H8 and 22% for weld Hg during the RFO 19 (1996) examination. No flaws were found. Therefore an adequate baseline of welds H8 and H9 was performed.

No welds other than H8 and H9 require examination Is accordance with BWRVIP-38 for a plant with Vermont Yankee's core shroud support configuration. The NRC requires Inspection tooli and methodologies be developed that allow the welds In the lower plenum to be made accessible.

This requirement applies to the VYNPS shroud support leg welds. This inspection remains an open Ierm with the NRC per response to BWRVIP-38.

The re-inspection Interval Is established In BRWVIP-38, Paragraph 3.3.2. that states "¶f no flaws were found during the previous inspection, re-Inspections are performed on ten-year Intervals Ht UT techniques were used...' The RFO 19 (199%) H8 and H9 examination was an ultrasonic test augmented with eddy current and no flaws were found. Therefore the re-Inspection Interval Is ten years IH UT techniques are used, and six years If EVT-1 techniques are used (but see below). Accordingly, re-Inspection of H8 and H9 were re-Inspected In RFO 25(2005). by EVT-1 nine years following the baseline exam.

WANO Assessment Report will be available for on-site review during return audit (week of 5/1506).

Closed I0

!0)

CD P0 A',

Closed Closed 179 8.1.22-M-03 please provide a recent third party assessment of the preventive maintenance program.

Closed

1 BO Closed B.1.22.M-04 Following the proposed enhancement to the Periodic Surveilance and Preventive Maintenance Program, will It be apparent that these tasks contain an aging management element?

181 B.1.22-L-01 Program Description Rem. The GALL Report says The External Surfaces Monitoring program Is based on system Inspections and walkdowns. This program consists of periodic visual Inspections of steel components such as piping, piping components, ductlng, and other components within the scope of license renewal and subject to AMR in order to manage aging effects. The program manages aging effects through visual inspection of external surfaces for evidence of material loss. Loss of material due to boric acid corrosion Is managed by the Boric Acid Corrosion Program.' The LRA says This program entails Inspections of external surfaces of components subject to aging management review. The program Is also credited with managing loss of material from Internal surfaces, for situaticns in which Internal and external material and ernvirm.n ent combinations are the same such that external surface condition is representative of Internal surface condlitlon What materials are within the scope of this AMP?

182 B.1.22-L-02 Program Description Ktem. What examination methods are used?

The Periodic Surveillance and Preventive Maintenance program Includes two types of tasks, Inspections and surveillances.

Inspections Include various visual or other non-destrucVve examinations to manage loss of material, cracking, and fouling of components. Following the proposed enhancements. it wilt be apparent that these tasks contain an aging management element. To properly Inspect for evidence of loss of material, cracing, or fouling, the Inspector must be aware that he Is looking for these aging effects and as such new guidance to Identify these aging effects will be Included as required.

Surveillances Include the secondary containment capability check, which will confirm the absence of aging effects for reactor building exterior concrete walls during the period of extended operation; leakage testing on the equipment lock doors, which will confirm the absence of aging effects for the rubber door seals during the period of extended operation; and temperature monitoring during operability testing of diesel generators to confirm the absence of fouling of diesel heat exchangers during the period of extended operation. To perform these tests, the performer does not need to be aware that he Is confirming the absence of aging effects. If the applicable acceptance criterion is not met, the performer will Initiate a condition report In accordance with the corrective action program, causes for the condition wil be evaluated, Including those that are due to aging of components.

The Walkdown program Is not exclusive of any system material condition. It should be noted that the wadaowr process may find signs of external piping degradation that would be evaluated for potential Inmpact to Interior piping surfaces. The walkdown program is not Intended to Inspect interior piping and component surface unless they have been revealed for Inspection during maintenance and repairs. As indicated In the tables In Section 3 of the LRA.

the System Walkdown program manages aging for external surfaces of carbon steel, stainless steel, cast iron, low alloy steel, aluminum, and copper alloy components. The program also manages loss of material from Internal surfaces in situations in which Internal and external material and environment combinations are the same such that external surface condition Is representative of internal surface condition.

For current term operatiot, system walkdowns use ' eye contact examination. System Engineers are not qualtled In visual examination methods such as those used to quallty welding. The Entergy walkdown procedure provides a Wating and a checklist of examinations to be performed during the wkldown. Plant Issues ranging from standard housekeeping to equipment problems are documented and acted upon accordingly through work planning and the condition reporting system. For the License Renewal term, under the System Walkdown program, visual Inspection activities are performed and associated personnel are qualified in accordance with site controlled procedures and processes.

Closed Closed

183 8.1.22-L-03 Operating Experience Item.. Has VY experienced any external surfaces-related operating experience? Please describe.

184 9.1.22-L-04 Operating Experience item: Has VY reviewed and applied the industry operating experience that relates to external surfaces?

185 B.1.22-L-05 Operating Experience Rem: Is any VY plant-speclfic operating experience not bounded by industry operating experience?

186 B.1.22-L-06 Program Description item. Is boric acid leakage that fafls/sprays on VY components managed by the Boric Acid Corrosion Program?

187 6.1.22-L-07 Scope of Program Item. Please expand the explanation of the enhancement Identified In LRPD-0Z page 218.

System Walkdowns, both online and during refueling outages, have found corrosion on piping and component surfaces. For Instance, each refueling.

the interior of the condenser hotwet1 and waterboxes are inspected. Repairs and or more detailed inspections are Implemented as required. In Refueling Outage 24 (November 2005) examination of spring cans supporting service water piping revealed rust and the need for recoating. Corrective actions driven by condition reporting and work order planning has resulted In scheduling repair for the 2006 outage.

Vermont Yankee System Engineers have received training In the EPRI Aging Management Field guide, which In effect is a collection of OE from many nuclear plant systems, both mechanical and electrical. as well as buidings and structures Intended to provide specific details of corrosion and degradation throughout the plant. Review of OE Is an ongoing actilvty for Vermont Yankee System Engineers intended to ensure latest issues are known and to continue to develop background related to assigned systems.

Through Its condition reporting system, Vermont Yankee will contribute to Industry OE as its Condition Reporting Committee directs. Aging related issues with Vermont Yankee are typical of Industry based OE.

Vermont Yankee Is a Boiling Water Reactor and therefore does not have a Boric Acid Corrosion Prevention program. The Standby Uquid Control system, which contains Sodium Pentaborate, and is maintained In a clean condton. Rare cases of leakage from standby liquid control system valve packing or other system components have occurred, but were promptly corrected prior to Impacting the Intended function of components subject to aging management review for license renewal. The external surfaces of SLC components and components in the area are managed by the System Walkdown program.

License Renewal Commitment 024 LRA Amendment The enhancement In LRPD-02, page 218 was identified after the LRA was submitted to NRC for review. Entergy decided that the System Walkdown program Implementing procedure should be enhanced to specify that systems In scope and subject to aging management review for license renewal In accordance with 10 CFR 50.54 (a)(1) and (a)(3) shall be walked down. Guidance as to what systems are walked-down Is currentiy Included In less formal plant guidelines. Also, although the System Waikdown program Implementing procedure currently provides guidance to Inspect nearby systems that could Impact the system being walked down. Entergy decided that this guidance should be clarified. The enhancement In LRPD-02, page 218 is commitment # 24 on the list of commitments for license renewal.

Closed Closed Closed Closed Accepted

188 8.1.22-.-08 Scope of Program Item. Enhancements will need specific commitments.

189 8.1.22-L-09 Parameters MonItored/Inspected Item. The LRA does not specify the same examples that the GALL Report does, e.g., material wastage, leakage.

Insulation condition. etc. What Is the Justification for not addressing these parameters?

190 8.1.22-L-10 Parameters Morntoredinspected Item. Several of these parameters are not addressed In EN-DC-178. Should this procedure be enhanced?

191 B.1.22-L-11 Detection of Aging Effects Item. GALL focuses on the pertinent surfaces.

LRPD-02, page 215, says that the program will manage the loss of material for Internal and external surfaces by visual inspection of external surfaces.

How Is this accomplished?

192 B.1.22-L-12 Operating Experience Rem: Has VYNPS experienced any external surfaces-related operating experience? Please describe.

193 B.1.22-L-13 Operating Experience Item. Has VYNPS reviewed and applied the Industry operating experience that relates to external surfaces?

194 B.1.22-1-14 Operating Experience item. Is any VY plant-specIfic operating experience not bounded by Industry operating experience?

License Renewat Commitment #24 Vermont Yankee commits to those Items related to Aging Management and will update the Entergy waftdown procedure accordingly commensurate with the License Renewal schedule. Training In the EPRI Field Guide Is ongoing at this time. The enhancement In LRPD-02, page 218 Is commitment # 24 on the list of commitments for license renewal.

See also related Audit Item #384 These Items are docum.ented on a monthly basis, as found during walkdowns, In walkdown reports. Any material condition Is assessed at the time discovered and acted upon according to Its conditions. AD system conditions, Including those found In walkdowns, plant monitoring and dally operations are summarized In Quarterty System Health reports.

License Renewal Commitment 924 Specificealy discussed during License Renewal program reviews were Insulation and the need to visually examine It for signs of leakage, corrosion beneath and missing insulation. License Renewal Commftment # 24 addresses the Walkdown procedure.

Walkdowns may find signs of piping external surface degradation and wil assess any potential impact on Interior surfaces.

Consistent with GALL Section XI.M36, External Surfaces Monitoring, the VYNPS System Walkdown program will manage loss of material for Internal surfaces exposed to the same environment as the external surfaces.

Externat surface condition on components exposed to the same Internal and external environments Is Indicative of internal surface condition. Components with signs of external surface degradation wil be assessed for potential Impact on Interior surfaces impact.

In addition to the service water piping spring cans noted In Question 183 and a few other examples are:

1. Cooling Tower wood structural member splltlng (normal aging and checking of wood). VY's preventative maintenance program drves Inspection and replacement as required.

2. Switchyard tower base age related cracldng. Evaluated for structural Impact, found satisfactory, future work to coat bases.

Yes, the OE has helped identify specific causes and 'best practice repatrs.

The EPRI Aging Management Fid Guide has been particularly useful.

Review of Aging Related OE to date has not found such OE.

Accepted Closed Accepted Closed Closed Closed Closed

195 B.1.22-L-15 Operating Experience item. Several findings are Identified under the OE tab.

Are these the total findings that were made or are they simply representative?

196 Regarding the UT Indicatkin at 215 degrees on the RPV cladding adjacent to a dryer support log: Does WNPS plan to re-nspect this Indication by UT?

197 3.1.1-01-P-01 On page 3.1-65, the component type 'supports stabbTizer pads support sldrt Is managed using TLAA - metal fatigue. In all cases where the LRA lists

'Cracking -fatgue" as the AERM, change It to 'Fat"gue damage' (apptles to multiple Table 1 items but Is asked only once).

198 3.1.1-02-P-01 On page 3.1-38, the component type closure flange studs, nuts, washers and bushings' and the component type other pressure boundary bolting, flange bolts and nuts (N6A, N6O, NT), CR0 flange cap-screws and washers' are managed using TLAA - metal fatigue. Please confirm that aging of these components will be managed using the new 'Bolting Integrity' AMP.

Email Edit 5/11/2006 -3.1.1-02-P-01 Geherc question 2: When bolting Integrity AMP Is added. many AMR Table 2 items need to be revised. WIIU VYNPS provide bolting Integrity program to manage bolts?

These examples are representative. WNPS can supply others on specific systems as requested.

VYNPS performed enhanced UT's In accordance with commitment described In BVY 92-055 and BW 93-112. These UTs were performed from the RPV OD and determined that the cracks do not penetrate to the RPV base metal.

The steam dryer lugs will be re-inspected In accordance with BWRVIP-48 by VT-1.

Cumulative fatigue damage Is a generic term. However, only when fatigue damage accmnulates to the point that the component cracks Is the function of the component In jeopardy. VYNPS uses the aging effect of cracking due to fatigue to represent the physical result of cumuattve fatigue damage. The meaning of 'Cracking - fatigue* is consistent with the Intent of 'Cumulative Fatigue Damage'.

License Renewal Commitment #34 LRA Amendment Revised Answer to 5/11/2006emalt A Bolting Integrity Program Is In development that wtll address the aging management of bolting in the scope of license renewal. The Bolting Integriy Program will be Implemented prior to the period of extended operation In accordance with commitment number #34.

The Identification of T"LAA - metal fatigue In the aging management program column Is provIded as a convenient means to Indicate that these components are susceptible to cracking due to fatigue which Is addressed In Section 4.3:1 of the LRA as a TLAA. it Is not knplying that TLAA - metal fatigue Is an aging management program. An aging management program Is one of the three resolutions for the evalustion of a TLAA.

The component type closure flange studs, nuts, washers and bushings are for the reactor head and are managed by the Reactor Head Closure Studs Program described In Section B.1.23 of the LRA which is comparable with the NUREG-1801 XI.M3 program. This approach Is consistent with the GALL Bolting Integrity program XI.MI 8 which states that the aging management of reactor head closure studs Is addressed by XI.M3, and Is not Included In this program. A Bolting Integrity Program Is in development that will address the aging management of other bolting In the scope of license renewal.

Closed Closed Closed Accepted

199 3.1.1-02-P-02 On page 3.1-54. the component type internal attachments shroud support ring pad (1) shroud support feet (14) jet purmp riser pads (20) core spray brackets (4) guide rod brackets (2) steam dryer brackets (4) dryer hold-down brackets (4) survelliance specimen holder brackets feedwater sparger brackets (8)' Is managed using TLAA - metal fatigue. Please explain why these components are not managed In accordance with GALL v2 Item IV.81.14.

200 3.1.1-13-P-01 In many cases, loss of material Is managed using Water chemistry control-BWR. Please confirm that the VYNPS Water Chemistry - BWR AMP is consistent with GALL XI.M32, 'One-Time inspection,* as well as with XI.M2,

'Water Chemistry.'

Edit from 5/11=006 emall - In many cases (e.g. page 3.1-67 piping& fitting),

loss of material Is managed using Water chemistry control - BWR alone.

Please confirm that the VYNPS Water Chemistry - BWR AMP Is consistent with GALL XI.M32, "One-Time Inspection," as well as with XI.M2, 'Water Charnistry" Many NUREG-1 801, Volume 2 Items are very similar In terms of materials, Closed environment. aging effect and aging management program. Where a NUREG-1801 item lists the same component, the choice Is straightforward.

Where NUREG-1801 does not match the specific component, the selection of the item to compare to the aging management review results Is somewhat arbitrary. Item IV.B1-14 would certainly have been an acceptable choice for the comparison. However, In this particular case, the components were considered a subset of the reactor vessel (hence the listing within the reactor vessel table) and the comparison was made to the fatigue Item within the NUREG-1 801 BWR reactor vessel table. The aging management review results In NUREG-1801 are the same for erem IV.A1-7 as for IV.B1-14.

LRA Amendment As stated In LRA Section 8.1.30.2, the Water Chemistry Control - BWR Program Is conststent with the program described in NUREG-101,Section XI.M2. 'Water Chemistry.* The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems. Water Chemist Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material. and fouling is not occurring. As stated In IRA Section 8.1.21, the One-Time Inspection Program Is a new program which witl be consistent with the program described in NUREG-18010 Section XI.M32, One-Time Inspection.

LRA Tables 3.1.1, 32.1, 3.3.1, and 3.4.1 indicate that the One-Time Inspection Program Is credited along with the water chemistry control programs for tine Items for which GALL recommends a one-time Inspection to confirm water chemistry cortrol For simplicity, the subsequent tables (Table 2's) do not list the One-Trne Inspection Program each lme a water chemistry control program Is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, It Is also applicable to each line item that credits a water chemistry control program.

To provide further clarification, the effectiveness of the Water Chemistry Control - Auxtliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A.

SAR supplement descriptions for the Water Chemistry Control -Auiliary Systems, BWR and Closed Cooling Water programs to explvty state One-Time Inspection Program actvties will confirm the effectness of these programs.

Accepted

201 3.1.1.14-P-02 On page 3.1-53, the component type 'weld SLC nozzle to safe end weld N10)'

Is managed using BWR vessel Internals, Water chemistry control -BWR. The AMP applied. BWR VI, Is acceptable, however, this differs from what Is recommended by GALL Please explain why Note E was not assigned.

Edit from 5/11/2006 emaMl

- On page 3.1-53, the component type weld SLC nozzle to safe end weld (N0)' is managed using BWR vessel internals, Water chemistry control -BWFL Please explain how the BWR Vessel Internal program manage loss of material for SLC Nozzle to SE weld (N10) and provide either document or Inspection plan to support this AMPR.

Closed 202 3.1.1-17-P-01 (Original Question]

On page 3.1-39. the component type 'reactor vessel shell, Intermed 0ate beil*e sheWl is managed using reactor vessel surveillance and TLAA -

neutron tluence. Please confirm that the neutron fluence at the LPCI and RHR Injection nozzle will remain <1E17 n/cm2 (E>IMeV) through the end of the period of extended operation.

[Follow-up Question]

In view of the power uprate, and based upon the graphic provided in GE-NE-0000-0014-0292-01, 'Vermont Yankee Nuclear Power Station Extended Power Uprate RPV Flux Evaluation." fluence at the nozzle appears to be very close to lxl 017 nrcm2. Please provide a calculation of the flux at the edge of the nozzle closest to the active fuel regon.

NUREG-1801 Item MAI -8 specifies the water chemist program for BWRs augmented to verify program effectiveness by an inspection program such as the one-time Inspection (OT) program. The OTI program will be used to verify the effectiveness of the water chemistry - BWR program wherever It Is appled. Rather than list the OTI program every thme the water chemistry -

BWR program Is lsted in the 3.x.2 tables, the usa of the O11 program Is Identified in the rollup (3.x.1) tables and in the further evaluation discussions.

The use of the water chemistry - BWR program augmented by the Ot program is the basis for the use of Note A. Where another program, such as the BWR vessel Internals program could also be used to verify water chemistry program effectiveness, we have conservatively Included it In the list oc programs. however, it is coirfed a supplement to and not different from the NUREG-1 801 ldentified programs.

Revised Answer to Revised Question -The BWRVIP augments the ISI Program for weld N10-SE, the SLC (NIO) safe end to vessel weld. The VYNPS Inspection requirements for this weld are thus in PP 7027, Reactor Vessel Internals Management Program.' The SLC nozzle to safe end weld examination schedule and history is discussed In detail In section 15.0 of Appendix B to PP 7027.

POTENTIAL RAI

[Original Response]

As stated in LRA Section 4.2.1, there are no nozzles in the vertical section of the reactor vessel ID that will receive greater than 1E17 n/cm2 (E > 1 MeV) during the period of extended operation.

[Follow-up Response]

VYNPS extrapolated the fluence near the recirculation inlet nozzles from known data as follows.

From drawing 104R940, the top of the nozzles is 202 Inches.

The fluence versus height Is given In GE-NE-0000-0007-2342-R1-NP, figure 6-1. This curve was ratioed to account for the power Increase to 1912 MW.

This resulted In an ID surface fluence of 1E17 at 204 Inches, missing the nozzles by 2 Inches. The adjustments to RTNDT and USE are based on % T fluence. The surface fluence Is 35% higher than the % T fluence. The point at which the % T fluence exceeds 1 Et7 Is approximately the bottom of the active fuel, 5.5 Inches above the nozzle. The peak fluence values were calculated in accordance with Regulatory Guide 1.90 (See LRA section 4.2.1) and include conservatisms to ensure they are maximum values. Given these factors, the recirculation Inlet nozzles do not exceed the 1 E17 threshold for neutron embrittlement Even If the fluence at the nozzle slightly exceeds 1E17 threshold, the correction factors from Regulatory Guide 1.99 are very small when Just above the irrit. (The RTNDT fluence factor Is only 0.11 at 1 E17. The curves for calculating the decrease In USE don' start till fluence reaches 1E18; the formulas for the curves predict about 6% reduction in USE at 1E17.)

Accepted

203 3.1.1-19-P-01 On page 3.1-67., the component type'plplng and fittings <4' NPS Is managed using water chemistry control - BWR, One-time Inspection. The GALL suggests that a plant-specific program Is appropriate for managing SCC of these components. Please Identify the Inspection technlques that are to be used and the basis for concluding that one-the Inspection Is appropriate, rather than periodic Inspection.

Edit from 5111/2008 - On page 3.1 -7. the component type 'piping and fittings

<4* NPS is managed using water chemlsty control - BWR, One-time Inspection. Why VY does not credit ISI program?

204 3.1.1-29-P-01 On page 3.1-62, the component type 'steam dryers Is managed rusing BWR vessel Internals. The AMR Indicates that cracking of the steam dryers will be managed using the BWR VI program, yet they are not listed In the scope of the program. Please provide a plant-specfc AMP as recommended by GALL or ensure that each of the 10 attributes of an acceptable management program are to be addressed.

LRA Amendment All piping and fittings less than 4 NPS. except for the head seal leak detection line, are covered by NUREG-1801 Item IV.C1-1, whlch Identifies ISt. water chemistry for BWRs and one-time Inspection (OTI) for small bore piping as the applicable aging management programs for cracking. The VYNPS ISI program Includes piping and fittngs less than 4" NPS. The LRA will be clarified to indicate that Ist In addition to water chemistry control -

SWR and O11 applies to these components.

LR Commitment #37 VYNPS submitted a steam dryer monitoring plan as part of the recent power uprate application. That plan was approved by the NRC. That plan will continue dryer Inspections for at least three consecutive refueling outages after the power uprate.

BWRVIP-139, Steam Dryer Inspection and Flaw Evaluation Guidelines, has been submitted to the NRC for review and approval. ThIs BWRVIP document is expected to be approved by the NRC prior to the period of extended operation and as such will become a part of the BWR Vessel Internals Program. The VYNPS vessel Internals procedure commits VY to comply with every approved BWRVIP. As such, VYNPS will manage cracking of the steam dryers per the BWR Vessel Internals Program during the period of extended operation.

In the unlikely event that BWRVIP-1 39 Is not approved prior to the period of extended operation, VYNPS will continue Inspections In accordance with the Steam Dryer Monitoring Program, Revision 3. as previously approved by the NRC as part of the Extended Power Uprate. These Inspections will be In accordance with the guidance In SIL 644, Rev. 1.

Commitment #37 will state the following Continue inspections In accordance with the Steam Dryer Monitoring Program, Revision 3 In ft event that the BWRVIP-139 Is not approved prior to the period of extended operation.

Although Item IV.AI-5 lists the BWR Penetrations program for cracking, the program description in NUREG-1801 Chapter XI does not Include the CRD stub tubes are In the program scope. The BWR Vessel Intemials program does not specifically address the CRD stub tubes either, but is a more appropriate aging management program for this particular component. Note E Is assigned to this line since the program does not match that listed In the NUREG-1801 item.

Accepted Accepted 205 3.1.1-40-P-01 On page 3.1-40, the component type ýCRD stub tubes' Is managed using BWR Vessel Internals, water chemisty control - BWR. For this item, GALL recommends the use of a program consistent with ).MS, "BWR Penetrations.* No exception was taken to the scope of VYNPS AMP B.1.4.

"BWR Penetrations Program. It would also seem appropriate to assign Note E to this Item tsleas the AMP assigned Is changed.

Closed

206 3.1.1-40-P-02 On page 3.1-41. the component type 'incore houslngs Is managed using inservice nspction water chemistry control - BWR. Please conflrm that the correct GALL Item Is referenced.

207 3.1.1-41-P-01 On page 3.1-72. the component type Yestrictors (ms)l is managed using water chemisty control - BWR. One-time inspection. Please provide the basis for excluding this component from the BWR Stress Corrosion Cracking program.

Edit from 5/1112006 email-On page 3.1-72, the component type retiotors (ms)' Is managed using water chemistry control - BWR, One-time inspection.

Please provide the basis for excluding this component from the BWR Stress Corrosion Cracking program. Is restictor (ms) weld Inspection part of ISI also?

208 3.1.1-41-P-02 On page 3.1-41, the component type 'nozzles recirc outlets (NI), rectrc inlets (N2)' and on page 3.1-43, the component type 'nozzles, core spray (N5). head spray (N6A), head Instrumentation (N6B), head vent (NW), let pump ins entaton (N8)' are managed using inse-vice inspection, water chemistry control - BWR. The GALL item referenced In this AMR Is for Stainless steel and nickel-based alloy components that may be subject to SCC. it does not appear to be appropriate for low-alloy steel. Please Identify a more suitable GALL item.

Inse-vice inspection (1OS) and water chemistry - BWR are listed for the management of both loss of material and cracking. The listed NUREG-1 801 item Is correct for both aging effects. For loss of material, the water chemistry - BWR and one-time Inspection programs (see response to question 3.1.1-14-P-02 for discussion on OTI program appilcabTIf are the basis for the use of Note A. and the ISI program Is spplemental. For cracking, Note E is used since the ISI program Is different from the program (BWR Penetrations) listed In NUREG-1 801.

The BWR Stress Corrosion Cracking Program (GALL Saction XI.M7) Is designed for pressure boundary piping. The main steam flow restrtctors are not pressure boundary components. As such they are not subject to ASME Inspection requirements and were not a good fit for the BWRSCC program.

VYNPS opted to manage them by One Time Inspection.

The material for these components Is Identified as low allow steel with stainless steel cladding. The material exposed to the internal environment of reactor coolant (treated water) Is the stainless steel cladding. When evaluating surface aging effects such as cracking and loss of material, the stainless steel cladding is the material that must match the NUREG-1801 item. NUREG-1801 hem IVAI-1 provides the best match for the material.

environment and aging effect combination within the BWR reactor vessel table.

The applicable material for the external environment (air) Is low alloy steel (or

'steer in NUREG-1 801 terms).

Closed Closed Closed

209 3.1.1-41-P-03 On page 3.1-45, the component type 'nozzles flange leak-off (N13, N14), on page 3.1-47, the component type 'flanges, head nozzle flanges (N6, N7),

blank flanges (N6)'; on page 3.1-51, the component type 'safe ends < 4" core SCWP (N10), Instrumentation (Nl1. N112); and on page 3.1-52, the component type 'thermal sleeves, feedwater Inlets (N4)' are managed using Inservlce Inspecton, water chemistry control-BWR. Please explain why these are not managed using the BWR SCC program.

Edit from 5/11/2006 email - on page 3.1-47, the component type 'flanges, head nozzle flanges (N6, N7), blank flanges (N6)'; Instrumentation (Nil, N12)'; and on page 3.1-52. the component type 'thermal sleeves, feedwater Inlets (N4)' are managed using Inservnce inspection, water chemistry control -

BWR. Please conflrm these nozzles are less than 4 NPS. Please clarify how to manage feedwater Inlets thermal sleeve with ISI program.

210 3.1.1-43-P-01 On page 3.1-56, the component type'control rod guide tubes, bases' Is managed using BWR vessel Internals, water chemistry control - BWRL The component type appears to be described by the structure and/or component column in GALL Table IV.B1. Please clarify the basis for assigning Note D.

LRA Amendment The BWRSCC program (GALL Section XI.M7) applies to stainless steel piping >.-4 In diameter. N13 and N14 are 2nozzles. Safe ends <4" N10 Is a 2" safe end. Nil and N12 are 2nozzles.

N6 and N7 am low alloy steel and thus not susceptible to IGSCC. N6 blank flanges are 6" stainless steel flanges. These flanges were Included In the ISI Program with the rest of the nozzle assembly.

The feedwater thermal sleeves (N4) are a combination of stainless steel and nlckel-based alloy In a 10 Inch nozzle. The BWRSCC program In NUREG-1801 does not appear to include feedwater thermal sleeves. Therefore, the feaedwater thermal sleeves were included in the ISI and water chemistry control programs.

The status of the feedwater thermal sleeves has already been given In response to question 291. That response Is reproduced below.

The feedwater nozzle thermal sleeves are In Table 3.1.2-1 with an Intended function of pressure boundary. Cracking of the thermal sleeves Is managed by Inservnce Inspection and Water Chemistry Control - BWR.

Further review of the thermal sleeve design (to determine exactly how ISI inspects them) determined that the VY sleeves are not welded In place, rather they are an Interference fIt As such, there Is no weld to the pressure boundary piping thaI can be examined by ISI.

Given that there Is no pressure boundary weld, these sleeves are not part of the pressure boundary. As such they have no Intended function for license renewal, and with no Intended function they are not subject to aging management review1. Therefore, Vermont Yankee will amend the license renewal appricatfon to Indicate that the feedwater thermal sleeves are not subject to aging management review.

The feedwater thermal sleeves have no non-safety affecting safety related (a2) function. They are completely contained within the feedwater piping and cannot spray or leak on other equipment. The feedwater thermal sleeves are a part of the feedwater piping Inside the vessel, and failure of that piping does not defeat the deivery of water to the vessel annulus, as any leakage also goes to the vessel annulus.

This requires an amendment to the LRA The matching of component types between the plant and NUREG-1 801 Is not always straightforward. Minor differences In component names (as In this example) can lead to uncertainty In the Intended scope of components In the NUREG-1 801 item. Our approach was to err conservatively, so Notes C and D were sometimes used where Notes A and B might have been acceptable.

Since the comparison Is equally valid with either set of notes, this conservative approach Is considered appropriate.

Accepted Closed

211 3.1.1-44-P-01 On page 3.1-52, the component type 'thermal sleeves recik inlet (N2) core spray (NS)' Is managed using BWR vessel Intemals and water chemistry control - BWR. Please confirm that for the reckrc let nozzle thermal sleeve.

Note B would apply.

Edit from 5/1112006 email -On page 3.1-5Z the component type 'thermal sleeves reclrc Inlet (N2) core spray (NS)' Is managed using BWR vessel internals and water chemistry control - BWFL Please confirm that for the reclrc Inlet nozzle thermal sleeve, Note B would apply. Please clarify how BWR Vessel Internal Program manages reca inlet thermal sleeves.

212 3.1.1-47-P-01 In many cases (beginning on page 3.1-56), component types are managed using water chemistry control - BWR and not the ISI program. Please provide the basis for excluding them from the ISI program.

Edit from 511112006 email-In many cases (beginning on page 3.1-56),

component types are managed using water chemistry control - BWR alone for loss of materiaL Please provide the basis for excluding them from the ISI program.

213 3.1.1-48-P-02 On page 3.1-73, the component type tank (CRD accumulator)' Is managed using water chemistry control - BWR, One-time inspection. It is not clear that the tank Is <NPS4, so ISI would seem a more appropriate AMP for verification (and a different GALL Item may be a more useful reference).

The recirc inlet thermal sleeve Is a match for the jet pump assembly thermal sleeve In NUREG-1 801 Item IV.B1-13, so Note B could be applied to that portion of this line for cracking. However, the core spray thermal sleeve does not match and Note D was selected to conservatively cover both component types. As described in the response to question 3.1.1-43-P-01, the comparison Is equally valid with the selection of either Note B or D.

Revised Answer to Revised Question -The recik inlet thermal sleeve is a match for the Jet pump assembly thermal sleeve In NUREG-1801 Item IV.B1 -

13, so Note B could be applied to that portion of this fine for cracking.

However, the core spray thermal sleeve does not match and Note D was selected to conservatively cover both component types. NUREG-1801 Item IV.B1-7 could also have been referenced for the core spray thermal sleeve with a Note B and credit for the same programs. As described In the response to question 3.1.1-43-P-01 the comparison Is equally valid with the selection of either Note B or D.

Appendix B of the application Identifies some exceptions to the NUREG-1801 description of the BWR Vessel Internals Program; however, none of these exceptions are related to the reckrc Inlet (let pump assembly) thermal sleeve.

The VYNPS BWR Vessel Internals Program management of cracking for the reckrc Inlet thermal sleeve Is consistent with the NUREG-1 801 program that Is credited In Item IV.B1-13 for this component.

Page 3.1-56 is the beginning of the reactor vessel iernals (Table 3.1.2-2).

In general the reactor vessel Internals are not code parts and are not Included In the Inservice Inspection Program. This is discussed in Item 3.1.1-47 In Table 3.1.1 of the LRA.

Even In cases lke the shroud support. where the components are considered code parts, the BWRVIP provides the approved inspections for these components. Those Inspections are Implemented by augmenting the inservice Inspection program, but the BWR Vessel Internals program is credited as the controlling program.

The One-Time Inspection Program as described In LRA Appendix B, Section B.1.21, Includes all piping and valves <4" NPS. The CRD accumulators are Included In this program. While they are slightly larger than 4", they are connected to the RCS by long runs of 1 Inch piping and are therefore treated with that smali bore piping.

The CRD accumulators are not reactor coolant pressure boundary parts.

Each drive has two accumulators, one of which is filled with nitrogen and the other with part nitrogen and part water, These components are not subject to ISI. Consequently, Water Chemistry Control augmented by One-Time Inspection Is the best option.

Closed Closed Closed 2...

214 3.1.1-48-P-03 On page 3.1-63, the component type 'condensing chambers' Is managed using water chemistry control - BWR, One-time Inspection. Please confirm that this component Is <NPS4 215 3.1.1-49-P-01 On page 3.1-62, the component type 'shroud support, ring, cylinder. and legs, access hole cover Is managed using BWR vessel internals, water chemistry control. BWR. For the access hole cover plate, GALL recommends ISI and water Chemistry. Please Identify the specific Inspection(s) for tlts component under the RVI program.

Extended question from meeting on 6M27/06. VY credits the BWR vessel Internals program for managing the access hole covers, but the NRC Is not aware of any BWRV1P document that addresses the access hole covers.

Please clarify how VYNPS manages the access hole covers.

The One-Time Inspection Program Includes all piping and valves <4e NPS.

The Instrumentation condensing chambers on the main steam flow elements are Included In this program. While they may be slightly larger than 41, they are connected by 1 Inch Instrum-ent piping and are treated with that small bore piping.

These chambers are not subject to other Inspections such as ISI.

POTENTIAL RAI VY performed a VT In 1995 and 1996, a MVT' In 1998, and an EVT1 In 1999 and 2002. Additional EVT1 Inspections are scheduled for 2008 and 2009.

[Appendix A of PP 7027] The examination coverage Includes the entire weld surface, In addition to the heat-affected zones.* [Sac 4.3 of NE 8067]

Section 4.3 of NE 8067 is reproduced below. It requires that the access hole covers be examined by EVT-1.

4.3 Access Hole Cover Welds - The access hole cover welds shall be examined by the EVT 1 method.

There are two oval access hole cover welds, located at 0 and 180 degrees.-

They are designated as 0-AHC and 180-AHC. The GTAW portion Is Inconel Alloy 82 and the SMAW portion Is Inconel Alloy 182. Note that because these are nickel based welds, the required examination coverage includes the entire weld surface, in addition to the heat affected zones.

See drawing 5920 253 License Renewal Commitment #34 LRA Amendment The Inservice Inspection program is used to manage cracking of this Class I bolting since these components are required to be Inspected in accordance with ASME Section X1 IWB requ~rements. A Boling Integrity Program Is under development (commitment #34) that will address the agIng management of boing In the scope of lcense renewal Including the bolwing Identified In this line item. The GALL Boiling Integrity Program XILM1 8 states that the ASME Section XI Inservice Inspection Program XI.M1 supplements the Boiling Integrity Program. GALL line item OVAI-9) Identified In the LRA for comparison Is for BWR high-strength low-alloy steel closure studs and nuts exposed to air with an aging effect of cracking. A review of GALL Chapter IV Identified no other BWR closure boiling line items exposed to air with cracking as an aging effect. Therefore this line IRem was selected as the appropriate comparison and will remain the appropriate comparison with the Inclusion of the Bo"ling Integrity Program.

NUREG-1801 Item IV.B1-11 also applies. The resulting note would be Note A.

0 Closed Accepted 216 3.1.1-50-P-01 On page 3.1-36, the component type 'other pressure boundary bolting, flange bolls and nuts (N6A, N68, NT), CRD flange cap-screws and washers' Is managed using Inservice Inspection. Please confirm that the new Bolting Integrity AMP will be applied to this item, and Identify a more appropriate GALL Item.

217 3.1.1-51-P-01 On page 3.1-60, the component type ']et pump castings, transition piece Inlet elbow/ nozzle, mixer flange and flare, diffuser collar Is managed using thermal aging embrittlement of CASS. Please cofmir that IV.B1-1 I also applies.

Accepted Closed

Accepted 218 3.1.1-52-P-01 On page 3.1-36. the component type incore housing bolting, flange bolts.

flange nut and washer Is managed using Inservice Inspection. Please confirm that the new Bolting Integrity AMP will be applied to this hem, and Identify a more appropriate GALL Item.

Ucense Renewal Commitment U34 LRA Amendment Revised answer for 5/11/2006 email -A Bolting integry Program Is under development (commitment #34) that will address the aging management of bolting In the scope of license renewal Including the bolting Identified In this line item. In addition, the InservIce Inspection Program Is used to manage cracking of this Class 1 bolting since these components are required to be Inspected In accordance with ASME section )a IWB requirements. The GALL Bolting Integrity Program XI.M18 states that the ASME Section XI Inservice Inspection Program XLM1 supplements the Bolting Integrity Program. The GALL line hem (IV.A2-6) Identified in the LRA for comparison is for stainless steel flange bolting exposed to air with an aging effect of cracking. A review of GALL Chapter IV identified no BWR stainless steel bolting line hems exposed to air with cracking as an aging effect. Therefore this line item was selected as the appropriate comparison.

A Bolting Integrity Program Is under development that wil address the aging management of bolting In the scope of license renewal Including the bolting Identified In this line item. The Inservice Inspection program is used to manage cracking of this Class I bolting since these components are required to be Inspected in accordance with ASME section XI IWB requirements. The GALL Boling Integrity Program XI.MI 8 states that the ASME Section Xl Inservice Inspection Program XI.Mt supplements the Bolting Integrty Program. The GALL line item (IV.A2-6) Identified in the LRA for comparison is for stainless steel flange boiting exposed to air with an aging effect of cracking. A review of GALL Chapter IV Identified no BWR stainless steel boting line Items exposed to air with cracking as an aging effect. Therefore this line Item was selected as the appropriate comparison and will remain the appropriate comparison with the inclusion of the Bolting Integrity Program.

Pump casing and cover - The VYNPS ISI program is a plant-specific program, not compared to the GALL Xt.M1 program. Therefore, Note E was applied wherever the ISl program was called for In GALL Note that earlier on this same page. WCC and ISI are used to manage loss of material and Note A Is used - that Is because GALL only requires water chemistry and the use of ISI here is over and above what GALL requires.

For valve bodies <4" NPS - GALL manages reduction of fracture toughness (ROFT) using ISI, however, ISI only requires Inspections of valves bodies

>-4" NPS. Therefore, the OTI (small bore piping) program is used to mange ROFT for these small valves.

Valve bodies >=4* NPS - The VYNPS ISI program Is a plant specific program, not compared to the GALL XI.M1 program. Therefore. WNPS applied Note E wherever the ISI program was Identified In GALL 219 3.1.1-55P-01 On page 3.1-71. the component type 'pump casing and cover (RR)' Is managed using inservice inspection. On page 3.1-75, the component type

'valve bodies <4" NPS' is managed using one-time inspection. On page 3.1-79, the component type Valve bodies >-4* NPS' Is managed using Inservice Inspection. Please clarify the basis, in each case, for asserting that the AMP used is different from the one suggested by GALL Closed

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4 220 3.1.1-57-P-01 On page 3.1-72, the component type 'restrilcons (ms)' is managed using one-lime inspection. Please describe how OI satisfies the recommendations of GALL AMP XI.M12, Thermal Aging Embrltliement of CASS.

221 3.3.1-03-K-01 On page 3.3-91, the component type bieat exchanger (tubes)' Is managed using water chemistry control. BWR. Please confirm that the VYNPS Water Chemitry - BWR AMP addresses fouling In heat exchanger tubes.

GALL program YJ.M1 2 Is applicable to primary pressure boundary and reactor vessel internals components' and the main steam flow restrictors are neither. As the main steam flow restrtctors are not ASME pressure boundary components, program )U.M12 Is not applicable. Thermal aging embrittlement results In Increased rates of crack growth, which are evidenced by cracidng In the material. The One-Time Inspection Program will be used to verify that reduction of fracture toughness has not progressed to the point that unacceptable cracking of the component has occurred.

As stated In LRA Section 3.3.2.22. reduction of heat transfer due to fouling for stainless steel heat exchanger tubes exposed to treated water Is managed by the Water Chemistry Control - BWR Program. The effectiveness of the Water Chemistry Control-SWR Program will be confirmed by the One-Time Inspection Program through an inspectlon of a representative sample of components crediting this program Including areas of stagnant flow.

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4 222 3.3.1-0S-K-01 On page 3.3-74, the component type 'heat exchanger (tubes) ' Is managed using water chemistry control - BWA. GALL recommends a plant-specific program. Please clarify how each of the attrbltes of SRP-LR Appendix Al Is addressed by a purely preventive program.

Edit from 5/11/2006 email - On page 3.3-74, the component type heat exchanger (tubes)' Is managed using water chemistry control - BWR. GALL recommends a plant-specific program. Please clarify how this component Is addressed by a purely preventive program.

SRP-LR Appendix Al Is applicable to purely preventive programs. In fact, Closed Section A.1.2.3.3, Item 4, states, "For prevention and mitigation programs, the parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects. An example Is the coolant oxygen level that Is being controlled in a water chemistry program to mitigate pipe cracldng."

As stated In LRA Section 8.1.30.2. the Water Chemistry Control - BWR Program Is consistent with the program described In NUREG-1 801.Section XI.M2. Water Chemistry.' The One-Time Inspection Program, described in IRA Section B.1.21 includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxdliary Systems, Water Chemistry Control - BWR. and Water Chemis Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated In LRA Section B.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described in NUREG-1801,Section XI.M32. One-Trrre Inspection.'

The 10 attributes of SRP-LR Appendix Al for the Water Chemistry Control -

BWR Program and the One-Time Inspection Program are the same as the attributes of the NUREG-1 801 programs XI.M2 and X.M32.

Added Response to 5/11M2006 email -

Page 3.3-74 has multiple line Items for heat exchanger (tubes) managed using Water Chemistry Control - BWR. The response assumes this question refers to the line Item for cracking of heat exchanger (tubes) since this line Item references NUREG-1 801 Item VILE3-3 which recommends a plant-specftc program.

As stated In IRA Section B.1 30Z the Water Chemistry Control - BWR Program optimizes the primary water chemistry to minimize the potential for lose of material and crackdng. This Is accomplished by limiting the levels of contaminants In the RCS that could cause loss of material and cracking.

Additionally. VYNPS has instituted hydrogen water chemistry (HWC) with noble metals to limit the potential for Intergranular SOC (IGSCC) through the reduction of dissolved oxygen In the treated water is consistent with the program described In NUREG-1 801.Section XI.M2, 'Water Chemistry.' The One-Time Inspection Program, described In LRA Section B.1.21 includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems. Water Chemistry Control - BWR. and Water Chemit Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling is not occurring.

223 3.3.1-13-K-01 On page 3.3-9Z the component type 'neutron absorber (bore!)' Is managed using water chemnisliy control -BWR. GALL recommends a plant-spectfc program. Please clar"fy how each of tie attrtbutes of SRP-LR Appendix Al Is addressed by a parely preventive program.

Edit from 5/11/2006 email -On page 3.3-92, the component type 'neutron absorber (boral)' Is managed using water chemistry control - BWR. GALL recommends a plant-specific program. Please clarify how this component Is addressed by a purely preventive program.

Page 3.3-92 has multiple line items for neutron absorber (bore!) managed Closed using Water Chemistry Control - BWR. The response assLumes this question refers to the line Item for loss of material for neutron absorber (boral) since this line Item references NUREG-1 801 item VI.A2-3 which recommends a plant-specific program.

SRP-LR Appendix Al Is applicable to purely preventive programs. In fact, Section A.1.2.3.3, Item 4, states, 'For prevention and miigatlon programs, the parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects. An example Is the coolant oxygen level that is being controlled In a water chemistry program to mitigate pipe cracking.*

As stated in LRA Section 8.1.30.Z the Water Chemistry Control - BWR Program is consistent with the program descrtbed in NUREG-1801,Section XI.M2, Water Chernlstry.* The One-Time Inspection Program, described in LRA Section B.12.21 Includes Inspections to verity the effectiveness of the water chemistry control aging management programs (Water Chemist Control - Auxliary Systems, Water Chemistry Control - BWR, and Water Chemistr Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated In LRA Section 8.1.21. the One-Time Inspection Program Is a new program which will be consistent with the program described In NUREG-1 801,Section XI.M32, "One-Time Inspection."

The 10 attributes of SRP-LR Appendix Al for the Water Chemistry Control -

BWR Program and the One-Time Inspection Program are the same as the attributes of the NUREO-1 801 programs XI.M2 and XI.M32.

Added Response per 5/11/2006 erali As stated In LRA Section 8.1.302, the Water Chemistry Conrol - BWR Program optimizes the primary water chemistry to minimize the potential for loss of material and cracklng. This Is accomplished by limiting the levels of contaminants in the RCS that could cause loss of material and cracking.

Additionally. VYNPS has instituted hydrogen water chemisby (HWC) with noble metals to limit the potential for Intergranuar SCC (IGSCC) through the reduction of dissolved oxygen in the treated water is consistent with the program described In NUREG-1801,Section XI.M2, 'Water ChemistV. The One-Time Inspection Program, described In IRA Section B.121 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring.