ML062850258
| ML062850258 | |
| 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: ML062850258 (75) | |
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Pat From:
"Hamer, Mike" <mhamer@entergy.com>
To:
"Jonathan Rowley" <JGR@nrc.gov>
Date:
Mon, Sep 18, 2006 4:48 PM
Subject:
VY LR D-Base Rev. 4 - Part 2 of 2
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VY LR D-Base Rev. 4 - Part 2 of 2 Mon, Sep 18; 2006 4:46 PM "Hamer, Mike" <mhamer@entergy.com>
mhamer@entergy.com Recipients nrc.gov TWGWPO03.HQGWDOO1 JGR (Jonathan Rowley)
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"7 224 3.3.1-14-K-01 In many cases, beginning on page 3.3-61 for auxiliary systems, component types exposed to oil are managed using the oil analysis program. Please confirm that the VYNPS Oil Analysis AMP Is consistent with GALL XI.M3Z
- One-Time Inspection,' as well as with XI.M39, 'Lubricating O4 Analysis.*
LRA Amendment As stated in LRA Section 3.2.2.7. steel piping and components in auxiliary systems at VYNPS that are exposed to lubricating oil are managed by the Oil Analysis Program, which includes periodic sampling and analysis of lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment that Is not conxducve to corrosion. As stated In IRA Section B.1.20, the Ol Analysis Program Is consistent with the program described in NUREG-1801,Section XI.M39, Lubricating Oil Analysis, with a minor exception.
The Oil Analysis Program Is not consistent with GALL XI.M32. 'One-Time Inspection,' nor are one-time inspections necessary to verify the effectiveness of the program. Metals are not corroded by the hydrocarbon components of lubricants. Lubricating oils are not good electrolytes and the oil film on the wetted surfaces of components tend to minimize the potential for corrosion. Corrosion in lube onl systems only occurs as the result of the presence of Impurities or moisture. Therefore, an effective oil analysis program, which maintains Impurities and moisture below specified Umits, precludes the need for one-time inspactions. Operating experience at VYNPS has confitmed the effectiveness of the Oil Analysts Program in maintaining moisture and Impurities within limits such that corrosion has not and wilt not affect the intended functions of these components.
In numerous past precedents (including NUREG-1828, Arkansas Nuclear One Unit 2 SER, Section 3.0.3.3.6, and NUREG-1831, Donald C. Cook SER0 Section 3.0.3.3.8), the staff concluded that an effective oil analysis program, which maintains impurities and moisture below specified limits, is sufficient to demonstrate that the effects of aging will be adequately managed so that the Intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
The One-Time Inspection program will be revised to include activities to confirm the effectiveness of the Oi Analysis and Diesel Fuel Monitoring programs.
Accepted
49 225 33.1-20-K-01 Beginning on page 3.3-166, many component types are managed using the diesel fuel monitoring program. Please cornrm that the VYNPS Diesel Fuel Monitoring AMP is consistent with GALL XI.M32, One-Tire Inspection.' as well as with XI.M30, 'Fuel Oil Chemlst*y.
LRA Amendment As stated In LRA Section 3,2.2.9, loss of m'aterial due to general, pitting, crevice, and MIC for carbon steel piping and components exposed to fuel oil Is managed by the Diesel Fuel Monitoring Program. This program Includes sampling and monitoring of fuel oil quality to ensure levels of water, particulates, and sediment remain within the specified limbs. Maintaining parameters within rinm ensures that slgniflcant loss of material will not occur. Ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate will be performed to confirm the effectiveness of the Diesel Fuel Monitoring Program. As stated In LRA Section B.1.9. the Diesel Fuel Monitoring Program Is conslstent with the program described In NUREG-1 801. Section XJ.M3, Fuel Oil Chemistry Program, with minor exceptions.
The Diesel Fuel Monitoring Program Is not consistent with GALL XI.M32,
- One-TIme Inspection," nor are one-time Inspections necessary to verify the effectiveness of the program. The Diesel Fuel Monitoring Program Includes periodic cleaning, visual Inspection, and ultrasonic inspection of storage tank bottoms where water and contaminants accumulate to confirm the effectiveness of the oil quality monitoring activites to preserve an environment that Is not conducive to corrosion The One-lime Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
This requires and amendment to the LRA.
Accepted a
- 1 226 3.3.1-21-K-01 On page 3.3-106, the component type heat exchanger (bonnet)'; on page 3.3-141. the component type Iheat exchanger (shell'; and an page 3.3-78, the component type 'heat exchanger (shel)' are managed using the oil analysis program. Please confirm that the VYNPS Oil Analysis AMP Is consistent with GALL XI.M32, 'One-Time Inspection," as well as with XI.M39. "Lubricating Oil Analyss."
LRA Amendment Accepted As stated In LRA Section 3.2.2.7. steel piping and components In auxiliary systems at VYNPS that are exposed to lubricating oil are managed by the Oil Analysis Program. which includes periodic sampling and analysts of lubricating oin to maintain contaminants within acceptable rlmits, thereby preserving an environment that Is not conducive to corrosion. As stated In LRA Section B.1.20, the Oil Analysis Program Is consistent with the program described In NUREG-1801.Section XI.M39, Lubricating Oil Analysis, with a minor exception.
The O5 Analysis Program is not consistent with GALL XI.M32, "One-Tlme Inspection," nor are one-time Inspections necessary to verify the effectiveness of the program. Metals are not corroded by the hydrocarbon components of lubricants. Lubicating oils are not good electrolytes and the oil film on the wetted surfaces of components tends to minimize the potential for corrosion. Corrosion In lube oil systems only occurs as the result of the presence of Impurities or moisture. Therefore, an effective oil analysis program, which maintains Impurities and moisture below specified limits.
precludes the need for one-tlime Inspections. Operating experience at VYNPS has confirmed the effectiveness of the Oil Analysis Program in maintaining moisture and Impurities within rrnits such that corrosion has not and will not affect the Intended functions of these components.
In numerous past precedents (including NUREG-1828, Arkansas Nuclear One Unit 2 SER, Section 3.0.3.3.6, and NUREG-1 831. Donald C. Cook SER, Section 3.0.3.3.8). the staff concluded that an effective oil analysis program.
which maintains impurities and moisture below specified limits, Is sufficient to demonstrate that the effects of aging will be adequately managed so that the intended furictions will be maintained consistent with the current licensing basis for the period of extended operation.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oi Analysis and Diesel Fuel Monitoring programs.
-D CAD
41 Accepted 227 3.3.1-23-K-01 Beginning on page 3.3-221, component types exposed to treated water are managed using water chemistry control -BWR. Please confirm that the VYNPS Water Chemistry - BWR AMP is consistent with GALL XI.M32, 'One-Time Inspection," as well as with X)a12, Water Chemistry."
LRA Amendment As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR program is consistent with the program described In NUREG-1 801,Section XI.M2, 'Water Chemistry." The One-Time Inspection Program. described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR. and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated in LRA Section B.1.21, the One-Time Inspection Program Is a new program which will be consistent with the program described in NUREG-1 801.Section XI.M32, One-Tima Inspection.'
LRA Tables 3..1, 3.2.1,3.3.1, and 3.4.1 Indicate that the One-Time Inspection Program Is credited along with the water chemistry control programs for line items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program is listed. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, It Is also applicable to each line item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chem"isy 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 -Auxil*ary Systems, BWR and Closed Cooling Water programs to explicly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
11 228 3.3.1-25-K-01 On page 3.3-65. the component type, beat exchanger (tubes)' and on page 3.3.
129. the component type 'heat exchanger (lubes)' are managed using service water Integrity. GALL recommends a plant-spectfic program. Please clarify how each of the attibutes of SRP-LR Appendix Al is to be addressed for this hem.
Ed*t from 51 1Q2006 email - On page 3.3-65, the component type 'heat exchanger (tubes)' and on page 3.3-129, the component type 'heat exchanger (tubes)' are managed using service water integrity. GALL recommends a plant-specIflc program. Please clarify how service water Integrity program manages this Rem.
Page 3.3-129 has multiple tne items for heat exchanger (tubes) managed using Service Water Integrity. The response assumes this question refers to the line Item for loss of material for heat exchanger (tubes) exposed to external condensation managed using Service Water integrity since this line item matches the line item on page 3.3-65 for heat exchanger (tubes) managed using Service Water Integrity.
These tine hems are for reactor building recirculation unit coolers, which are enclosed housing air-handling units with copper cooling colts (tubes). Saw water flows through the copper tubes, white external surfaces of the tubes are exposed to condensation.
Consistent with NUREG-1 801 line Item VII.C1-3. loss of material on the Internal surfaces of these copper heat exchanger tubes Is managed by the Service Water Integrity Program. The Service Water Integrity Program, in accordance with NRC GL 89-13, Includes a condition and performance monitoring program which Inspects components for erosion, corrosion, and blockage and verifies the heat transfer capability of safety-related heat exchangers cooled by service water. Therefore, this program Is equally as effective at managing loss of material on the external surfaces of the heat exchanger tubes as It Is at managing loss of material on the internal surfaces of the tubes. However, the line items in question were compared with NUREG 1801 item VII.FI-16 (which recommends a plant-specIfic program) because NUREG 1801 Section ViI.C1 does not address the external surfaces of copper alloy heat exchanger tubes containing raw water.
As stated In LRA Section B.1.26, the Service Water Integrity Program Is consistent with the program described In NUREG-1 801,Section XI.M20.
"Oper-Cycte Cooling Water System,* with minor exceptions.
The 10 attlbutes of SRP-LR Appendix Al for the Service Water Integrity Program are described In the Aging Management Program Evaluation Results (AMPER) Report, which Is available for on-site review.
Closed
229 3.3.1-26-K-01 Beginning on page 3.3-80, the components exposed to fuel oil are managed using the onl analysis program. Please confirm that the VYNPS Diesel Fuel Monitoring AMP Is consistent with GALL XI.M32, One-Tke Inspection., as well as with XI.M30, 'Fuel 01 Chemistry.'
Edit from 5/ 112006 ernall -Beginning on page 3.3-80, the components exposed to lube oll are managed using the Oil Anaysis program. Please confirm that the VYNPS Oil Anatysis AMP is consistent with GALL XI.M32, "One-TIme Inspection,' as wet as with XI.M39, "Lube Oil Chem"sty.,
LRA Amendment Accepted As stated in LRA Section 3.2.2.9, loss of material due to general, pitting, crevice, and MIC for carbon steel piping and components exposed to fuel oil Is managed by the Diesel Fuel Monitoring Program. This program Includes sampling and monitoring of fuel oil quality to ensure levels of water, particulates, and sediment remain within the specified limits. Maintaining parameters within limits ensures that significant loss of material will not occur. Ultrasonlc Inspection of storage tank bottoms where water and contaminants accumulate will be performed to confirm the effectiveness of the Diesel Fuel Monitoring Program. As stated in LRA Section B.1.9, the Diesel Fuel Monitoring Program Is consistent with the program described In NUREG-1801,Section XI.M3, Fuel O0 Chemistry Program, with minor exceptions.
The Diesel Fuel Monitoring Program Is not consistent with GALL XI.M32,
'One-Time Inspection, nor are one-time Inspections necessary to verify the effectiveness of the program. The Diesel Fuel Monitoring Program includes periodic cleaning, visual Inspection, and ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate to confirm the effectiveness of the oil quality monitoring activities to preserve an environment that Is not conducive to corrosion.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
230 3.3.1-27-K-01C On page 3.3-69, the component type 'suction barrar is managed using service water Integrity. GALL recommends a pLant-specefic program. Please claitfy how each of the attributes of SRP-IR Appendix AI Is addressed for this item.
Page 3.3-69 has multiple line items for suction barrel managed using Service Closed Water Integrity. The response assumes this question refers to the line item for loss of material for suctin barrel with an external environment of condensation since this lOne iRem references NUREG-1801 item VII.FI-which recommends a plant-specific program.
These Oine Items are for residual heat removal service water pump suction barrels which are made of AL6XN which Is a type of stainless steel that Is highly resistant to corrosion. The suction barrels are in contact with raw water Intemally and condensation externally.
As can be seen In the other suction barrel line item, consistent with NUREG-1801 line item VlI.C1 -15, loss of material on the Internal surfaces of the suction barrel is managed by the Service Water Integrity Program. The Service Water Integrity Program, In accordance with NRC GL 89-13, includes a condition monitoring program which Inspects components such as pump barrels for erosion, corrosion, and blockage. Since the external environment of condensation Is much milder than the Internal enviroinment of raw water, this program Is equally as effective at managing loss of material on the external surfaces of the suction barrels as it is at managing loss of material on the Internal surfaces of the barrels. However, the line item In question was compared with NUREG 1801 item VII.F1-1 (which recommends a plant-specific program) because NUREG 1801 Section VII.C1 does not address the external surfaces of stainless steel components containing raw water.
As stated In LRA Section B.1.26, the Service Water Integrity Program Is consistent with the program described in NUREG-1 801,Section XI.M20, "Open-Cycle Cooling Water System. with minor exceptions.
The 10 attributes of SRP-LR Appendix Al for the Service Water Integrity Program are the same as the 10 attributes of the program described In NUREG-1801,Section XI.M20 with the exceptlons described In LRA Appendix B. Section 0.1.26
231 3.3.1-28-K-01 On page 3.3-102, the component type aw" body' Is managed using Instrument air quality. Please clarify how the effectiveness of the IAQ program is to be verified.
Page 3.3-102 has multiple line Items for valve body managed using Closed Instrument Air Ouartly. The response assumes this question refers to loss of material for both copper atloy and stainless steel valves exposed to treated air on Internal surfaces.
As stated In LRA Section 8.1.16. the Instrunent Air Quality Program maintains humidity and partilcuates within acceptable limits, thereby preserving the environment of treated air that is not conducive to corosion.
Actions to verify the effectliveness of the program are not necessary.
Corrosion In treated air systems only occurs as the result of the presence of impurities or moisture. Therefore, an effective instrument air quality program.
tinlch maintains Impurities and moisture below specified limits, precludes the need for Inspections. Operating experience at VYNPS has confirmed the effectiveness of the Instrument Air Quality Program in maintaining moisture and Impulties within limits such that corrosion has not and will not affect the Intended functIons of these components.
In a previously approved staff position (NUREG-1 831, Donald C. Cook SEA, Section 3.0.3.3.7), the staff concluded that an effective Instrument air quality program, which maintains impurities and moisture below specified lmits, Is sufficient to demonstrate that the effects of aging will be adequately managed so that the Intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
In another precedent (Millstone SER, Section 3.3B.2.3.12 and NUREG-l 839.
Point Beach SER. Section 3.2.2.3.1), on the basis of Its review of current Industry research and operating experience, the staff concluded that air on metal will not result In aging that will be of concern during the period of extended operation. The staff considers a dried air environment benign and that Its contact with carbon steel, low-alloy steel, stainless steel, and cast stainless steel surfaces will not result In aging effects.
232 3.3.1-30-K-01 Beginning on page 3.3-1, the component types exposed to treated water are managed using water chemistry control - BWR. Please confirm that the VYNPS Water Chemistry - BWR AMP Is consistent with GALL XI.M32, 'One-Time Inspection," as well as with XI.M2, "Water Chemistry.'
LRA Amendment As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program Is consistent with the program described In NUREG-1 801,Section XI.M2. 'Water Chemlstryý. 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 - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. As stated In LRA Section 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.'
LRA Tables 3.1.1, 3.2.1, 3.3.1. and 3.4.1 Indicate that the One-Time Inspection Program is credited along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. For simpicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program is reted. However, since the One-Time Inspection Program Is applicable to each water chemistry control program, It is also applicable to each line hem that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemist Control -Auxiliary Systems, SWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities wIll confirm the effectiveness of these programs.
Accepted Co 10(0
233 3.3.1-31-K-01 On page 3.2-50 In ESF and page 3.3-146 In auxiliary systems, component types exposed to treated water are managed using water chemistry control -
BWR. Please confirm that the VYNPS Water Chemistry -BWR AMP Is consistent with GALL XI.M32, "One-Time Inspection,' as well as with XI.M2,
'Water Chemistry."
LRA Amendment As stated In LRA Section B.1.30.2, the Water Chemistry Control - BWR Program Is consistent with the program described In NUREG-1801,Section XI.M2, 'Water Chemistry." The One-Time Inspection Program. described In IRA Section B.1.21 IncWudes 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 matertal, and fouling Is not occurring. As stated In LRA Section 6.1.21, the One-Time Inspection Program is a new program which will be consistent with the program described In NUREG-1 801.Section XI.M3Z 'One-Time Inspection.
IRA Tables 3.1.1,3.2.1 3.3.1, and 3.4.1 Indicate that the One-Time Inspection Program Is credited Wong with the water chemistry control programs for line Items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However. since the One-Time Inspection Program Is applicable to each water chemistry control program, It Is also applicable to each line Item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -AuxilIary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
Partial Duplicate of next question.
LRA Amendment That Is correct. The NUREG-1801 Vol. 2 Item should be VI-F1-8 ratherthan V1ILF1-8 for these lines.
Accepted 234 3.3.1-51-K-01 On page 3.3-132, the component type 'pipig' Is managed using water chemistry control - auxillary systems. Please confirm that GALL v2 Item VII.F1-8 Is Intended (not *II1.F1-8).
235 3.3.1-51-K-01 On page 3.3-131. the component type 'hurnildfier housing' and on page 3.3.
132, the component type 'piping' Is managed using water chemistry control -
auxiliarysystems. Please confirm that GALL v2 Item VII.F1-8 is ihended (not VIII.F1-8).
Closed Accepted
236 3A.1-M-01 In IRA Table 3.4.1, Item Number 3.4.1-22. the applicant states that their existing 'System Walkdown Program%...:manages the loss of material for steel bolting through the use of visual Inspectlons...". How does the applicant Intend to address the potential loss of bolting material for subject bolting (nonnally flange bolting) that cannot be readily seen - "visually Inspected"-
since most such bolting Is usualy covered by insulationltlashing material?
Added Edit from s 112006 emall - Note: See generic question 2.
237 3.4.1-M-02 In reference to Question 3.4.1-1 above. It Is the staffs present understanding that the applicant currently Intends to develop a "GALL.recommended" bolting integrity program. If such a program Is eventually developed, will It Include inspections of plant condensate and feedweaer system bolting; Le., specirfally flange bolting?
Closed As stated In LRA Section B.1.28, the System Walkdown Program Is consistent with the program descn'bed in NUREG-1i801,Section XI.M36.
'Extemal Surfaces Monitoring.' In accordance with this program descrition.
surfaces that are Insulated are Inspected when the external surface Is exposed (I.e., maintenance) at such Intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their Intended function during the period of extended operation.
EPRI aging assessment field 1007933 guide was reviewed by the staff.
Ucense Renewal Commitment #34 IRA Amendment A Bolting Integrity Program Is under development that will address the aging management of bolting In the scope of license renewal Including In scope flange bolting for the feedwater and condensate systems.
Accepted
238 3.4.1-M-03 The staff has recently discovered-during the Api VYNPS AMP audit-that plant main condenser tubing contains an adnmrlty brass-type of material which contain copper & zinc. Such material:- copper & zinc -has been known to leach out of condenser tubing via either by direct raw water erosion of the Inside of the condenser tubes and/or by way of phenomena known as
- de-zincification." Recent third-party chemist.ycontrol audits of VYNPS have presented evidence that both copper and zinc Ions are currently leaching out of the main condenser tubing and have been leaching out at a measurable rate for the last five (5) years. However as noted In VYNPS LRA Table 3.4.1, Item Number 3.4.1-35. the applicant stated that; '..Othere are no copper alloy components subject to selective leaching In the steam and power conversion systems...* What does the applicant intend to do to reduce and/or eliminate the apparent measurable and continued leaching out of copper and zinc ions from the main condenser tubing? What does the applicant intend to do to eliminate and/or mitigate the Introduction of these Ions (primealy the copper Ions) into the reactor core areas of the plant?
Edit from 5/11/2006 email - The staff has recently discovered - during the April VYNPS AMP audit -that plant main condenser tubing contains an admiralty brass-type of material which contains copper & zinc. Such material
-copper & zinc - has been known to leach out of condenser tubing via either by direct raw water erosion of the Inside of the condenser tubes and/or by way of phenomena known as dezincification.
Recent third-party chemrtry control audits of VYNPS have presented evidence that both copper and zinc Ions are currently leaching out of the main condenser tubing and have been leaching out at a measurable rate for the last five (5) years. However, as noted In VYNPS IRA Table 3.4.1, Iem Number 3.4.1-35. the applicant stated that '....there are no copper alloy components subject to selective leaching in the steam and power conversion systems...* What does the applicant Intend to do to reduce and/or eliminate the apparent measurable and continued leaching out of copper and zinc ions from the main condenser tubing? What does the applicant Intend to do to efiminate and/or mitigate the Introduction of these Ions (primarily the copper ions) Into the reactor core areas of the plant?
LRA Table 3.4.1, Item Number 3.4.1-35 states that a Selective Leaching Program Is not applicable because there are no copper alloy components subject to selective leaching in the steam and power conversion systems.
This statement was Intended to mean that there are no copper alloy components requiring an aging management review that are subject to selective leaching in the steam and power conversion systems.
A summary of the aging management review of the main condenser may be seen In LRA Table 3.4.2-1. As shown in this table and explaned In plant-specific note 401, aging management of the main condenser Is not based on analysis of materials, environments and aging effects. Condenser Integrity required to perform the post-accident Intended function (holdup and plate-out of MSIV leakage) Is continuously confirmed by normal plant operation. This Intended function does not require the condenser to be leak-Utght, and the post-accident conditions in the condenser will be essentially atmospheric.
Since normal plant operation assures adequate condenser pressure boundary Integrity, the post-accident Intended function to provide holdup volume and plate-out surface Is assured. Previously approved staff positions (NUREG-1796, Dresden and Quad Cities SER, Section 3.4.2.4.4, and NUREG-1769. Peach Bottom SER. Section 3A..2.3). concluded that main condenser Integrity Is continually verified during normal plant operation and no aging management program is required to assure the post-accident Intended function.
Therefore, loss of material due to leaching of copper and zinc Ions from the main condenser tubing Is not an aging effect requiring management for the condenser tubes.
Leaching of copper and zinc ions from the main condenser tubing Is also not a license renewal Issue related to aging of other components managed by the Water Chemistry Control - SWR Program and exposed to the copper and zin ions from the condenser. BWRVIP-130. BWR Vessel Internals Project BWR Water ChemIst Guidelines - 2004 Revision, states that an assessment of risk to the fuel should be completed If feedwater copper values are above 0.1 ppb based on a quarteriy average, or It zinc values are above 0.4 ppb based on a quarterly average. These recommendations are followed by VYNPS and there have been no fuel fallures attribued solely to elevated feedwater copper or zinc in the last 20 years. Since the fuel Is periodically replaced, it Is not subject to aging management review.
Therefore, leaching of copper and zinc ions from the main condenser tubing Is not a license renewal Issue related to aging of fueL The leaching of zinc Ions from the condenser has actually been beneficial in that it has helped to mitigate out-of-core dose rates. In fact, many BWRs are Injecting zinc into the feedwater system to control out-of-core dose rates.
VYNPS is plamning to start zinc Injection towards the end of 2006. Zinc also has a synergistic beneficial effect along with hydrogen water chemistry resulting In Increased resistance of stainless steel and other alloys to intergranular stress corrosion cracking OGSCC).
Closed BWRViP-130 also states that since soluble copper acts as a cathodic reactant like dissolved oxygen, copper can exacerbate corrosion
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=.
3 0.
phenomenon such as IGSCC. However, VYNPS Injects low levels of hydrogen In a Noble metal environment to mitigate IGSCC by keeping stainless steel electrochemical potential (ECP) values less than -230 mV relative to the standard hydrogen electrode. VYNPS has made significant efforts to reduce the amount of copper entering the reactor over the past 10 years. Where cycle average feedwater copper was once around 0.8 ppb, It Is now near 0.3 ppb. Feedwater copper vraues for the first 4 moths of 2006 were <0.2 ppb.
Since VYNPS Is maintaining ECP values In the desired range and has maintained feedwater copper levels as low as achievable, VYNPS is following BWRVIP guidance for feedwater copper. No other Impacts of hligh copper 0
and zinc levels were identified In BWRVIP-130. Plant procedures assure that VYNPS will continue to follow BWRVIP guidance for water chemistry.
Therefore. further action Is not necessary to address leaching of zinc and copper from condenser tubing for the period of extended operation.
VYNPS technical justification for continued operation of Entergy Northwest.
Vermont Yankee (ENVY) with feedwater copper >0.2 ppb revision tl was reviewed by the staff.
239 3.42-M-01 The staff has recently discovered. In the applicant's LRA. 'Auxisary Systems.
Miscellaneous Systemse Tables 3.3.2-13-02 and 3.32-13-13, that the applicant Intends to use their existing Water Chemistry Control (BWR)
Program to control loss of material In their condensate and feedwaater systems; I.e., loss of material In carbon steel piping subjected to steam temperatures >220 degrees F. For these systems, the GALL recommends the Implementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitigate loss of material in system piping.
Does the applicant Intend to implement a One-lime Inspection Program as well as their existing Water Chemisty Control Program to both identify and mitigate the loss of material in their condensate and feedwater systems? If yes, does the applicant Intend to formally produce a commitment to Implement both programs? If the applicant does not intend to Implement both a One-Time Inspection and Water Chemistry Control Program. why not?
Edit from 5/11/2006 email - The staff has recently discovered, in the appcant's LRA, "Auxlliary Systems -Miscellaneous Systems! Tables 3.3.2 02 and 3.32-13-13, that the applicant Intends to use their existing Water Chemistry Control (BWR) Program to control loss of material in their condensate and feedwater systems; Le.. loss of material in carbon steel piping subjected to steam temperatures >220 degress F. For these systems, the GALL recommends the Implementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitigate loss of material in system piping. Does the applicant intend to Implement a One-Time Inspection Program as well as their existing Water Chemistry Control Program to both Identify and mitigate the loss of material In their condensate and feedwater systems? If yes, does the applicant Intend to formally produce a commitment to implement both programs? If the applicant does not Intend to Implement both a One-Time Inspection and Water Chemistry Control Program, why not?
License Renewal Commitment #16 LRA Amendment LRA Table 3.3.1 Indicates that the One-Time Inspection Program Is credited along with the water chemistry control programs for rine items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table Zs) do not list the One-Time inspection Program each time a water chemistry control program Is fisted.
However, since the One-Time Inspection Program Is applicable to each water chemistry control program, it Is also applicable to each line item that credits a water chemistry control program.
To provide further clarificatIon, the effectiveness of the Water Chemistry Control -Auxiliary Systems, BWR, and Closed Cooling Water programs is confirmed by the One-lime Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for te Water Chemistry Control -Auxiliary Systems. BWR and Closed Coorlig Water programs to explicltly state One-Tlime Inspection Program activities will confirm the effectiveness of these programs.
Also, license renewal commitment 16 has been issued to implement the One-Tame Inspection Program as described in IRA Section B.1.21. A commltment to implement the Water Chemistry Control - B1WR Program Is not necessary as this Is an existing program, which does not require enhancement AccePted
240 3.4.2-M-02 The staff has recently discovered, In the applicant's LRA. Table 3.4.2-1; 'Main Condenser and MSIV Leakage Pathway - Heat Exchanger Tubes," that the applicant Intends to use their existing Water Chemistry Control (BWR)
Program to control any loss of material In stainiess steel (SS) condenser tubes; Le., loss of material in SS piping (tubing) subjected to steam temperatures >270 degrees F. For these systems and any future modified systems, the GALL recommends Inplementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitlgate loss of material In system piping (tubing). Does the applicant intend to Implement a One-Time Inspection Program as well as their existing Water Chemistry Control Program to both Identify and mitigate loss of material from any future modified heat exchanger tubing that could contain stainless steel that could be subjected to steam (or high temperature and high pressure water) temperatures >270 degrees F? If yes, does the applicant intend to formally produce a commitment to Implement both piograms? If the applicant does not Intend to Implement both a One-Time Inspection and Water Chemistry Control Program for future. modified condensers, why not?
Edit from S1 1/2006 Email - The staff has recently discovered, in the applicant's LRA, Table 3.4.2-1: 'Main Condenser and MSIV Leakage Pathway
- Heat Exchanger Tubes," that the applicant intends to use their existing Water Chem%"r Control (BWR) Program to control any loss of material in stainless steel (SS) condenser tubes; Le., loss of material In SS piping (tubing) subjected to steam temperatures >270 degrees F. For thess systems and any future modified systems, the GALL recommends Implementation of both a Water Chemistry Control AND a One-Time Inspection Program to Identify and mitigate loss of material in system piping (tubing). Does the applicant Intend to Implement a One-Time Inspection Program as well as their existing Water Chemistry Control Program to both identify and mitigate loss of material from any future modified heat exchanger tubing that could contain stainless steel that could be subjected to steam (or high temperature and high pressure water) temperatures >270 degres F? If yes. does the applicant Intend to formally produce a commitment to Implement both programs? If the applicant does not intend to Implement both a One-Time Inspection and Water Chemistry Control Program for future, modified condensers, why not?
Ucense Renewal Commitment #16 LRA Amendment LRA Table 3.4.1 Indicates that the One-Time Inspection Program is credited along with the water chemistry control programs for line Items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2's) do not list the One-Time inspection Program each time a water chemistry control program Is listed.
However, since the One-Time Inspection Program is applicable to each water chemistry control program, It is also applicable to each line Item that credits a water chemistry control program.
To provie further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -Auxifiary Systems, BWR and Closed Cooing Water programs to expr-city state One-Time Inspection Program activities will confirm the effectiveness of these programs.
Also, license renewal commitment 16 has been Issued to Implement the One-Time Inspection Program as described In LRA Section B.1.21. A commitment to Implement the Water Chemistry Control - BWR Program is not necessary as this Is an existing program, which does not require enhancement.
Accepted
I 241 3.4.2-M-03 The staff has recently discovered, In the appiantrs LRA. Table 3.3.2-13-9; "Circulating Water System," that the aPplicant Intends to use their existing Periodic Surveillance and Periodic Maintenance (PSPM) Program to control
- loss of material In their circulating water condenser tubing (interior); I.e.. loss of material In copper alloy material (>15% zinc) subjected to raw water conditions. For this system, the GALL recommenda the Impiementation of an Open-Cycle Cooling Water Control Program to Identify and mitigate loss of material in system piping. Does the applicant intend to Implement only the PSPM Program to both Identify and mitigate loss of material In the main condenser tubes rather than a "GALL-recommended' Open-Cycle Cooling Water Control Program? If yes, does the applicant Intend to formally produce a commitment to modify and Implement the PSPM Program for control of material loss from the main condenser tubing? If the applicant does not Intend to Implement both a PSPM and 'GALL-recommer:ded" Open-Cycle Cooling Water Control Program, why not?
Edit from 5/1112006 email -The staff has rcety discovered, In the applicants LRA, 'Table 3.3.2-13-9; "Circulaing Water System," that the applicant Intends to use their existing Periodc Surveillance and Periodic Maintenance (PSPM) Program to control loss of material in their circulating water condenser tubing (interior); I.e., loss of mhterlal In copper alloy material
(>15% zinc) subjected to rwwater coriditions. For this system, the GALL recommends the Implementation of an Open-Cycle Cooling Water Control Program to identify and mitigate loss of material In system piping. Does the applicant Intend to Implement only the PSPM Program to both Identify and mitigate loss of material In the main condenser tubes rather than a 'GALL-recommended* Open-Cycle Cooling Water Control Program? If yes, does the applicant intend to formally produce a commitment to modify and Implement the PSPM Program for control of material loss from the main condenser tubing? It the applicant does not Intend to implement both a PSPM and
'GALL-recommended" Open-Cycle Cooling Water Control Program, why not?
242 3.5.1-13-W-1 In Table 3.5.2-1 on Page 3.5-50 of the LRA, for component Bellows (reactor vessel and drywea, one of the AMPs shown Is Ctl-rWE, which Is a plant.
specific AMP. A Note C has been asslged to this AMR lie Item, component Is different, but consistent with material, environment, aging effect, and aging management program for NUREG-1801 line item. AMP Is consistent with NUREG-1801 AMP description. Provide drawings showing how the LRA line item bellows are different from the GALLTable I Une Item 3.5.1-13 bellows.
Explaln how the plant-specilfi VYNPS CII-IWE AMP Is consistent with the GALL specified AMP.
LRA Table 3.3.2-13-9 does contain a fine Item for loss of material In copper alloy tubing subjected to raw water conditions. However, this line item does not represent the circulating water condenser tubing. Rather, it represents copper alloy Instrument tubing In the circulating water system In cooling tower NZ cell I that requires aging management review due to potential spatial interaction.
A summary of the aging management review of the main condenser may be seen In IRA Table 3.4.2-1. As shown In this table and explained In plant.
specific note 401, VYNPS does not intend to Implement an aging management program for the main condenser.
Aging management of the main condenser Is not based on analysis of materials, environments and aging effects. Condenser integrity required to perform the post-accident intended fuinction (holdup and plate-out of MSIV leakage) Is continuously confirmed by normal plant operation. This intended function does not require the condenser to be leak-tight. and the post-accident conditons In the condenser will be essentially atmospheric, Since normal plant operation assures adequate condenser pressure boundary Integrity, the post-accident Intended function to provide holdup volume and plate-out surface Is assured. Previously approved staff positions (NUREG-1796, Dresden and Cuad Cities SER. Sectlon 3.4.2.4.4. and NUREG-1769.
Peach Bottom SER, Section 3.4.2.3), concluded that main condenser integrity is conti*uvaly verified during normal plant operation and no aglng management program Is required to assure the post-accldent Intended functon.
LRA Amendment Table 3.52-1 on Page 3.5-50 of the IRA, for component Bellows (reactor vessel and dryweli) Is not consistent with the referenced NUREG-18ol Vol. 2 Item. The Table 3.5.2-1 line item 'Bellows (reactor vessel and dryweli)" and the corresponding line item In Table 2.4-1 should be deleted. The reactor vessel and drywell bellows perform no license renewal intended functio.
These components are not safely-related and are not required to demonstrate compliance with regulations Iderntlfed In 10 CFR 54.4(a)(3).
Failure of the bellows will not prevent satisfactory accomplishment of a safety function. Leakage, If any, through the bellows Is directed to a drain system that prevents the leakage from contacting the outer surface of the drywall shell.
Closed Accepted
243 3.5-1-16-W-1 In Table 3.5.2-1 on page 3.5-54 of the LRA for component Drywall floor liner seal, the AMP shown Is Structures Mon"toi.
The applicant Is asked to verify that the CIt-fWE AMP will not be used Instead to manage the aging of the moisture barrier.
LRA Amendment The aging management actty will be the same whether Included under the uimbrella of the Structures Monitoring Program or under the umbrella of the CII-fWE Program, For clarification, the CiI-IWE Program will manage the effects of aging on the moisture berier through the period of extended operation. Note E remains the correct note since the CII-IWE Program Is plant specific. The IRA will be amended as follows:
Table 3.5.2-1 will be updated to reflect the AMP as CII-IWE Table line Item 3.5.1-16 will be updated to read:
'The aging effects cited In the NUREG-1 801 Item are loss of seaeing and leakage. Loss of sealing Is a consequence of the aging effects cracking and change in material properties.
For VYNPS, the Containment Leak Rate Program manages cracking end change In material properties for the primary containment seal and gaskets.
The Inservice Inspection -IWE manages cracking and change In material properties for the primary containment moisture barrier."
Also see Response 476 LRA Amendment Table 3.5.2-6 on Page 3.5-80 of the LRA, for component seals and gaskets (doors, manways and hatches), material rubber in a protected from weather environment the aging effects are cracking and change in material properties. The LRA will be clarified to indicate that Note A applies to the line for SMP.
RAI 3.6.2.2.N-08 The Vernon Dam FERC Inspection Program was described as a plant.
specific program in Appendix B of the application because there Is no program description in NUREG-1l801. As a plant-specific program, we selected Note E. Note A would be an acceptable alternative.
Accepted 0.
=r 0
(D 0
n 244 3.5.1-44-W-1 In Table 3.5.2-8 on Page 3.5-80 of the IRA, for comporent seals and gaskets (doors, manways and hatches), material ribber In a protected from weather environment; the aging effects are cracking and change in material properties. One of the aging management programs shown is Structures Monitoring. The GALL fine item referenced Is IIL.A8-12 and the Table I reference Is 3.5.1-44. The note shown Is E, different AMP than shown In GALL However, GALL Une Item III.A6-12 and Table 1 Une Item 3.5.1-44 both specify the Structures Monitoring Program. Explain why the note shown Is not A Instead of E for the lower half of this AMR line item.
245 3.5.1-45-W-1 In Table 3.52-5 on Page 3.5-67 of the IRA, for component Vernon Dam external walls above/below grade, material concrete In an exposed to flild enviroment; the AMP shown Is Vernon Dam FERC Inspection. The referenced GALL line item for at three environments is III.A6-7. GALL Une Item II1.A6-7 states the following under AMP: Chapter XI.S7, "Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power PLants or the FERCAJS Army Corp of Engineers dam inspections and maintenance programs. Since one of the AMPs under this GALL line Item Is FERC dam inspections, explain why the note assigned to the LRA AMR line item Is E Instead of A; consistent with GALL Accepted Closed
246 3.5.1-47-W-1 In Table 3.5.2-5 on Page 3.5-66 of tie LRA, for component Vernon Dam structural steel, material carbon steel In an exposed to weather, protected from weather, and exposed to fluid environment the AMP shown Is Vernon Dam FERC Inspection. The referenced GALL line Item for all tliee ervironmentsls I1.A6-11. GALL Une Item III.A6-1I states the following under AMP: Chapter XI.S7, *Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants' or the FERC/US Army Corp of Engineers dam inspections and maintenaice programs. Since one of the AMPs under this GALL line Item Is FERC dam Inspections, explain why the note assigned to the three LRA AMR line Items Is E instead of A; consistent with GALL 247 3.5.1-68-W-t In Table 3.5.2-6 on Page 3.5-71 of the LRA, for component conduit, material galvanized steel In a protected weather environment the aging effect is none.
The GALL line Item referenced Is III.B2-5, which Is for the following components: Support members; welds; boited connections; support anchorage to biliding structure. Explain why the LRA AMR line Item has a Note A shown Instead of a Note C, different component with respect to the GALL [be Item. Or as an aitemative, a letter Note A with a number note explaining that the componerrt Is different.
248 3.5.1-58-W-2 In Table 3.52-6 on Page 3.5-72 of the LRA. for component electrical and Instrument panels and enclosures. materiel galvanized steel In a protected from weather environment the aging effect Is none. The GALL iOne Item referenced Is LII.B3-3, which Is for the following components: Support members; welds; bolted connections; support anchorage to building structure.
Explain why the IRA AMR tine item has a Note A shown instead of a Note C.
different component with respect to the GALL line item. Or as an alternative, a letter Note A with a number note explaining that the component Is different.
RAI 3.6.2.2.N-08 The Vernon Dam FERC Inspection Program was described as a plant.
specific program In Appendix B of the application because there Is no program description In NUREG-1801. As a plant-specific program, we selected Note E. Note A would be an acceptable alternative.
NUREG-1801 does not mention every type of component that may be subject to aging management review (e.g., conduit is not In NUREG-1801) nor does the terminology used at a specific plant always align with that used In GALL Consequently, matching plant components to NUREG-1801 components Is occasionally subjective. In this particular case, conduit, which has no specific funotion other than to support and protect cable, was considered a support member and Note A was applied. The use of either Note A or C has no real impact on the aging management review results.
LRA Amendment NUREQ-1801 does not mention every type of component that may be subject to aging management review (e.g.. panel Is not In NUREG.1801) nor does the terminology used at a specific plant always align with that used In GALL Consequently, matching plant components to NUREG-1 801 componerds Is occasionatfy subjective. In this particular case, panels, which have no specific function other than to support and protect electrical equipment, was considered a support member and Note A was applied. The use of either Note A or C has no real impact on the aging management review results.
Note 'A' will be changed to Note 'C for component electrical and Instrument panels and enclosures, material galvanized steel In a protected from weather environment In Table 3.5.2-6 on Page 3.5-72 of the LRA. No change Is required to the other entries for this line Item.
IRA Amendment Unitie the conduits and panel compared to supports In questions 3.5.1 W-1 and W-Z the component flood curb should not have been considered a match. Note C should be applied here: although the use of either Note A or C has no real Impact on the aging management review results.
Note A will be changed to Note "C" for component flood curb, material galvanized steel In a protected from weather environment in Table 3.5.2-6 on Page 3.5-73 of the IRA. No change is required to the other entries for this line Item.
Closed Closed Accepted 24g 3.5.1-58-W-3 in Table 35.2-6 on Page 3.5-73 of the LRA, for component flood curb, material galvanized steel In a protected from weather environment the aging effect is none. The GALL fine Item referenced Is 1112l5-3, which Is for the following components: Support members; welds; bolted connections; support anchorage to building structure. Explain why the LRA AMR line Item has a Note A shown Instead of a Note C. diferent component with respect to the GALL line item. Or as an alternative, a letter Note A with a number note explaining that the component Is different.
Accepted
250 3.5.1-8-W-1 In Table 3.5.2-1 on Page 3.5-53 of the LRA for component Torus shell with the aging effect cracking-fatigue, the note assigned is F. Note E Is consistent with NUREG-I 801 material, environment, and aging effect but a different aging management program Is credited. Explain why this note Is E when the AMP shown for this line Item Is TLAA and the referenced GALL Line Item II.B1.1-4 also specifies a TLAA.
251 3.5.2-2-W-1 In Table 3.5.2-2 on Page 3.5-57 of the LRA, for component Spent fuel pool storage racks, material stainless steel In an exposed to fluid environment; the aging effect Is Iess of material. Explain by what aging mechanism Irss.of material occurs and why the aging effect is not cracking.
252 3.5.2-4-W-1 In Table 3.5.2-4 on Page 3.5-61 of the LRA, for component Blowout or blow-off panels, material aluminum In an exposed to weather environment; the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting &nd drying conditions.
253 3.5.2-4-W-2 In Table 3.5.2-4 on Page 3.5-61 of the LRA, for component Steel Piles, material carbon steel in an exposed to weather environment; the aging effect Is none. Note 504 discusses steel piles driven into sonis (a sot environment, not a weather environment) with no significant effects due to corrosion.
Explain how the soil environment relates to the weather environment to justify no aging effect.
254 3.5.2-&W-1 In Table 3.5.2-5 on Page 3.5-65 of the LRA, for component N2 tank steel supports, material stainless steel in an exposed to weather ernvironment; the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
255 3.5.2-5-W-2 In Table 3.5.2-5 on Page 3.5-65 of the IRA. for component Transmission towers, material galvanized steel in an exposed to weather environment the aging effect is none. Reference question A-W-13 and explain how this component Is protected from constant wettling and drying conditions.
LRA Amendment Note A should be appied here. The LRA will be amended to indicate Note A.
As shown In Table 3.5.2-2, the aging effect for component spent fuel pool storage racks Is loss of materiaL The specific aging mechanism is pitting and crevice corrosion because stainless steels are susceptible to this aging mechanism when exposed to oxygenated water in a treated water envlronment Cracking Is not an aging effect requiring management for stainless steel in the spent fuel pool because cracking due to stress corrosion is dependent on temperature (>140'F). The spent fuel pool treated water environment Is less than 1401F.
As Identified In the response to question A-W-13. loss of material due to pitting and crevice corrosion of aluminum components in an outdoor environment Is not applicable If the amonspheric environment Is non-aggressive. Plant-spectfic Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result in signtiicant loss of material In aluminum components, hence, them are no aging effects requiring management As Identified In Table 3.5.2-4 on Page 3.5-61 of the LRA, for steel piles, material carbon steel In an exposed to weather environment the aging effect Is none. Although a soil environment is not Identified, the listed environment, exposed to weather, Is Intended to Include both an above grade environment and a below grade environment as described In Table 3.0-2 of the application. The below grade environment applies to the steel piles. As such the statement made in Note 504 is applicable.
As Ident[ed in the response to question A-W-13, loss of material due to pitt"ng and crevice corrosion of stainless steel components In an outdoor environment is not applicable if the atmospheric environment is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment is non-aggressive. In this non-aggressive environment the occasional wetting and drying from normal outdoor weather does not result in significant loss of material In stainless steel components, hence, there are no aging effects requiring management LRA Amendment As Identified In the response to question A-W-13. loss of material Is the aging effect requiring management and the Structures Monitoring Program Is the aging management program. This Is consistent NUREG-1 801 Vol. 2 Item III.B4-7, summarized In Table 1 Item 3.5.1-50, and Note C applies.
Accepted Closed Closed Closed Closed Accepted
256 3.5.2-5-W-3 In Table 3.5.2-5 on Page 3.5-67 of the MRA, for component Vernon Dam external walis, floor slabs and Interior waifs, material concrete In a protected from weather environment; the aging effect shown Is none wi the AMP shown as Vernon Dam FERC Inspection. VYNPS discusses throughout Its "LRA Section 3.5 further evaluations that VYNPS concrete does not have aging effects because the quality of the concrete used during construcction was to the standards of ACI-318 and ACI 201.2R. Vernon Darn Is a very old structure and was not built by the owners of VYNPS. Provide documentation and justification that the quality of the concrete used at Vernon Dam Is also to the sitandar-ds of ACI-318 and ACI 201.R such that the AMR statement None for aging effects of the Dam concrete Is Justified.
257 3.5.2-8-W-1 In Table 3.5.2-6 on Page 3.5-71 of the LRA, for component conduit, material galvanlzed steel In an exposed to weather environment the aging effect Is none. Reference question A-W-1 3 and explain how this component Is protected from constant wetting and drying conditions.
258 3.5.2-6-W-2 In Table 3.5.2-6 on Page 3.5-71 of the LRA, for component conduit support,"
material gaivanized steel In an exposed to weather environment the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
259 3.5.2-6-W-3 In Table 3.5.2-6 on Page 3.5-72 of the LRA, for component electrical and Instrument panels and enclosures, material galvanized steel In an exposed to weather environment; the aging effect Is none. Reference question A-W-1 3 and explain how this component Is protected from constant wetting and drying conditions.
260 3.5.2-6-W-4 In Table 3.5.2-6 on Page 3.5475 of the LRA, for component Vents and louvers.
material aluminum In an exposed to weather environment the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
RAI 3.6.2.2.N-08 Since quality of concrete used at Vernon Dam has not been confirmed, it would have been more appropriate to show for the associated aging effects for the line items In question. However, the same aging management
- activi, the FERC Inspection, Is still appropriate to manage aging effects associated with the Vernon Dam concrete components.
LRA Amendment As Identified in the response to question A-W-13. loss of material Is the aging effect requiring management and the Stirutures Monitoring Program Is the aging management program. This Is consistent NUREG-1 801 Vol. 2 Item II.B4-7. summarized In Table 1 Item 3.5.1.50, and Note C applies.
IRA Amendment As Identified In the response to question A-W-13, loss of material Is the aging effect requiring management and the Structlres Monitoring Program Is the aging management program. This Is consistent NUREG-1 801 VoL 2 item 111.B4-7, summarized In Table 1 Item 3.5.1-50, and Note C applies.
LRA Amendment As Identified In the response to question A-W-13, loss of material is the aging effect requiring management and the Structures Monitoring Program Is the aging management program. This Is consistent NUREG-1801 Vol. 2 Item 111.B4-7, summarized In Table 1 Item 3.5.1-50, and Note C applies.
As Identified In the response to question A-W-13, loss of material due to pitting and crevice corrosion of aluminum components In an outdoor environment Is not applicable if the atmospheric environment Is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result In significant loss of material In aluminum components, hence, there are no aging effects requiring management Closed Accepted Accepted Accepted Closed
261 3.5.2-6-W-5 In Table 3.5.2-6 on Page 3.5-76 of the LRA. for component Anchor bolts, material stainless steel In an exposed to weather environment; the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
262 3`5.2-6-W-6 In Table 3.5.2-6 on Page 3.5-78 of the LRA, for component structural bolting, material stainless steel In an exposed to weather envfronment the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
263 3.5.2-&-W-7 In Table 3.5.2-6 on Page 3.5-78 of the LRA, for component structural bolting, material galvanized steel In an exposed to weather environment the aging effect Is none. Reference question A-W-13 and explain how this component Is protected from constant wetting and drying conditions.
264 3.5.2-6-W-8 In Table 3.5.2-6 on Page 3.5-80 of the LRA, for component water stops.
material PVC In a protected from weather ernvironment; the aging effect Is none. By definition the component stops water, so t could be exposed to water. In IRA Table 3.5.2-4 on Page 3.5-64 for component Cooling tower fill, material PVC, environment exposed to fluid environment the aging effects listed are cracldng and change In material properties. Provide a technical basis why PVC water stops do not have any aging effects which need aging management when they could be exposed to a fluid environment also.
Provide the specification that called for PVC water stops during construction Instead of rubber.
265 3.5.2-&-W-9 In Table 3.5.2-6 on Page 3.5-78 of the IRA, for component Fire proofing.
material Pyrocrete In a protected from weather environment: the aging effect Is none. Provide a technical basis why Pymcrete does not have any aging effects In the environment listed.
Closed As Identified In the response to question A-W-13. loss of material due to pitting and crevice corrosion of stainless steel components in an outdoor environment Is not applicable If the atmospheric environment Is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggressive environment, the occasional wetting and drying from normal outdoor weather does not result in slgnflcant loss of material In stainless steel components, hence, there are no aging effects requiring management As identified In the response to question A-W-13. loss of material due to pitting and crevice corrosion of stainless steel components In an outdoor environment Is not applicable If the atmospheric environment Is non-aggressive. Plant-specific Note 503 provides the basis for concluding the environment Is non-aggressive. In this non-aggresslve environment, the occasional wetting and drying from normal outdoor weather does not result In slgnificant loss of material In stainless steel components, hence, there are no aging effects requiring management.
IRA Amendment As Identified In the response to question A-W-13, loss of material is the aging effect requiring management and the Structures Monitoring Program Is the aging management program. This Is consistent NUREQ.1 801 Vol. 2 Item IIt.B4-7, summarized In Table 1 Item 3.5.1-50, and Note C applies.
The PVC water stops identified In Table 3.5.2-6 on Page 3.5-80 of the IRA are used In the cooling tower reinforced concrete basin and are not exposed to the same environment as the cooling tower fill material. Therefore the aging effects are not the same. The aging effects attributed to PVC water stops are evaluated based upon Section 7.0 of the Structural Tools. Exposure to water for these commodities Is insignificant. since the concrete encapsulating the PVC water stop and the protection provided by the surrounding concrete, provides ample protection such that aging management Is not required. USFAR Fig 12.2-33 (0-200357) 'Cooling Tower No. 2 Basin Plan View' identifies the use of PVC water stops at VYNPS.
Pyrocrete (used for fire proofing) Is cement base composite material.
Pyrocrete is not Identified In NUREG-1 801. As such, our technical evaluation of pyrocrete In determining applicable aging effects was the same as that for concrete which Is based on EPtI 1002950. Aging Effects for Structures And Structural Components (Structural Tools), Revision 1, Section 5.
Accordingly, no aging effects were determined for pyrocrete protected from weather. However, as Indicated In Table 3.5.2-6 on Page 3.578 of the LRA, the Fire Protection Program and Structures Monitoring Program will confirm the absence of significant aging effects throughout the period of extended operation.
0 0)
(D.
03
-n I
Closed Accepted Closed Closed
Accepted I
286 A-W-01 LRA Table 3.5.1, Item Number 3.5.1-5, has the following statement under the discussion coklmn: The drywell steel where the drywe shell is embedded Is Inspected in accordance with the Containment Inservice Inspection (IWE)
Program and Structures Monitoring Program. This Is an impossible Inspection. Change this discussion statement to agree with LRA Section 3.52.2.1.4 that states: The dywell steel shell and the moisture barrier where the drywell shell becomes embedded In the drywell concrete floor are Inspected In accordance with the Containment Inservice Inspection (IWE)
Program and Stnutucks Monitorlng Program.
LRA Amendment For LRA Table 3.5.1, hem 3.5.1-5. the discussion column should read. 'The drywell steel shell and the moisture barrier where the drywell shell becomes embedded kI the drywell concrete floor are Inspected In accordance with the Containment Inservlce Inspection (NME) Program. To be consistent. LRA Section 3.5.2.2.1.4, should indicate that the drywell to floor moisture barrier will be Inspected under the Containment Inservice Inspection (IWE)
Program. The Inspection is part of the Containment InservIce Inspection (IWE) Program and will be retained as part of that program through the period of extended operation. The IRA will be amended as stated by formal correspondence.
267 A-W-02 IRA Table 3.5.1, Item Number 3.5.1.9, has the folowing statement tinder the discussion column: Not applicable. See Section 3.5.221.8. However, the following statement Is made in LRA Section 3.5Z2.1.6: 'Fatigue TLAAs for the steel drywell. torus, and associated penetrations are evaluated and documented In Section 4.6.' The components associated with LRA Table 3.5.1. Item Number 3.5.1-9 are: penetration sleeves, penetration bellows; suppression pool shell, unbraced downcomers. Explain how Item number 3.5.1-9 Is not applicable when a fatigue TLAA has been performed for the torus and penetrations. Explain why the vent line, vent header and vent line bellows are not listed In LRA Sections 3.5.2.1.6 and 4.6 as referenced In Table 3.5.1, Une Item 3.5.1-8.
LRA Amendment The LRA will be amended to reflect the following changes. Fatigue analyses have been evaluated for the torus, drywell to torus vent system, and torus penetrations. The following line for the torus penetrations will be added to Table 3.52-1:
Torus mechanical penetrations PB, SSR Carbon steel'Protected from weather Cracking (fatigue) TILAA-metal fatlguetlI.B4-4 (0-13) 3.5.1 9A The evaluation of the drywell to torus vent system fatigue analysis determined that it was not a TLAA. The significant contributor to fatigue of the vent system is post-LOCA chugging, a once In plant-life event. As there will still be only one design basis LOCA for the life of the plant. Including the period of extended operation, this analysis Is not based on a time-limited assumption and is not a TLAA. Since fatigue for the vent system Is event driven and Is not an age related effect, the following rune will be deleted from Table 3.5.2-1:
Drywell to torus vent system PB, SSR Carbon steel Protected from weather Cracking (fatigue) TLAA-metal fatiguenll.B1.1-4 (C-21) 3.5.1 8 A The discussion column entry for Table 3.5.1 Item 3.5.1-8 will be changed to
- state, Fatigue analysis is a TLAA for the torus shell. Fatigue of the torus to drywell vent system Is event driven and the analysis Is not a TLAA. See Section 3.5.22-1.6.
The discussion column entry for Table 3.5.1 Item 3.5.1-9 will be changed to stater Fatigue analysis is a TLAA for the torus penetrations. See Section 3.5.2.2.1.6.
Section 3.5.2.2.1.6 will be changed to read as follows:
TLAA are evaluated in accordance with 10 CFR 54.21(c) as documented In Section 4. Fatigue TLAAs for the torus and associated penetrations are evaluated and documented In Section 4.6.
Section 3.52.3. Time-Limited Aging Analyses, will be changed to state:
TLAA Identified for structural components and commodities Include fatigue analyses for the torus and torus penetratims. These topics are discussed in Section 4.6.
Accepted
268 A-W-03 LRA Table 3.5.1. Rem Number 3.5.1-12, under the discussion column, does not make reference to LRA Section 15.2.2.1.8 for further evaluation. Explain why this link is not made to the further evaluation section. Explain the need for a*ugmented ultrasonic exams to detect fine cracks since a CLB fatigue analysis does exist.
269 A-W04 IRA Table 3.5.1, Item Number 3.5.1-13. under the discussion column, does not make reference to LRA Section 3.5.22.1.8 for further evaluation. Explain why this rink is not made to the further evaluation section. Explain the need for augmented ultrasonic exams to detect tine cracks since a CL fatigue analysis does exist 270 A-W-05 LRA Table 3.5.1, Item Number 3.5.1-16, under the discussion column, states that seals and gaskets are not included In to Containment lnservfce Inspection Program at VYNPS. One of the components for this item number Is moisture barriers. Explain how VYNPS seals the joint between the containment drywall shell and drywell concrete floor Uf there Is no moisture barner. Explain why the inspection of this Joint is not part of the Containment Inservtce Inspection Program at VYNPS.
LRA Amendment A link from Rems 3.5.1-12 and 3.5.1-13 wilt be added to section 3.5.2.2.1.8.
Section 3.5.2.2.1.8 should state.
Cyclic loading can lead to cracking of steel and stainless steel penetration bellows, and dissimilar metal welds of BWR containments and BWR suppression pool shell and downcomers.
Cracking due to cyclic loading Is not expected to occur In the drywel., torus and associated penetration bellows, penetration sleeves, unbraced downcomere, and dissimilar metal welds. A review of plant operating experience did not Identify cracking of the components, and primary containment leakage has not been Identified as a concern. Nonetheless the existing Containment Leak Rate Program with augmented ultra sonic exams and Containment Inservice Inspection - IWE. will continue to be used to detect cracking. Observed conditions that have the potential for Impacting an intended function are evaluated or corrected In accordance with the corrective action process. The Containment Inservice Inspection - IWE and Containment Leak Rate programs are descried in Appendix B.
IRA Amendment See response to Item 268.
LRA Amendment VYNPS uses a moisture barner to seal the joint between the containment drywell shell and drywall concrete floor. Moisture barrier Is listed In LRA table 3.5.2-1 as drywell floor liner seal. Aging effects on the drywall moisture barrier will be managed Linder the C IiWE program (also see audit question 3.5.1-16-W-1 above).
For clarity, drywleil floor liner seal will be changed to drywell shell to floor seal (moisture barrier). (Also see audit questions #76 and 243 which address changes to the LRA)
Accepted 5.
M;3 1-
-0 N) 01 "nl 9
Accepted Accepted
271 A-W-06 IRA Table 3.5.1, Item Number 3.5.1-17, under the discussion column, states that locks, hinges, and closure mechanisms are active components and are therefore not subject to an aging management review. Provide any license renewal regulatory guidance document or previous IRA NRC SER that has ever stated that locks, hinges, and closure mechanisms are active components. If locks, hinges. and closure mechanisms are active components at VYNPS, provide an Itemized list of these active components with their qualifted life or specifled time period of replacermet Explain how VYNPS tracks the active life of these components before replacement 272 A-W-07 IRA Table 3.5.1. Item Number 3.5.1-21, under the discussion column, states that VYNPS plant operating experence has not Identified fretting or lock up due to mechanical wear for the drywall head and downcomers. Plant operating experience does not find fretting or lock up due to mechanical wear, inspections do. Explain If VYNPS does not currently Inspect for wear of the drywell head and downcomer pipes under the CLB using the Containment Inservice Inspection Program. If WNPS does currently Inspect these components for wear, justify not performing these same Inspections during an extended license period. If required, provide drawigs showing the spacial distance between components such that fretting cannot occur.
It may be a misnomer to refer to these components as active components since 10CFR54.21 (e)(1)() does not refer to active or passive components, but rather excludes components from aging management review that perform an Intended function, as described In § 54.4, with moving parts or with a change In configuration or properties. Locks, hinges, and closure mechanisms perform their functions with moving parts.
This exception Is not based on a qualified life or specified time period of replacement for a component. 10CFR54.21(a)(1)(ii) provides a separate exclusion for components that are replaced based on a qualified life.
Other precedents for locks, hinges, and closure mechanisms as active components that have received approval by the NRC are found In Peach Bottom(NUREO 1769, Section 3.0.3.142 Pg 3-58) and Millstone (NUREG 1838, Section 3.3A.2.1.4 Pg 3-245)
Condition reports are a primary source of operating experience documentation reviewed for license renewal. Condition reports document negative inspectlon results. NUREG-1 801 defines neither fretting nor lockup and further confuses the subect by stating that fretting and lockup are caused by mechanical wear which Is an aging mechanism resulting in the aging effect loss of material. The definition in NUREG-1 801,Section IX.E, merely states that fretting and lockup Is an aging effect along with a cause, but doesn't say what it Is or what it looks like. As indicated In the line Item for drywell head In Table 3.5.2-1. the Containment Inservice Inspection-IWE Program and the Containment Leak Rate Program manage loss of material.
Loss of material Is the aging effect caused by mechanical wear. VYNPS Inspects the drywell head and downcomers (Torus vent system) per the requirements of ASME Section XI.
In addition, the drywall head is a stationary or fixed component and the downcomers are stationary, wela-braced components and the spatial distance between connecting components makes it unlikely for fretting and lockup to occur.
The NUREG-1 801 referenced programs Involve visual Inspections and leak testing which are not optimum methods for managing SCC. Therefore, when possible, it is more appropriate to assess the conditions and Identify whether the applicable aging effects require management. As stated In Section 3.52.2.1.7. stress conrsion cracking is not an aging effect requiring management for the penetration sleeves and bellows, since the conditions necessary for SOC do not exist.
However these components are evaluated for other aging effects requiring management, such as cracking, as shown In Table 3.5.2-1.
Closed Closed 273 A-W-08 LRA Table 3.51. Item Number 3.5.1-11. Wuder the discussion column, states that cracking due to stress corrosion cracking for stainless steel vent line bellows is not applicable. Explain If the VYNPS Containment Inservice Inspection Program and Containment Leak Rate Program are used currently to detect cracking of stainless steel vent line bellows by Inspection and testing. Explain why It Is not more appropriate to take credit for these two programs to detect cracking without the need for additional enhanced examinations then to say not applicable.
Closed
274 A-W-09 LRA Table &5.1, Item Number 3.5.1-26, under the discussion column, states that freeze-thaw Is not an applicable aging mechanism for these groups of strut at VYNPS. Provide documentation showing the weathering conditions (weathering Index) for VYNPS and the specification requiring concrete to have an air content of 3% to 6% and water to cement ratio of 0.35 to 0.45.
275 A-W-10 For LRA Table 3.5.1. Item Number 3.5.1-27, provide documentation showing that Inaccesmile areas concrete was constructed In accordance with the recommendations In ACI 201.2R-77.
276 A-W-11 For LRA Table 3.5.1, Item Number 3.5.1-33. provide the maximum temperatures that concrete experiences In Group I through 5 structures.
277 A-W-12
[Folow-up Question]
The applicant Is asked to verify that there are no non-metallic (rubber) v'bration Isolation elements used to structurally support the emergency diesel generator. HVAC system equipment, and miscellaneous mechanical equipment end that all vibration isolation to systems attached to these components Is by expansion joints and flexble connections.
[Original Question]
LRA Table 3.5.1. Item Number 3.5.1-41, under the discussion column, states that no vibration Isolation elements at VYNPS are In scope and subject to aging management review. Explain the lack of vibration Isolation elements for HVAC system components, the emergency diesel generator and miscellaneous mechanical equipment VYNPS Inaccessible and accessible concrete areas are designed In accordance with American Concrete Institute (ACI) specification ACI 318-63.
Buitdlng Code Requirements for Reinforced Concrete. VYNPS concrete also meets requirements of later ACI guide ACt 201.2R-77. Guide to Durable Concrete, since both documents use the same American Society for Testing and Material (ASTM) standards for selection. application and testing of concrete.
VYNPS concrete was provided with air content between 3% and 5% and a water/cement ration between 0.44 and 0.60 (Pet. VYNPS site specification EBASCO 15-65, Sections 7.0 and 12.5). WNPS Is located at severe weathering region (weathering index >100 day-inchyr) as Indicated In ASTM C33. FG. 1.
Although the water/cement ratio falls outside the listed range of 0.35 to 0.45, given all parameters associated with concrete mix design VYNPS concrete meets the quality requirements of ACI to ensure acceptable concrete is obtained. Nonetheless concrete will be managed under the aging management programs Identified In the 3.5.2 tables.
For construction of concrete, VYNPS site Specification EBASCO 15-65, Concrete Large Work, identifies the same ASTM standards for achieving durable concrete as those Identified In AC! 201.2R77, 'Guide to durable concrete."
The VYNPS concrete Is expected to experience average general area temperature of 1501F and local area maximum temperature less than 200"F.
The dry'etl cooling system recirculates the drywell atmosphere through heat exchangers to maintain ambient temperature In the drywel between 135 and 165°F (average 150"F). (Ref VYNPS UFSAR 5.23.2 and 10.12.3) The concrete temperature around piping penetrations for high temperature lines.
such as the steam lines and other reactor system lines Is protected by piping Insulation and air gaps. (Ref UFSAR 5.2.3.4.2).
[Original Response]
LRA Table 3.5.1 relates only to structures and structural supports. Thus, the statement that no vibration Isolation elements are In scope and subject to aging management review applies only to structural vibration Isolation elements. Vibration Isolation elements for mechanical system components are subject to aging management review. For example, LRA Table 3.3.2-4 contains expansion joint In the emergency diesel generator system and LRA Table 3.3.2-10 contains duct flexible connections and expansion joints In heating, ventilation, and air conditioning systems.
(New Response)
As stated In Table 3.5.1 Line Item 3.5.1-41, there are no non-metallic (rubber) vibration Isolation elements used to structurally support the EDG, HVAC system equipment, and miscellaneous mechanical equipment that Is within the scope of license renewal. Vibration isolation to systems attached to these components Is by expansion joints and flexible connections.
Closed Closed Closed Closed
278 A-W-13 LRA Table 3.5.1, Item Number3.5.1-50, under the discussion column, states that loss of material due to pitting and crevice corrosion of groups 82 and B4 galvanized steal, aluminum, and stainless steel components In an outdoor air envtrornent Is not applicable at VYNPS. NUREG-1 833 on Page 93 for Item TP-6 states an approved precedent exists for adding this material, environment. aging effect. and program combination to the GALL Report. As shown in RNP SER Section 3.52.4.3.2. galvanized steel and stainless steel In an outdoor air environment could result In loss of material due to constant waeting and drying conditions. Aluminum would also be susceptible to a similar ldnd of aging effect In the outdoor environment. Provide a discussion of the actual group 82 and B4 galvanized steel, aluminum, and stainless steel VYNPS components which are within the scope of license renewal and exposed to an outdoor air environment. Discuss the location of these components at VYNPS and how they are protected from constant wetting and drying conditions.
LRA Amendment Accepted Loss of material due to pitting and crevice corrosion of aluminum and stainless steel components in an outdoor environment Is not applicable iN the atmospheric environment Is non-aggresslve. The ambient environment at VYNPS Is not chemically polluted by vapors of sulfur dcioxide or other similar substances and the external environment does not contain saltwaler or high chloride content. in this non-aggressive envIronment, the occasional wetting and drying from normal outdoor weather does not result In any significant loss of material In, anuminum or stainless steel components. The conclusion that no aging effects require management for these materials In an outdoor air environment is supported by operating experience and by previously approved staff positions documented in the Farley SER (NUREG-1825, page 3-314).
Components that may be considered in the D2 and B4 grouping consists of those line Items In Table 3.52-6 including the plant specific Note 503. Note 503 provides the basis for concluding the environment Is non-aggressive and the conclusion that there are no aging effects requiring management The aging management review results for galvanized steel components In outdoor air should indicate loss of material as an aging effect with structures monitoring as the aging management program. The following discussion applies to the discussion column entry for item 3.5.1-50.
Consistent with NUREG-1 801 for galvanized steel components In outdoor air. The Stnrctures Monitoring Program will manage loss of material Loss of material Is not an applicable aging affect for stainless steel or aluminum components in outdoor air. The ambient environment at VYNPS Is not chemically polluted by vapors of sulfur dioxide or other similar substances and the external environment does not contain saltwater or high chlorides.
Therefore, loss of material due to pitting and crevice corrosion Is not an aging effect requiring management for aluminum and stainless steel components exposed to the external environment.
279 Accepted A-W-14 LRA Table 3.5.1, Item Number 3.5.1.5Z under the discussion column, states that loss of mechanical function due to the listed mechanisms Is not an aging effect Proper design preyens distortion, overload. and fatigue due to vibratory and cyclic thermal boads. Explain how loss of mechanical function due to corrosion Is not an aging effect w*ich needs to be managed for the period of extended operation. If proper design prevents distortion, overloed, and fatigue due to vibratory and cyclic thermal loads, explain If them has never been a component failure at VYNPS due to any of these conditions.
Explain If there has never been a component failure In the nuclear Industy due to any of these conditions. Explain where sliding support bearing and s"ding support surfaces are used In component groups B2 and S4 at VYNPS and provide the environment they are exposed to.
LRA Amendment Loss of material due to corrosion Is an aging effect that can cause a loss of Intended function. Loss of mechanical function would be considered a loss of Intended functlon. Loss of mechanical function Is not an aging effect, but is the result of aging effects. There have been component failures in the industry due to distortion, overload, and excessive vibration. Such failures typically result from Inadequate design or events rather than the effects of aging. Failures due to cyclic thermal loads are very rare for structural supports due to their relatively low temperatures.
The sliding surface material used at VYNPS Is lubrite, which Is a corrosion resistant material. Components are Inspected under ISI-IWF for torus saddle supports and Strctures Monitoring Program for the tubrite components of radial beam seats. Plant operating experience has not Identified failure of lubrite components used In structural applications. No current Industry experience has Identlifed failure associated with lubrite siding surfaces.
Components associated with 52 grouping are limited to the torus radial beam seats and support saddles. Them are no sliding support surfaces associated with the 84 component grouping for sliding surfaces at VYNPS.
LRA Table 3.5.1, Item 3.5.1-52 will be revised to read as follows.
- Loss of mechanical function due to the listed mechanisms Is not an aging effect. Such failures typically result from Inadequate design or operating events rather than from the effects of aging. Failures due to cyclic thermal loads are rare for structural supports due to their relatively low temperatures.*
280 A-W-15 IRA Table 3.5.1, Item Number 3.5.1-54. under the discussion column, states that loss of mechanical function due to the rlted mechanisms Is not an aging effect. Proper design prevents distortion, overload, and fatigue due to vibratory and cyclic thermal loads. Explain how loss of mechanical function due to corrosion Is not an aging effect whilch needs to be managed for the period of extended operation. If proper design prevents distortion, overload, and fatigue due to vibratory and cyclic thermal loads, explain If there has never been a component failure at VYNPS due to any of these conditions.
Explain If there has never been a component failure In the nuclear Industry due to any of these conditions. Explain what VYNPS Inspects for during VT-3 visual examinations of groups B1.1, B1.2 and 81.3 components under its Inservice Inspection Program during its current license and also anticipated VT-3 visual examinations during Its possible extended license period.
LRA Amendment The discussion for Item Number 3.5.1-54 was not saying that failures have not occurred, but that loss of mechanical function Is not an aging effect For license renewal, Entergy Identifies a number of aging effects that can cause loss of Intended function. Loss of intended function includes loss of mechanical function. The loss of function Is not considered an aging effect Aging effects that could cause loss of mechanical function for components in Item Number 3.5.1-54 are addressed elsewhere in the aging management reviews. For example, loss of material due to any mechanism Is addressed in Table 3.52-6 under listings for component and piping supports ASME Class 1. 2.3 and MC (Page 3.5-70), and component and piping supports (Page 3.5-71). Component failures at VYNPS and In the nuclear Industry have certainty occurred due to overload (typically caused by an event such as water hammer) or vibratory and cyclic thermal loads. Because of the low operating temperatures, failures due to cyclic thermal loads are extremely rare for structural commodities. Failures due to distortion or vibratory loads have also occurred due to inadequate design, but rarely if ever, due to the normal effects of aging.
IRA Table 3.5.1, Item 3.5.1-54 will be revised to state:
Loss of mechanical function due to distortion, dirt, overload, fatigue due to vibratory, and cyclic thermal loads Is not an aging effect requiring management Such failures typically result from inadequate design or events rather than the effects of aging. Loss of material due to corrosion, which could cause lose of mechanical function, is addressed under Item 3.5.1-53 for Groups B1.1, 81.2, and 81.3 support members!
The NUREG-1801 referenced programs involve visual Inspections and leak testing which are not optimurn methods for managing SOC. Therefore, when possible, ift is more appropriate to assess the conditions and Identify whether the apprlcable aging effects require management. As stated in section 3.5.2.2.1.7, stress corrosion cracking Is not an aging effect requiring management for the penetration sleeves and bellows, since the conditions necessary for SCC do not exist However these components are evaluated for aging effects requiring management, such as cracldng, as shown In Table 3.5.2-1 (Reference Item for Drywall to torus veal line bellows).
LRA Amendment NUREG-1800, Item Number 3.5.1-34 indicates that further evaluation is necessary only for aggressive environments. No reference was provided to further evaluation In LRA Section 3.5.2.2.2.4 (1) since the VYNPS environment Is not aggressive as noted In LRA Table 3.5.1, Item Number 3.5.1-34, under the discussion column.
LRA Table 3.5.1, Une Item 3.5.1.34 discussion will be revised to add *See Section 3.52.2.2.4(1)".
Accepted 281 A-W-16 IRA Table 3.5.1. Item Number 3.5.1.10. under the discussion column, states that cracking due to stress conosion crackirg for stainless steel penetration sleeves and penetration bellows Is not applicable. Explain f the VYNPS Containment Inservice Inspection Program and Containment Leak Rate Program are used curently to detect cracking of stainless steel penetration sleeves and penetration bellows by inspection and testing. Explain why It Is not more appropriate to take credit for these two programs to detect cracking without the need for additional enhanced examinations then to say not applicable.
282 A-W-17 IRA Table 3.5.1, Item Number 3.5.1-34, under the discussion column, does not make reference to IRA Section 3.5.2.22.4 (1) for further evaluation.
Explain why this link Is not made to the further evaluation section.
Closed Accepted
-1
283 A-W-18 LRA Table 3.5.1. Item Number 3.5.1-35, under the discussion column, does not make reference to LRA Section 3.5.22.2.4 (2) for further evaluation.
Explain why this link Is not made to the further evaluation section. Provide a copy of ACI-301 as listed under the discussion.
284 A-W-19 LRA Table 3.5.1, Item Number 3.5.1-36, under the discussion column, does not make reference to IRA Section 3.5.2.2.2.4 (3) for further evaluation.
Explain why this link Is not made to the further evaluation section. The statement 'See Section 3.5.2.22.1 (5) for additional discussion* needs further clarification that this section is for Groups 1-5. 7-9, however it would apply to accessible Group 6 concrete. Explain why LRA Section 3.5.2.22.4 (3) lists cracking of concrete due to Stress Corrosion Cracking (SCC).
285 A-W-20 LRA Table 3.5.1, Item Number 3.5.1-37, under the discussion column, states not applicable and makes reference to Section 35.222.4(3). Section 3.5.2.2.2.4(3) discusses Inaccessible areas only. Explain why VYNPS under the discussion section for Item Number 3.5.1-37 does not state: 'Nonetheles the Structures Monitoring Program wil confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components.' This would apply to above grade concrete, like I Line Item 3.5.1-36 for accesibli concrete.
286 A-W-21 LRA Table 3.5.1, Item Number 3.5.1-40, under the discussion column, states Plant experience has not Wentified reduction in concrete anchor capacity or other concrete aging mechanisms. Nonetheless, the Structures Monitoring Program will confirm absence of aging effects requiring management for VYNPS concrete components.r The proWect team cannot find an AIR fine Item In Table 2 for this component (Buiding concrete at locations of expansk and grouted anchors; grout pads for support base plates). Provide the Table number, LRA page number, and component for where this AMR line item is evaluated and shown.
IRAAmendment Due to an administrative error the reference to ACI should have been ACI 318 and not ACI 301. LRA Table 3.5.1, Item 3.5.1-35 dliscusslon will be revised to refer to ACI 318. For clarification, a reference to Section 3.5.2.2.2.4(2) will also be added to the discussion.
See also Response 284 IRA Amendment IRA Table 3.5.1. Une item Number 3.5.1-36 discussion will be revised to read as follows.
Reaction with aggregates is not an applicable aging mechanism for VYNPS concrete components.
See Section 3.5.2.2.2.1 (5) (although for Groups 1-5, 7. 9 this discussion is also applicable for Group 6).
See Section 3.5.2.2.2.4(3) additonal discusslon Nonetheless, the Structures Monltorlng Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components.
Due to an administrative oversight, the heading of IRA Section 3.5.22.2.4 (3)
Inadvertently lists cracking of concrete due to Stress Corrosion Cracldng (SOC). This section heading should have begun with 'Cracking Due to Expansion and Reaction with Aggregates...'. Stress corrosion cracking is not discussed In the body of this section.
LRA Amendment For clarification, LRA Table 3.5.1, Item Number 3.5.1-37, will be revised to state the following.
a,
'Not applicable. Nonetheless the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components. See Section 35.2-2-2.4(3)r e
LRA Amendment Building concrete at locations of expansion and grouted anchors; grout pads for support base plates are shown as 'foundation' and 'Reactor vessel support pedestal' in IRA Table 3.5.2.1 (page 3.5-54). 'foundation' in Tables 3.5.2-2 thru 3.5.2-5 (pages 3.5-58, 3.5-60, 3.5-62. and 3.5-66), and as 3n
'Equipment pads/foundations' In Table 3.52-6 (page 3.5-78). Further
.2 evaluation is provided In LRA section 3.5.2.2.2.e(1), page 3.5-14.
IRA Table 3.5.1. Item Number 3.5.1-40 discussion will be revised to add
'See Section 3.5.2.2.2.6(1)'.
Accepted Accepted Accepted Accepted
287 3.1.1-19-P-02 Please claify the basis for omitting the leak-off Kines themselves from Table 3.1.2-1.
288 3.1.1-25-P-01 Please clarify the basis for omitting the Jet pump sensing lines from Table 3.1.2-2 289 3.1.1-40-P-02 On page 3.1-41, for the stainless Incore housings, please conlirm that the correct GALL item Is referenced.
290 3.1.1-41-P-02 On page 3.1-41 and 3.1-43, the GALL items referenced in this AMR are for stainless steel and nickel-based alloy components that may be subject to SCC. It does not appear to be appropriate for low-afloy steel. Is there a more suitable GALL Item?
The head seal leak detection leies are not part of the pressure vessel but are Included In Table 3.1.2-3 with other reactor coolant pressure boundary piping. They are Included on page 3.1-67 with piping and fittings <4"NPS.
Plant specific note 104 Identifies the applicability of this aging management review result to the leak detection line.
The let pump sensing lines do not appear In Table 3.1.2-2 (Reactor Vessel Internals Summary of Aging Management Evaluation) because the jet pump sensing lines Inside the vessel are not subject to aging management review.
These lines are not required to maintain pressure boundary and hence have no license renewal Intended function. The Jet pump sensing fines outside the vessel are Included with the piping <41 In Table 3.1.2-3.
Many NUREG-1 801. Volume 2 Items are very similar in terms of materials.
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 arbiltary. In this case, the components were considered a subset of the reactor vessel (hence the HIating within the reactor vessel table) and the comparison was made to the cracldng Item within the NUREG-1 801 BWR reactor vessel table that best (subjectively) represented the Incore housings.
The material for these components Is Identified as low allow steel with stainless steel cladding. The material exposed to the internal environment of reactor coolant (treated water) Is the stainless steel cladding. When evaluating surface aging effects such as cracking and loss of material, the stainless steel cladding Is the material that must match the NUREG-1 801 Item. NUREG-1801 item IV.A1-1 provides the best match for the material.
environment and aging effect combination within the BWR reactor vessel table.
The applicable material for the external environment (air) Is low alleoy sleet (or steer In NUREG-1 801 terms).
Closed Closed Closed Closed CD
291 3.1.1-41-P-04 On page i,-5Z the component type 'thermal sleeves. feedwater Inlets (N4)' Is managed using krseMce Inspection and water chemistry control - BWR. How are the thermal sleeves to be Inspected?
292 3.1.1-51-P-01 On page 3.1-60, the CASS let pump castIngs exposed to treated water am managed. Please corfirm that GALL Item IV.B 1-11 applies, and whether there Is a cast ortficed fuel support or CRD component that Is also managed this way.
LRA Amendment 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 Inservlce Inspection and Water Chemistny 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 that can be examined by ISI Given that there Is no pressure boundary weld, these sleeves are not part of the pressure boundary. As such they have no Intended function for Ucense Renewal, and with no Intended function they are not subject to aging management review1. Therefore. Vermont Yankee will amend the License Renewal Application to Indicate that the feedwater thermal sleeves are not subject to aging management review.
1 The feedwater thermal sleeves have no non-safety affecting safety related (a2) function. They are completely contained within the feedwater piping and cannot spray or leak on other equipment. The feedwater thermal sleeves are a part of the feedwater piping Inside the vessel, and failure of that piping does not defeat the delivery of water to the vessel annulus, as any leakage also goes to the vessel annulus.
Same question on #217.
Accepted Closed l*
293 3.3.1-32-K-01.
Beginning on page 3.3-94, many component types are managed using the diesel fuel monitoring program. Please confirm that the VYNPS Diesel Fuel Monitoring AMP Is consistent with GALL XI.M3Z 'One-Time Inspection.' as well as with XI.M30, "Fuel Oil Chemistry.'
LRA Amendment Accepted As stated In LRA Section 3.22.9, loss of material due to general, pitting.
crevice, and MIC for carbon steel piping and components exposed to fuel oil Is managed by the Diesel Fuel Monitoring Program. This program Includes sampring and monitoring of fuel oIl quality to ensure levels of water, particulates, and sediment remain within the specified limits. Maintaining parameters within limits ensures that significant loss of material will not occur. Ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate will be performed to confirm the effectiveness of the Diesel Fuel Mon"toring Program. As stated In LRA Section B.1.9, the Diesel Fuel Monitoring Program Is consistent with the program described In NUREG-1 801,Section XI.M3. Fuel Oil Chemistry Program. with minor exceptions.
The Diesel Fuel Monitoring Program Is not consistent with GALL XI.M32, "One-Tlme Inspection.' nor are one-time inspections necessary to verify the effectiveness of the program. The Diesel Fuel Monitoring Program includes periodic cleaning, visual Inspection, and ultrasonic Inspection of storage tank bottoms where water and contaminants accumulate to confirm the effectiveness of the oil quality monitoring activities to preserve an environment that is not conducive to corrosion.
The One-TIme Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysts and Diesel Fuel Monitoring programs.
Accepted 294 3.3.1-33-K-01 Beginning on page 3.3-71, several component types In a tube oil environment are managed using the VYNPS oil analysis program. Please confimi that the VYNPS O1 Analysis AMP is consistent with GALL XI.M3Z "One-Time Inspection,° as well as with XLM39, Lubrl*catng Oil Analysis.* See 3.3.1-14-K-01 LRA Amendment As stated In LRA Section 3.2.2.7, steel piping and components In aoliary systems at VYNPS that are exposed to lubricating ol are managed by the Oil Analysis Program, which includes pertodlc sampling and analysis of lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment that is not conducive to corrosion. As stated In LRA Section B.1.20. the Oil Analysis Program Is consistent with the program described In NUREG-1 801.Section XI.M39, Lubrlcating Oil Analysis. with a minor exception.
The Oti Analysis Program Is not consistent with GALL XI.M32, 'One-Time Inspection,' nor are one-time Inspections necessary to verily th" effectiveness of the program. Metals are not corroded by the hydrocarbon components of lubricants. Lubricating oils are not good etectrolytes and the oil film on the wetted surfaces of components tends to minimize the potential for corrosion. Corrosion In lube oil systems only occurs as the result of the presence of Impurities or moisture. Therefore, an effective oil analysis program, which maintains Impurities and moisture below specified limits, precludes the need for one-time Inspections. Operating experience at VYNPS has confirmed the effectiveness of the Oil Analysis Program In maintaining moisture and impurities within limits such that corrosion has not end will not affect the Intended functions of these components.
In numerous past precedents (including NUREG-1 828, Arkansas Nuclear One Unit 2 SER, Section 3.0.3.3.6, and NUREO-1831, Donald C. Cook SER, Section 3.0.3.3.8), the staff concluded that an effective on analysis program, which maintains Impurities and moisture below specified limits, Is sufliclent to demonstrate that the effects of aging will be adequately managed so that the Intended functions wiU be maintained consistent with the current licensing basis for the period of extended operation.
The One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
A
295 3.3.1-38-K-01 Beginning on page 3.3-138, SCC of many stainless steel components exposed to reactor coolant above 140F Is managed by the water chemistry -
BWR program. Provide docurnentatlon that demonstrates that these are outside the scope of the BWR SCC program. Also, please claritfy how the effectiveness of the AMP witl be verified. (Since some of these components are <NPS 4, the review team understands that they are outside the scope of the BWR SCC program. However, It Is not dear whether OTI for small-bore piping will be used or the OlI Included In the VYNPS water chemIstry programs.
296 3.3.1-40-K-01 On page 3.3-97, a carbon steel tank Is addressed. Please describe how the system walkdown program will satisfy the recommendations of GALL AMP X1.M29, -Aboveground Steel Tanks.-
IRA Amendment LRA Table 3.32-11 Includes stainless steel post-accident sampling system (PASS) sample line tubing and valves that are exposed to treated water or steam from the reactor coolant system on internal surfaces. The components are less than 4 NPS and am outside the Class I reactor coolant system (RCS) pressure boundary. They are, therefore, outside the scope of the BWR SCC program. Aging of the PASS sample lUne tubing and valves Is managed by the Water Chemistry Control - BWR Program, which Is verified by the One-Time Inspection Program. To provide further clarification, the effectiveness of the Water Chemistry Control - Auxtllary 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 explicity state One-Time Inspection Program activitles will confirm the effectiveness of these programs. However, Inspections performed under the small-bore piping activity, which applies to components within the Class-I RCS pressure boundary, will also provide data useful for evaluating the condition of these downstream components.
The tanks descr5led on page 3.3-97 are diesel fuel oli tanks with external protective coatIngs.
The attributes In GALL AMP XI.M29, 'Aboveground Steel Tanks' Include preventive measures to mitigate corrosion by protecting the external surface of steel tanks with paint or coatings In accordance with standard Industry practice. This program relies on periodic system walkdowns to monitor degradation of the protective paint or coating. This program also montor corrosion at Inaccessible locations such as the tank bottom by thickness measurement The System Walkdown Program provides the preventive measures to protect the external accessible surfaces by visual inspection of carbon steel tanks to Identify degradation of coatings, sealants. and caulldng plus indications of leakage. Readily accessible tank surfaces are Inspected at least once per refueling cycle and are normally performed more frequently.
Corrosion at Inaccessible locations of the tank Is addressed by thickness measurements conducted as part of the Diesel Fuel Monitoring Program.
This program applies to the concrete (ext) environment for the tank bottom as shown on page 3.3-97.
Protective coatings on accessible external surfaces are repaired as pert of the corrective action process following periodic inspection. Corrective action is taken as necessary on the tank bottom should minimum wall requirements not be maintained.
These combined actions satisfy the requirements of the GALL AMP XLM29,
- Aboveground Steel Tanks-.
Accepted Closed
297 3.3.1-47-K-01 Beginning on page 3.3-72, gray cast Iron and carbon steel exposed to treated water Is managed using the WC-CCW program. GALL recommends performance monitoring to confirm the effectiveness of the CCCW program.
Please Iderntfy an acceptable alternative method that will be used to verify the effectiveness of the WC - CCW program.
IRA Amendment The One-Time Inspection Program, described In LRA Section B.1.21 Includes Inspections to verify the effectiveness of the water chemistry control aging management programs (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling is not occurring. As stated In LRA Section B.1.21, the One-Time Inspection Program is a new program which will be consistent with the program described In NUREG-1 801, Section )U.M32. 'One-Time Inspection."
IRA 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 line Items for which GALL recommends a one-time Inspection to confirm water chemistry control. For simpl"ciy, the subsequent tables (Table 2Zs) do not list the One-Time Inspection Program each time a water chemistry control program Is listed. However, since the One-Time Inspection Program is applicable to each water chemistry control program, it Is also applicable to each line item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Chemistry Control - Auxdfry 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 Chemist Control -Auxilary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
License Renewal Commitment #30 This tank Is In the C02 system. The system wallfdown program was selected since It Is the program that Is the most used for managing external aging effects of components In almost all systems similar to the External Surfaces Monitoring Program In GALL Inspections in this program must be performed at least once per refueling. The GALL AMP XI.M26, Fire Protection requires visual Inspection once every six months for C02 system components where the system walkdown frequency is once each refueling cycle. Since aging effects for this tank external surface In Indoor air would be manifested over several years. it was determined that this variation In Inspection frequency Is not significant such that system walldown was still appropriate. However, per license renewal commitment 30, VYNPS will perform C02 system wafdowns every six months starting no later than the beginning of the period of extended operation.
Accepted
- =r C-
ý3
,0
-on 298 3.3.1-58-K-01 On page 3.3-121, loss of material from external surfaces of a tank Is managed using the system walkdown program Instead of the tIre protection program.
Since the tank In question Is In the FP system, please confirm that the FP AMP does not manage this aging effect.
Accepted
299 3.3.1-68-K-01 On page 3.3-194, loss of material from carbon steel components is managed using PS&PM. Please explain the intended function (pressure boundary) of the Instrument air system and how It relates to the a(2) category to which the system has been assigned. Also, please explain how this GALL v2 Item was chosen, since it Invokes a fire protection AMP.
For components Included for (a)(2) the pressure boundary function Is two Closed fold. The Wirst Is the pressure boundary of the passive component that ensures that the component cannot spatially Interact through spray or leakage oft0 a safety related components. The second applies for non-safety components connected to safety related components where the non-safety components provide structural support for the safety related such that loss of pressure boundary would be Indicative of structural Integrity. For the carbon steel components containing untreated water that are managed by PSPM the pressure boundary function is only for preventing spray or leakage.
The instrument ak s myste Is an auxiliary system. This GALL Item was chosen because In chapter VII for Auxiliary systems it was the best match for a material, environment, aging effect combination. A note E was selected since a different program than Fire Protection was Invoked.
300 3.3.1-68-K-02
[Original Question]
On page 3.3-213, loss of material from carbon steel components Is managed using OTI. Please explain how this GALL v2 Item was chosen, and justify the use of O11 for carbon steel exposed to raw water as opposed to a periodic Inspection.
[Folow-up Question]
Looking for commitment to do more than OTI for carbon steel exposed to raw water.
LRA Amendment
[Original Response]
The environment for these components Is untreated water from the radwaste system which Is defined In table 3.0-1 of the LRA as water that was originally treated but now may contain contaminants. Carbon steel In treated water Is not expected to experience any significant aging effects. As a result this untreated water environment Is not expected to result In significant aging such as loss of material, however a one time Inspection will be performed to confirm the absence of significant aging effects. If significant aging Is found to be occurring the corrective action program wil determine the need for future Inspections Including a periodic Inspection or possible replacement.
This GALL line Item was chosen since the radwaste system Is an auxiliary system In GALL chapter VII. For the material. environment. and aging effect combination of this Item, (where untreated water is equivalent to raw water) this line Item was the most appropriate. A note E was selected since a different program was used. No LRA Amendment for the original" question.
See below.
[Foflow-up Response]
The 'untreated water' environment for the carbon steel and copper alloy radwaste system components In LRA Table 3.3.2-13-32 Is originally treated water that may now contain contaminants that could result In an aggressive environment Therefore, the aging management program will be changed from One-Time Inspection to Periodic Surveillance and Preventive Maintenance for managing loss of material for carbon steel and copper alloy components In the radwaste system exposed to untreated water (LRA Table 3.3.2-13-32).
This requires a change to the LRA.
Accepted
1301 3.3.1-68-K-03
[Follow-up Ouestion]
Looklng for commitment to do more than OTi for carbon steel exposed to raw water.
[Orgnl" Quesflonj Beginning on page 3.3-206, loss of material from carbon steal components Is managed using oT. Please Justify the use of OTI for carbon steel exposed to raw water as opposed to a periodic Inspection.
[Original Ouestion]
Closed The components In question are In the potable water system. Potable water, though not treated In accordance with a GALL program such as water chemistry, is treated to an extent before used at the site such that It is acceptable for human consumption. However, since It Is not monitored by the site it was Identified as untreated water which Is defined In table 3.0-1 of the LRA as water that was originally treated but now may contain contaminants. Carbon steel In treated water Is not expected to experience any significant aging effects. As a result this untreated water environment Is not expected to result In slgntlicant aging such as loss of material which could Impact the intended function of the component However a one time inspection will be performed to confirm the absence of significant aging effects. If significant aging Is found to be occurring the corrective action program will determine the need for future Inspections Including a perlcdic Inspection or possible replacement.
(New Response): The 'untreated water" environment for the carbon steel potable water system components in LRA Table 3.3.2-13-29 Is not 'raw water'; it Is actualy treated water. Water for this system comes from four onslte wells and Is monitored and treated to meet the regulations of the state of Vermont. It was labeled 'untreated water' because conductivy and dissolved oxygen are not monitored. However, carbon steel Is not expected to experience significant aging effects In a treated water environment As Indicated In the IRA, a One-Time Inspection of carbon steel potable water system components exposed to "untreated water* will be performed to confirm the absence of signlflcant aging effects. Therefore, a commitment to do more to manage aging of these components is not necessary.
CLOSED TO RAI 3.3.1-68-K-03 302 3.3.1-6M-K-01 On page 3.3-104, loss of material from stainless steel components is managed using FP. Please explain why the filter and filter housing are managed with the fire protection program Instead of the fire water system program-303 3a3.1-70-K-01 Beginning on page 3.3-106, loss of material from copper alloy components In raw water Is managed using FP. Please explain why these components are managed with the fire protection program Instead of the fire water system program.
The stainless steel fitters and filter housings exposed to raw water on page 3.3-106 are filters that support the operation of the diesel fire pump by filtering the cooling source to the engine. The Fire Protection Program performs tests and Inspections of the diesel engine and its support components and Is therefore credited for management of these components.
The tubing exposed to raw water on page 3.3-106 supports the operation of the diesel fire pump by supplying the cooling water source to diesel engine.
The Fire Protection Program performs tests and Inspections of the diesel engine and its support components and therefore Is credited for management of these components.
Ciosed Closed
- 1. RAI-AppendixA-1 SRP-LR states that the reviewer should confirm that the applicant has identified and committed in the license renewal application to any future aging management activities, including enhancement and commitments, to be completed before entering into the period of extended operation.
NEI letter dated Feb. 26, 2006, in response to NRC letter dated Dec.16, 2002, the industry has agreed to identify the high level future commitments in their UFSAR supplement (Appendix A of the LRA)
JAF LRA did not include a "Commitment List"; therefore, descriptions of any proposed new AMPs and AMP "enhancements" are incomplete. The staff requests the applicant to provide a commitment list to show all regulatory commitments. In addition, for each commitment that is placed on the application in either the original version or subsequent revisions of the commitment list, the staff requests that the applicant amend the applicable UFSAR Supplement summary description section in the JAF LRA Appendix A for each of the respective AMP or TLAA. This will provide the appropriate reference.for each of the specific commitment that has been placed on the LRA for the AMP or TLAA under review.
304 33.1-70-K-02
[Follo-up Queston]
Looking for commitment to do more than OTt for carbon steel exposed to raw water.
(Original Ouestion]
On page 3.3-213, loss of material from copper alloy components in raw water LI managed using O"I. Please explain the basis for applying an OIl program Instead of the fire water system program.
iRA Amendment Accepted (Original Response]
The environment for these components is untreated water from the radwaste system which is defined In table 3.0-1 of the IRA as water that was originally treated but now may contain contamriants. Since this component Is not in the fire protection system the use of the fire protection program is not appropriate. Copper alloy in bested water Is not expected to experience any significant aging effects. Because this untreated water began as treated water It is also not expected to result In significant aging such as loss of material which could impact the intended function of the component However a one time Inspection was chosen to confirm the absence of significant aging effects. It significant aging is found to be occurring the corrective action program will determine the need for future Inspections including a periodic inspection or possible replacement 305 3.3.1-83-K-01 On page 3.3-107. fouling of copper alloy heat exchanger tubes in raw water is managed using FP, where GALL suggests OCW. Please Identify the specific heat exchanger to which this AMR applies, and the basis for the choice of AMP.
306 3.3.2-04-01-K-01 On page 3.3-78. fouling of aluminum heat exchanger fbis In air is managed using PSM. Please provide the procedure under which fouling is monitored.
(New Response) The unztreated water environment for the carbon steel and copper alloy radwaste system components in LRA Table 3.3.2-13-32 Is originally treated water that may now contain contaminants that could result In an aggressive environment Therefore, the aging management program will be changed from One-Tirme Inspection to Periodic Surveillance and Preventive Maintenance for managing loss of material for carbon steel and copper alloy components in the radwaste system exposed to untreated water (LRA Table 3.3.2-13-32).
The heat exchangers represented are the fire pump diesel jacket water heat exchanger and the gear box oil cooler. Both heat exchangers use water from the fire water system (raw water) for cooling. The Fire Protection Program performs tests and Inspections of the diesel engine. Since these heat exchangers are part of the fire diesel it is appropriate to manage fouling with the Fire Protection Program which tests the engine and Its auxiliaries.
These Fis are part of the emergency diesel generator air coolers that are reviewed in VY-AMRM-13. The diesel generators are tested periodically in procedure OP 4126 *Diesel Genertors SurveillanW. This Is an extensive test procedure that Includes verification of local diesel operating conditions Includimg the hitercooler air temperature during diesel operation. The monitoring of this temperature within temperature limits confirms the proper operation of the intercooler which provides the indication that fouling that can Impact the diesel performing its intended function is not occurring. The data is recorded in the Diesel Generator Operating Datae at the end of OP4126 and page 1 of 6 has the Intercooler air temperature with normal range and acceptance criteda shown.
Closed Closed
307 3.3.2-04-03-K-01 On page 3.3-79, fouling of copper exclhangr tubes In air Is managed using PSM. Please provide the procedure under which fouling Is monitored.
308 B.1.16-P-02 GALL recommends an AMP that Is consistent with GALL AMP XI.M24.
'Compressed Air Monitoring.! VYNPS uses a plant specilic AMP, B.1.16, Instrument Air Monitoring Program.' which does not include the pressure testing that Is suggested by the GALL AMP. What program will be used to perform pressure testing of the Insbument air system?
309 al.1-0t-P-02 Generic Question 1: VY LRA Identified that cracking fatigue credits TLAA -
metal fatigue for almost all the components in RCS (Section 3.1). In Appendix C, BWRVIP applicanra action items (AAIs) Identified that there Is no plant-specific TLAAs. Please clarify the difference between AMR and AAIs.
Note: This question applied to all Sections (3.1 thru 3.6). If TLAA was credited in the LlA, the TLAA analysis should be available to support the AMR.
These tubes are part of the emergency diesel generator air coolers that are reviewed In VY-AMRM-13. The diesel generators are tested periodically In procedure OP 4126 'Diesel Generators Surveillance'. This is an extensive test procedure that includes verification of local diesel operating conditions Including the intercooler air temperature during diesel operation. The monitoring of this temperature within temperature limits confirms the proper operation of the intercooler which provides the Indication that fouling that can Impact the diesel performing its Intended function Is not occurring.
The Instrument Air Quality program at VYNPS Is a plant specific program.
Through monitoring of air quality, the Instrument Air Quality Program maintains Instrument air free of significant contaminants and water, thereby preventing loss of material. This approach to manage loss of material Is more effective than leakage moniltoring using pressure testing. Pressure testing of components detects leakage that would be an Indication of loss of the pressure boundary intended function. This testing does not ensure that their passive Intended function of maintaining pressure boundary Is managed. As a result, the Instrument Air Quality program at VYNPS does not Include pressure testig of components. However, by maintaining the Instrument air system free of significant contaminants and water, the Instrument Air Quality Program Is more effective than pressure testing for managing loss of material in the inst.ument air system.
LRA Amendment Under Entergy's approach, the Section 3 table entries listing Cracking-fatigue with TLAA - metal fatigue only indicate that the component meets the acreening criteria (temperature) for fatigue, and should be reviewed to determine the existence of TLAA (metal fatigue analyses). That review Is documented in Section 4 of the LRlA.
Based on requirements of the liceAse renewal rnle Section 4 includes discussion of only those entres that concluded there were associated TLAA.
This resulted In numerous "T.LAA - metal fatigue entries In Section 3 with no corresponding discussion in Section 4.
Entergy will modify the tables in Section 3 to delete the TLAA - metal fatigue" entries for which there Is no TLAA discussed In Sect~on 4.
Closed closed Accepted
310 B.3.22-HI-01 In IRA Table 32.2-1 on page 32-34, the applicant proposed to manage the loss of material of carbon steel. in a treated water environment, using Water Chemistry Control - BWR Program. NUREG-1801 recommends the Water Chemistry Control - BWR along with a One-Time Inspection Program. The staff request the applicant provide Justification for only using the Water Chemistry Control - SWR Program.
IRA Amendment As stated in IRA Section B.1.302, the Water Chemistry Control - BWR Program ls consistent with the program described in NUREG-1501.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 -Auxiilary Systems, Water Chemistry Control - BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling is not occurring. As stated in LRA Section B.1.21, the One-Time Inspection Program is a new program which will be consistent with the program described in NUREG-1801, Section XLM32, "One-Time Inspection.*
IRA Tables 3.1.1, 3.2.1, 3.3.1, and 3.4.1 indicate that the One-Time Inspection Program is credited along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. For simplicity, the subsequent tables (Table 2s) do not list the One-Time Inspection Program each time a water chemistry control program is listed. However, since the One-Time Inspection Program is applicable to each water chemistry control program, it Is also applicable to each line Ktem that credits a water chemistry control program.
To provide further clarification of the Water Chemistry Control -Aulilary 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 -Auxiary Systems, BWR and Closed Cooling Water programs to ewplicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
Accepted 311 B.32.2-11-02 In IRA Table 3.2-2-1 on page 3.2-33, the applicant proposed using the Water Chemistry Control - DWR Program to manage cracking in treated water envronrnent. Please give justificatlon why the Aging Management Program credited is not in accordance with the NUREG-1801 recommended program.
'rho component In question is assLined to be the cyclone separator with an aging effect of cracking that credits GALL line Item V.132-29. The GALL fine Item chosen lot this component specifies the SWR SCC program in addition to Water Chemistry. The BWR SCC program Is applicable to all BWR piping and piping welds made of austenitir; SS and nickel allay that Is 4 h or larger In nominal diameter and contains reactor coolant at a temperature above UTC (200*F) during power operation, regardless of code classification. The components Included In this "
Item are less than 4"NPS and are outside the reactor coolant system (RCS) pressure boundary. They are. therefore, outside the scope of the BWR SOC program. As a result the Water Chemistry Control - BWR program Is used alorm As stated In LRA Section B.1.302, the Water Chemistry Control - BWR Program is consistent with the program described In NUREG-1801, Section)(J.MZ 'Water Chemistry.* The One-Time Inspection. Program, described In LRA Section BA 21 includes Inspections to verify the effectiveness of Me water chemistry control aging management program (Water Chemistry Control -AwMary 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.
Closed
312 B.3.2-2-H 1-03 In LRA Table 3.2.2-1 on page 3.2-34. the applicant proposed to manage the loss of material of gray cast Iron, in a treated water enviroment. using Water Chemistry Control - Closed Cooling Water Program. The applicant states the program is consistent with NUREG-1801 with one exception, there Is not performance and functional testing. The staff request the applicant provide justification on why the Water Chemistry Control - Closed Cooling Water Program Is used for this line Rem.
LRA Amendment As stated in LRA Section B.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. Control of water chemistry ensures that toss of material will not occur In gray cast Iron components in a treated water environment. Also the one-time inspection program described In IRA Section B.1.21 Includes Inspections to verify the effectiveness of all the water chemistry control aging mranagement programs by confirming that unacceptable cracking, loss of material, and fouling Is not occurring. In most cases, functional and performance testing verifies that component active functions can be accomplished and as such would be Included as part of Maintenance Rule (IOCFRSO.65). Passive Intended functions of pumps, heat exchangers and other components will be adequately managed by the closed cooling water chemistry program through monitoring and control of water chemistry parameters. The use of the Water Chemistry Control. Closed Cooling Water and One time Inspection programs are effective programs to manage loss of material for gray cast iron in a treated water environment To provide further clarification of the Water Chemistry Control -Auxxilary 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 - Auillary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
IRA Amendment To provide furlher clarification of the Water Chemistry Control - Auxdllary Systems. BWR. and Closed Cooling Water programs Is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A. SAR supplement descriptions for the Water Chemistry Control - Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activites will confirm the effectiveness of these programs.
Accepted 313 B.3.2.2-HI-04 In Section 3.2 of the LRA the applicant uses Water Chemistry Control -
Closed Cooling Water Program as an Aging Management Program. The program Is stated to be consistent with NUREG-1 801 Closed Cycle-Cooling Water System with one exception. Please provide justikaton why the Water Chemistry Control - Closed Cooling Water Program is used without the recommended testing and Inspection to monitor the effects of corrosion and SCO on the Intended function of components.
Accepted
314 8.3.2`24-1-05 In Table 3.2 In Section 3.2 of the LRA the applicant uses Water Chemistry Control - BWR Program to manage the aging effect of cracking on stainless steel material. NUREG-1801 recommends Water Chemistry and BWR Stress Corrosion Cracking Program. Please provide justification why the applicant Is not In accordance with the recommended NUREG-Ie01.
It cannot be determined exactly which line Items are referred to but the BWR Closed SCC program Is applicable to all BWR piping and piping welds made of austenitic SS and nickel alloy that Is 4 In. or larger In nominal diameter and contains reactor coolant at a temperature above 93*C (200)F] during power operation. regardless of code classification. The piping components included In section 3.2 with temperatures above 200 this fine item are less than 4" NPS and are outside the reactor coolant system (RCS) pressure boLhdary.
They are, therefore, outside the scope of the 8WR SCC program. As a result the Water Chemistry Control - BWR program Is used alone. As stated In IRA Section B.1.30.2. the Water Chemistry Control - BWR Program is consistent with the program described in NUREG-1801,Section XI.M2Z
'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 -
A*wliary 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.
315 LRA Amendment Accepted B.32.2-HI-06 In Table 32.2-4 in Section 3.2 of the LRA, the applicant uses Oil Analysis Program to manage carbon steel In a lube oil environment with loss of material as the aging effect. Please provide justification to the staff why the Table 2 line Items do not have an Inspection program to evaluate detection of aging effects as recommended by NUREG-l 801.
As stated In LRA Section 32-2.7, steel piping and components In auxilary systems at WNPS that are exposed to lubricating oil are managed by the Oil Analysis Program, which Includes periodic sampling and analysis of lubricating oil to maintain contaminants within acceptable Inmits, thereby preserving an environment that Is not conducive to corrosion. As stated In LRA Section B.1.20, the Oil Analysis Program Is consistent with the program described In NUREG-1801, Section XLM39, Lubricating Oil Analysis, with a mior exception.
The Oil Analysis Program Is not consistent with GALL Xl.M32. "One-Tlme Inspection., nor are one-time inspections necessary to verily the effectiveness o1 the program. Metals are not corroded by the hydrocarbon components of lubricants. Lubricating oils are not good electrolytes and the oil film on the wetted surfaces of components tend to minimize the potential for corrosion. Corrosion in lube oil systems only occurs as the result of the presence of Impurities or moisture. Therefore, an effective oil analysis program, which maintains Impurities and moisture below specified lim*ts, precludes the need for one-time Inspections. Operating experience at VYNPS has confirmed the effectiveness of the Oil Analysis Program In maintaining moisture and impurities within limits such that corrosion has not and will not affect the Intended functions of these components.
In numerous past precedents (Including NUREG-1828, Arkansas Nuclear One Unit 2 SER, Section 3.0.3.3.6, and NUREG-1 831, Donald C. Cook SER, Section 3.0.3.3.8). the staff concluded that an effective oil analysis program.
which maintains Impurities and moisture below specified limits. is sufficient to demonstrate that the effects of aging will be adequately managed so that the Intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
T'he One-Time Inspection program will be revised to Include activities to confirm the effectiveness of the Oil Analysi and Diesel Fuel Monitoring programs.
VYNPS wl~l continue to use the analysis and evaluation techniques described in 10 CFR 50.49 and IEEE 323. The equipment in the EQ program Is both active and passive. The EQ program documentation has recently been updated to reflect the normal and accident environments under EPU conditions. The program considers equipment degradation from EPU radialtion dose, normal and accident (LOCA, HELB) temperatures as well as cycling, pressure, humidity. etc.
For the period of extended operation, the EQ program requires WNPS to update the EQ documentation to reflect the additional service life. The environmental conditions (both ambient and accident) resulting from EPU are the basis for evaluations and analysis going forward.
This is consistent with the description of the EQ program in the VyNPS LRA.
316 When Entergy Vermont Yankee (ENVY) goes to the period of extended operation, how will ENVY analyze and evaluate the equipment In the Electrical Equipment Cuafication (EG) program for 60 years per 10 CFR 54.21?
Include In the response that the environmental concditions (both ambient and accident) resulting from EPU wil be used as the bases for te analysis and evaluation going forward. Also confirm that the approach described In the response to this question is consistent with the ENVY LRA.
Closed
317 LRA-4.6 Torus Piping
- a. Is VY bounded by MPR 751? Please provide a statement indicating that the estimate of Via total number of 60 year SRV actuations used in the design fatigue analysis remains valid and conservative, based on the actual SRV actuations counted through 2005.
- b. Is VY still bounded by MPR 751 after power uprate?
- a. Par the MPR 751 excerpt provided below. all domestic Mark 1 BWRs Closed appear to meet MPR 751 for both current operating and license renewal terms. it should be noted that VY-SRV operation has been very low and therefore SRV valve cycling and related attached piping has been very low.
VY has not had a leaking SRV's since the early 1980's. VY only functionally tests Its SRVs once per cycle during reactor shutdown. Based on discussions with Operations, VY has had two SRV actuations events of note e.g.:
- Loss of Normal Power Event (1990).
- Loss of Switchyard Insulator Event (2005).
VY replaces all of its 4 Installed SRVs every refueling cycle with readied spares. This refurbishment strategy has ensured that inadvertent SRV operation has been minimized.
MPR-751 - Results and Conclusions Relevant to SRV piping (To NRC by GE letter MFN--87--82 dated 1 3O/82).
3.0 RESULTS AND CONCLUSIONS This section contains the results of the fatigue evaluations performed on over 30 torus piping systems. These systems were selected by each A/E as representative of the most highly stressed torus piping systems in their respective plants. Thirty percent of these were SRV discharge lines and the remainder were lines attached to the torus with sizes ranging from 2-inch to 24-inch. All torus piping systems had a fatigue usage less than 0.5. The fatigue evaluation results, which are tabulated In Table 3-1, are summarized as follows:
SRV Discharge Piping:
Percent less than 0.3 fatigue usage -
72.7%
Percent less than 0.5 fatigue usage -
100%
A very conservative methodology has been developed for fatigue analysis of Mark I Class 2 piping. The fact that the calculated fatigue usage factors are low coupled wit the very conservative approach used to develop the fatigue analysis methodology shows that fatigue is not a concern for attached piping.
Thus this report answers the concern expressed by the NRC regarding the effect of cyclic mechanical loads on fatigue. Accordingly, there Is no need for a complete evaluation of torus piping fatigue on a plant-unique basis.
B. Yes. There are no significant changes In the function or performance of theSRVe for EPU conditions. The SRV sizes. Rx dome pressure, SRV set points remain the same as for original licensed power. Also, checked flow condltions at the exit of the SRVs limits any significant increase In flow for the SRV discharge piping. Reference W-RPT-05-00087, Rev.0.
EPU Task Report for ER 04-1409.
Additional Information:
Based on a review of plant operating records, VYNPS has estimated approximately 150 actuations of a safety relief valve In 35 years of operation.
Extrapolating this number to 60 years gives less that 260 lifts, or less than 65 lifts per valve. This is less then. 1% of the analyzed 7500 lifts.
318 The CUF values in LRA Table 4.3-1 that are based on NUREG CR 6260 are not applicable to VY and need to be removed and the Issue addressed.
Please clarify the commitment made to perform a fatigue re-analysis to be used to address environmental impact. The re-analysis needs to be made to a single code date.
License Renewal Commitment #27 IRA Amendment LRA table 4.3-1 will be amended to remove the NUREG/CR-6260 values.
LRA table 4.3-3 wig be amended to enter NA" for the CUFs for the core spray safe end, feedwater piping, RHR return piping, and RR piping tee entries. VYNPS will replace these entries with VYNPS-specsfic values as discussed below.
For the NUREGICR-6260 locations, VYNPS wil determine CUFa incorporating the potential effects of reactor water environment by applying Fen factors to valid CUFs determined by one of the following methods.
1 OFor locations with existing fatigue analysis. use the existing CUP.
20More limiting VYNPS-specdic locations with a valid CUF may be substituted for the NUREGC-CR-6260 locations.
3DRepresentative CUF values from other plants or from NUREG/CR-6260 may be used if they are adjusted to or envelope the VNPS-specilic external loads.
40An analysis using an NRC-approved version of the ASME code may be performed for the NUREG/CR-6260 location to determine a valid CUF.
Commitment 27 will be revised to Indicate a due date of 2 years prior to the period of extended operation and to include reference to performing the analysis to an NRC-approved version of the ASME code.
Accepted
319 LRA Page4.3-3 and 4 -
A) Discuss how VY developed the condensed list of transients provided In Table 4.3-2 from the complete list in the design spec. Also provide a copy a the design-spec(s) with the complete list of transients for NRC review.
B) LRA Pg 4.3-4 Modify the statement on the bottom of Pg 4.3-4 that the TLAA remains valid except for exceptions where CUF including EAF for 60 years exceed 1.0. please discuss the exceptions.
320 LRA Page 4.3-5 Ensure that Reference 4.3-1 is correct If not, provide the correct reference 321 LRA Section 4.3.1.2 - Reconole/revise the discrepancy in Section 3 tables and Section 4.0 on whether a plant-specific analysis is performed.
LRA Amendment Accepted A) The condensed list of transients In Table 4.3-2 was developed to simplify f
cycle tracking by the plant operations staff. The basis for reducing the number of transients tracked is contained in Calculations VYC-378 Rev.0 and Rev.1. Attachment I of VYC-378 Rev.1 Is titled "Recommendatons for Tracking/Limiting Reactor Transient Events for Vermont Yankee Nuclear Power Station, November 13,1987. The complete list of design transients Is contained in Attachment 1 pgs 24 to 27 and 31 to 32. Copies of VYC-378 Rev.0 and Rev.1 were provided for review.
The updated Reactor Vessel Specification for Extended Power Uprate Is GE Specification No. 26A6019 Rev.1 dated 6=202O03. It Is supplemented by the original GE Reactor Vessel Design Specification No. 21 Al 115 Rev.4 issued 10/21/169.
Copies of both specifications were provided for review.
B) The last paragraph of Section 4.3.1.1 will be clarified as follows.
The VYNPS Fatigue Monitoring Program will assure that the allowed number of transient cycles Is not exceeded. The program requires corrective action if transient cycle limits are approached. Consequently, the TLAA (fatigue analyses) based on those transients will remain valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i). However.
when the effects of reactor coolant environment on fatigue are added to the existing fatigue analyses, several locatixns have a projected cumulative usage factor In excess of 1.0. See section 4.3.3 for further discussion of the effects of reactor water environment on fatigue.
IRA Amendment Accepted The correct reference is letter BW96-96. not 96-4&. The originator, addressee, title and date were correct, only the letter number was wrong.
The following Is the correct citation for Reference 4.3-1.
4.3-1 Solka. R. E. (VYNPS), to USNRC Document Control Desk. 'Response to Request for Additional Information Regarding Vermont Yankee Core Shroud Modification,' BVY 96-96, letter dated August 7, 1996.
LRA Amendment Closed Tables 3.1.2-1. 3.1.2-2 and 3.1.2-3 Will be revised to eliminate ¶TLAA
- metal fatigue" whenever there is no corresponding TLAA in Section 4.0.
This requires an amendment to the IRA.
Close item to #309.
0~
0 on.
322 LRA Section 43.1.3 - Table 4.3-1 stated that piping that no plant specific fatigue analysis was found/perforned for RHR to RR Tee. However, Section 4.3.1.3 says that such analysis was perormed. Please resolve this discrepancy.
IRA Amendment Accepted The statement in Section 4.3.1.3 was taken from GE calculations 23A559 (RR Loop A Stress Analysis) and 23A5570 (RR Loop B Stress Analysis).
Upon review of the RR piping replacement project records, no such fatigue analyses were located. The statement was made as part of the GE template for these calculations as many plants were replacing the RR piping to the ASME Section IlII code. VYNPS replaced their piping to the original B31.1 code rather than ASME Section III and no planit specific analysis was performed for VYNPS. Unfortunately the statement was not deleted from the report and the statement was then quoted in the LR application. This requires an amendment to the LRA to achieve consistency between Section 4.3.1.3 and Table 4.3-1.
In addition, we will modify section 4.3.2 to make changes consistent with 4.3.1.3. We will add a statement summarizing Section 2.Z2 of LRPD-06 that none of the non-class I non-piping components have TLAA.
Section 4.3.1.3 and 4.3.2 should read as follows.
4.3.1.3 Class I Piping and Components VYNPS replaced reactor recirculation (RR) system piping In 1986. Also replaced were connecting portions of the residual heat removal (RHR) system piping. The new piping was designed and analyzed to ANSI B31.1 but was Inspected and tested to ASME Section III requirements. Stress analyses for the reactor recirculation system were performed to B31.1 requirements.
B31.1 does not require a detailed fatigue analysis that calculates a CUF, but allows up to 7000 cycles with a stress reduction factor of 1.0 in the stress analyses. The 7000 thermal cycle assumption is valid and bounding for 60 years of operation. Therefore, the pipe stress calculations are valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1).
There are no TLAA for Class 1 non-pipIng components other than the reactor vessel as none of them are designed to codes that require fatigue analyses.
UFSAR Section 4.6.3 states that the main steam Isolation valves are
- designed for 40 years based on 100 cycles of operation the first year and 50 cycles of operation per year thereafter. This statement may be interpreted to Imply a TLAA. This TLAA will remain valid through the period of extended operation per 10 CFR 54.21(c)(1)(1. The MSIVs will not exceed 2050 cycles SIn 60 years (34 cycles per year].
4.3.2 Non-Class 1 Fatigue The design of safety class 2 and 3 piping systems Incorporates the Code stress reduction factor for determining acceptability of piping design with respect to thermal stresses. The design of ASME B31.1 Code piping also Incorporates stres reduction factors based upon an assumed number of thermal cycles. In general. 7000 thermal cycles are assumed, leading to a stress reduction factor of 1.0 In the stress analyses. VYNPS evaluated the validity of this assumption for 60 years of plant operation. The results of this evaluation Indicate that the 7000 thermal cycle assumption is valid and bounding for 60 years of operation. Therefore, the pipe stress calculations are valid for the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(i).
There are no TLAA for any non-clss I non-piping components as none of
them are built to codes that require fatigue analyses.
Some applicants for license renewal have estimated that piping In the primary sampling system will have more than 7000 thermal cycles before the end of the period of exended operation. The sampling system Is used to take reactor coolant samples every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> during normal operation. However.
the normal samples are taken from the RWCU filter Influent, where the water has already been cooled. Thus normal sampling does not cause a thermal cycle. Alternate samples may be taken directly from the B discharge header of the reactor recirculation system via containment penetration X-41; however. this Is an infrequently performed procedure and this piping.
designed to ASME B31.1, will not exceed 7000 cycles prior to 60 years of operation.
The deletion of the RHR to RR tee CUF from table 4.3-3 will leave a blank for this component Other deletions will be made from this table per database question 318." WNPS will complete tMe table per Ucense Renewal commitment #27 as explained in response to Item 318.
-n
323 Does VY plan to perform Environmentally Assisted Fatigue (EAF) on plant specific locations or NUREG 6260 locations?
Does tou revised FW nozzle analysis (Table 4.3-3) include high cycle fatigue?
If not, please explain why.
VY plans to review the NUREG-6260 locations versus the VY plant Closed configuration, and confirm whether they represent the limiting locations for VY. VY will then calculate Environmentally Assisted Fatigue (EAF)
Cumulative Usage Factors (CULs) for the NUREG-6260 locations and supplement these with plant-specific lImiting locations as required. See Commitment No. 27.
The revised FW nozzle analysis, documented In Structural Integrity Associates Report SIR-04-020, does not Include high cycle fatigue. The analysis evaluates the feedwater nozzle for the design transients contained in GE specifications No. 21A! 115, 'Reactor Pressure Vessel, and No.
26A6019, Revision 1, 1Reactor Vessel - Extended Power Uprate'. The design transients do not include 'high cycle' fatigue.
HKgh cycle fatigue In BWR Feedwater nozzles Is attributable to leakage of relatively cold feedwater around the thermal sleeve mixing with the hot water in the annulus returning from the steam dryer and steam separator. The mixing of the cold feedwater and the hot water in te annulus results in rapid thermal cycling In the nozzle blend (inner radius) region. The rapid thermal cycling causes cracks to develop in the stainless steel clad on the blend radius. Subsequent system cycling can cause these surface cracks to grow Into the nozzle base metal.
In response to Generic Letter ao-095 and NUREG-061 9, VY performs Inspections on the feedwater nozzles. To support the inspection frequency requirements, calculation VYC-10056 'Crack Growth Calculation for Vermont Yankee Feedwater Nozzles" was developed. This calculation isa fatigue crack growth calculation of a postulated flaw In the blend region. Inspections are scheduled prior to the postulated flaw growing to 20% of the ASME Section XI maximum allowable flaw size. The current version of the caiculation Is VYC-1005, Revision 2. The methodology used Is in compliance with GE BWR Owners Group Topical Report 'Alternate BWR Feedwater Nozzle Inspection Requirements'. GE-NE-523-A71-0694.
Revision 1, August 1999. and the NRC Final Safety Evaluation (TAC No.
MA6787) dated March 10, 2000.
In summary, VYNPS manages this aging by monitoring system thermal cycles and perlodlicaty inspecting to assure cracking has not Initiated. The NRC has previously reviewed and approved this approach, reference Letter D.H. Dorman (USNRC) to DA Reid (VYNPC).
Subject:
Evaluation of Request for Relief from NUREG-061O9 for VYNPS dated 2/6/95, (TAO No. M88803).
CLOSED TO RAI 4.3-H-02 U)
CD 0
t 0'
nI, 324 GE Spec - Clarify how code case N-415 on alternate rules for pressure relief devices relates to fatigue evaluation described In the final T0302 Vessel Integrity Report 325 GE Spec-Provide for review only, proprietary versions of NEDC-32424P-A (Reference 1.1)
NEDC-32523P-A (Reference 1.2)
The reference in T0302 Is not to an ASME Code Case; It is to paragraph N-415 of Sect III of the 165 version of the code. Section N-415 Is tited
'Analysis of Cyclic Operation and is applicable as referenced.
Copies of these reports have been provided.
Closed Closed
326 Please provide the fatigue analysis as referenced In the EPU-FSAR:
- PUSAR Table 3.7 327 Do you have any plans to use "Fatigue-Pro* other than for cycle counting?
so, explain and supplement application as appropriate.
328 B.1.13-M-01 The staff has discovered, as a result of previous discussions with the applicant, that the VY FAC program calculations are very specific In terms calculations, as compared to other wail thickness applicants that we have reviewed Please provide us with a couple of examples of these calculasior 329 B.113-M-02 The stafl has also noted In their review of the LRA. that the VY program operational experience appears to be above average in discovery and Identification of FAC-related Issues. Please provide us with a couple of examples of piping FAC discovery using the present program.
330 3.1.1-19-P-03 How does Vermont Yankee do volumetric examinations of small bore pipir socket welds?
There Is no reactor vessel Intemals fatigue analysis using the 1986 ASME Section III code as a guideline. The fatigue analysis listed in the PUSAR is Task 0303 and it references NEDC-32424P-A and NEDC-32523P-A; copies of these analyses were provided In response to question 325.
If Current plans for Implementing Fa4uePro at VY are to use Stress Based Fatigue (SBF) monitoring for the Feedwater Nozzles. Automated or manual cycle counting (CBF) are planned for the remaining components.
Components Identified for automated CBF were selected using the following criteria; components with a design basis usage factor greater 0.40 for 40 yrs, Class I piping components or where field experience suggests that a fatigue concern exists.
The transient data acquisition capabiities in FatiguePro may be used for future development of S8F models and/or operational transient cycle counting for components as required to address operational changes and/or environmentally assisted fatigue concerns.
Provided RFO 25 (Fall 2005) large bore Inspection report evaluations for Inspection nos. 2005 -01, 2005-02 2005-09, 2005-10,2005-36. and 2005-37; of and small bore evaluations 05-SBO2 and 0&_SB03. Also provided a copy of RFO outage inspection report W-RPT-06-000002 Rev.0.
Is.
Provided scoping / planning worksheets for both RFO 25 and RFO 26. These list FAC Industry OE evaluation for VY.
UcensI Renewal Commimient #16 Ig VYNPS performs visual examinations of these welds as required by Section XI of the ASME code.
The One-rune Inspection program will also Include destructive or non-destructive examination of one (1) socket welded connection using techniques proven by past Industry experience to be elfective for the Identification of cracking In small bore socket welds. Should an Inspection opportunity not occur (e.g.. socket weld failure or socket weld replacement), a susceptible small-bore socket weld will be examined either destructlvely or non-destructively prior to entering the period of extended operation.
Closed Closed Closed Closed Accepted I
- .. [." -.
331 32.2-H1.07 In Tabte3.2.2-1 of Section 3.2 In the IRA System Walkdovvr Program Is used to manage loss of material In the bolting components. Please provide justification why System Walkdown Program Instead of NUREG-1 801 Is recommended Bolting Integrity Program.
License Renewal Commitment #34 Accepted LRA Amendment The System Walkdown Program is used to manage loss of material In bolting through the use of visual Inspectiocs that are performed at least once per refueling cycle. The GALL Bolting Integrity Program XI.M18 also credits the system walkdown program for the detection of leakage In bolted joints which could lead to loss of material but does not specify an Inspection frequency.
The application of the System Walkdown program to manage loss of material Is therefore consistent with the GALL XI.M18 program.
332 3.2-2-H1 -08 In Table 3.2.2-1 on Page 3.2-35 of the IRA, can the applicant provide Justification why Service Water Integrity Program Is used to manage cracking In stainless steel raw water environment? The scope of the program does not include cracking as a managed effect. What controlled techniques will be used to manage cracking?
333 3.2.2-1-11-09 In Table 32s of the LRA, please Justify the use of System Walkdown Program on bolting components with loss of material aging effect. The NUREG-180t recommends Bolting Integrity Program please Justify your position on these Section 3.2 line Items.
In addition, a Bolting Integrity Program Is In development that will address the aging management of bolting in the scope of license renewal. The Bolting Integrity Program will be Implemented prior to the period of extended operation in accordance with commitment number 34.
The component In question Is the heat exchanger tubes In the RHR heat exchanger. These tubes are cooled by service water and can be exposed to temperatures above the threshold for stress corrosion cracking on the RHR side of the tubes. Since this heat exchanger Is cooled by service water it Is pait of the Service Water Integrity program. In LRPD-02 section 4.20.B.1.b the scope of this program includes the aging effect of cracking. As described In section 4.20.1.4.b under Detection of Aging Effects, heat exchanger tubes are eddy current tested to detect the presence of cracking. The RHR heat exchanger tubes identified by this line item are periodically eddy current tested which would detect the presence of cracking.
License Renewal Commitment #34 IRA Amendment The System Walkdown Program is used to manage loss of material In bolting through the use of visual inspections that are performed at least once per refueling cycle. The GALL Bolting Integrity Program XI.Mt 8 also credits the system walkdown program for the detection of leakage In bolted joints which could lead to loss of material but does not specify an Inspection frequency.
The application of the System Walkdown program to manage loss of material Is therefore consistent with the GALL)XI.Mt 8 program.
In addition, a Bolting Integrity Program Is In development that will address the aging management of bolting In the scope of license renewal The Bolting Integrity Program will be Implemented prior to the period of extended operation In accordance with commirnent number 34.
This item concerns materials susceptible to IGSCC that would have been the subject of Generic Letter 88-01. A copy of the VYNPS response to G.L 88-01 was provided for review as were drawings of the RWCU system and the Piping specificaton. Based on the Information In the response to G.L 88-01, none of the piping In the RWCU system Is susceptible to IGSCC. Therefore, the GALL BWR Reactor Water Cleanup System Program )U.M25 Is not required for aging management Closed Accepted 334 3.3.1-37-K-01 Please provide documentation of the material(s) used In the RWCU system.
Including welds.
Closed
335 3.3.1-61-W-1 In Table 3.5.2-6 on page 3.5-80 of the LRA for component Peneltxalon sealant, material elastomer in a protected from weather environment; the aging effects are cracking and change In material properties. Two AMPs are shom. Fire Protection and Structures Monitoring. The referenced GALL line item is VII.G-1 and the Table 1 ltne Item Is &3.1-61. GALL ne Item VII.G-1 is for component Fire barrier penetration seals. In the LRA on page 3.3-49 for table I line Item 3.3.1-61-W-1 There Is this sentence In the discLssion: Cracking and the change in material properties of elastomer seals are managed by the Fire Protection Program.
Explain why this AMR linr item is not split Into two lines: (1) penetration sealant (fire) with AMP Fire Protection, GALL reference VILG-1, Table 1 ine Item 3&3.1-61 and a note B as wall as (2) penetration sealant (flood, radiation) with AMP Structures Monitoring. GALL reference II1.A5-12, Table 1 line Item 3.5.1-44 and a note C.
LRA Amendment Accepted In Table 3.5.2-6 on Page 3.5-80 of the IRA, the aging effects for component Penetration sealant, material elastomer In a protected from weather environment are cracking and change In material properties. For clarification.
this component line item wil be aeparated into two line Items as follows.
In Table 3.52-6 on Page 3.5-80 of the LRA, the aging effects for component Penetration sealant, material elastomer in a protected from weather environment are cracking and change in material properties. For clarification, this component tine Item will be separated into two tine Items as follows.
Delete tine item:
Penetration sealant (fire, flood, radiation)
- EN. FB, FIB, PB, SNS
- Elastomer
-Protected from weather
- Cracking Change in material properties
- Fire protection Stnictures Monitoring
- IILA5-12 (TP-7)
- 3.5.1-44
-C Add lUne items:
Penetration sealant (fire)
- EN. FB. PB, SNS SEtastomer
- Protected from weather SCracking Change in material properties
- Fire Protection
- VI.G-1(A.1g)
- 3.3.1-61
-8 Penetration sealant (flood, radiation)
- EN, FLB. PB, SNS
- Elastomer
- Protected from weather
- Cracking Change In material properties StructuresI Monitoring SIlI.AS-12 (TP-7)
-3.5.1-44
-C
336 3.3.1-61-W-2
'in Table 3.5.2-6 on page 3.5-60 of the LRA for component Seismic isolation joint, material elastomers In a protected from weather environment; the aging effects are cracking and change In material properties. The AMP shown Is Fire Protection. The referenced GALL line Item Is Vii.G-1 and the Table I line tem Is 3.3.1-61. GALL line Item VI.G1 Is for component Fire barrier penetration seals. In the LRA on page 3.3-49 for table 1 line Item 3.3.1-61 there is this sentence in the discussion: "Cracking and the change in material propertlee of elastomer seats are managed by the Fire Protection Program."
There is no mention of seismic gaps.
In the IRA on page 3.6-39 for table I line Item 3.5.1-44 there are these sentences in the discussion: "Loss of sealing Is a consequence of elastomer cracking and change In material properties. Component types Include:
moisture barrier. cormpresible joints and seals used for seismic gaps, and fire barrier seals. The Structures Monitoring Program manages cracking and change in material properties.- Since this discussion talks about seismic gaps and lire barrier seals, explain why this AMR lUne Item does not show Sructures Monitoring as the AMP instead of Fire Protection with GALL reference IILA6-1Z Table 1 line Item 3.5.1-44 with note C.
LRA Amendment In Table 3.62-6 on page 3.5-80 of the LA, the aging effects for component Seismic isolation,oint, material elastomers In a protected from weather environment are cracking and change in material properties. The AMP shown Is Fire Protection. The referenced GALL line Item is VII.G-1 and the Table 1 line Item is 3.3.1-61. The following changes will be made.
- 1) Note C wil be changed to Note'E'
- 2) The discussion In Table line Item 3.3.1-61, Page 3.3-49 will be clarified to read as follows.
'This line Item was not used in the auilary systems tables. Fire barrier seals are evaluated as structural components In Section 3.5. Cracking and change in material properties of elastomer seals. including seismic isolation joints located In fire barriers, are managed by the Fire Protection Program!
- 3) An additional line item will be added to read as follows.
Seismic isolation joint
-SSR
- Elastomer
- Protected from weather
-Cracking Change In material properties
-Structures Monitoring
- IIIA6-12 {TP-7)
- 3.5.1-44
-C LRA Amendment In Table 3.5.2-6 on Page 3.5-72 of the LIRA. the aging effect for component Fire doors, material carbon steel In a protected from weather environment Is loss of material.
'Note C' will be changed to 'Note B' since the component matches NUREG-1801 and the AMP has exceptions.
Accepted 337 3.3.1-63-W-1 In Table 3.52-6 on page 3.5-72 of the IRA for component Fire doors, material carbon steel In a protected from weather environment; the aging effect is loss of material. The referenced GALL line item Is VII.G-3 and the Table 1 ine Rem Is 3.3.1-63. GALL line Item VII.G-3 is for component Fire rated doors.
Explain why the note is C. (different component but consistent with GALL otherwise) for this AMR fine Rem, Instead of note B (Consistent %Mth GALL. but AMP takes exceptions)
Accepted
338 3.3.1-71-K-01 Diesel system carbon steel piping, piping components, and piping elements exposed to air axe to be Inspected for loss of material Please provide implementing procedures that are used to manage Ibis aging effect 339 3.2.2-H1-10 In Table 3.2.2-7 of the IRA, why Is Contairnent Leak Program used to manage loss of material in untreated water environment? Why is the Service Water Integrity not used to manage these line items?
It Is understood that the line items being referred to are carbon steel components exposed to untreated ak that credit the Periodic Surveillance and Preventive Maintenance (PSPM) program. The tasks that are proposed to perform the inspections of these components currently require enhancement to Include the components and perform the inspection and are not available for review, but will be created prior to the period of extended operation. However, in Attachment 3 of LRPD-02 'Aging Management Program Evaluation Results" there Is a listing of the activities Included In the PSPM program. The line Item in this table applicable to these components is listed under AMRM-13 Credited Activities (Emergency Diesel Generator System).. This listing provides the following Infonnation about each of the activities:
- Procedure or activity to be enhanced or created,
- scope of program,
- parameters monitored or inspected,
- detection of aging effects and acceptance criteria.
The untreated water environment In these components is in the Drywell floor drains sump and equipment drains containment penetrations and is not service water which would be called out as an environment of raw water.
Therefore, the service water program would not be appropriate to manage this component Since this is a containment penetration It Is tested as part of the Containment Leak Rate Program which performs containment penetration leak rate testing. The testing of this penetration confirms the integrity of the penetration and provides evidence that there are no significant aging effects present that could Impact the ability of the containment penetration to perform its Intended function of isolating conalnenL In addition, the penetration will be visually inspected during the testing process while connecting test equipment to confm the lack of significant aging effects. As documented In LRPD-02 the Containment Leak Rate Program Is supplemented by the Containment Inservice Inspection Program which peforms inspections of containment Including the penetrations.
Closed Closed
340 3.32-1-11 In the Standby Gas Treatment System the valve body and piping components In a raw water environment is managed by Periodic Surveillance and Preventive Maintenance Program, what procedures and following actions are used to manage this component?
It Is understood that the line Items being referred to are carbotstainless steel components exposed to raw water that credit the Periodic Surveillance and Preventive Maintenance (PSPM) program. The tasks that are proposed to perform the Inspections of these components currently require enhancement to Include the components and perform the Inspection and are not available for review, but will be created prior to the period of extended operation.
However, in Attachment 3 of LRPD-02 "Aging Management Program Evaluation ResultsW there is a listing of the activities Included In the PSPM program. The line item In this table applicable to these components Is listed under AMRM-07 Credited Activities (Standby Gas Treatment System).. This sting provides the following Information about each of the activities:
Procedure or activtty to be enhanced or created, scope of program, parameters monitored or inspected, detection of aging effects and acceptance criteria.
The demister drainage system Is captured In the PSPM program when It is developed. Provided copies of the following: Dwg G-191238, ME-118 (PM Basis) and various photos of the Standby Gas Treatment dernister drainage system to demonstrate evidence of maintenance and Inspection that Is performed on the demister drainage system.
It is understood that the line items being referred to are steel ducting and components exposed to condensation (Cit) that credit the Periodic Surveillance and Preventive MaIntenance (PSPM) program. The tasks that are proposed to perform the Inspections of these components currently require enhancement to perform the inspection and are not available for review but will be created prior to the period of extended operation. However, in Attachment 3 of LRPD-02 *Aging Management Program Evaluation Results" there Is a listing of the activities Included in the PSPM program. The line items In this table applicable to these components are listed under AMRM-1 9 credited activities (Heating, Ventilation and Air Conditioning System) and AMRM-1 1 credited activities (Service Water Systems) This listing provides the foliowing Information about each of the activities:
Procedure or activity to be enhanced or created, scope of program, parameters monitored or Inspected, detection of aging effects and acceptance criteria.
Closed
.341 3.3.1-72-K-01 Steel HVAC and SWS system ducting and components exposed to condensation (Internal surfaces) are to be inspected. Please provide the Implementing procedures that are used to manage this aging effecL Closed
342 3..2-10-W-1
[Original Question]
In Table 13.2-10 on page 3.3-126 of the LRA for component Duct flexible connection, material fiberglass in an Air Indoor (int) environment; the aging effect is none. Provide the technical basis justifying that fiberglass material does not have any aging effects in an indoor air environment.
IFollow-up Question]
For other non-metallic components, two mechanisms of degradation (from sustained vibratory loading and from wea) were considered. Please clarify the basis for concludng that these aging mechanisms are not applicable to flexible duct connections of fiberglasss, IRA Amendment
[Odginal Response]
The aging effects were based on the Non-Class I Mechanical Implementation Guideline and Mechanical Tools, Revision 3, EPRI, Palo Alto, CA: 2001. 1003056 (The Mechanical Tools). The evaluation of aging effects for non-metalics In air Is Included in Appendix 0 of the Mechanical Tools..
This section concludes for non-metallics other than elastomers there are no aging effects requiring management.
[Follow-up Question Response]
Response: As shown in LRA Section 3.3 tables. the elastoner components exposed to indoor air and sAuject to aging management review are duct flexible connections In the heating, ventilation, and air conditioning system (LRA Table 3.3.2-10). These connections are an elastomer coated fiberglass duct fabric installed between ventilation fans and ductwork to reduce vibration and noise resulting from operation of the fans. Loss of material due to wear occuRS due to the relative motion between two surfaces. Since the connections are fixed at both ends and are not in contact with other components, they have no relative motion with other components that would produce an aging effect of loss of material due to wear.
In accordance with GALL and the Structural Tools, sustained vibration loading Is a mechanism that could lead to cracking of the fiberglass duct flexible connections. Since this component has an elsatomer coating.
VYNPS uses the Periodic Surveillance and Preventive Maintenance Program to manage cracking as a result of sustained vibratory loads as shown in IRA Table 3.3.2-10 Line Item [Duct flewible connection" Material / "eLstome.].
LRA Section 3.32.2.13 Loss of Material due to Wear will be revised to state the following, Wear Is the loss of surface layers due to relative motion between two surfaces. At VYNPS, in the auxiliary systems, this specific aging effect is not applicable because the heating, ventilation, and air conditioning eiastomer coated fiberglass duct flexible connections are fixed at both ends, precluding wear. This Item Is not applicable to VYNPS auxiliary systems.
The aging effects were based on the Non-Class 1 Mechanical Implementation Guideline and Mechanica] Tools, Revision 3, EPRI, Palo Alto, CA: 2001.1003056 (The Mechanical Tools). The silicone fluid used in these Instrument lines is a non-conductive and essentially inert fluid. The evaluation of aging effects for external surfaces is included in Appendix E of the Mechanical Tools. As can be seen in Appendix E Table 4-1, "Aging Effects Summary-Extemal Surface', there are no aging effects requiring management for external stainless steel surfaces exposed to silicone due to the inherent resistance of stainless steel to aging effects when not wetted by water or exposed to aggressive chemicals.
Accepted 343 3.32-11-W-1 In Table 3.32-11 on page 3.3-135 of the IRA for component Diaphragm, material stainless steel in a silicone (ext) environment; the aging effect is none. Provide the technical basis justifying that stainless steel material does not have any aging effects in a silicone environment.
Closed
344 3.3.2-13-40-W-1 In Table 3.3.2-13-40 on page 3.3-228 of the IRA for component Sight glass, material glass In a Sodium pentaborate solution (int) environment; the aging effect is none. Provide the technical basis Justifying that glass material does not have any aging effects In a sodium pentaborate solution.
345 3.3.2-13-9-W-1 In Table 3.32-13 on page 3.3-163 of the IRA for component bolting, material stainless steel in an air - outdoor (ext) environment; the aging effect is none.
NUREG-1 833 on page 93 for item TP-6 provides a new MEAP for stainless steel, in an Air-outdoor envirnment with an aging effect of loss of materlaVpitnng and crevice corrosion. In the precedent/technical basis column for this new MEAP It Is stated that an approved precedent exists for adding this material. environment, aging effect. and program combination to the GALL Report As shown in RNP SER Sectlpn 3.5.2.4.3.Z galvanized steel and stainless steel in an outdoor air environment could result In loss of material due to constant wetting and drying contditons. Discuss the location of the circulating water system boiling components at VYNPS and how they are protected from constant wetting and drying conditions.
346 3.3.2-6-W-1 In Table 3.3.2-6 on page 3.3-94 of the IRA for component flame arrestor.
material aluminum in an air -outdoor (eaxt) environment the aging effect is none. NUREG-1833 on page 93 for item TP-6 provides a new MEAP for aluminum. in an Air-outdoor environment with an aging effect of loss of materiaYpitting and crevice corrosion. In the precedent/technical basis column for this new MEAP It is stated that an approved precedent exists for adding this material, environment, aging effect, and program combination to the GALL Report As shown In RNP SER Section 3.5.2.4.3.2, galvanized steel and stainless steel In an outdoor air environment could result in loss of material due to constant wetting and drying conditions. Aluminum would also be susceptible to a similar kind of aging effect in the outdoor environment.
Discuss the location of the flame arrestor component at VYNPS and how It is protected from constant wetting sad drying conditions.
347 3.3.2-6-W-2 In Table 3.32-6 on page 3.3-96 of the LRA for component Piping, material fiberglass in a Fuel od (int) environment: the aging effect is none. Provide the technical basis Justifying that fiberglass material does not have any aging effects In a Fuel oa enrvironment.
The aging effects were based on section 2.1.8 of Appendix A in the Non-Class I Mechanical Implementation Guideline and Mechanical Tools, Revision 3, EPRI, Palo Alto. CA: 2001. 1003056 (The Mechanical Tools).
This section identifies for glass that there are no aging effects requiring management in a treated water environment as long as it is not In contact with hydrofluoric acid or caustics. The sight glass in question is on the test tank in the SLC system. The Test Tank and sight glass is filled with Demineralized Water (pH - 6.0 to 7.0) during testing. and the main SLC tank sodium pentaborate solution is also an essentially neutral solution (pH of 7.03)such that the sight glass can only be exposed to a neutral solution of treated water and sodium pentaborste that will not affect the glass.
IRA Amendment This Is an error in the LRA for this line Item. Stainless steel that Is exposed to outdoor air and wet/dry cycling is subject to loss of material. This correction requires an amendment to the IRA to identify loss of material as an aging effect which Is managed by the system wakdown program.
Closed Accepted In accordance with EPRI report 10010639 'Non Class 1 Mechanical Implementation Guideline and Mechanical Toolse aluminum is a material that Is highly resistant to corrosion In atmospheric environments. The outdoor air environment at VYNPS Is non aggressive due to lts remote location from Industrial facilities and salt water. As a result the amount of contaminants in the air do not provide an environment where wet/dry cycling from rain would concentrate contaminants to a sufficient degree that wouid lead to loss of material in aluminum.
The aging effects for fiberglass In fuel oil are based on the Non-Class I Mechanical Implementation Guideline and Mechanical Tools. Revision 3, EPRI. Palo Alto. CA: 2001,1003056 (The Mechanical Tools). Appendix C, section 2.1.6 of the guideline states "Therefore, based on industry operating expeatence review and the assumption of proper design and application of the material, aging of glass (Including fiberglass) and thermoplastics in lubrication and fuel oil environments is not an applicable aging effect" Closed Closed
348 33.2-6-W-3 In Table 3.3.2-6 on page 3-3-97 of the LRA for component Tank, material fiberglass in an Interstitial fluid (brine) (Int) environment; the aging effect Is none. Provide the technical basis justifying that fiberglass material does not have any aging effects In a Interstitial fluid (brine) environment.
The interstitial fluid (brine) environinent Is colored treated water with Closed antifreeze located between the Inner and outer walls of a double-walled fiberglass fuel oil tank and can be considered a treated water environment due to Its benign effects on materials. The fluld Is used for leak detection and Is provided by the manufacturer of the tank. The aging effects for fiberglass in interstitial fluid are based on Section 2.1.8 of the Non-Class I Mechanical Implementation Guideline and Mechanical Tools, Revision 3. EPPI. Palo Alto.
CA. 2001. 1003056 (the Mechanical Tools) which states;
'Therefore, based on industry operating experience review and the assumption of proper design and applcation of the material, aging of glass and thermoplastics in treated water environments is not an applicable aging effect.
349 33.2-6-W-4 In Table 3.3.2-6 on page 3.3-97 of the LIRA for component Tank, material fiberglass In an Interstitial fluid (brine) (Int) environment; the aging effect Is none. Provide the technical basis justifying that fiberglass material does not have any aging effects In a Interstitial fluid (brine) environment.
Duplicate of #348.
Closed
350 B.1.27.3-E-01 Please clardfy tMe FERC provisions under which the Vernon Darn Is Inspected.
The dam is now exempt from Provisions of Tide 18, Part 12, Subpart D.
(Inspection by Independent Consultant).
LRA Amendment Accepted The Vernon Dam is inspected in accordance with the Provisions of Title 18 Pars a and 12. The IRA Appendix A tern A.2.1.31 states that, subpart D (Inspection by Independent Consultant) is applicable, however an exemption from this requirement for an Independent consultant review has been received and this secondary review is no longer performed.
This will require the following:
- 1) LRPD-02 Section 4.21.3.8. Program Descryi
" will be revised to read; The Vernon dam Is subject to the Federal Energy Regulatory Commission (FERC) Inspection program. This program consists of visual Inspections In accordance with FERO guidelines and Is In conpliance with Title 18 of the Code of Federal Regulations, Conservation of Power and Water Resources, Part 12 (Safety of Water Power Projects and Project Works) and Division of Darn Safety and Inspections Operating Manual. The operation inspection frequency for licensed and exempt low hazard potential darns Is bier*ially.
NRC has found that mandated FERO inspection programs are acceptable for aging management.
LRPD-02 Section 4.21.3.C-SummaJy will be revised to read:
The Vernon Dam FERC Inspection (performed blennially) has been effective at managing aging effects...*
The Vernon dar is subject to the Federal Energy Regulatory Commission (FERO) Inspection program. This program consists of visual inspections In accordance with FERO guidelines and is In compliance with Tide 18 of the Code of Federal Regulations, Conservation of Power and Water Resources, Part 12 (Safety of Water Power Projects and Project Works) and Division of Dam Safety and Inspections Operating Manual. The operation Inspection frequency for licensed and exempt low hazard potential dams is biennially. As Indicated In NUREG-1 801 for water control structures, NRC has found that FERRC US Army Corp of Engineers dam inspections and maintenance programs are acceptable for aging management.
351 B,1.27.3-E-02 Please provide copies of Vernon Dam biennial FERC Inspection Reports Issued since 8/24/2002.
RAI 3.6.22.N-08 The requested Inspection reports are not readily available for security reasons. After September 11, 2001, access to Vernon Dam Inspection reports has been restricted. Entergy VY has worked wft the Vermont's Department of Public Service legal staff and has located these reports (e.g.
Vermont required access to these reports for the sale of Vernon Darn to TransCanada). Sarah Hofmann, Esquire and Director for Public Advocacy, Department of Public Service in Montpelier, VT (Phone # = 80282.8-3088),
can be contacted to view this Information.
Closed
352 Are the VY fatigue analyasm of record based on design rates of change of temperature, or on actual plant limits?
How will future analyses be done?
Follow on Question 6/26. Have Itre been transients In which the actual rates of change In temperature exceed the rates of change used in the design anayis?
353 Provide a copy of SIR-01-301 showing the system design transients for VY.
RAI 4.3-H-03 Closed The existing VY fatigue analyses are done based on design rates of change of temperature.
Future fatigue analyses will be based on design rates of change or on actual plant operating limits, if required, Follow on Question Response:
A review of early plant vessel thermal cycle experience is contained in calculation VYC-378 Rev.1 (at Attachment I page 56 of 131). Table 4 documents heatup-cooldown cycles from plant startup in 1972 thru 4/80. The table documents 7 cooldown events and 2 heatups occunring from 1972 through 1974 where the rate of temperature change exceeds 1OOF per hour.
However, each of these events applies to a limited time (typically 0.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) and only over a limited temperature range within the heatup or cooldown event. The maximum temperature change of 120F vs. the full temperature range of 446F (I OOF to 546F).
Theses events occurred In Mie early years of operation, with operating experience, Table 4 shows only one heatup in which the rate of temperature change exceed I1OF.
This was a scram on 2378 w*we the rate of change Is documented as 120Ffit. This was noted as non-typical due to loss of Vital AC.
A copy of SIR-01 -301 has been provided.
Closed F.,
-9
354 Do the analyses for internals (Section 4.7.2) Include all system transients?
Do the CUF values calculated in the BWRVIPs really apply to VY? If not, should these analyses be consIdered TLAA?
355 GE report 26A6019 states that some components have fatigue analyses done to later code versions than 1965. What are those components and code versions?
357 The PUSAR (Table 3-3 of NEDC-33090P) shows no changes to the stresses of components other than the FW nozzles. Why Is this correct when temperature and changed 0.6%.
LRA Amendment Accepted The TLAA discussed In Section 4.7.2-3 (Shroud Support) and Section 4.7.2.4 (Lower Plenum) are VYNPS specific calculations that are Included In Table 4.3-1 of the LIlA. These analyses are based on the VYNPS design system transients.
The analyses in Section 4.7.25 (Vessel ID attachment welds) and Section 4.72-6 (Instrument penetrations) are generic analyses performed in the BWRVIP documents. These are not WNPS specific calculations. As such, these are not TLAA for VY.
This requires an amendment to the LRA to delete Section 4.7.2.5 delete Section 4.72-6.
delete vessel ID attachment welds and Instrument penetrations from IRA Table 4.1-10 delete the crackIng-fatigue with TLAA-metal fatigue from the Internals attachments entry in LRA table 3.1.2-1 (page 3.1-54) Note cracking managed by the BWR Vessel ID Attachment Welds Program remains In the table.
delete the cracldng-fatigue with TLAA-metal fatigue from the nozzles.
Instrumentation, NI I and N12 In LRA table 3.1.2-1 (page 3.1-44). Note that cracking managed by the SWR Penetrations Program remains In the table.
delete Section A.2.27 delete Section A.292.8 No changes to App. B' or 'App. C Provided copy of PUSAR Chapter 3.2 which ists the RR nozzle safe ends Closed and Instrumentation'nozzle safe ends and the code year used for each. They were done to the 1982 version of ASME Section Ill.
Provided copy of PUSAR Chapter 3.2 which shows that the core spray safe Closed ends repair was performed using ASME Section XI, 1986.
As discussed In Sectlon 3.2.2.2 of NEDC-33090P. the original stress Closed evaluations were performed at conditions that bound the slight change in operating conditlons for the CPPU. Only the feedwater nozzle had enough of a change In parameters to need a re-calculation of CUF.
358 Please provide a description or a reference to the 'augmented class 2/3 For the Torus attached piping plant-specific fatigue analyses are performed fatigue methodology that was developed to account for cycle mechanical for each penetration.
loads.
The calculation for the SRV vent pipe penetratons is Teledyne Engineering Services (TES) Calculation No. 6319-28. Rev.0 SRV Vent Pipe Penetration Stress Evaluation Vermont Yankee SRV Unes A - D0. The penetration analysis Is performed using a finite element model of the penetration and vent pipe. Loads are taken from the attached piping model. Stress Intensities and secondary stress ranges are calculated and compared with ASME allowables. The fatigue evaluation is shown on page 65. Stress concentratlons from WRC Bulletin 107 are used. The maximum usage factor calculated is 0.49 for 10,000 cycles.
Closed For torus attached piping, the calculations ilrude an ASME stress evaluation of the torus nozzle. A local WRC Bulletin 107 type nozzle analysis Is performed and the results are combined with free shell stresses from a finite element model of the torus shel. Loads are taken from the attached piping model Stre Intensities and secondary stress ranges are calculated and compared with allowables. Stress concentrations from WRC Bulletin 107 are used.
A typical torus nozzle calculation Is (TES) Calculation No. 5319-X227.7 Rev.0
'Torus Attached Piping -X227. The fatigue evaluation Is shown on page 42.
The maxium usage factor calculated is 0.33 for 10.000 cycles.
359 3A2-M-04 Currently, In VYNPS LRA Section 3.4.2.1, the applicant identified the following programs that manage the aging effects related to the main condenser and MSIV leakage pathway components and component groups; 1) Flow-Accelerated Corrosion, 2) System Walk-Down, 3) Water Chemistry Control-BWR, and 4) Water Chemistry Control-Closed Cooling Water. Will the One-Time Inspection program be added to this listing?
LRA Amendment As stated in LRA Section B.1.30.Z the Water Chemistry Control - BWR Program Is consistent with the program described in NUREG-1 801,Section XI.,2. 'Water Chemistry.' The One-Trime 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 Chemisty Control - Closed Cooling Water) by confirming that unacceptable cracking. loss of material. and fouling is not occurring. As stated in LRA Section B.1.21, the One-Time Inspection Program is a new program which wIll be consistent with the program described in NUREG-1 801. Section X1M32, 'One-Time Inspection.'
IRA Tables 3.1.1,3+/-.1, 3.3.1. and 3.4.1 Indicate that the One-Tmne Inspection Program is credited along with th water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. For siplry, the subsequent tables (Table 2's) do not list the One-Time Inspection Program each time a water chemistry control program is listed. However, since the One-Time Inspection Program is applicable to each water chemistry control program, it is also applicable to each Une item that credits a water chemistry control program.
To provide further clarification, the effectiveness of the Water Cheml.sty Control - Aurdliary Systems. BWR. and Closed Cooling Water programs is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A, SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.
No. there have been no changes In the scope of equipment subject to aging management review since the sooping and screening results presented in the application were approved. No plant changes have been implemented that would affect the Intended functions for license renewal. The statements in Section 3.4.2.22 of the application remain valid. There are no steel or stainless steel tanks exposed to bested water with Intended functions in the steam and power conversion systems. The Intended function of main condenser and MSIV leakage pathway components, for post-accident holdup and plate-out of MSIV leakage is continuously assured by normal plant operation and cannot be affected by aging effects.
No, there have been no changes In the scope of equipment subject to aging management review since the scoplng and screening results presented in the application was approved. No plant changes have been Implemented that would affect the intended functions for license renewal. The statement in Section 3.4.22.2.2 of the application remains valid. There are no steel components exposed to lubricating oil with intended functions In the steam and power conversion systems.
Accepted
-. 7 01 0
0n-360 3.4.2-M-06 In Section 3.4.2.22 of the LRA, the applicant stated hat....there are no tanks or steel heat exchanger components Included in the steam and power conversion systems.- They also stated that. -. the condenser Is Included as par of the main condenser and MSIV leakage pathway but has no aging effects= requiring aging management since their intended function Is for holdup
& plate-out of radioactive materials. Have any changes occurred since Initial scoping that would change the above statement.
361 3.4.2-M-06 In Section 3.4222Z of the IRA. the applicant stated that (in reference to the steam and power conversion systems at VYNPS) I...they have no carbon steel components requiring aging management which are exposed to lubricating ciL" Therefore, they further state that *...this specific Item is not applicable to VYNPS. Have any changes occurred since initial soeping that would change the above statement.
Closed Closed
362 3.4.2-M-07 The applicant stated, in Section 3.4Z2.3 of the IRA, that "...for loss of material due to general, pitting, crevice. MIC, and fouling - which could occur In steel piping. piping components, amd piping elements exposed to raw water - In the steam and power conversion systems at VYNPS; they have no carbon steel components requiring aging management which are exposed to raw water.' Therefore, they further state that I...thls Item is not applicable to VYNPS. Have any changes occurred since Initial scoping that would change the above statement 363 3.4.2-M-08 The applicant stated, In Section 3.4.2.5.1 of the LRA, that I...for the loss of material due to general, pitting, crevice, and MIC - which could occur In carbon steel (with or without coating or wrapping) piping, piping components, piping elements and tanks exposed to sod - In the steam and power conversion systems at VYNPS; they have no carbon steel components requiring aging management that are exposed to soll." Therelora, they lurther state that '...ths item Is not applicable to VYNPS. Have any changes occurred since itial scoping that would change the above statement.
364 3"4.2-M-09 The applicant stated, In Section 3.422.7.2 of the LRA, that *...for the loss of material due to pitting and crevice corrosion - which could occur In sainlss steel piping, piping components, and piping elements exposed to soil - In the steam & power conversion systems at VYNPS; they have no stainless steel components requiring aging management that are exposed to soll."'Therefore.
they further state that "...this Item is not applicable to VYNPS. Have any changes occurred since Initial scoping that would change the above statement. Have any changes occurred since Initial soping that would change the above statement.
365 3"2.-Hl-12 In Section 3.2 of the LRA, there are numerous line Items In Table 3"2'a with TLAA-metal fatigue as the Aging Management Program. Can you provide the staff with the TLAA analysis for each line item?
366 3.4.1-M-04 Currently, In VYNPS LRA Table 3.4.1. Item 3.4.1-23 discussion column, the applicant states, I...the cracking of stainless steel piping, piping components, and piping elements exposed to closed cycle cooling water >60 C (> 140 F) due to SCO is not applicable at VYNPS.' In light of statements presented in GALL VIII.E-25 (for the Condensate System), further explain how this "MEA" combination Is not applicable to VYNPS.
No, there have been no changes in the scope of equipment subject to aging management review since the scoping and screening results presented in the application were approved. No plant changes have been implemented that would affect the Intended functions for license renewal. The statement in Section 3.4.2.2.3 of the application remains valid. There are no steel components exposed to raw water with intended functions In the steam and power conversion systems.
No, there have been no changes in the scope of equipment subject to aging management review since the scoping and screening results presented In the application were approved. No plant changes have been implemented that would affect the Intended functions for license renewal. The statement In Section 3A.2.2.5.1 of the application remains valid. There are no steel components with Intended functions exposed to soil in the steam and power conversion systems.
No, there have been no changes In the scope of equipment subject to aging management review since the scoping and screening results presented In the application were approved No plant changes have been Implemented that would affect the intended tunctions for license renewal. The statement In Section 3.4Z2.72 of the application remains valid. There are no stainless steel components exposed to soil with Intended functions In the steam and power conversion systems.
See response to Question 309.
Close Item to Item #309.
The discussion column entry for item 3.4.1-23 states, 'Not applicable. There are no stainless steel components exposed to closed cycle cooling water In the steam and power conversion systems.' This statement is meant to Imply that w*itn t*e steam and power conversion systems, there are no components with an Intended function for license renewal that are made of this material and exposed to this environment This may be confirmed by an inspection of Table 3.4.2-1. White there may be such components In systems that are included In the scope of license renewal, these components have been screened out because they are not needed to complete the license renewal intended functions.
Closed Closed Closed Closid Closed r-m 0'
co CD
.,)
367 3A.11-M-05 Currently, In VYNPS LRA Table 3.4.1, Item 3.4.1-35 discussion column. the applicant states, '...the loss of material of copper alloy >15% Zn piping, piping components, and piping elements exposed to closed cycle cooling water, raw water, or treated water due to selective leaching is not applicab at VYNPS.
In light of statements presented in GALL VIIIE-20 (for the Condensate System - Main Condenser Outside Tube Side). further explain how this "MEA" combination is not applicable to VYNPS.
The discussion column entry for Item 34.1-35 states, 'Not applicable. There are no copper alloy components subject to selective leaching in the steam and power conversion systems.* The only components within the steam and power conversion systems with an intended function for license renewal that are composed of copper with >15% zinc, are the condenser tubes. As Identified In plant specific note 401, the intended function of condenser components is for post-accident holdup and plate-out of MStV leakage. This function Is continuously assured by normal plant operation and cannot be affected by selective leaching of the tubes. Thus, this aging effect does not require management and is not Included in Table 3.52-1.
The discussion column entry for Item &4.1-23 states, "Not applicable. There are no gray cast iron components exposed to raw water with intended functions in the staam and power conversion systems. This statement is meant to Iply that wYthM the steam and power conversion systems, there are no components with an intended function for license renewal that are made of this material and exposed to this environment. This may be confirmed by an Inspection of Table 3.42-1. White there may be such components In systems that are Included In the scope of license renewal, these components have been screened out because they are not needed to complete the license renewal intended functions.
Closed Closed 0
0-11 368 3A.A-M-06 Currently. In VYNPS IRA Table 3.4.1, Item 3.4.1-36 discussion column, the applicant states,...tie loss of material of gray cast imn piping, piping components, and piping elements exposed to soil, treated water, or raw water due to selective leaching is not applicable at VYNPS." In light of statements presented In GALL VIII.E-22 (for the Condensate System - Main Condenser Piping), further explain how this 'MEA combination is not applicable to VYNPS.
t
369 3.2.2-H1-13 On page 3.2-49 why is cracking being managed by Oil Analysis Program.
when the program does not have a performance testing program to veri"y the effectiveness of the program.
IRA Amendment As stated in LRA Table 3.2.2-4 stainless steel components in the HPCI system at VYNPS that are exposed to lubricating oil are managed by the Oil Analysis Program, which includes periodic sampling and analysis of lubricating o0 to maintain the presence of water within acceptable limb, thereby preserving an environment that Is not conducive to cracking. As stated in LRA Section B.120, the Oil Analysis Program is consistent with the program described In NUREG-1801,Section XI.M39, Lubricating Oil Analysis, with a minor exception.
The Oil Analysis Program Is not consistent with GALL XIM32, One-Tkne Inspection. nor are one-time Inspections necessary to verity the effectiveness of the program. Cracking in lube oil systems can only occur with the presence of water. Therefore, an effective oil analysis program, which maintains the amount of water at levels that are not conducive to cracking. precludes the need for one-time Inspections. Operating experience at VYNPS has contfrmed the effectiveness of the Oil Analysis Program in maintaining moisture and Impurities within limits such that cracking has not and will not occur and affect the Intended functions of these components.
In numerous past prcedents (including NUREGo1828, Arkansas Nuclear One Unit 2 SER, Section 3.0..3.6, and NUREG-1831, Donald C. Cook SEP, Section 3.0.3.3.8), the staff concluded that an effective oil analysis program, which maintains Impurities and moisture below specified limits, is sufficiet to demonstrate that the effects of aging will be adequately managed so that the Intended luictions will be maintained consistent with the current ifcensing basis for the period of extended operation.
The One-TIme Inspection program wil be revised to include activities to confirm the effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs.
The component In question is a steam heater in the RCIC system. The entry says cracking-fatigue is an aging effect requiring management and It Is managed by the Heat Exchanger Monitoring program.
As suggested In questions 309 and 365, a metal fatigue TLAA is not automatically associated with every component exceeding the temperature threshold for cracking-fatigue. TLAA-metal fatigue is the appropriate enty only if there Is In fact a TLAA (faUgue analysis) for the component in question In this case there is no fatigue analysis and an AMP was specified that manages cracking-fatigue.
Accepted 7-ý 0
CD' 0u to 370 3.2.2-H1-14 On Table 322-5 page 3.2-66, can you provide justification why cracking-fatigue aging effect does not have a TLAA-metai fatigue, Aging Management Program?
Closed
.Di
-4,
371 In the Table 4.3-2 of VT LRA, the design basis cycles for Design Transient 6 (Reactor stairtupshutdown cycles) has to be determined based on the design analysis. Please provide LRA supplement to address this Issue LRA Amendment RAI 4.3-H-01 Acct 10 iii CD 0
Tiu 0
nv 372 3.3.1-22-K-01 Please confirm that no auxiliary components have elastomer linings or SS cladding-or if there are such components, provide additional justifcation for the determination that pitting and crevice corrosion do not require aging management.
373 3.3.1-34-K-O0 Please identify the plant-specIfic program that will be used to manage loss of material due to wear. It Is not clear to the project team that operating experience provides a sufficient basis for determining that this aging mechanism Is not applicable at VYNPS.
The IRA will be amended to Include the following discussion of the VYNPS transient monitoring program.
The VYNPS Fatigue Monitoring Program includes counting of the cycles incurred by the plant. Five transients are monitored by plant operations and recorded as they occur. It Is projectad that less than 60% of the design cycles for these five translents will be used through the fIrst 60 years of operation, Including the PEO. The remaining transients are monitored by plant engineering based on review of operating data at the end of each fuel cycle. These remaining transients are summarized In the Fatigue Monitoring Program as the sixth transient (Reactor Startups and Shutdowns).
Engineering evaluates these transients and advises operations if the number of design cycles is being approached RAI 3.3.1-22-K-01 As stated in IRA section 3.3.2.210, stainless steel cladding or elastomer linings are conservatively not credited to prevent loss of material of underlying carbon steel material in auxliary systems and as such are not Identified or known. Pitting and crevice corrosion are aging effects requilng management for the carbon steel auxiliary components exposed to treated water and are managed by the water chemistry control program.
IRA Amendment As shown in LRA Section 3.3 tables, the elastomer components exposed to Indoor air and subject to aging management review are duct flexible connections In the heating, ventilation, and air conditioning system (IRA Table 3.3.2-10). These connections are an elastorner coated fiberglass duct fabric Installed between ventilation fans and ductwork to reduce vibration and noise resulting from operation of the tans. Loss of material due to wear occurs due to tMe relative motion between two surfaces. Since the connections are fixed at both ends and are not in contact with other coripoents, they have no relative motion with other components that would produce an aging effect of loss of material due to wear.
LRA Section 3.3.22.13 Loss of Material due to Wear wll be revised to state, Wear Is the removal of surface layers due to relative motion between two surfaces. At VYNPS, In the auxiliary systems, this specific aging effect Is not applicable because the heating, ventilation, and air conditioning elastomer coated fiberglass duct flexible connections are fixed at both ends, precluding wear. This item is not applicable to WNPS a~uxliary systems.
Closed Accepted
374 3.3.1-50-K-02 Table I states that ¶]or stainless steel components of the demineralized water system, the Water Chemistry Control - Auxiliary Systems program manages loss of materiaL No items In 3.3.2-13-12 were found that credited this AMP. Please clarify.
375 3.3.1-51.-K-02 Table I states that "If)or copper alloy components of the...demineratzed water system... the Water Chemistry Control-Auxiliary Systems program manages loss of materiaL! No Items in 3.3.2-13-12 were found that credited this AMP.
Please clarify.
376 3.3.1-69-K-02.
In the discussion section of VYNPS LRA Table 3.3.1 item 3.3.1-69, the applicant stated that the loss of material in stainless steel components exposed to raw water is managed by the Fire Water System, Fire Protection.
and One-Trme Inspection Programs. During the audit and review, the project team noted that the applicant did not apply the One-Time Inspection Program to any AMR line items to which Table 3.3.1 Item 3.3.1-69 was applied. Please 3T7 3.3.1-73-K-01 Please confirm that aging management of steel crane structural girders in load handlilng will conform to the standards cited In GALL XLM23.
378 3.3.1-74-K-01 Please confirm that aging management of steeol crane rails will conform to the standards cited In GALL XLM23.
This error was previously noted and clarification supplied In the response to Audit Item 165 (see below).
To clarify, Items 3.3.1-50 and 3.3.1-51 In LRA Table 3.3.1. the Water Chemistry Control - BWR Program (not the auxiliary systems) Is credited for managing the effects of aging on the demineralized water system as Indicated in LRA Table 3.3.2-13-12, Deme*ralized Water (DW) System Nonsafety-Related Components Affecting Safety-Reisted Systems Summary of Aging Management Evaluation.
This error was previously noted and clarification supplied in the response to Audit Item 165 (see below).
To clarify Items 3.3.1-50 and 3.3.1-51 in IRA Table 3.3.1, the Water Chemistry Control - BWR Program (not the auxiliary systems) is credited for managing the effects of aging on the demineralized water system as Indicated In LRA Table 3.3.2-13-12, Demlneralized Water (DW) System Nonsafety-Related Components Affecting Safety-Related Systems Summary of Aging Management Evaluation.
LRA Amendment Reference to One-Time Inspection will be removed from the discussion column In table 3.3.1 item 69.
License Renewal Commitments 817 and #20 Reactor building steel crane structural girders used in load handling are Inspected under the Periodic Survelilance and Preventive Maintenance Program (PSPM) Identified In Appendix B of the application. Process facility crane rails and girders are inspected under the Structures Monitoring Program as identified In Appendix B. The Structures Monitoring Program will be enhanced, as identified In App B, to address crane rails and girders.
Aging management activities for crane rails and girders under these two programs are consistent with the attributes described for the program in GAL. XI.M23. Reference commitments 17 & 20.
Please see Response to # 377.
Reference commitments 17 & 20.
Closed 0.
C0 0~
~0 n-Closed Accepted Accepted Cosed
379 3.5.1-15-W-2 In the accepted response to question 3.5.1-16-W-1 the aplpiCJ 3.5.1 line Item 3.5.1-16 will be updated to read: *the aging aff NUREG-1801 item are loss of sealing and leakage. Loss of s consequence of the aging effects cracking and change In mat, For WNPS. the Containment Leak Rate Program manages o change in material properties for the primary containment sea The Inservice InspectionrrWE manages cracking and change properties for the primary containment moisture bafrler.
In Table 3.5.2-6 (Bulk Commodities) on Page 3.5-80 of the L1 component seals and gaskets (doors. man-ways and hatches) rubber in a protected from weather environment the aging eff cracking and change in material properties. The GALL line liv 11.B4-7 and the Table I reference is 3.5.1-16. However, the A this line item Is Period'ic Surveillance and Preventive Mainteni 3.5.1 lUne item 3.5.1-16 relates to primary containment seals a The applicant has stated above in the previous paragraph that Containment Leak Rate Program manages cracking and chan properties for the prnmary containment seals and gaskets. Th4 asked to explain if this table 2 line item Is for containment sea and also Class I structures seals and gaskets. I.f it Is for both seals and gaskets and Class I structures seals and gaskets.
asked to explain whny the line Is not broken into two AMPs. tm two table I items and two notes. The AMP for the cortainmr gaskets would be Containment Leak Rate Program wh the
- 7. the Table I Item 3.5.1-16 and a note A. The AMP for theC seals and gaskets would probably be the Perlodlc Su-veillanc Maintenance Program.
LRA Amendment ant stated: Table ects cited in the Table 3.5.2-6 line item 'Seals and gaskets... on page 3.5-80 is for Class I eallng is a structure seals and gaskets not associated with primary containment rial properties.
boundary. Containment seals and gaskets are addressed in Table 3.5.2-1 rackdng and Line Item "Prnmary containment electrical penetration..." on page 3.5-55.
Is and gaskets.
in material For clarity, the following discussion wil be added to Table 3.5.1-16.
L, for
-For reactor building seals and gaskets, the Periodic Surveillance and
),material Preventive Maintenance Program manages cracking and change in material acts are properties for the railroad inner and outer lock doors elastomer seats.!
an referenced Is MP shown for See also response to Item 243.
moe. Table and gaskets.
tthe nge in material applicarnIs Is and gaskets containment the applicant Is C
GALL Items, nt seals and LALL Item 11.4-
-lass 1 structures a and Preventive RAI 3.5.1-63-W-I LRA, for exposed to fluid GALL line item I1I.Bt1.1-11 (treated water environment), material-stainless ne item shown Is steel; steel was considered a submerged environment. Since the VYNPS hown for this line component IS carbon steel in an air-moist environent. (it Is not actually is for an Indoor submerged in the fluid environment). GALL line item 111.1.1-13 was asked to explain considered a better fit for this component.
nd Table 1 and the VYNPS e Inservice Accepted 380 3.5.1-53-W-1 In Table 3.5.2-1 (Primary Containment) on Page 3.5-54 of the component vent header support, materal carbon steel in an envirornent; the aging effect Is loss of material. The GALL 111.B1.1-13 and the Table 1 reference is 3.5.1-53. The AMP a item is Inservlce Inspectlon-IWF. GALL line Item Ili.B11.1-13 uncontrolled air or outdoor air environment The applicant Is why GALL line Item 111.B1.1-11 (treated water environment) 81 reference 3.5.1-49 are not associated with is AMR line item Water Chermistry Conrol - BWR Program also shown with th Inspection-IWF AMP.
Closed
381 B.1.30.1-M-04 Clarify commitment to performance monftoringAesting of HX (fouling) and pumps (LoM) managed using OCCW (SWI) and CCCW (WCC-Aux &
WCC-CCW) AMPs.
382 Original Question: Gail AMPs X1.E1, X1,E2, XI.E3. AND XI.E4 Indicate that aging effects of cables and connections and metal enclosed bus may exist In the LRA, you have stated that there Is no operating experience. Provide Industrial and plant specific operating experience for each VY AMP associated and consistent with Xl.E1, X1.E2, X1.E3 and X1.E4. Confirm that the review of plant specific operating experience did not reveal any degradation not bound by Industry experience.
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 part of the existing program, a separate commitment is not necessary.
As stated in the IRA and prior RAt 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 IRA Section 5.1.21, the One-Time Inspection program will verity 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, arid other components wi be adequately managed without condition or performance monitoring. [Conditlon and performance testing of heat exchangers and pumps is performed under the Maintenance Rule 10CFR50.65, but Is not considered part of these aging management programs.]
LRA Amendment The programs will be updated to Include the following, The X)X program Is a new aging management program. Industry operating experience that forms the basis for the program is described in the operating experience element of the NUREG-1801 program description. VYNPS plant.
specific operating experience has been reviewed against the Industry operating experience identified In GALL Although VYNPS has not experienced all of the aging effects isted in GALL. the VYNPS program wilt manage all of the aging effects identified In the Operating Experience section of GALL The program is based on the program description In NUREG-1801, which in turn is based on relevant Industry operating experience. As such, this program will provide reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their Intended functions consistent with the current licensing basis for the period of extended operation. As additional operating experience Is obtained, lessons learned can be used to adjust the program, as needed.
The main steam isolation valves are built to the ASME Code for Pumps and Valves for Nuclear Power, November 1968 Draft and March 1969 addendum, Issued for trial use and comment (main steam design basis document)
Based on a review of plant operating records, VYNPS has estimated 687 operations of the main steam line isolation valves In 35 years of operation.
Extrapolating this number to 60 years of operation (considering changes In surveillance testing of the valves) gives 785 cycles. This is only 36% of the design 2050 cycles for these valves.
Closed Accepted 383 Please Identify the design code and the number of operating cycles for the MSIVs.
Closed
- ..{.,,- -, -.........::
364 Vermont Yankee Intends to use the System Walkdown Program to inspect external surfaces of components subject to aging management review. Also the program Is credited with managing loss of material from internal surface for situations Is which Internal and external material and environment combinations are the same such that exteral surface condition is representative of Internal surface conditon. (IRA page B-88). You have stal that Vermont Yankee System Engineers whom will perform the walkdowns have received training In the EPRI Aging Management Field Guide. Please provide proof of qualification and certification of system walkdown training.
- 1) How frequently do the engineers receive re-qualification and recertification?
- 2) How often do the engineers perform system walkdowns to verify ther ability to provide accurate results?
License Renewal Commitment #35 Accepted s,
The NRC was provided with the System Walkdown Qualif*catlion List on 06/26&06.
A common Entergy activity qualfication ENN-TK-ESPG-033 covers the Ad System Walkdown process and VY has provided training to System Engineering personnel during cyclic training on use of the EPRI Aging Assessment Field Guide. The activity code for that hem Is VLP-ESP-AGE-FG. The EPRI Guide has been provided to System Engineers. and others as requested. Personnel receiving the guide have acknowledged receipt on a.
sign-off form.
- 1) 0: How frequenty do the engineers receive re-qualification and recertification?
A: Re-qualificatiortrecertificaton is rooted in the SAT process that VYNPS employs to ensure that the training provided for a particular activity results In expected performance. Programs and processes are periodically monitored through the EN-LI-1 04; *Self Assessment and Benchmark Process" and the EN-TQ-201; "Systematic Approach to Training Process", to Identify personnel performance strengths and weaknesses. When weaknesses are Identified through those ongoing processes, either the Corrective Action Process or the TEAR (Training Request) process is used to Identify and provide solutions for performance problems. If training Is Identified as a solution when performance problems exist, the appropriate training course of action is identified and Implemented and then evaluated for success. Currently. periodic refresher training and re-qualification Is not a scheduled event because VYNPS has no data to suggest that performance shortfalls exisL
- 2) 0: How often do the engineers perform system walkdowns to verify their ability to provide accurate results?
A: System Engineers are required to perform a mrnimum of one system walkdown per month for systems that are accessible with the plant on-line.
Many more detailed inspections are performed during outage periods.
System Engineering Supervisors are required to observe a minimum of two system walkdowns per quarter.
Commitment Number 35 has been created to 'Enhance the System Walkdown Training Program as appropriate to document biennial refresher training of Engineers to demonstrate inclusion of the methodology for aging management of plant equipment as described In EPRI Aging Assessment Field Guide or comparable instructional guide.'