ML062850287

Email: (PA) VY LRA Amendment 4 & 5

ML062850287
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	07/14/2006
From:	Hamer M Entergy Nuclear Vermont Yankee
To:	Rowley J NRC/NRR/ADRO
References
%dam200611, TAC MD2297
Download: ML062850287 (70)

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R d E-mch.. VY LRA Amendment 4 and5 Page5V From:

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

To:

"Jonathan Rowley" <JGR@nrc.gov>

Date:

Fri, Jul 14, 2006 3:54 PM

Subject:

VY LRA Amendment 4 and 5

Jonathan, This correspondence contains two letters (see attached) to formally transmit the following information:

responses to the NRC Request for Additional Information on June 7, 2006 with regard to the Vernon Hydroelectric Station and Electrical Connectors, and, the LRA Supplement that contains the LRA Amendment List and TLAA Table changes.

Also included are "Word" formatted versions of the attachments within the letters. Please contact me if you require any additional information.

<<BVY 06-063 LRA Am. 4 - RAI Response.PDF>> <<BVY 06-064 Am. 5 - LRA Supplement.PDF>> <<BVY 06-063 LRA Am 4 Attachment 1.doc>> <<LRA A5 Attachment l.doc>> <<LRA A5 Attachment 2.doc>>

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

"Sullivan, Theodore A" <TSULLI2@entergy.com>, "Maguire, William F"

<WMaguil @entergy.com>, "Rademacher, Norman L" <NRADEMA@entergy.com>, "Devincentis, Jim"

<jdevinc@entergy.com>, "Hoffman, John" <jhoffml @entergy.com>, "Metell, Mike"

<hmetell@entergy.com>, "COX, ALAN B" <ACOX@entergy.com>, "Lach, David J"

<DLach@entergy.com>, "YOUNG, GARRY G" <GYOUNG4@entergy.com'>, "McCann, John (ENNE Licensing Director)" <jmccanl @entergy.com>, "Faison, Charlene D" <CFaison@entergy.com>, "Gill, Jeanne" <jgill2@entergy.com>, "Finn, Brian" <bfinn@entergy.com>, "Harms, Ed"

<eharms@entergy.com>, "Dreyfuss, John" <jdreyfu@entergy.com>, "Wierzbowski, George"

<gwierzb @ entergy.com>

c:\\terTip\\dW)00001.TMP Page~li c:\\ternp\\OW}OOO01.TMP Page 1 ii Mail Envelope Properties (44B7F65A.C1C :23:15388)

Subject:

Creation Date From:

Created By:

VY LRA Amendment 4 and 5 Fri, Jul 14, 2006 3:53 PM "Hamer, Mike" <mhamer@entergy.com>

mhamer@entergy.com Recipients nrc.gov TWGWPO03.HQGWDO01 JGR (Jonathan Rowley) entergy.com gwierzb CC (George Wierzbowski) jdreyfu CC (John Dreyfuss) eharms CC (Ed Harms) bfinn CC (Brian Finn) jgill2 CC (Jeanne Gill)

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

GYOUNG4 CC (GARRY G YOUNG)

DLach CC (David J Lach)

ACOX CC (ALAN B COX) hmetell CC (Mike Metell) jhoffml CC (John Hoffman) jdevinc CC (Jim Devincentis)

NRADEMA CC (Norman L Rademacher)

WMagui 1 CC (William F Maguire)

TSULLI2 CC (Theodore A Sullivan)

Post Office TWGWPO03.HQGWDO01 Files Size MESSAGE 810 TEXT.htm 5689 BVY 06-063 LRA Am. 4 - RAI Response.PDF BVY 06-064 Am. 5 - LRA Supplement.PDF BVY 06-063 LRA Am 4 Attachment 1.doc LRA A5 Attachment 1.doc 111104 LRA A5 Attachment 2.doc 153088 Mime.822 1

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Entergy Entergy Nuclear Operations, Inc.

Ve.,mont Yankee P 0 Bcx O5CH) 185 Old Ferri Road Branieboro. VT 05302-0500 re! :002 2.57 5271 July 14, 2006 Docket No. 50-271 BVY 06-063 TAC No. MC 8634 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

1. Letter, Entergy to USNRC, 'Vermont Yankee Nuclear Power Station, License No.

DPR-28, License Renewal Application," BVY 06-009, dated January 25, 2006.

2. Letter, USNRC to Entergy, "Request for Additional Information for the Review of Vermont Yankee Nuclear Power Station License Renewal Application", dated June 7, 2006.

3. Letter, Vermont Yankee Nuclear Power Corporation to USNRC, "Request for Exemption from 10 CFR Part 50, Appendix R, Section Ill.L, "Alternative and Dedicated Shutdown Capability". BVY 96-43, dated April 4,1996.

4. Letter, Vermont Yankee Nuclear Power Corporation to USNRC, "Clarification Regarding Use of Vernon Tie for Appendix R Compliance", BVY 97-25, dated February 19, 1997

Subject:

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

License Renewal Application. Amendment 4 On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the License Renewal Application for the Vermont Yankee Nuclear Power Station (VYNPS) as indicated by Reference 1. Attachment 1 transmits the VYNPS response to a Request for Additional Information as described in Reference 2.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 14, 2006.

• dA.

Sullivan Site Vice President Vermont Yankee Nuclear Power Station cc: See next page.

I BVY 06-063 Docket No. 50-271 Page 2 of 2 cc:

Mr. James Dyer, Director U.S. Nuclear Regulatory Commission Office O5E7 Washington, DC 20555-00001 Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Jack Strosnider, Director U.S. Nuclear Regulatory Commission Office T8A23 Washington, DC 20555-00001 Mr. Jonathan Rowley, Senior Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike MS-O-1 1 F1 Rockville, MD 20853 Mr. James J. Shea, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G9A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 (for mail delivery)

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

A BVY 06-063 Docket No. 50-271 Attachment I Vermont Yankee Nuclear Power Station License Renewal Application - Amendment 4 Request for Additional Information RAI 3.6.2.2-N-08 RAI 3.6.2.2-N-01

J ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES RAI 3.6.2.2-N-08 10 CFR 54.4 (a)(3) requires, in part, that all systems, structures, and components (SSCs) relied on in safety analyses or plant evaluation to perform a function that demonstrates compliance with the Commission's regulations for station blackout (10 CFR 50.63) are within the scope of license renewal. Vernon Hydroelectric Station (VHS) has been designated as the station blackout (SBO) alternate alternating current source and is used to meet SBO requirements of 10 CFR 50.63.

Are all SSCs (including electrical, mechanical, structural, and civil) associated with the VHS included in the scope of license renewal? If they are not, please explain why not.

If they are, please provide an aging management review for long-lived, passive SSCs associated with the hydroelectric station.

VYNPS Response to RAI 3.6.2.2-N-08 Equipment in the Scope of License Renewal The Vernon Hydroelectric Station (VHS) is the alternate alternating current (AAC) source credited for Vermont Yankee Nuclear Power Station (VYNPS) to demonstrate compliance with 10CFR 50.63, Loss of all alternating current power (the station blackout rule). As such, all VHS structures, systems, and components (SSCs) are in the scope of license renewal.

Aping Management Review The following discussion provides-the aging management review for long-lived, passive SSCs associated with the Vernon hydroelectric station.

A. Background Of the plants that have applied for license renewal in the United States, Peach Bottom is the only other plant that credits an offsite hydroelectric station as its AAC source for station blackout. Peach Bottom received its renewed operating license in May 2003. For the Peach Bottom plant license renewal, the only aging management program credited for the AAC hydroelectric station was the Federal Energy Regulatory Commission (FERC) dam inspection and maintenance program requirements, provided in 18 CFR 12. This is appropriate considering the mechanical and electrical equipment associated with the turbine generator constitute an active assembly that is routinely confirmed available through normal operation.

Entergy, consistent with the Peach Bottom precedent, credited the FERC dam inspection program to manage the effects of aging on civil and structural elements of the VHS. In accordance with NUREG-1 801, for dam inspection and maintenance, programs under the regulatory jurisdiction of FERC or the U.S. Army Corps of Engineers, continued through the period of extended operation, will be adequate for the purpose of aging management.

Notwithstanding the previously approved staff position regarding the alternate AC source for the Peach Bottom plant, Entergy performed an integrated plant assessment (IPA) for passive, long-lived electrical, mechanical, civil and structural SSCs of the VHS.

B. Integrated Plant Assessment for the Vernon Hydroelectric Station BVY 06-063 Page 1 of 8

ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES To perform the IPA, Entergy reviewed the current licensing basis to identify the license renewal intended function of the VHS. For each discipline, the review then considered the aging effects, if any, that could prevent satisfactory accomplishment of the intended function for the VHS as a whole. The review also identified appropriate programs or activities to effectively manage the effects of aging to ensure that the VHS will continue to perform its intended function in accordance with the current licensing basis (CLB) through the period of extended operation.

C. License Renewal Intended Function for the VYNPS Alternate AC (AAC) Source As described in UFSAR Section 8.5.5.1, VYNPS uses an AAC source approach for coping with a station blackout (SBO) using the methodology of RG 1.155, "Station Blackout," dated August 1988. VYNPS relies on the Vernon Hydroelectric Station (VHS) to provide power to an emergency bus until offsite or onsite AC power is available.

For an alternate AC source, NUMARC 87-00 specifies that a licensee provide assurance that the AAC source is available at least 95% of the time. Therefore, the license renewal intended function of the VHS for the purposes of demonstrating compliance with the SBO rule is to be available to VYNPS at least 95% of the time the reactor is operating.

D. Integrated Plant Assessment for Civil and Structural SSCs Civil and structural SSCs that support the intended function of the VHS are the structural steel and concrete elements of the dam. In license renewal application (LRA) Table 3.5.2-5, consistent with the Peach Bottom precedent and with NUREG-1 801, VYNPS credited the FERC dam inspection program to manage the effects of aging on civil and structural elements of the VHS. In accordance with NUREG-1 801, for dam inspection and maintenance, programs under the regulatory jurisdiction of FERC or the U.S. Army Corps of Engineers, continued through the period of extended operation, will be adequate for the purpose of aging management.

E. Integrated Plant Assessment for Mechanical SSCs Description Mechanical SSCs that support the intended function of the VHS are multiple turbine generator units and the mechanical support systems that provide cooling and lubrication for the turbines and generators. Two turbine generator units have black start capability each with its own independent cooling and lubrication subsystems. The turbines are cooled by natural circulation within the Vernon Dam structure. Mechanical sluice gates control the flow of water.

A skid-mounted diesel engine-driven generator provides backup power for turbine generator field flashing, an air compressor, and the lubricating oil support systems. A fiberglass coated underground tank supplies fuel via carbon steel piping to the skid-mounted diesel generator. A double wall day tank at the diesel engine is equipped with alarms to indicate fuel oil leakage.

VHS Components Subiect to Aping Management Review.

Passive, long-lived mechanical components of the turbine generator units and support equipment are subject to aging management review.

BVY 06-063 Page 2 of 8

ATTACHEMENT I LICENSE RENEWAL RAI RESPONSES The skid-mounted diesel engine-driven generator is an active assembly that is tested monthly to ensure continued reliability This testing is analogous to testing credited under the maintenance rule to ensure continued reliability of active equipment in nuclear power plants.

Aging Effects Requiring Management Aging effects requiring management are those that can prevent accomplishment of the VHS intended function. Because of the multiple independent generating units and associated support systems within the VHS, no single mechanical component failure due to the effects of aging can prevent accomplishment of the VHS intended function. Therefore, no aging effects require management for the mechanical equipment of the VHS.

F. Integrated Plant Assessment for Electrical SSCs Description Electrical SSCs for the VHS include the generators associated with each turbine, cables and bus for power transmission, instrumentation and control components and their associated cables and connections. Power from the generators is supplied to the VHS switchyard via two medium-voltage (13.8 kV) underground cables to two independent step-up transformers in the switchyard. Switchyard bus downstream of each step-up transformer feeds the 69kV to 13.2 kV transformer that feeds the Vernon tie breaker. The Vernon tie breaker connects power from the transformer to the 13.2 kV underground cable going to the VYNPS. Passive, long-lived components from the breakers feeding the 69 kV to 13.2 kV transformer to and including the 13.2 kV underground cable are included in the aging management review for plant electrical and instrument and control systems as described in LRA Sections 2.5 and 3.6.

The Vernon tie is a highly reliable connection between the VHS and either of the two VYNPS 4160 V emergency buses and is capable of supplying power to required loads under postulated SBO conditions. Loss of the Vernon tie is annunciated and its voltage is monitored in the VYNPS control room. Surveillance testing of the Vernon tie demonstrated the ability to energize an emergency bus and supply required SBO loads in less than 10 minutes. Additionally, the plant is able to safely cope with a total loss of AC power for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the onset of the SBO to the restoration of offsite AC power.

The VHS is designated as a "black-start" facility under arrangements with the regional grid operator. TransCanada has affirmed that they are committed under tariff to provide black-start capability of the VHS to ISO-NE. Both the NEPOOL and REMVEC procedures state that "the most critical power requirement after a blackout is the assurance of reliable shutdowns of nuclear generators, and that expeditious restoration of alternative off-site power sources to nuclear units is imperative to promote the continued reliability of shutdown operations."

TransCanada conducts and documents the black-start of the VHS annually.

As a backup to local indication available to grid operators of a regional blackout, VYNPS procedures direct operators to immediately contact the regional grid control center to initiate a black start of the VHS if the Vernon tie is unavailable due to a regional grid blackout. The regional grid control center procedures direct hydro-station operators (including the VHS operators) to initiate black start procedures, and upon notification that the units are started, provide instructions to align power to VYNPS and to communicate when these actions are BVY 06-063 Page 3 of 8

ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES complete to the VYNPS control room. The owner of the VHS has a procedure for the actual black start.

The combination of the periodic testing of the AAC source together with the test of the emergency bus that is conducted every operating cycle encompasses the condition of the SBO event, and provides added assurance of VHS availability to meet the requirement of 10 CFR 50.63.

Based on the designation of the TransCanada VHS units as black start units by ISO-NE, the procedural requirements for achieving black start, and the operating history of the VHS units, there is reasonable assurance that a VHS unit will be available within the SBO coping timeframe.

VHS Commodities Subiect to Aging Management Review Consistent with the approach described in LRA Section 2.1.2.3, Screening of Electrical and Instrumentation and Control Systems, the commodity groups that perform an intended function without moving parts or without a change in configuration) are;

• high voltage insulators, and

• cables, connections and electrical busses.

Other electrical and I&C commodity groups, including transformers, are active and do not require aging management review.

Aging Effects Requiring Management Aging effects requiring management are those that can prevent accomplishment of the VHS intended function. Because of the multiple independent generators and power transmission circuits within the VHS, no single component failure due to the effects of aging can prevent accomplishment of the VHS intended function. Therefore, no aging effects require management for electrical and instrumentation and control commodity groups within the VHS.

Within the VHS switchyard (owned by National Grid), two circuits provide power to the 69 kV to 13.2 kV transformer that feeds through the Vernon tie breaker to the underground 13.2 kV cable routed to VYNPS. The switchyard bus and associated connections involved with this circuit are subject to aging management review. Aging management review of this portion of the switchyared was addressed in the VYNPS LRA, Section 3.6, for the SSCs described in Section 2.5 under Evaluation Boundaries on Page 2.5-2. Specifically, the path includes the switchyard circuit breakers near the Vernon Dam that feed the Vernon tie transformer, switchyard bus and insulators, and cables and connections in the circuit to the emergency bus and structures.

Two independent paths constitute the remainder of the circuit that provides power from the VHS to the VHS switchyard. Because of the two independent power transmission circuits, no single component failure due to the effects of aging can prevent accomplishment of the VHS intended function. Therefore, there are no aging effects requiring management for this portion of the circuit.

Availability of the Vernon tie line is tracked on a three year rolling basis. Over the last 4 years the line has been available 99.32% of the time. Approximately 60% of the unavailability was due to the planned replacement of the 4kV underground cable between the 13.2 kV / 4.16kV transformer and the VYNPS 4.16 kV buses. This operating experience indicates the BVY 06-063 Page 4 of 8

4 ATTACHEMENT 1 t.

LICENSE RENEWAL RAI RESPONSES effectiveness of routine switchyard maintenance in achieving acceptable performance of the switchyard circuit between VHS and VYNPS.

G. Quality Assurance Although the VHS is not under the VYNPS QA program, it consists of multiple generating sources and connections to the switchyard. The system, taken as a whole, exhibits a high reliability even though individual components are not operated under the VYNPS QA program.

From 1965 through 1989, VHS demonstrated very high reliability (e.g. 99.9% availability). On this basis, the staff concluded in 1991 [NVY 91-98], that the QA issue has been satisfactorily considered. As previously discussed, availability data for the Vernon tie line indicate that very high reliability continues today.

VYNPS Technical Specifications credit the Vernon tie as an alternate electrical power source for a standby gas treatment system during certain shutdown operations. In addition during reactor operation, VYNPS commitments made in BVY 96-43 and BVY 97-25, assure continued availability of power from the Vernon tie line. The reactor must be shut down within 15 days unless the Vernon tie is returned to service or the basis for maintaining continued operation is written and approved. If the Vernon tie cannot be returned to service within 15 days, within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> VYNPS must submit a report to the NRC in accordance with 1 OCFR50.4 outlining the reason for the unavailability, corrective actions being taken to restore the Vernon tie, compensatory actions in place to provide AC power for Appendix R alternative shutdown fire scenarios, and the time required to make the Vernon tie available. This commitment carries forward into the period of extended operation.

Based on the above, the appropriate controls for VHS and the Vernon tie are in place to provide reasonable assurance of continued acceptable performance through the period of extended operation. Unavailability of the Vernon tie is cause for entry into the VYNPS corrective action program, which invokes associated elements of the QA program. The corrective action program requires evaluation and appropriate corrective action to correct the nonconforming condition.

Therefore, QA attributes are adequate for license renewal.

H. Operating Experience Per BVY 94-33, dated March 11, 1994, the "Vernon Hydro Station with multiple units, has demonstrated reliability far in excess of an auxiliary generator (99.9% compared to 95%)."

Subsequent to SBO communications between NRC and VY in the mid 1990's, Vernon Dam has continued to demonstrate high availability. The VHS remained on line throughout the Northeast blackout of August 14, 2003.

Entergy recently held discussions with TransCanada, the owner/operator of the VHS, and the regional grid control center regarding procedural requirements and communication protocols for a postulated SBO event. These communications resulted in system restoration procedure improvements and served to promote a better understanding of the expectations relative to Entergy's reliance on the VHS during an SBO.

Entergy has established administrative controls to assure performance of a once per operating cycle tabletop review of the procedures that complete the actions to re-power a VYNPS 4KV bus from the VHS. This review discussed interfaces with the operator of VHS and the regional BVY 06-063 Page 5 of 8

ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES grid operator to verify that roles and responsibilities and timelines are understood and that there have been no changes that would impact the assumption in the VYNPS SBO coping strategy.

Entergy provides the participants with insights regarding offsite power issues for nuclear power stations including plant response to and consequences of an SBO.

Similar to experience at VYNPS, VHS has experienced microbiological and conventional corrosion attack on carbon steel lines exposed to river water (e.g. turbine seal cooling). VHS replaced these lines with copper and stainless steel lines to eliminate loss of material caused by these mechanisms. This experience indicates the effectiveness of the routine maintenance of the VHS in managing the effects of aging. In addition, maintaining high availability in light of this degradation further supports that the multiple independent systems associated with the VHS can be maintained through routine maintenance without impacting the overall intended function of the VHS.

I. Conclusion In accordance with NUREG-1 801, FERC dam inspection and maintenance programs are credited with managing the effects of aging on civil and structural components of the VHS.

Consistent with the current licensing basis (CLB), because of the multiple generating sources and connections to the switchyard, the effects of aging on other components associated with the VHS cannot cause loss of the intended function and have no aging effects requiring management. VHS switchyard passive, long-lived commodity groups that do not involve multiple independent circuits are effectively maintained through routine maintenance by the switchyard owner. Nevertheless, VYNPS will monitor the availability of the VHS to ensure continued conformance with the availability specified in NUMARC 87-00. If availability falls below the acceptable level, VYNPS will respond to the condition through the corrective action program. The corrective action program requires evaluation and appropriate corrective action to correct the nonconforming condition.

Per BVY 94-33, dated March 11, 1994, the "Vernon Hydro Station with multiple units, has demonstrated reliability far in excess of an auxiliary generator (99.9% compared to 95%)."

Subsequent to 1994, the VHS has continued to demonstrate very high availability. The VHS remained on line throughout the Northeast blackout of August 14, 2003.

This recent operating experience indicates that existing commitments and maintenance practices provide reasonable assurance that the VHS will remain capable of performing its intended function in accordance with the current licensing basis throughout the period of extended operation.

RAI 3.6.2.2-N-01 In the license renewal application (LRA) Table 3.6.2-1, under cable connections (metallic parts),

you have stated that there are no aging effects requiring management and no aging management program (AMP) is required. Further, in LRA Table 3.6-1, under discussion of cable connection metallic parts, you have stated that cable connections outside of active devices are taped or sleeved for protection; and operating experience with metallic parts of electrical cable connections at VYNPS indicated no aging effects requiring management.

Electrical cable connections (metallic parts) are subject to the following aging stressors: thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. NUREG-1801, Revision 1, AMP XI.E6, "Electrical Cable Connection not Subject to 10 CFR 50.49 Environmental Qualification Requirements," specifies that connections BVY 06-063 Page 6 of 8

ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES associated with cables within the scope of license renewal are part of this program, regardless of their association with active or passive components. Please provide a basis document including an AMP with the ten elements for cable connections or provide a justification for why an AMP is not necessary.

VYNPS Response to RAI 3.6.2.2-N-01 Electrical cable connections at VYNPS are inspected under the maintenance rule program as directed by Entergy procedures. The maintenance rule program is in compliance with 10 CFR 50.65. The maintenance rule program is based on industry guidance provided in NUMARC 93-01 and Reg. Guide 1.160.

The maintenance rule program scope includes the following.

" Safety-related structure, systems and components (SSCs)

Non-safety related SSCs that mitigate accidents or transients Non-safety related SSCs used in emergency operating procedures Non-safety related SSCs whose failure could prevent safety-related SSCs from fulfilling their safety function.

Non-safety related SSCs whose failure could cause a scram or safety system actuation.

Electrical cable connections are subcomponents of SSCs that are in the scope of the maintenance rule.

The maintenance rule program includes performance monitoring and trending for SSCs that are in scope. Monitoring and trending is:

Performed frequently enough to detect and correct degrading equipment performance Used to evaluate equipment performance following maintenance or modification Based on manufacturer's recommendations, operational or industry experiences with plant equipment or plant specific information

• Subject to the corrective action and work order programs Subject to management review and oversight Monitoring and trending includes normal plant maintenance activities. Maintenance includes activities associated with identifying and correcting actual or potential degraded conditions (e.g.,

repair, surveillance, diagnostic examinations, and preventive measures) as well as support functions for the conduct of these activities.

Thermography is used to detect potential degraded conditions. Thermography can detect "hot spots" in cable connections that are indicative of a high resistance connection.

As a part of the maintenance rule program, periodic assessments are performed. A periodic assessment is performed to evaluate the effectiveness of maintenance activities. This assessment is performed at least every operating cycle, not to exceed 24 months.

Plant operating experience has shown that the maintenance rule program has been effective at detecting, evaluating and repairing electrical cable connection degradation.

Since the maintenance rule program includes scoping, performance monitoring, trending and periodic assessments, this program provides reasonable assurance that electrical cable BVY 06-063 Page 7 of 8

ATTACHEMENT 1.,

LICENSE RENEWAL RAI RESPONSES connections will remain capable of performing their intended functions through the period of extended operation. No aging management program (AMP) for license renewal is required at VYNPS since the regulatory mandated maintenance rule program effectively maintains electrical cable connections.

BVY 06-063 Page 8 of 8

Entergy Nuclear Operations, Inc.

V*smont Yr'ake*.

P 0. Box 05160

%=ý'ýEnbeWl,*at~erorc,.

VT 05302-05c)(

1'e! *02 257 5271 July 14, 2006 Docket No. 50-271 BVY 06-064 TAC No. MC 8634 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

1.

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

Subject:

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

License Renewal Application. Amendment 5 On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the License Renewal Application for the Vermont Yankee Nuclear Power Station (VYNPS) as indicated by Reference 1. Attachment 1 transmits changes to the VYNPS License Renewal Application in response to NRC staff questions received during on-site license renewal audits. transmits changes to the VYNPS License Renewal Application tables in Sections 3.1 through 3.4 to address time-limited aging analyses in response to Audit Question 309.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 14, 2006.

Sincerely, Ted A. Sullivan Site Vice President Vermont Yankee Nuclear Power Station Attachments 1 and 2 cc: See next page

BVY 06-064 Docket No. 50-271 Page 2 of 2 cc:

Mr. James Dyer, Director U.S. Nuclear Regulatory Commission Office O5E7 Washington, DC 20555-00001 Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Jack Strosnider, Director U.S. Nuclear Regulatory Commission Office T8A23 Washington, DC 20555-00001 Mr. Jonathan Rowley, Senior Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike MS-O-1 1 F1 Rockville, MD 20853 Mr. James J. Shea, Project Manager U.S. Nuclear Regulatory Commission Mail Stop O8G9A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 (for mail defivery)

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

BVY 06-064 Docket No. 50-271

(

)

Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 5

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 11: LRA Section B.1.7 is revised as follows.

1. Delete the exception to the BWR vessel internals program related to the core shroud (page B-27).

2. Delete exception Note #1 on page B-29.

Audit item 26: Add the following text to LRA Section B.1.10 to include the "EQ Component Reanalysis Attributes" specified in NUREG-1801 Vol. 2 Section X.E1.

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

Analytical Methods The analytical models used in the re-analysis of an aging evaluation are the same as those previously applied during the prior evaluation. The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, one acceptable method of establishing the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.

Data Collection and Reduction Methods Reducing excess conservatism in the component service conditions (for example, temperature, radiation, cycles) used in the prior aging evaluation is the chief method used for a re-analysis. Temperature data used in an aging evaluation is to be conservative and based on plant design temperatures or on actual plant temperature data. When used, plant temperature data can be obtained in several ways, including monitors used for Technical Specification compliance, other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running). A representative number of temperature measurements are conservatively evaluated to establish the temperatures used in an BVY 06-064 Page 1 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST aging evaluation. Plant temperature data may be used in an aging evaluation in different ways, such as; (a) directly applying the plant temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation. Any changes to material activation energy values as part of a re-analysis are to be justified on a plant-specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations can be used for radiation and cyclical aging.

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

Acceptance Criteria and Corrective Actions The re-analysis of an aging evaluation could extend the qualification of the component. If the qualification cannot be extended by re-analysis, the component is to be refurbished, replaced, or re-qualified prior to exceeding the period for which the current qualification remains valid. A re-analysis is to be performed in a timely manner (that is, sufficient time is available to refurbish, replace, or re-qualify the component if the re-analysis is unsuccessful).

Audit items 30, 141, and 146: LRA Section B.1.28 is revised to include an enhancement to perform C02 system inspections every 6 months under the System Walkdown Program. The required inspections will be initiated prior to the period of extended operation. Commitment 30.

Audit item 39: LRA Section B.1.12.2 is revised to delete the exception to the annual fire hydrant gasket inspections. Commitment 31.

Audit item 40: LRA Section B.1.12.2 is revised to delete the exception to the annual fire hydrant flow tests. Commitment 31.

Audit item 48: LRA Section B.1.17 is revised as follows. 'VYNPS inspection for water accumulation in manholes is conducted in accordance with a plant procedure. An evaluation per the Corrective Action Process will be used to determine the need to revise manhole inspection frequency based on inspection results."

Audit item 51: LRA Section B.1.18 is revised as follows. "The first test of neutron monitoring system cables that are disconnected during instrument calibrations shall be completed before the period of extended operation and subsequent tests will occur at least once every 10 years.

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

BVY 06-064 Page 2 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 53: To clarify the technical basis for sampling, the sampling discussion in LRA Section B.1.19 for the Non-EQ Insulated Cables and Connections Program is revised to read as follows. "Most cables and connections installed in adverse localized environments are accessible. This program is a sampling program. Selected cables and connections from accessible areas will be inspected and represent, with reasonable assurance, all cables and connections in the adverse localized environments. If an unacceptable condition or situation is identified for a cable or connection in the inspection sample, a determination will be made as to whether the same condition or situation is applicable to other accessible cables or connections.

The sample size will be increased based on an evaluation per the Corrective Action Process."

Audit item 64: The exception taken to NUREG-1801 Section XI.M3 in LRA Section B.1.23 is deleted. In accordance with ASME Code Case N-652, future examination will be visual only.

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

Revision 14. As this Code Case is now endorsed, this inspection is no longer an exception to NUREG-1801.

Audit items 76, 80, 81, 243, 266, and 270: Aging effects on the drywell moisture barrier will be managed under the Containment Inservice Inspection Program instead of the Structures Monitoring Program. In support of this, the LRA is revised as follows.

1. In the LRA Table 3.5.2-1 line item for "Drywell floor liner seal" change the aging management program from "Structures Monitoring" to "CII-IWE". For clarification, change "drywell floor liner seal" to "drywell shell to floor seal (moisture barrier)." The clarification of this terminology also applies to Table 2.4-1 and Section B.1.27.2.

2. In LRA Table 3.5.1 line Item 3.5.1-16 the Discussion column is revised to read: "The aging effects cited in the NUREG-1801 item are loss of sealing and leakage. Loss of sealing is a consequence of the aging effects "cracking" and "change in material properties." For VYNPS, the Containment Leak Rate Program manages cracking and changes in material properties for the primary containment seal and gaskets. The Inservice Inspection -IWE Program manages cracking and changes in material properties for the drywell shell to floor seal (moisture barrier)."

3. In LRA Table 3.5.1, Line Item 3.5.1-5, the Discussion column last paragraph is revised to read "The drywell steel shell and the moisture barrier where the drywell shell becomes embedded in the drywell concrete floor are inspected in accordance with the Containment Inservice Inspection (IWE) Program."

4. LRA Section 3.5.2.2.1.4 is revised to delete from the end of the first paragraph, the phrase "and Structures Monitoring Program". The drywell to floor moisture barrier will be inspected under the Containment Inservice Inspection (IWE) Program only. The Structures Monitoring Program is not used.

Audit item 77: LRA Section B.1.27.2 for the Structures Monitoring Program is revised to include an enhancement to perform at least once every five years an engineering evaluation of groundwater samples to assess for groundwater being aggressive to concrete. Commitment 33.

Audit items 85, 86, 87, 166, 200, 232, 233, 239, 240, 295, 297, 310, 312, 313, and 359: The effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs is confirmed by the One-Time Inspection program. To provide further clarification, LRA Appendix A is revised for these three water chemistry control programs to BVY 06-064 Page 3 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST include the sentence 'The One-Time Inspection Program will confirm the effectiveness of the program".

Audit item 93: In order to address transmission connections, in LRA Table 3.6.2-1, change line item Transmission conductors to Transmission conductors and connections. Revise Section 3.6.2.2.3 to include the following text after the second paragraph.

The aging effects for transmission conductors evident in industry operating experience are loss of conductor strength and loss of material (wear).

The prevalent mechanism contributing to loss of conductor strength of an aluminum conductor steel reinforced (ACSR) transmission conductor is corrosion, which includes corrosion of the steel core and aluminum strand pitting. Corrosion in ACSR conductors is a very slow acting mechanism, and the corrosion rates depend on air quality, which includes suspended particles chemistry, S02 concentration in air, precipitation, fog chemistry and meteorological conditions. Air quality in rural areas generally contains low concentrations of suspended particles and S02, which keeps the corrosion rate to a minimum. Tests performed by Ontario Hydroelectric showed a 30% loss of composite conductor strength of an 80 year old ACSR conductor due to corrosion.

VYNPS transmission conductors include ACSR and aluminum conductor alloy reinforced (ACAR) conductors. ACAR conductors are aluminum conductors reinforced with alloy steel. ACAR conductors are more resistant to loss of conductor strength since the core of the conductor is a more corrosion resistant alloy steel. AMR conclusions regarding ACSR conductors conservatively bound ACAR conductors.

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

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

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

Loss of material due to mechanical wear can be an aging effect for strain and suspension insulators that are subject to movement caused by transmission conductor vibration or sway from wind loading. Design and installation standards for transmission conductors consider sway caused by wind loading. Experience has shown that transmission conductors do not normally swing and that when they do swing because of substantial wind, they do not continue to swing for very long once the wind has subsided. Wear has not been identified during routine inspection; therefore, loss of material due to wear in not an aging effect requiring management.

BVY 06-064 Page 4 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 97: The VYNPS Metal-Enclosed Bus program ten element comparison to NUREG-1801 (excerpt from the Aging Management Program Evaluation Report LRPD-02) will be provided in later correspondence along with associated revisions to the LRA.

Audit item 118: LRA Section B.1.17 is revised to replace the last sentence in the Program Description with; "The specific type of test to be performed will be determined prior to the initial test and is to be a proven test for detecting deterioration of the insulation system due to wetting as described in EPRI TR-1 03834-Pi -2, or other testing that is state-of-the-art at the time the test is performed."

Audit item 120: LRA Section B.1.17 Program Description is revised to state that medium-voltage cables include cables with operating voltage level from 2kV to 35kV.

Audit item 124: LRA Section B.1.19 Program Description is revised to include the following.

'The program applies to accessible electrical cables and connections within the scope of license renewal that are installed in adverse localized environments caused by heat or radiation in the presence of oxygen."

Audit Item 159: LRA Section B.1.12.1 is revised to add fire dampers to the list of components in the Program Description that require a periodic visual inspection.

Audit item 165: Line Items 3.3.1-50 and 3.3.1-51 in LRA Table 3.3.1 are revised to replace the Water Chemistry Control - Auxiliary Systems program in the Discussion column with the Water.

Chemistry Control - BWR Program Audit item 187: LRA section B.1.28 is revised to add the following enhancements. The System Walkdown Program implementing procedure will be enhanced to specify that systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 50.54 (a)(1) and (a)(3) shall be inspected. In addition, the implementing procedure will be enhanced to provide guidance to inspect nearby systems with the potential for spatial interaction. These enhancements will be implemented as shown in Commitment 24.

Audit item 198, 216, 218, 237, 331 and 333: The VYNPS Bolting Integrity Program ten element comparison to NUREG-1801 (excerpt from the Aging Management Program Evaluation Report LRPD-02) will be provided in later correspondence along with associated changes to the LRA.

The Bolting Integrity Program will be implemented prior to the period of extended operation in accordance with Commitment 34.

Audit item 203: LRA Table 3.1.2-3 is revised to indicate that with the exception of the head seal leak detection line, the Inservice Inspection Program applies to all component types of Piping and fittings < 4" NPS with an aging effect of cracking in addition to the Water Chemistry Control

- BWR and One-Time Inspection Programs.

Audit Item 209 and 291: LRA Table 3.1.2-1 on page 3.1-52 is revised to remove all the line items for the component type of Thermal Sleeves Feedwater Inlets (N4). The thermal sleeves are not subject to aging management review since they perform no intended function for license renewal. The sleeves are installed with an interference fit rather than welded so they have no impact on the reactor coolant pressure boundary.

BVY 06-064 Page 5 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit items 224, 225, 226, 229, 293, 294, 315, and 369: LRA Section B.1.21 is revised to state that the One-Time Inspection program will verify effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs by confirming the absence of loss of material, cracking and fouling, where applicable.

Audit item 235: In LRA Table 3.3.2-10 for the NUREG-1 801 Vol. 2 Item for component types "humidifier housing" and "piping", change item VIII.F1-8 to item VII.F1-8. The incorrect number was entered due to a typographical error.

Audit item 242: LRA Table 3.5.2-1 is revised to delete line items for "Bellows (reactor vessel and drywell)". Also the corresponding line item in Table 2.4-1 is deleted.

Audit item 244: LRA Table 3.5.2-6 is revised to indicate that Note "A" applies to component seals and gaskets (doors, man-ways and hatches) with the aging management program of Structures Monitoring Program.

Audit item 248: LRA Table 3.5.2-6 is revised to change Note "A" to Note "C" for electrical and instrument panels and enclosures with a material of galvanized steel in a protected from weather environment. Aging effect and associated aging management program are unchanged.

Audit item 249: LRA Table 3.5.2-6 is revised to change Note "A" to Note "C" for flood curb with a material of galvanized steel in a protected from weather environment. Aging effect and associated aging management program are unchanged.

Audit item 250: LRA Table 3.5.2-1 is revised to change Note "E" to Note "A" for torus shell with an aging effect of cracking-fatigue. Aging effect and associated aging management program are unchanged.

Audit items 255, 257, 258, 259, 263, and 278: The LRA is revised to indicate loss of material as an aging effect requiring management with the Structures Monitoring Program as the aging management program and the NUREG-1801 Vol. 2 Item as III.B4-7 with a Note C in the following cases.

1. Table 3.5.2-5 for transmission towers with a material of galvanized steel in an exposed to weather environment

2. Table 3.5.2-6 for conduit with a material of galvanized steel in an exposed to weather environment

3. Table 3.5.2-6 for conduit support with a material of galvanized steel in an exposed to weather environment

4. Table 3.5.2-6 for electrical and instrument panels and enclosures with a material of galvanized steel in an exposed to weather environment

5. Table 3.5.2-6 for structural bolting with a material of galvanized steel in an exposed to weather environment LRA Table 3.5.1, item 3.5.1-50 is revised to include the following in the Discussion column: "Consistent with NUREG-1 801 for galvanized steel components in outdoor air.

The Structures Monitoring Program will manage loss of material."

BVY 06-064 Page 6 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 267:

LRA Table 3.5.2-1 is revised to delete the following line.

Drywell to PBý Carbon Protected Cracking) TLAA-1 II.B1.1-4 3.5.1-8 A

torus vent SS steel from (fatigue) metal (C-21) system I

weather I fatigue

( )___

The Discussion column for LRA Table 3.5.1 item 3.5.1-8 is revised to read as follows.

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

The Discussion column of LRA Table 3.5.1 item 3.5.1-9 is revised to read as follows.

"Fatigue analysis is a TLAA for the torus penetrations. See Section 3.5.2.2.1.6.

The Discussion column of LRA Section 3.5.2.2.1.6 is revised 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.

LRA Section 3.5.2.3, Time-Limited Aging Analyses, is revised to read as follows. `TLAA identified for structural components and commodities include fatigue analyses for the torus and torus penetrations. These topics are discussed in Section 4.6."

Audit items 268 and 269: The LRA is revised as follows.

1. For clarification, the Discussion column of Table 3.5.1, line items 3.5.1-12 and 3.5.1-13 is revised to add the following statement at the end of the existing information.

"See Section 3.5.2.2.1.8".

2. LRA Section 3.5.2.2.1.8 is revised to read as follows. "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 drywell, torus and associated penetration bellows, penetration sleeves, un-braced downcomers, and dissimilar metal welds. A review of plant operating experience did not identify cracking of the components, and primary containment leakage has not been identified as a concern.

Nonetheless the existing Containment Leak Rate Program with augmented ultrasonic exams and Containment Inservice Inspection - IWE, will continue to be used to detect cracking. Observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process. The Containment Inservice Inspection - IWE and Containment Leak Rate programs are described in Appendix B."

Audit item 279: For clarification, LRA Table 3.5.1, Item 3.5.1-52 discussion is revised to read as follows. "Loss of mechanical function due to the listed mechanisms is not considered an aging BVY 06-064 Page 7 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST 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."

Audit item 280: For clarification, LRA Table 3.5.1, Item 3.5.1-54 discussion is revised as follows. "Loss of mechanical function due to distortion, dirt, overload, fatigue due to vibratory, and cyclic thermal loads is not considered an aging effect requiring management. Such failures typically result from inadequate design or events rather than the effects of aging. Loss of material due to corrosion, which could cause loss of mechanical function, is addressed under Item 3.5.1-53 for Groups B1.1, B1.2, and B1.3 support members."

Audit item 282: For clarification, LRA Table 3.5.1, Line Item 3.5.1-34 discussion is revised to add "See Section 3.5.2.2.2.4(1)".

Audit item 283: LRA Table 3.5.1, Item 3.5.1-35 discussion is revised to replace ACl 301 with ACI 318 and add "See Section 3.5.2.2.2.4(2)" at the end of the existing discussion.

Audit item 284: LRA Table 3.5.1, Line item Number 3.5.1-36 discussion column is revised as follows. "Reaction with aggregates is not an applicable aging mechanism for VYNPS concrete components. See Section 3.5.2.2.2.1(5) (although for Groups 1-5, 7, 9 this discussion is also applicable for Group 6). See Section 3.5.2.2.2.4(3) additional discussion. Nonetheless, the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components."

To correct an administrative error, the heading of LRA Section 3.5.2.2.2.4 (3) is revised to begin with "Cracking Due to Expansion, Reaction with Aggregates...". The term stress corrosion cracking is deleted from the heading as it does not apply to this section.

Audit item 285: The Discussion column of LRA Table 3.5.1, Item Number 3.5.1-37, is revised to state the following. "Not applicable. Nonetheless the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components.

See Section 3.5.2.2.2.4(3)".

Audit item 286: For clarification, LRA Table 3.5.1, Item Number 3.5.1-40 discussion column is revised to add "See Section 3.5.2.2.2.6(1)".

Audit Item 304: LRA Table 3.3.2.13-32 is revised to replace the aging management program of One-Time Inspection with Periodic Surveillance and Preventive Maintenance for all line items containing carbon steel and copper alloy with an environment of untreated water.

Audit item 309: LRA Section 3.1, 3.2, 3.3 and 3.4 tables will be revised to remove 'TLAA-metal fatigue" from all line items for which Section 4 does not discuss evaluation of a TLAA. Line by line changes to the tables are provided in Attachment 2 to this letter.

Audit item 318: LRA Table 4.3-1 is revised to remove the NUREG/CR-6260 values for core spray safe end, feedwater piping, RHR return piping, and RR piping tee and replace them with N/A. Commitment 27 requires an analysis that addresses the effects of reactor coolant environment on fatigue performed to an NRC-approved version (year) of the ASME code.

BVY 06-064 Page 8 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 319: The last paragraph of LRA Section 4.3.1.1 is replaced with the following. '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 considered in the existing fatigue analyses, several locations have a projected cumulative usage factor in excess of 1.0. See Section 4.3.3 for further discussion of the effects of reactor water environment on fatigue."

Audit item 320: LRA Reference 4.3.1 on page 4.3-9 is revised as follows; "4.3-1 Sojka, R. E.

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

Audit item 322: LRA Section 4.3.1.3 is replaced with the following.

"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)(i).

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)(i). The MSIVs will not exceed 2050 cycles in 60 years (34 cycles per year)."

In addition LRA section 4.3.2 is replaced with the following.

'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 stress 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-Class 1, non-piping components as they are not built to codes that require fatigue analyses.

BVY 06-064 Page 9 of 12

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST 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 extended 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."

Audit item 335: LRA Table 3.5.2-6 lists the aging effects for component Penetration sealant, material elastomer in a protected from weather environment as "cracking" and "change in material properties." For clarification, the LRA is revised to separate this component line item into two line items as follows:

1. Delete line item:

Penetration EN, Elastomer Protected

Cracking, Fire Ill.A6-3.5.1-C sealant FB, from Change protection, 12 44

FLB, weather in Structures (fire, flood, PB, material Monitoring (TP-7) radiation)

SNS properties

2. Add line item:

Penetration EN, Elastomer Protected

Cracking, Fire VII.G-1 3.3.1-B sealant FB, from Change in protection (A-19) 61

( PB, weather material (fire)

SNS properties

3. Add line item:

Penetration EN, Elastomer Protected

Cracking, Structures -Il.A6-3.5.1-C sealant

FLB, from Change Monitoring 12 44 (flood, PB, weather in (TP-7) radiation) material properties Audit item 336: LRA Table 3.5.2-6 lists the aging effects for the Seismic isolation joint, with a material of elastomer in a protected from weather environment as "cracking" and "change in material properties." For clarification, the LRA is revised to make the following changes.

1. Note C is changed to Note E for this line item.

2. The discussion in Table 3.3.1 line Item 3.3.1-61, Page 3.3-49 is revised to read as follows. 'This line item was not used in the auxiliary systems tables. Fire barrier BVY 06-064 Page 10 of 12

t,;

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST 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 is added to read as follows.

Seismic SSR Elastomer Protected

Cracking, Structures Ill.A6-3.5.1-C isolation from Change in Monitoring 12 44 joint weather material (TP-7) properties Audit item 337: LRA Table 3.5.2-6 lists the aging effect for Fire doors, with a material of carbon steel in a protected from weather environment as "loss of material." For clarification, the LRA is revised to change 'Note C' to 'Note B' for this line item.

Audit item 345: LRA Table 3.3.2-13 lists the aging effect for component type of bolting, with a material of stainless steel in an air - outdoor (ext) environment as "none." The LRA is revised to identify loss of material as an aging effect for this line item as shown below.

Bolting Pressure Stainless Air-ILoss of System IG boundary steel outdoor material walkdown Audit item 350: LRA Section A.2.1.31 Structures Monitoring-Vernon Dam FERC Program is replaced with the following. "The Vernon dam is subject to the Federal Energy Regulatory Commission (FERC) inspection program. This program consists of visual inspections in accordance with FERC guidelines and complies with Title 18 of the Code of Federal Regulations, Conservation of Power and Water Resources, Part 12 (Safety of Water Power Projects and Project Works) and Division of Dam Safety and Inspections Operating Manual.

The operation inspection frequency for licensed and exempt low hazard potential dams is biennially. As indicated in NUREG-1 801 for water control structures, NRC has found that FERC

/ US Army Corp of Engineers dam inspections and maintenance programs are acceptable for aging management.

Audit item 354: The LRA is revised to delete Sections 4.7.2.5, 4.7.2.6, A.2.2.7 and A.2.2.8.

Also the component type of vessel ID attachment welds and instrument penetrations in LRA Table 4.1-1 is deleted. The items discussed in these sections do not meet the definition of time-limited aging analyses.

In LRA table 3.1.2-1 (page 3.1-54) for the component type of internals attachments the line with the aging effect of cracking-fatigue and TLAA-metal fatigue as the aging management program is deleted. Cracking managed by the BWR Vessel ID Attachment Welds Program remains in the table.

In LRA table 3.1.2-1 (page 3.1-44) for the component type of nozzles, instrumentation, Nil the line item with the aging effect of cracking-fatigue and TLAA-metal fatigue as the aging management program is deleted. Cracking managed by the BWR Penetrations Program remains in the table.

BVY 06-064 Page 11 of 12

ATRACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 371: LRA Section B.1.1 1 is revised as follows. 'The VYNPS Fatigue Monitoring Program includes counting of the cycles incurred by the plant. Five transients are monitored by plant operations and recorded as they occur. It is projected that less 60% of the design cycles for these five transients will be used through the first 60 years of operation, including the period of extended operation. 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."

Audit item 373: LRA Section 3.3.2.2.13 Loss of Material due to Wear is 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 VYNPS auxiliary systems."

Audit item 376: LRA Table 3.3.1 line item 3.3.1-69 is revised to remove the reference to the One-Time Inspection Program.

Audit item 379: LRA Table 3.5.1 line item 3.5.1-16 discussion is revised to add the following paragraph. "For reactor building seals and gaskets, the Periodic Surveillance and Preventive Maintenance Program manages cracking and change in material properties for the railroad inner and outer lock doors elastomer seals."

Audit item 382: The operating experience discussion in LRA Appendices B.1.17, B.1.18, and B.1.19 is replaced with the following.

'This 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-1 801 program description. VYNPS plant-specific operating experience has been reviewed against the industry operating experience identified in NUREG-1 801. Although VYNPS has not experienced all of the aging effects listed in NUREG-1801, the VYNPS program will manage all of the aging effects identified in the Operating Experience section of NUREG-1 801.

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."

BVY 06-064 Page 12 of 12

A BVY 06-064 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 5

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Audit item 309 - Tables and text of LRA Sections 3.1, 3.2, 3.3 and 3.4 are modified as follows:

Intende Aging Effect Aging NUREG-Table Component Type i ntn Material Environment Requiring Management 1801 Vol.

1aite Notes Change Description Function Management Programs 2 Item I Item Table Ic Vess Table 3.1.2-1 Reactor Vessel Closure flange studs, nuts, washers and bushings Aging effect entry for component line deleted -

Cracking managed by Reactor Head Closure Studs Program in following entry of line.

Incore housing bolting

" Flange bolts

" Flange

• Nut and washer Aging effect entry for component line deleted -

Cracking managed by Inservice Inspection Program in following entry of line.

Other pressure boundary bolting

" Flange bolts and nuts (N6A, N6B, N7)

" CRD flange caps-crews and washers I

I Aging effect entry for component line deleted -

Cracking managed by Inservice Inspection Program in following entry of line.

CAP

• CRD return line (N9)

Aging effect entry for component line deleted -

Cracking managed by BWR CRD Return Line Nozzle Program in following entry of line.

BVY 06-064 Page 1 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Intended Aging Effect Aging NUREG-Table Component Type Function Material Environment Requiring Management 1801 Vol.

1 Item Notes Change Description Management Programs 2 Item Thermal sleeves Pressure Stainless Treated water

• aGi4-T-LAA-meaIV 1-:7 3.1.4-2 A

Aging effect entry for

" Recirc inlet (N2) boundary steel

>2709F (int) fatgiue fa4

(-04) component line deleted -

" Core spray (N5)

Cracking managed by BWR Vessel Internals Program in

_following entry of line.

T-hoRral rsoovo Pe e

Stainless T-eatedwate aekg--

T-M 111A1-3-.4-1.-.2 A

Deleted entire line -

F Foodwator n-tc*,..U.a Me

>a 2702F (nt) fue fatigue (R-94)

Feedwater inlet thermal

-N4)

Nik-el sleeves are not welded to based nozzles and are not subject a4ley to aging management review (See audit items 209 and 291).

Weld Pressure Nickel-Treated water ngý-

1L-A=AA---metal !V.A4 7

.4.42 A

Aging effect entry for

• SLC nozzle to boundary based

>270QF (int) fatigue faWie (R-04) component line deleted -

safe end weld alloy Cracking managed by BWR (N10)

Penetrations Program in following entry of line.

Table 3.1.2-2 Reactor Vessel Internals Control rod guide Support for Stainless Treated water G~aekimn -

TA-mtoat

• .91 4*

3..1 54-A Aging effect entry for tubes Criterion steel

>2702F (int) fatigue WaWe (q-"3) component line deleted -

• Tubes (a)(1)

Cracking managed by BWR equipment Vessel Internals Program in following entry of line.

Control rod guide Support for CASS Treated water ael-ing-T=6A-metal

!V.13144 3.1.4-A Aging effect entry for tubes Criterion

>4822F (int) faUki fatigue component line deleted -

• Bases (a)(1)

Cracking managed by BWR equipment Vessel Internals Program in

_following entry of line.

Core plate Support for Stainless Treated water GFaekin;-

ThAAmetal

!V.131 -I' 4 21 4 A

Aging effect entry for

" Plate, beams Criterion steel

>2709F (int) faligue fa (R-03) component line deleted -

" Blocks, plugs, (a)(1)

Cracking managed by BWR

" Alignment equipment Vessel Internals Program in assemblies following entry of line.

BVY 06-064 Page 2 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT

.TLAA TABLE CHANGES Intended Aging Effect Aging NUREG-Table Component Type Function Material Environment Requiring Management 1801 Vol.

1 Item Notes Change Description Management Programs 2 Item Core spray lines Flow Stainless Treated water GTaeI.ig-6A -metal I-W.B!4 3.1.1-A Aging effect entry for distribution steel

>2709F (int) fatigue fatigue (R-63) component line deleted -

Cracking managed by BWR Vessel Internals Program in following entry of line.

Fuel support Support for CASS Treated water ing -

.A-i=etal

,-,!V.131-44 3.4-5 A

Aging effect entry for pieces Criterion

>4829F (int) fatke fatigue component line deleted -

" Orificed supports (a)(1)

Cracking managed by BWR

" Peripheral equipment Vessel Internals Program in supports following entry of line.

Incore dry tubes Pressure Stainless Treated water.raekig--

T1_,,metal

!V.84-',44 3.4-6 A

Aging effect entry for boundary steel

>270QF (ext) fatgg fatigue (R-4 component line deleted -

Cracking managed by BWR Vessel Internals Program in following entry of line.

Incore guide tubes Pressure Stainless Treated water Grakig--

Ti=AA-meta IV.64-44 3.4.I-A Aging effect entry for boundary steel

>2709F (ext) fatigue fatigue (R-63) component line deleted -

Cracking managed by BWR Vessel Internals Program in following entry of line.

BVY 06-064 Page 3 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Intended Aging Effect Aging NUREG-Table Component Type Incten Material Environment Requiring Management 1801 Vol.

1te Notes Change Description Function Management Programs 2 Item Jet pump Floodable Stainless Treated water G*.ae..*9-T4AA-meta P1.111-14 3.4.4-6 A

Aging effect entry for assemblies volume steel

>270QF (int) fatigue fatigue (R-63) component line deleted -

• Risers, riser Cracking managed by BWR braces Vessel Internals Program in

• Riser hold down following entry of line.

bolts

• Mixer barrels and adapters

• Restraint

brackets, wedges, bolts

• Diffusers and tailpipes

• Adapter upper rings Jet pump Floodable Nickel-Treated water Gra,,i4.

TLAA-mnetal 4V.314-44 34A--*6 A

Aging effect entry for assemblies volume based

>270QF (int) fagiue fatigue (1-643) component line deleted -

• Hold-down alloy Cracking managed by BWR beams Vessel Internals Program in

• Adapter lower following entry of line.

ring Jet pump castings Floodable CASS Treated water

,"aG4.., T,6A-meta

!V,,,

.13.-1,4 3.1-A Aging effect entry for

" Transition piece volume

>482QF (int) fatigue fatige (R53) component line deleted -

• Inlet elbow/

Cracking managed by BWR nozzle Vessel Internals Program in

" Mixer flange following entry of line.

and flare

" Diffuser collar Shroud Floodable Stainless Treated water Gaein,,-

TAA-eta*I PV,.91-44 3.4.*

A Aging effect entry for volume steel

>270QF (int) latigue fatie (R-63) component line deleted -

Cracking managed by BWR Vessel Internals Program in following entry of line.

BVY 06-064 Page 4 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Intended Aging Effect Aging NUREG-Component Type Function Material Environment Requiring Management 1801 Vol.

Notes Change Description Management Programs 2 Item Shroud support Support for Nickel-Treated water

.a

,g--

T-AA-met IVRI-4 3.-.6 6

A Aging effect entry for

• Ring, cylinder, Criterion based

>2709F (int) fatig"e fatigue (R-63) component line deleted -

and legs (a)(1) alloy Cracking managed by BWR

• Access hole equipment Vessel Internals Program in cover following entry of line.

Top guide Support for Stainless Treated water G.aGkig.-

T-.A A-mtUaIV R-V 4 244 1-6 A

Aging effect entry for assembly Criterion steel

>270QF (int) fatigue fatigue (R-63) component line deleted -

(a)(1)

Cracking managed by BWR equipment Vessel Internals Program in following entry of line.

Table 3.1.2-3: Reactor Coolant System Pressure Boundary Aging effect entry for component line deleted -

Cracking managed by One-Time Inspection Program in previous entry of line.

I Environment for this component line changed.

CRD drive temperatures maintained below threshold for fatigue. Aging effect entry for component line deleted.

BVY 06-064 Page 5 of 10

ATrACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Intended Aging Effect Aging NUREG-Table Component Type Function Material Environment Requiring Management 1801 Vol.

I Item Notes Change Description Management Programs 2 Item Pump casing and Pressure CASS Treated water GaeJi..".

TI-PAA---me;

.. 4446_ 34.*

44*

A Aging effect entry for cover (RR) boundary

>482°F (int) fatigue fatigue (R-220) component line deleted -

Cracking managed by BWR Stress Corrosion Cracking and Inservice Inspection Programs in preceding entry of line.

Restrictors (MS)

Flow CASS Treated water raek!g-.*

T-AVA, mt 9

V.-146 3.4.4-3 A

Aging effect entry for control

>482°F (int) fatigue fatigue (R-220) component line deleted -

Cracking managed by One-Time Inspection Program in preceding entry of line.

Intended Aging Effect Aging NUREG-Table Component Type Function Material Environment Requiring Management 1801 Vol.

1 Item Notes Change Description FuctonManagement Programs 2 Item Table 3.2.2-1: Residual Heat Removal System Heatexehane Pressure GaFbeR Triated wa tr

,aGkiFg-Metal fatigue

-7D2 3.24 G

Line deleted. See next line.

(sheu) b.u.,a*.

steel

• 27WoF-%

fatigue T-(E-40)

Heat exchanger Pressure Carbon Treated water Cracking One-Time V.D2-32 3.2.1-1 E

New line item.

(shell) boundary steel

>270°F (int)

Inspection (E-.O)

HeeelWg F

essuFe StaiFless TFeated wate:

Gr,,kng-Metalfatigue V11.63-44 3...4-G Line deleted - Cracking (tubes) b.u.-da-,

steel

• 270!F ext) fatigue TI=AA (A-62) managed by Water Chemistry Control - BWR augmented by One-Time Inspection in preceding line of table BVY 06-064 Page 6 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Intended Aging Effect Aging NUREG-Table Component Type Function Material Environment Requiring Management 1801 Vol Table Notes Change Description Management Programs 2 Item 1 Item Hea

gex, Pec*c Sftainless

.eated water Grckiig-Metal fatigue V

44 3.3*24 G

Line deleted - Cracking (tubes) b.u'da y steel

>-02!F (iit) fatue T-LM (A-621) managed by Water Chemistry Control - BWR augmented by One-Time Inspection in preceding line of table P.......

PSssu Gben leated w racking-Metal fatigue V... 2

• 4

&,44 A

Line deleted. See next line.

boundafy steel

• 270Fat fatigue (E40)

Pump casing Pressure Carbon Treated water Cracking One-Time V.D2-32 3.2.1-1 E

New line item.

boundary steel

>270"F(int) I

_I Inspection (E-10)

Table 3.2.2-4: High Pressure Coolant Injection System

Fb-ineeGasiR*

PFessure GaFben Stea-A >ri2g-Metal fatigue I... 2..

3.4.

G Line deleted. See next line.

boundaFy steel

(

fatigue (S-8)

Turbine casing Pressure Carbon Steam > 2700P Cracking One-Time VII1.B2-5 3.4.1-1 E

New line item.

boundary steel (int)

Inspection (S-08)

Table 3.2.2-5: Reactor Core Isolation Cooling u-:bi~e Gasing Prese4r-e GarbeR Sieam> 220F GraGkling-.

Metal fatigue VI1.132-5 3.4i G

Line deleted. See next line.

Turbine casing Pressure Carbon Steam > 2200 Cracking One-Time VIII.B2-5 3.4.1-1 E

New line item.

boundary steel (int)

Inspection (S-08) 3.3.2-13-36: Reactor Water Clean-Up System.

Heat e-rha-eW Peuie Salles

-T-reated-wate Caki*_...

Metal fatigue 1P-44 22.1-2 C

Line deleted - Cracking (ebboubda.:y Steel 7-2r-(in. )

fatigueM (A-624 managed by Water Chemistry Control - BWR augmented by One-Time Inspection in preceding line of table BVY 06-064 Page 7 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Intended Aging Effect Aging NUREG-Component Type unctiond Material Environment Requiring Management 1801 Vol.

Table Notes Change Description Function Item Management Programs 2 Item PUMPe ye StaiGse*

"r,-,,,

T

.Fea.ed watF Giaek!;,,

Metal fatpige V1,.0-14 3*_.-

A Line deleted - Cracking b

da.

steel

>- 2°.!,*(...)

fatgue T

(A-62-)

managed by Water Chemistry Control - BWR augmented by One-Time Inspection in preceding line of table P:T-an, k

w el S,,les.

,,eaed wate Gag-Met*.tl..e VI,,E3-4 3.A-A Line deleted - Cracking bu.da.y steel

>270rm

n. )

f,,..

TI A (A-62) managed by Water Chemistry Control - BWR augmented by One-Time Inspection in preceding line of table 3.4.2-1: Main Condenser and MSIV Leakai Heat exehanWe (tubes)

Line deleted - Cracking managed by Water Chemistry Control - BWR augmented by One-Time Inspection in preceding line of table BVY 06-064 Page 8 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Table 3.2.1: Engineered Safety Features, NUREG-1 801 Vol. 1 Further Item Cmoet Aging Effect/

Aging Management Fute Number Component Mechanism Programs Evaluation Discussion Change Description Recommended 3.2.1-1 Steel and stainless Cumulative fatigue TLAA, evaluated in Yes, TLAA Fatigue is a TLAA for Discussion modified as steel piping, piping damage accordance with 10 most components.

shown components, and CFR 54.21(c)

The One-Time piping elements in Inspection Program emergency core manages cracking for cooling system components susceptible to fatigue with no TLAA.

See Section 3.2.2.2.1.

Section 3.2.2.2.1 is revised as follows:

3.2.2.2.1 Cumulative Fatigue Damage Where identified as an aging effect requiring management for components designed to ASME Code requirements, the analysis of fatigue is a TLAA as defined in 10 CFR 54.3. TLAAs are evaluated in accordance with 10 CFR 54.21(c). Evaluation of this TLAA is addressed in Section 4.3.

Where fatigue damage is identified as an aging effect requiring management for components with no fatigue design requirements, the aging effect is managed by Inspection. The One-Time Inspection program will manage cracking due to fatigue for these components.

BVY 06-064 Page 9 of 10

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Table 3.4.1: Steam and Power Conversion Systems, NUREG-1801 Vol. 1 Further Item Cmoet Aging Effect/

Aging Management Fute Number Component Mechanism Programs Evaluation Discussion Change Description Recommended 3.4.1-1 Steel piping, piping Cumulative fatigue TLAA, evaluated in Yes, TLAA Fatigue is a TLAA for Discussion modified as components, and damage accordance with 10 most components.

shown piping elements CFR 54.21(c)

The One-Time exposed to steam Inspection Program or treated water manages cracking for components susceptible to fatigue with no TLAA.

See Section 3.4.2.2.1.

Section 3.4.2.2.1 is revised as follows:

3.4.2.2.1 Cumulative Fatigue Damage Where identified as an aging effect requiring management for components designed to ASME Code requirements, the analysis of fatigue is a TLAA as defined in 10 CFR 54.3. TLAAs are evaluated in accordance with 10 CFR 54.21(c). Evaluation of this TLAA is addressed in Section 4.3.

Where fatigue damage is identified as an aging effect requiring management for components with no fatigue design requirements, the aging effect is managed by Inspection. The One-Time Inspection program will manage cracking due to fatigue for these components.

BVY 06-064 Page 10 of 10

RicIJardEmch'-_ BVY-06-063 LRA Am 4 Attachment. 1.doc

.Page l11 Rich' ard***** Emch. BV 06-06 LR Am.... 4 Attachment

.1.do P...age*

.. ~

• Tr.

• • * - I T h f AT-ACHEMENT 1 LICENSE RENEWAL RAI RESPONSES RAI 3.6.2.2-N-08 10 CFR 54.4 (a)(3) requires, in part, that all systems, structures, and components (SSCs) relied on in safety analyses or plant evaluation to perform a function that demonstrates compliance with the Commission's regulations for station blackout (10 CFR 50.63) are within the scope of license renewal. Vernon Hydroelectric Station (VHS) has been designated as the station blackout (SBO) alternate alternating current source and is used to meet SBO requirements of 10 CFR 50.63.

Are all SSCs (including electrical, mechanical, structural, and civil) associated with the VHS included in the scope of license renewal? If they are not, please explain why not.

If they are, please provide an aging management review for long-lived, passive SSCs associated with the hydroelectric station.

VYNPS Response to RAI 3.6.2.2-N-08 Equipment in the Scope of License Renewal The Vernon Hydroelectric Station (VHS) is the alternate alternating current (AAC) source credited for Vermont Yankee Nuclear Power Station (VYNPS) to demonstrate compliance with 1 OCFR 50.63, Loss of all alternating current power (the station blackout rule). As such, all VHS structures, systems, and components (SSCs) are in the scope of license renewal.

Aging Management Review The following discussion provides.the aging management review for long-lived, passive SSCs associated with the Vernon hydroelectric station.

A. Background Of the plants that have applied for license renewal in the United States, Peach Bottom is the only other plant that credits an offsite hydroelectric station as its AAC source for station blackout. Peach Bottom received its renewed operating license in May 2003. For the Peach Bottom plant license renewal, the only aging management program credited for the AAC hydroelectric station was the Federal Energy Regulatory Commission (FERC) dam inspection and maintenance program requirements, provided in 18 CFR 12. This is appropriate considering the mechanical and electrical equipment associated with the turbine generator constitute an active assembly that is routinely confirmed available through normal operation.

Entergy, consistent with the Peach Bottom precedent, credited the FERC dam inspection program to manage the effects of aging on civil and structural elements of the VHS. In accordance with NUREG-1 801, for dam inspection and maintenance, programs under the regulatory jurisdiction of FERC or the U.S. Army Corps of Engineers, continued through the period of extended operation, will be adequate for the purpose of aging management.

Notwithstanding the previously approved staff position regarding the alternate AC source for the Peach Bottom plant, Entergy performed an integrated plant assessment (IPA) for passive, long-lived electrical, mechanical, civil and structural SSCs of the VHS.

BVY 06-063 Page 1 of 8

[fRicharýdEmch - BVY 06-063 LRA Am 4 Attachment 1.docPe Page 2 i ATrACHEMENT I LICENSE RENEWAL RAI RESPONSES B. Integrated Plant Assessment for the Vernon Hydroelectric Station To perform the IPA, Entergy reviewed the current licensing basis to identify the license renewal intended function of the VHS. For each discipline, the review then considered the aging effects, if any, that could prevent satisfactory accomplishment of the intended function for the VHS as a whole. The review also identified appropriate programs or activities to effectively manage the effects of aging to ensure that the VHS will continue to perform its intended function in accordance with the current licensing basis (CLB) through the period of extended operation.

C. License Renewal Intended Function for the VYNPS Alternate AC (AAC) Source As described in UFSAR Section 8.5.5.1, VYNPS uses an AAC source approach for coping with a station blackout (SBO) using the methodology of RG 1.155, uStation Blackout," dated August 1988. VYNPS relies on the Vernon Hydroelectric Station (VHS) to provide power to an emergency bus until offsite or onsite AC power is available.

For an alternate AC source, NUMARC 87-00 specifies that a licensee provide assurance that the AAC source is available at least 95% of the time. Therefore, the license renewal intended function of the VHS for the purposes of demonstrating compliance with the SBO rule is to be available to VYNPS at least 95% of the time the reactor is operating.

D. Integrated Plant Assessment for Civil and Structural SSCs Civil and structural SSCs that support the intended function of the VHS are the structural steel and concrete elements of the dam. In license renewal application (LRA) Table 3.5.2-5, consistent with the Peach Bottom precedent and with NUREG-1801, VYNPS credited the FERC dam inspection program to manage the effects of aging on civil and structural elements of the VHS. In accordance with NUREG-1 801, for dam inspection and maintenance, programs under the regulatory jurisdiction of FERC or the U.S. Army Corps of Engineers, continued through the period of extended operation, will be adequate for the purpose of aging management.

E. Integrated Plant Assessment for Mechanical SSCs Description Mechanical SSCs that support the intended function of the VHS are multiple turbine generator units and the mechanical support systems that provide cooling and lubrication for the turbines and generators. Two turbine generator units have black start capability each with its own independent cooling and lubrication subsystems. The turbines are cooled by natural circulation within the Vernon Dam structure. Mechanical sluice gates control the flow of water.

A skid-mounted diesel engine-driven generator provides backup power for turbine generator field flashing, an air compressor, and the lubricating oil support systems. A fiberglass coated underground tank supplies fuel via carbon steel piping to the skid-mounted diesel generator. A double wall day tank at the diesel engine is equipped with alarms to indicate fuel oil leakage.

VHS Components Subiect to Aging Management Review Passive, long-lived mechanical components of the turbine generator units and support BVY 06-063 Page 2 of 8

Richarf Em'ch - BVY 06-063 LRA Am 4 Attachment 1.doc.Pge 3I ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES equipment are subject to aging management review.

The skid-mounted diesel engine-driven generator is an active assembly that is tested monthly to ensure continued reliability This testing is analogous to testing credited under the maintenance rule to ensure continued reliability of active equipment in nuclear power plants.

Aging Effects Requiring Management Aging effects requiring management are those that can prevent accomplishment of the VHS intended function. Because of the multiple independent generating units and associated support systems within the VHS, no single mechanical component failure due to the effects of aging can prevent accomplishment of the VHS intended function. Therefore, no aging effects require management for the mechanical equipment of the VHS.

F. Integrated Plant Assessment for Electrical SSCs Description Electrical SSCs for the VHS include the generators associated with each turbine, cables and bus for power transmission, instrumentation and control components and their associated cables and connections. Power from the generators is supplied to the VHS switchyard via two medium-voltage (13.8 kV) underground cables to two independent step-up transformers in the switchyard. Switchyard bus downstream of each step-up transformer feeds the 69kV to 13.2 kV transformer that feeds the Vernon tie breaker. The Vernon tie breaker connects power from the transformer to the 13.2 kV underground cable going to the VYNPS. Passive, long-lived components from the breakers feeding the 69 kV to 13.2 kV transformer to and including the 13.2 kV underground cable are included in the aging management review for plant electrical and instrument and control systems as described in LRA Sections 2.5 and 3.6.

The Vernon tie is a highly reliable connection between the VHS and either of the two VYNPS 4160 V emergency buses and is capable of supplying power to required loads under postulated SBO conditions. Loss of the Vernon tie is annunciated and its voltage is monitored in the VYNPS control room. Surveillance testing of the Vernon tie demonstrated the ability to energize an emergency bus and supply required SBO loads in less than 10 minutes. Additionally, the plant is able to safely cope with a total loss of AC power for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the onset of the SBO to the restoration of offsite AC power.

The VHS is designated as a "black-start" facility under arrangements with the regional grid operator. TransCanada has affirmed that they are committed under tariff to provide black-start capability of the VHS to ISO-NE. Both the NEPOOL and REMVEC procedures state that "the most critical power requirement after a blackout is the assurance of reliable shutdowns of nuclear generators, and that expeditious restoration of alternative off-site power sources to nuclear units is imperative to promote the continued reliability of shutdown operations."

TransCanada conducts and documents the black-start of the VHS annually.

As a backup to local indication available to grid operators of a regional blackout, VYNPS procedures direct operators to immediately contact the regional grid control center to initiate a black start of the VHS if the Vernon tie is unavailable due to a regional grid blackout. The regional grid control center procedures direct hydro-station operators (including the VHS BVY 06-063 Page 3 of 8

Richa Ech -BVY06-063 LA Am 4Att'adhrent 1.doc ATnACHEMENT 1 LICENSE RENEWAL RAI RESPONSES operators) to initiate black start procedures, and upon notification that the units are started, provide instructions to align power to VYNPS and to communicate when these actions are complete to the VYNPS control room. The owner of the VHS has a procedure for the actual black'start.

The combination of the periodic testing of the AAC source together with the test of the emergency bus that is conducted every operating cycle encompasses the condition of the SBO event, and provides added assurance of VHS availability to meet the requirement of 10 CFR 50.63.

Based on the designation of the TransCanada VHS units as black start units by ISO-NE, the procedural requirements for achieving black start, and the operating history of the VHS units, there is reasonable assurance that a VHS unit will be available within the SBO coping timeframe.

VHS Commodities Subiect to Aging Management Review Consistent with the approach described in LRA Section 2.1.2.3, Screening of Electrical and Instrumentation and Control Systems, the commodity groups that perform an intended function without moving parts or without a change in configuration) are;

• high voltage insulators, and

• cables, connections and electrical busses.

Other electrical and I&C commodity groups, including transformers, are active and do not require aging management review.

Aging Effects Requirinq Management Aging effects requiring management are those that can prevent accomplishment of the VHS intended function. Because of the multiple independent generators and power transmission circuits within the VHS, no single component failure due to the effects of aging can prevent accomplishment of the VHS intended function. Therefore, no aging effects require management for electrical and instrumentation and control commodity groups within the VHS.

Within the VHS switchyard (owned by National Grid), two circuits provide power to the 69 kV to 13.2 kV transformer that feeds through the Vernon tie breaker to the underground 13.2 kV cable routed to VYNPS. The switchyard bus and associated connections involved with this circuit are subject to aging management review. Aging management review of this portion of the switchyared was addressed in the VYNPS LRA, Section 3.6, for the SSCs described in Section 2.5 under Evaluation Boundaries on Page 2.5-2. Specifically, the path includes the switchyard circuit breakers near the Vernon Dam that feed the Vernon tie transformer, switchyard bus and insulators, and cables and connections in the circuit to the emergency bus and structures.

Two independent paths constitute the remainder of the circuit that provides power from the VHS

• to the VHS switchyard. Because of the two independent power transmission circuits, no single component failure due to the effects of aging can prevent accomplishment of the VHS intended function. Therefore, there are no aging effects requiring management for this portion of the circuit.

BVY 06-063 Page 4 of 8

RIcj!Kq Emch BV'--6-LAA 4 t'he.do'cPaeI A-TACHEMENT 1 LICENSE RENEWAL RAI RESPONSES Availability of the Vernon tie line is tracked on a three year rolling basis. Over the last 4 years the line has been available 99.32% of the time. Approximately 60% of the unavailability was due to the planned replacement of the 4kV underground cable between the 13.2 kV / 4.16kV transformer and the VYNPS 4.16 kV buses. This operating experience indicates the effectiveness of routine switchyard maintenance in achieving acceptable performance of the switchyard circuit between VHS and VYNPS.

G. Quality Assurance Although the VHS is not under the VYNPS QA program, it consists of multiple generating sources and connections to the switchyard. The system, taken as a whole, exhibits a high reliability even though individual components are not operated under the VYNPS QA program.

From 1965 through 1989, VHS demonstrated very high reliability (e.g. 99.9% availability). On this basis, the staff concluded in 1991 [NVY 91-98], that the QA issue has been satisfactorily considered. As previously discussed, availability data for the Vernon tie line indicate that very high reliability continues today.

VYNPS Technical Specifications credit the Vernon tie as an alternate electrical power source for a standby gas treatment system during certain shutdown operations. In addition during reactor operation, VYNPS commitments made in BVY 96-43 and BVY 97-25, assure continued availability of power from the Vernon tie line. The reactor must be shut down within 15 days unless the Vernon tie is returned to service or the basis for maintaining continued operation is written and approved. If the Vernon tie cannot be returned to service within 15 days, within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> VYNPS must submit a report to the NRC in accordance with 1 OCFR50.4 outlining the reason for the unavailability, corrective actions being taken to restore the Vernon tie, compensatory actions in place to provide AC power for Appendix R alternative shutdown fire scenarios, and the time required to make the Vernon tie available. This commitment carries forward into the period of extended operation.

Based on the above, the appropriate controls for VHS and the Vernon tie are in place to provide reasonable assurance of continued acceptable performance through the period of extended operation. Unavailability of the Vernon tie is cause for entry into the VYNPS corrective action program, which invokes associated elements of the QA program. The corrective action program requires evaluation and appropriate corrective action to correct the nonconforming condition. Therefore, QA attributes are adequate for license renewal.

H. Operating Experience Per BVY 94-33, dated March 11, 1994, the "Vernon Hydro Station with multiple units, has demonstrated reliability far in excess of an auxiliary generator (99.9% compared to 95%)."

Subsequent to SBO communications between NRC and VY in the mid 1990's, Vernon Dam has continued to demonstrate high availability. The VHS remained on line throughout the Northeast blackout of August 14, 2003.

Entergy recently held discussions with TransCanada, the owner/operator of the VHS, and the regional grid control center regarding procedural requirements and communication protocols for a postulated SBO event. These communications resulted in system restoration procedure improvements and served to promote a better understanding of the expectations relative to BVY 06-063 Page 5 of 8

[ Rich'a-rd' Em-c-h - BVY'06-063'LR-A Am 4 Attachment 1.doc Page 6 11 I Richard Emch - BVY 06-063 LRA Am 4 Attachment 1.doc Page 611 ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES Entergy's reliance on the VHS during an SBO.

Entergy has established administrative controls to assure performance of a once per operating cycle tabletop review of the procedures that complete the actions to re-power a VYNPS 4KV bus from the VHS. This review discussed interfaces with the operator of VHS and the regional grid operator to verify that roles and responsibilities and timelines are understood and that there have been no changes that would impact the assumption in the VYNPS SBO coping strategy.

Entergy provides the participants with insights regarding offsite power issues for nuclear power stations including plant response to and consequences of an SBO.

Similar to experience at VYNPS, VHS has experienced microbiological and conventional corrosion attack on carbon steel lines exposed to river water (e.g. turbine seal cooling). VHS replaced these lines with copper and stainless steel lines to eliminate loss of material caused by these mechanisms. This experience indicates the effectiveness of the routine maintenance of the VHS in managing the effects of aging. In addition, maintaining high availability in light of this degradation further supports that the multiple independent systems associated with the VHS can be maintained through routine maintenance without impacting the overall intended function of the VHS.

I.

Conclusion In accordance with NUREG-1801, FERC dam inspection and maintenance programs are credited with managing the effects of aging on civil and structural components of the VHS.

Consistent with the current licensing basis (CLB), because of the multiple generating sources and connections to the switchyard, the effects of aging on other components associated with the VHS cannot cause loss of the intended function and have no aging effects requiring management. VHS switchyard passive, long-lived commodity groups that do not involve multiple independent circuits are effectively maintained through routine maintenance by the switchyard owner. Nevertheless, VYNPS will monitor the availability of the VHS to ensure continued conformance with the availability specified in NUMARC 87-00. If availability falls below the acceptable level, VYNPS will respond to the condition through the corrective action program. The corrective action program requires evaluation and appropriate corrective action to correct the nonconforming condition.

Per BVY 94-33, dated March 11, 1994, the "Vernon Hydro Station with multiple units, has demonstrated reliability far in excess of an auxiliary generator (99.9% compared to 95%)."

Subsequent to 1994, the VHS has continued to demonstrate very high availability. The VHS remained on line throughout the Northeast blackout of August 14, 2003.

This recent operating experience indicates that existing commitments and maintenance practices provide reasonable assurance that the VHS will remain capable of performing its intended function in accordance with the current licensing basis throughout the period of extended operation.

RAI 3.6.2.2-N-01 In the license renewal application (LRA) Table 3.6.2-1, under cable connections (metallic parts),

you have stated that there are no aging effects requiring management and no aging management program (AMP) is required. Further, in LRA Table 3.6-1, under discussion of cable connection metallic parts, you have stated that cable connections outside of active BVY 06-063 Page 6 of 8

I Frchard-r:mch'-"BVY 06-063 LRA Am 4.A -ttachme -nt.1.doc I

Pagle 71 Richard~mch-BVY 06-063 LRA Am 4 Attachment 1.doc Paae7il ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES devices are taped or sleeved for protection; and operating experience with metallic parts of electrical cable connections at VYNPS indicated no aging effects requiring management.

Electrical cable connections (metallic parts) are subject to the following aging stressors:

thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. NUREG-1801, Revision 1, AMP XI.E6, "Electrical Cable Connection not Subject to 10 CFR 50.49 Environmental Qualification Requirements," specifies that connections associated with cables within the scope of license renewal are part of this program, regardless of their association with active or passive components. Please provide a basis document including an AMP with the ten elements for cable connections or provide a justification for why an AMP is not necessary.

VYNPS Response to RAI 3.6.2.2-N-01 Electrical cable connections at VYNPS are inspected Under the maintenance rule program as directed by Entergy procedures. The maintenance rule program is in compliance with 10 CFR 50.65. The maintenance rule program is based on industry guidance provided in NUMARC 93-01 and Reg. Guide 1.160.

The maintenance rule program scope includes the following.

Safety-related structure, systems and components (SSCs)

" Non-safety related SSCs that mitigate accidents or transients

" Non-safety related SSCs used in emergency operating procedures Non-safety related SSCs whose failure could prevent safety-related SSCs from fulfilling their safety function.

• Non-safety related SSCs whose failure could cause a scram or safety system actuation.

Electrical cable connections are subcomponents of SSCs that are in the scope of the maintenance rule.

The maintenance rule program includes performance monitoring and trending for SSCs that are in scope. Monitoring and trending is:

" Performed frequently enough to detect and correct degrading equipment performance Used to evaluate equipment performance following maintenance or modification Based on manufacturer's recommendations, operational or industry experiences with plant equipment or plant specific information

" Subject to the corrective action and work order programs Subject to management review and oversight Monitoring and trending includes normal plant maintenance activities. Maintenance includes activities associated with'identifying and correcting actual or potential degraded conditions (e.g.,

repair, surveillance, diagnostic examinations, and preventive measures) as well as support functions for the conduct of these activities.

Thermography is used to detect potential degraded conditions. Thermography can detect "hot spots" in cable connections that are indicative of a high resistance connection.

As a part of the maintenance rule program, periodic assessments are performed. A periodic assessment is performed to evaluate the effectiveness of maintenance activities. This assessment is performed at least every operating cycle, not to exceed 24 months.

BVY 06-063 Page 7 of 8

Rih0..Emch - BVY 06-063 LRA Am-4-Attac-hme'nt 1.d oc P a ge 81EJ ATTACHEMENT 1 LICENSE RENEWAL RAI RESPONSES Plant operating experience has shown that the maintenance rule program has been effective at detecting, evaluating and repairing electrical cable connection degradation.

Since the maintenance rule program includes scoping, performance monitoring, trending and periodic assessments, this program provides reasonable assurance that electrical cable connections will remain capable of performing their intended functions through the period of extended operation. No aging management program (AMP) for license renewal is required at VYNPS since the regulatory mandated maintenance rule program effectively maintains electrical cable connections.

BVY 06-063 Page 8 of 8

Richla-rd-tEmch -LRA A5 Attachment_.oc

-Pgeill ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 11: LRA Section B.1.7 is revised as follows.

1. Delete the exception to the BWR vessel internals program related to the core shroud (page B-27).

2. Delete exception Note #1 on page B-29.

Audit item 26: Add the following text to LRA Section B.1.10 to include the "EQ Component Reanalysis Attributes" specified in NUREG-1801 Vol. 2 Section X.El.

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

Analytical Methods The analytical models used in the re-analysis of an aging evaluation are the same as those previously applied during the prior evaluation. The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, one acceptable method of establishing the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.

Data Collection and Reduction Methods Reducing excess conservatism in the component service conditions (for example, temperature, radiation, cycles) used in the prior aging evaluation is the chief method used for a re-analysis. Temperature data used in an aging evaluation is to be conservative and based on plant design temperatures or on actual plant temperature data. When used, plant temperature data can be obtained in several ways, including monitors used for Technical Specification compliance, other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running). A representative number of temperature BVY 06-064 Page 1 of 12

Ri6haidEm c'_h_-_LRAA5'Attachrn -ent 1. 1 do c.-

Page 2 1

[RichaFd'Ernch - LRAA5 Attachment 1.doc Page 2~I ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST measurements are conservatively evaluated to establish the temperatures used in an aging evaluation. Plant temperature data may be used in an aging evaluation in different ways, such as; (a) directly applying the plant temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation. Any changes to material activation energy values as part of a re-analysis are to be justified on a plant-specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations can be used for radiation and cyclical aging.

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

Acceptance Criteria and Corrective Actions The re-analysis of an aging evaluation could extend the qualification of the component.

If the qualification cannot be extended by re-analysis, the component is to be refurbished, replaced, or re-qualified prior to exceeding the period for which the current qualification remains valid. A re-analysis is to be performed in a timely manner (that is, sufficient time is available to refurbish, replace, or re-qualify the component if the re-analysis is unsuccessful).

Audit items 30, 141, and 146: LRA Section B.1.28 is revised to include an enhancement to perform C02 system inspections every 6 months under the System Walkdown Program. The required inspections will be initiated prior to the period of extended operation. Commitment 30.

Audit item 39: LRA Section B.1.12.2 is revised to delete the exception to the annual fire hydrant gasket inspections. Commitment 31.

Audit item 40: LRA Section B.1.12.2 is revised to delete the exception to the annual fire hydrant flow tests. Commitment 31.

Audit item 48: LRA Section B.1.17 is revised as follows. "VYNPS inspection for water accumulation in manholes is conducted in accordance with a plant procedure. An evaluation per the Corrective Action Process will be used to determine the need to revise manhole inspection frequency based on inspection results."

Audit item 51: LRA Section B.1.18 is revised as follows. "The first test of neutron monitoring system cables that are disconnected during instrument calibrations shall be completed before the period of extended operation and subsequent tests will occur at least once every 10 years.

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

BVY 06-064 Page 2 of 12

I Ri'cfiýdd'Em-c'h'-'LkA'A5-Atta-chment 1.doc-Page 31 I R...h..........

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A1TACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 53: To clarify the technical basis for sampling, the sampling discussion in LRA Section B.1.19 for the Non-EQ Insulated Cables and Connections Program is revised to read as follows. "Most cables and connections installed in adverse localized environments are accessible. This program is a sampling program. Selected cables and connections from accessible areas will be inspected and represent, with reasonable assurance, all cables and connections in the adverse localized environments. If an unacceptable condition or situation is identified for a cable or connection in the inspection sample, a determination will be made as to whether the same condition or situation is applicable to other accessible cables or connections.

The sample size will be increased based on an evaluation per the Corrective Action Process."

Audit item 64: The exception taken to NUREG-1801 Section XI.M3 in LRA Section B.1.23 is deleted. In accordance with ASME Code Case N-652, future examination will be visual only.

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

Revision 14. As this Code Case is now endorsed, this inspection is no longer an exception to NUREG-1 801.

Audit items 76, 80, 81, 243, 266, and 270: Aging effects on the drywell moisture barrier will be managed under the Containment Inservice Inspection Program instead of the Structures Monitoring Program. In support of this, the LRA is revised as follows.

1. In the LRA Table 3.5.2-1 line item for "Drywell floor liner seal" change the aging management program from "Structures Monitoring" to "CiI-IWE". For clarification, change "drywell floor liner seal" to "drywell shell to floor seal (moisture barrier)." The clarification of this terminology also applies to Table 2.4-1 and Section B.1.27.2.

2. In LRA Table 3.5.1 line Item 3.5.1-16 the Discussion column is revised to read: "The aging effects cited in the NUREG-1801 item are loss of sealing and leakage. Loss of sealing is a consequence of the aging effects "cracking" and "change in material properties." For VYNPS, the Containment Leak Rate Program manages cracking and changes in material properties for the primary containment seal and gaskets. The Inservice Inspection -IWE Program manages cracking and changes in material properties for the drywell shell to floor seal (moisture barrier)."

3. In LRA Table 3.5.1, Line Item 3.5.1-5, the Discussion column last paragraph is revised to read "The drywell steel shell and the moisture barrier where the drywell shell becomes embedded in the drywell concrete floor are inspected in accordance with the Containment Inservice Inspection (IWE) Program."

4. LRA Section 3.5.2.2.1.4 is revised to delete from the end of the first paragraph, the phrase "and Structures Monitoring Program". The drywell to floor moisture barrier will be inspected under the Containment Inservice Inspection (IWE) Program only. The Structures Monitoring Program is not used.

Audit item 77: LRA Section B.1.27.2 for the Structures Monitoring Program is revised to include an enhancement to perform at least once every five years an engineering evaluation of groundwater samples to assess for groundwater being aggressive to concrete. Commitment 33.

Audit items 85, 86, 87, 166, 200, 232, 233, 239, 240, 295, 297, 310, 312, 313, and 359: The effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs is confirmed by the One-Time Inspection program. To provide further BVY 06-064 Page 3 of 12

1_ýýkrýýmch _114A A5-Attakhment 1-.doc L~i9.~Ld~mch LRA 5 Atachmnt 1.docPage 4 I ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST clarification, LRA Appendix A is revised for these three water chemistry control programs to include the sentence "The One-Time Inspection Program will confirm the effectiveness of the program".

Audit item 93: In order to address transmission connections, in LRA Table 3.6.2-1, change line item Transmission conductors to Transmission conductors and connections. Revise Section 3.6.2.2.3 to include the following text after the second paragraph.

The aging effects for transmission conductors evident in industry operating experience are loss of conductor strength and loss of material (wear).

The prevalent mechanism contributing to loss of conductor strength of an aluminum conductor steel reinforced (ACSR) transmission conductor is corrosion, which includes corrosion of the steel core and aluminum strand pitting. Corrosion in ACSR conductors is a very slow acting mechanism, and the corrosion rates depend on air quality, which includes suspended particles chemistry, SO2 concentration in air, precipitation, fog chemistry and meteorological conditions. Air quality in rural areas generally contains low concentrations of suspended particles and S02, which keeps the corrosion rate to a minimum. Tests performed by Ontario Hydroelectric showed a 30% loss of composite conductor strength of an 80 year old ACSR conductor due to corrosion.

VYNPS transmission conductors include ACSR and aluminum conductor alloy reinforced (ACAR) conductors. ACAR conductors are aluminum conductors reinforced with alloy steel. ACAR conductors are more resistant to loss of conductor strength since the core of the conductor is a more corrosion resistant alloy steel. AMR conclusions regarding ACSR conductors conservatively bound ACAR conductors.

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

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

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

Loss of material due to mechanical wear can be an aging effect for strain and suspension insulators that are subject to movement caused by transmission conductor vibration or sway from wind loading. Design and installation standards for transmission conductors consider sway caused by wind loading. Experience has shown that transmission conductors do not normally swing.and that when they do swing because of substantial wind, they do not continue to swing for very long once the wind has subsided. Wear has not been identified during routine inspection; therefore, loss of BVY 06-064 Page 4 of 12

ýio4qb ch - LRAA5 Attachment 1.d 0_6 Paale 5 ý

[Richard Ernch -LRA A5 Attachment 1.doc Paae 5 ~I ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST material due to wear in not an aging effect requiring management.

Audit item 97: The VYNPS Metal-Enclosed Bus program ten element comparison to NUREG-1801 (excerpt from the Aging Management Program Evaluation Report LRPD-02) will be provided in later correspondence along with associated revisions to the LRA.

Audit item 118: LRA Section B.1.17 is revised to replace the last sentence in the Program Description with; "The specific type of test to be performed will be determined prior to the initial test and is to be a proven test for detecting deterioration of the insulation system due to wetting as described in EPRI TR-1 03834-Pl -2, or other testing that is state-of-the-art at the time the test is performed."

Audit item 120: LRA Section B.1.17 Program Description is revised to state that medium-voltage cables include cables with operating voltage level from 2kV to 35kV.

Audit item 124: LRA Section B.1.19 Program Description is revised to include the following.

'The program applies to accessible electrical cables and connections within the scope of license renewal that are installed in adverse localized environments caused by heat or radiation in the presence of oxygen."

Audit Item 159: LRA Section B.1.12.1 is revised to add fire dampers to the list of components in the Program Description that require a periodic visual inspection.

Audit item 165: Line Items 3.3.1-50 and 3.3.1-51 in LRA Table 3.3.1 are revised to replace the Water Chemistry Control - Auxiliary Systems program in the Discussion column with the Water Chemistry Control - BWR Program Audit item 187: LRA section B.1.28 is revised to add the following enhancements. The System Walkdown Program implementing procedure will be enhanced to specify that systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 50.54 (a)(1) and (a)(3) shall be inspected. In addition, the implementing procedure will be enhanced to provide guidance to inspect nearby systems with the potential for spatial interaction. These enhancements will be implemented as shown in Commitment 24.

Audit item 198, 216, 218, 237, 331 and 333: The VYNPS Bolting Integrity Program ten element comparison to NUREG-1801 (excerpt from the Aging Management Program Evaluation Report LRPD-02) will be provided in later correspondence along with associated changes to the LRA.

The Bolting Integrity Program will be implemented prior to the period of extended operation in accordance with Commitment 34.

Audit item 203: LRA Table 3.1.2-3 is revised to indicate that with the exception of the head seal leak detection line, the Inservice Inspection Program applies to all component types of Piping and fittings < 4" NPS with an aging effect of cracking in addition to the Water Chemistry Control

- BWR and One-Time Inspection Programs.

Audit Item 209 and 291: LRA Table 3.1.2-1 on page 3.1-52 is revised to remove all the line items for the component type of Thermal Sleeves Feedwater Inlets (N4). The thermal sleeves are not subject to aging management review since they perform no intended function for license renewal. The sleeves are installed with an interference fit rather than welded so they have no impact on the reactor coolant pressure boundary.

BVY 06-064 Page 5 of 12

Rich*ddmch-LRA A5 Attachment 1doc Page6t ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit items 224, 225, 226, 229, 293, 294, 315, and 369: LRA Section B.1.21 is revised to state that the One-Time Inspection program will verify effectiveness of the Oil Analysis and Diesel Fuel Monitoring programs by confirming the absence of loss of material, cracking and fouling, where applicable.

Audit item 235: In LRA Table 3.3.2-10 for the NUREG-1801 Vol. 2 Item for component types "humidifier housing" and "piping", change item VIII.F1-8 to item VII.F1-8. The incorrect number was entered due to a typographical error.

Audit item 242: LRA Table 3.5.2-1 is revised to delete line items for "Bellows (reactor vessel and drywell)". Also the corresponding line item in Table 2.4-1 is deleted.

Audit item 244: LRA Table 3.5.2-6 is revised to indicate that Note "A" applies to component seals and gaskets (doors, man-ways and hatches) with the aging management program of Structures Monitoring Program.

Audit item 248: LRA Table 3.5.2-6 is revised to change Note "A" to Note "C" for electrical and instrument panels and enclosures with a material of galvanized steel in a protected from weather environment. Aging effect and associated aging management program are unchanged.

Audit item 249: LRA Table 3.5.2-6 is revised to change Note "A" to Note "C" for flood curb with a material of galvanized steel in a protected from weather environment. Aging effect and associated aging management program are unchanged.

Audit item 250: LRA Table 3.5.2-1 is revised to change Note "E" to Note "A" for torus shell with an aging effect of cracking-fatigue. Aging effect and associated aging management program are unchanged.

Audit items 255, 257, 258, 259, 263, and 278: The LRA is revised to indicate loss of material as an aging effect requiring management with the Structures Monitoring Program as the aging management program and the NUREG-1801 Vol. 2 Item as III.B4-7 with a Note C in the following cases.

1. Table 3.5.2-5 for transmission towers with a material of galvanized steel in an exposed to weather environment

2. Table 3.5.2-6 for conduit with a material of galvanized steel in an exposed to weather environment

3. Table 3.5.2-6 for conduit support with a material of galvanized steel in an exposed to weather environment

4. Table 3.5.2-6 for electrical and instrument panels and enclosures with a material of galvanized steel in an exposed to weather environment

5. Table 3.5.2-6 for structural bolting with a material of galvanized steel in an exposed to weather environment LRA Table 3.5.1, item 3.5.1-50 is revised to include the following in the Discussion column: "Consistent with NUREG-1 801 for galvanized steel components in outdoor air.

The Structures Monitoring Program will manage loss of material."

BVY 06-064 Page 6 of 12

I RichaidE m-ch - LkA A5 Attac hment 1.doc

'Pag6' 7 11 Richard'Emch - LRA A5 Attachment 1.doc Page 7 II ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 267:

LRA Table 3.5.2-1 is revised to add the following line.

Torus PB, Carbon Protected Cracking TLAA-11.B4-4 3.5.1-8 A

mechanical SSR steel from (fatigue) metal (C-13) penetration weather fatigue LRA Table 3.5.2-1 is revised to delete the follwing line.

Drywell to PB1, Carbon Protected Crackingr TLAA-11.B1.1-4 3.5.1-8 A

torus vent SSR steel from (fatigue) metal (C-21) system weather fatigue The Discussion column for LRA Table 3.5.1 item 3.5.1-8 is revised to read as follows.

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

The Discussion column of LRA Table 3.5.1 item 3.5.1-9 is revised to read as follows.

"Fatigue analysis is a TLAA for the torus penetrations. See Section 3.5.2.2.1.6.

The Discussion column of LRA Section 3.5.2.2.1.6 is revised 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.

LRA Section 3.5.2.3, Time-Limited Aging Analyses, is revised to read as follows. "TLAA identified for structural components and commodities include fatigue analyses for the torus and torus penetrations. These topics are discussed in Section 4.6."

Audit items 268 and 269: The LRA is revised as follows.

1. For clarification, the Discussion column of Table 3.5.1, line items 3.5.1-12 and 3.5.1 -

13 is revised to add the following statement at the end of the existing information.

"See Section 3.5.2.2.1.8".

2. LRA Section 3.5.2.2.1.8 is revised to read as follows. "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 drywell, torus and associated penetration bellows, penetration sleeves, un-braced downcomers, and dissimilar metal welds. A review of plant operating experience did not identify cracking of the components, and primary containment leakage has not been identified as a concern.

Nonetheless the existing Containment Leak Rate Program with augmented ultrasonic exams and Containment Inservice Inspection - IWE, will continue to be used to detect cracking. Observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process. The Containment Inservice Inspection - IWE and Containment Leak Rate programs are described in Appendix B."

BVY 06-064 Page 7 of 12

I --Riýc--ha-r'd"'t*m--c-h--'LftA A ý At t-achhient i.-doic Page 8i1 I Richard ~mch - LRA A5 Attachment 1.doc Page 8~I ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 279: For clarification, LRA Table 3.5.1, Item 3.5.1-52 discussion is revised to read as follows. "Loss of mechanical function due to the listed mechanisms is not considered 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."

Audit item 280: For clarification, LRA Table 3.5.1, Item 3.5.1-54 discussion is revised as follows. "Loss of mechanical function due to distortion, dirt, overload, fatigue due to vibratory, and cyclic thermal loads is not considered an aging effect requiring management. Such failures typically result from inadequate design or events rather than the effects of aging. Loss of material due to corrosion, which could cause loss of mechanical function, is addressed under Item 3.5.1-53 for Groups B13.1, B13.2, and B13.3 support members."

Audit item 282: For clarification, LRA Table 3.5.1, Line Item 3.5.1-34 discussion is revised to add "See Section 3.5.2.2.2.4(1)".

Audit item 283: LRA Table 3.5.1, Item 3.5.1-35 discussion is revised to replace ACI 301 with ACI 318 and add "See Section 3.5.2.2.2.4(2)" at the end of the existing discussion.

Audit item 284: LRA Table 3.5.1, Line item Number 3.5.1-36 discussion column is revised as follows. "Reaction with aggregates is not an applicable aging mechanism for VYNPS concrete components. See Section 3.5.2.2.2.1(5) (although for Groups 1-5, 7, 9 this discussion is also applicable for Group 6). See Section 3.5.2.2.2.4(3) additional discussion. Nonetheless, the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components."

To correct an' administrative error, the heading of LRA Section 3.5.2.2.2.4 (3) is revised to begin with "Cracking Due to Expansion, Reaction with Aggregates...". The term stress corrosion cracking is deleted from the heading as it does not apply to this section.

Audit item 285: The Discussion column of LRA Table 3.5.1,.Item Number 3.5.1-37, is revised to state the following. "Not applicable. Nonetheless the Structures Monitoring Program will confirm the absence of aging effects requiring management for VYNPS Group 6 concrete components. See Section 3.5.2.2.2.4(3)".

Audit item 286: For clarification, LRA Table 3.5.1, Item Number 3.5.1-40 discussion column is revised to add "See Section 3.5.2.2.2.6(1)".

Audit Item 304: LRA Table 3.3.2.13-32 is revised to replace the aging management program of One-Time Inspection with Periodic Surveillance and Preventive Maintenance for all line items containing carbon steel and copper alloy with an environment of untreated water.

Audit item 309: LRA Section 3.1, 3.2, 3.3 and 3.4 tables will be revised to remove "TLAA-metal fatigue" from all line items for which Section 4 does not discuss evaluation of a TLAA. Line by line changes to the tables are provided in Attachment 2 to this letter.

Audit item 318: LRA Table 4.3-1 is revised to remove the NUREG/CR-6260 values for core spray safe end, feedwater piping, RHR return piping, and RR piping tee and replace them with N/A. Commitment 27 requires an analysis that addresses the effects of reactor coolant environment on fatigue performed to an NRC-approved version (year) of the ASME code.

BVY 06-064 Page 8 of 12

Richard Emch - LRA A5 Attachment 1.doc.

Page_ 9 ATTACHMENT I LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST Audit item 319: The last paragraph of LRA Section 4.3.1.1 is replaced with the following. "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 considered in the existing fatigue analyses, several locations have a projected cumulative usage factor in excess of 1.0. See Section 4.3.3 for further discussion of the effects of reactor water environment on fatigue."

Audit item 320: LRA Reference 4.3.1 on page 4.3-9 is revised as follows; "4.3-1 Sojka, R. E.

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

Audit item 322: LRA Section 4.3.1.3 is replaced with the following.

"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)(i).

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)(i).

The MSIVs will not exceed 2050 cycles in 60 years (34 cycles per year)."

In addition LRA section 4.3.2 is replaced with the following.

"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 stress 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).

BVY 06-064 Page 9 of 12

Richiýrd Eim-ch - LRA A5_Attachrý_en I t 1.doc Page, 10d I Richa~rd Emch - LRA A5Attachment 1.doc Page 1011 a

ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST There are no TLAA for any non-Class 1, non-piping components as they are not 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 extended 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."

Audit item 335: LRA Table 3.5.2-6 lists the aging effects for component Penetration sealant, material elastomer in a protected from weather environment as "cracking" and "change in material properties." For clarification, the LRA is revised to separate this component line item into two line items as follows:

1. Delete line item:

Penetration EN, Elastome Protected

Cracking, Fire Ill.A6-3.5.1-C sealant FB, r

from Change protection, 12 44

FLB, weather in Structures (fire, flood, PB, material Monitoring (TP-7) radiation)

SNS properties

2. Add line item:

Penetration EN, Elastome Protected

Cracking, Fire VII.G-1 3.3.1-B sealant FB, Ir from Change in protection (A-19) 61 (fre PB, Iweather material (fire)

JSNS j properties

3. Add line item:

Penetration EN, IElastome Protected Cracking, Structures lll.A6-3.5.1 -

C sealant

FLB, r

from Change Monitoring 12 44 (flood, PB, J

weather in (TP-7) radiation)

SNSI material properties Audit item 336: LRA Table 3.5.2-6 lists the aging effects for the Seismic isolation joint, with a material of elastomer in a protected from weather environment as "cracking" and "change in material properties." For clarification, the LRA is revised to make the following changes.

BVY 06-064 Page 10 of 12

I RichardEm c-li __LRA A5 Attachment -1 1 doc Pagell1il I Richard Emch - LRA A5 Attachment 1.doc Paae 11 ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST

1. Note C is changed to Note E for this line item.

2. The discussion in Table 3.3.1 line Item 3.3.1-61, Page 3.3-49 is revised to read as follows. "This line item was not used in the auxiliary systems tables. Fire barrier seals are evaluated as structural components in Section 3.5. Cracking and change 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 is added to read as follows.

Seismic SSR Elastome Protected

Cracking, Structures III.A6-3.5.1-C isolation r

from Change in Monitoring 12 44 joint weather material (TP-7) properties Audit item 337: LRA Table 3.5.2-6 lists the aging effect for Fire doors, with a material of carbon steel in a protected from weather environment as "loss of material." For clarification, the LRA is revised to change 'Note C' to 'Note B' for this line item.

Audit item 345: LRA Table 3.3.2-13 lists the aging effect for component type of bolting, with a material of stainless steel in an air - outdoor (ext) environment as "none." The LRA is revised to identify loss of material as an aging effect for this line item as shown below.

Bolting Pressure Stainless Ar

-I Loss°'

o System G

I boundary steel outdoor material walkdown Audit item 350: LRA Section A.2.1.31 Structures Monitoring-Vernon Dam FERC Program is replaced with the following. "The Vernon dam is subject to the Federal Energy Regulatory Commission (FERC) inspection program. This program consists of visual inspections in accordance with FERC guidelines and complies with Title 18 of the Code of Federal Regulations, Conservation of Power and Water Resources, Part 12 (Safety of Water Power Projects and Project Works) and Division of Dam Safety and Inspections Operating Manual.

The operation inspection frequency for licensed and exempt low hazard potential dams is biennially. As indicated in NUREG-1 801 for water control structures, NRC has found that FERC

/ US Army Corp of Engineers dam inspections and maintenance programs are acceptable for aging management. "

Audit item 354: The LRA is revised to delete Sections 4.7.2.5, 4.7.2.6, A.2.2.7 and A.2.2.8.

Also the component type of vessel ID attachment welds and instrument penetrations in LRA Table 4.1-1 is deleted. The items discussed in these sections do not meet the definition of time-limited aging analyses.

In LRA table 3.1.2-1 (page 3.1-54) for the component type of internals attachments the line with the aging effect of cracking-fatigue and TLAA-metal fatigue as the aging management program is deleted. Cracking managed by the BWR Vessel ID Attachment Welds Program remains in the table.

BVY 06-064 Page 11 of 12

Rchard mch - LRA A5 Attachment -1.doc -Page 12J ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST In LRA table 3.1.2-1 (page 3.1-44) for the component type of nozzles, instrumentation, N11 the line item with the aging effect of cracking-fatigue and TLAA-metal fatigue as the aging management program is deleted. Cracking managed by the BWR Penetrations Program remains in the table.

Audit item 371: LRA Section B.1.11 is revised as follows. "The VYNPS Fatigue Monitoring Program includes counting of the cycles incurred by the plant. Five transients are monitored by plant operations and recorded as they occur. It is projected that less 60% of the design cycles for these five transients will be used through the first 60 years of operation, including the period of extended operation. 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."

Audit item 373: LRA Section 3.3.2.2.13 Loss of Material due to Wear is 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 VYNPS auxiliary systems."

Audit item 376: LRA Table 3.3.1 line item 3.3.1-69 is revised to remove the reference to the One-Time Inspection Program.

Audit item 379: LRA Table 3.5.1 line item 3.5.1-16 discussion is revised to add the following paragraph. "For reactor building seals and gaskets, the Periodic Surveillance and Preventive Maintenance Program manages cracking and change in material properties for the railroad inner and outer lock doors elastomer seals."

Audit item 382: The operating experience discussion in LRA Appendices B.1.17, B.1.18, and B.1.1 9 is replaced with the following.

"This 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-1 801 program description. VYNPS plant-specific operating experience has been reviewed against the industry operating experience identified in NUREG-1 801. Although VYNPS has not experienced all of the aging effects listed in NUREG-1801, the VYNPS program will manage all of the aging effects identified in the Operating Experience section of NUREG-1 801.

The program is based on the program description in NUREG-1 801, 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."

BVY 06-064 Page 12 of 12

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S JI ATTACHMENT 1 LICENSE RENEWAL APPLICATION SUPPLEMENT AMENDMENT LIST BVY 06-064 Page 13 of 12

I Richa-rd Emch-LRA'A5 Attachment 2.doc'"-

Page 1 ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Audit item 309 - Tables and text of LRA Sections 3.1, 3.2, 3.3 and 3.4 are modified as follows:

Component Intende Material Environme Aging Aging NUREG-Table Notes Change Description Type d

nt Effect Manageme 1801 Vol.

1 Item Functio Requiring nt 2 Item n

Manageme Programs nt Table 3.1.2-1 Reactor Vessel Closure flange Pressure Low alloy Air-indoor GraG-A M A 1-4 341-G 1-0 Aging effect entry for studs, nuts, boundary steel (ext) fatigue fatigue

{--04) component line deleted -

washers and Cracking managed by bushings Reactor Head Closure Studs Program in following entry of line.

Incore housing Pressure Stainless Air-indoor G aek-ng-ZAA---mt G

Aging effect entry for bolting boundary steel (ext) fatigue fatigue component line deleted -

• Flange bolts Cracking managed by

• Flange Inservice Inspection

• Nut and washer Program in following entry of line.

Other pressure Pressure Low alloy Air-indoor Gaig-AA.-.ma 1A14 344-G,40.

Aging effect entry for boundary bolting boundary steel (ext) fatique fatigue (R-04) component line deleted -

" Flange bolts Cracking managed by and nuts (N6A, Inservice Inspection N6B, N7)

Program in following entry

" CRD flange of line.

caps-crews and washers CAP Pressure Stainless Treated water Grac~g---

TA4.4

&4-.-..--..--.

44 A

Aging effect entry for

• CRD retum line boundary steel

>270QF (int) fatigue fatigue (R-04) component line deleted -

(N9)

Cracking managed by BWR CRD Return Une Nozzle Program in following entry of line.

BVY 06-064 Page 1 of 10

I Richard Lmch - LRA A5 Attachment 2.doc Pacle 2 fl I

'A ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Thermal sleeves Pressure Stainless Treated water Gracki;g.-.

A n

,l-A14.

24-A A

Aging effect entry for

• Recirc inlet (N2) boundary steel

>270QF (int) latigue fatigue 0;-04) component line deleted -

• Core spray (N5)

Cracking managed by BWR Vessel Internals Program in following entry of line.

Thw.mal-e.evan eree-Staileas-

49atedW-ater Ga*aking-T t"

AV..A4.

1-A Deleted entire line -

,*........,,,t, bounda seal and

.92F...

,,,(i.t) fatigue fatigue (R-04)

Feedwater inlet thermal NiN4et.

sleeves are not welded to bae4d-nozzles and are not subject a-ley to aging management review (See audit items 209 and 291).

Weld Pressure Nickel-Treated water Gra* k tLAI -

374-7 A

Aging effect entry for

• SLC nozzle to boundary based

>270QF (int) fatigue fatigue (R..4) component line deleted -

safe end weld alloy Cracking managed by BWR (N10)

Penetrations Program in if]_

I following entry of line.

Table 3.1.2-2 Reactor Vessel Internals Control rod guide Support Stainless Treated water Gracking-XTA-e**mta-W1.3-1-44 34-:4 A

Aging effect entry for tubes for steel

>270QF (int) fatigue fatigue-(R&3) component line deleted -

• Tubes Criterion Cracking managed by BWR (a)(1)

Vessel Intemals Program in equipment following entry of line.

Control rod guide Support CASS Treated water Gaekinq TI.A-,meta!

MB--4 R-4 A

Aging effect entry for tubes for

>482QF (int) fatigue fatigue-( -63) component line deleted -

• Bases Criterion Cracking managed by BWR (a)(1)

Vessel Internals Program in equipment I following entry of line.

Core plate Support Stainless Treated water GraGkleri-TI A.A -mntat P4.R84-44 214-A Aging effect entry for

• Plate, beams for steel

>270QF (int) fatigue fatigue-(R-63) component line deleted -

• Blocks, plugs, Criterion Cracking managed by BWR

• Alignment (a)(1)

Vessel Internals Program in assemblies equipment following entry of line.

Core spray lines Flow Stainless Treated water ain TI insta-

• tB444 34P.1----44:1-A Aging effect entry for distributio steel

>270QF (int) fatigue latigue-(R-3) component line deleted -

n Cracking managed by BWR Vessel Intemals Program in following entry of line.

BVY 06-064 Page 2 of 10

I Richard Emch - LRA A5 Attachment 2.doc Page 3 !1 b

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Fuel support Support CASS Treated water Graking -

TAA etA A

,t-4-44 344 A

Aging effect entry for pieces for

>482QF (int) fatigue fatigue (9-3) component line deleted -

" Onficed Criterion Cracking managed by BWR supports (a)(1)

Vessel Internals Program in

" Peripheral equipment following entry of line.

supports Incore dry tubes Pressure Stainless Treated water Grackt*-g-TLAA metal-P/ R1-14 3.4.

A Aging effect entry for boundary steel

>270QF (ext) fatique fatigue-(R-6) component line deleted -

Cracking managed by BWR Vessel Internals Program In I

I_

I following entry of line.

Incore guide tubes Pressure Stainless Treated water Ga4,kinq--

T'IAA, metat DV9--44 24 1-5 A

Aging effect entry for boundary steel

>2709F (ext) fatigue fatigue (R-53) component line deleted -

Cracking managed by BWR Vessel Internals Program in following entry of line.

Jet pump Floodable Stainless Treated water aGking-TlA.Ametal-P4-1B4-44 34---

A Aging effect entry for assemblies volume steel

>2709F (int) fatigue fatigue (R63) component line deleted -

" Risers, riser Cracking managed by BWR braces Vessel Internals Program in

" Riser hold down following entry of line.

bolts

" Mixer barrels and adapters

" Restraint brackets.

wedges, bolts

" Diffusers and tailpipes

" Adapter upper rings Jet pump Floodable Nickel-Treated water Grarking--

TLAA, metat P4 RI

.4-.-...4-A Aging effect entry for assemblies volume based

>270QF (int) fatigue fatigue-( 453) component line deleted -

• Hold-down alloy Cracking managed by BWR beams Vessel Internals Program in

• Adapter lower following entry of line.

ring_

BVY 06-064 Page 3 of 10

I Richard _EmCh - LRA A5 Attachment 2.doc Page 4t1 S

~

ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Jet pump castings Floo C* AS Treated GraJkina T..A.

A-14 3.4.-*5 A

Aging effect entry for

" Transition dabl S

water atig* e atigue-(R-63) component line deleted -

piece e

>482QF Cracking managed by BWR

• Inlet elbow/

volu (int)

Vessel Internals Program in nozzJe me following entry of line.

" Mixer flange and flare

" Diffuser collar Shroud Floodable Stainless Treated water Grakidq

FbAA-metaf IVR1-4 4 21 -

A Aging effect entry for volume steel

>270QF (int) faligue latigue-(R-3) component line deleted -

Cracking managed by BWR Vessel Internals Program in following entry of line.

Shroud support Support Nickel-Treated water GrackinT---

LA.-Ameta-R 3-.-4.4 34.4-6 A

Aging effect entry for

" Ring, cylinder, for based

>270QF (int) fatigue fatigue-(R53) component line deleted -

and legs Criterion alloy Cracking managed by BWR

" Access hole (a)(1)

Vessel Internals Program In cover equipment following entry of line.

Top guide Support Stainless Treated water GCacki*g--

T-lAA-.meta!

P4,R-1444 344.4-A Aging effect entry for assembly for steel

>270QF (int) fatigue fatigue (R-3) component line deleted -

Criterion Cracking managed by BWR (a)(1)

Vessel Internals Program in equipment following entry of line.

Table 3.1.2-3: Reactor Coolant System Pressure Boundary Detector (CRD)

Pressure Stainless Treated water

,aGkin T'...A.4A,

'WGI. 1 5

3 A

Aging effect entry for boundary steel

>270*F (int) fatigue faigue (R-220) component line deleted -

Cracking managed by One-Time Inspection Program In previous entry of line.

Drive (CRD)

Pressure Stainless Treated water Grak Tng T.A-4.mt 1V.1I 3.4.4 A

Environment for this boundary steel

.,-.,0o )

fatigue faigue (R-2-20) component line changed.

CRD drive temperatures maintained below threshold for fatigue. Aging effect entry for component line deleted.

BVY 06-064 Page 4 of 10

RcadEmch - LRA A5 Atta-chm ent 2.doc Page 5 I ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Pump casing and Pressure CASS Treated water Grackin T'..,*.

m.alW*.4 5 3.1.A A

Aging effect entry for cover (RR) boundary

>482°F (int) fatigue latigue

{

component line deleted -

Cracking managed by BWR Stress Corrosion Cracking and Inservice Inspection Programs In preceding entry of line.

Restrictors (MS)

Flow CASS Treated water GraGkk,,-

T.-

metal.

5 P4-3.

A Aging effect entry for control

>482°F (int) fatigue fatige (R220) component line deleted -

Cracking managed by One-Time Inspection Program in 1 preceding entry of line.

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o ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES

.... -, Page 6.'

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ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES H~aeX~aA@6 12'eee"e-SlaiAING StOeAm-Ga~Iking 9oa-J Une deleted - Cracking (tubes) bowna steel 2702P (W) latigue fatigue managed by Water Y

XI=AA Chemistry Control - BWR augmented by One-Time Inspection in preceding line of table BVY 06-064 Page 7 of 10

Richad Erch -LRA A5 A ttachment 2. doc Page 8i1 ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES Table 3.2.1: Engineered Safety Features, NUREG-1801 Vol. 1 Item Component Aging Effect/

Aging Management Further Discussion Change Description Number Mechanism Programs Evaluation Recommended 3.2.1-1 Steel and stainless Cumulative fatigue TLAA, evaluated in Yes, TLAA Fatigue is a TLAA for Discussion modified as steel piping, piping damage accordance with 10 most components, shown components, and CFR 54.21(c)

The One-Time piping elements in Inspection Program emergency core manages cracking for cooling system components susceptible to fatigue with no TLAA.

I See Section 3.2.2.2.1.

1 Section 3.2.2.2.1 is revised as follows:

3.2.2.2.1 Cumulative Fatigue Damage Where identified as an aging effect requiring management for components designed to ASME Code requirements, the analysis of fatigue Is a TLAA as defined in 10 CFR 54.3. TLAAs are evaluated in accordance with 10 CFR 54.21(c). Evaluation of this TLAA is addressed in Section 4.3.

Where fatigue damage is Identified as an aging effect requiring management for components with no fatigue design requirements, the aging effect is managed by Inspection. The One-Time Inspection program will manage cracking due to fatigub for these components.

Table 3.4.1: Steam and Power Conversion Systems, NUREG-1801 Vol. 1 Item Component Aging Effect/

Aging Management Further Discussion Change Description Number Mechanism Programs Evaluation Recommended S

BVY 06-064 Page 8 of 10

[Richard Em h - LRA A5 Attachment 2.doc Page 9 ATTACHMENT 2 LICENSE RENEWAL APPLICATION SUPPLEMENT TLAA TABLE CHANGES 3.4.1-1 Steel piping, piping Cumulative fatigue TLAA, evaluated in Yes, TLAA Fatigue is a TLAA for Discussion modified as components, and damage accordance with 10 most components.

shown piping elements CFR 54.21(c)

The One-Time exposed to steam Inspection Program or treated water manages cracking for components susceptible to fatigue with no TLAA.

I See Section 3.4.2.2.1.

1 Section 3.4.2.2.1 is revised as follows:

3.4.2.2.1 Cumulative Fatigue Damage Where Identified as an aging effect requiring management for components designed to ASME Code requirements, the analysis of fatigue isa TLAA as defined in 10 CFR 54.3. TLAAs are evaluated in accordance with 10 CFR 54.21(c). Evaluation of this TLAA is addressed in Section 4.3.

Where fatigue damage is identified as an aging effect requiring management for components with no fatigue design requirements, the aging effect is managed by inspection. The One-Time Inspection program will manage cracking due to fatigue for these components.

BVY 06-064 Page 9 of 10