ML063120106

E-mail: (PA-LR) VYNPS License Renewal Amendment 19

ML063120106
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	10/31/2006
From:	Hamer M Entergy Nuclear Vermont Yankee
To:	Rowley J NRC/NRR/ADRO/DLR
References
%dam200612, TAC MD2297
Download: ML063120106 (26)

Text

0"RichdarEmch - VYNPS License Renewal Amendment 19

______Page 11 From:

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

To:

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

Date:

Tue, Oct 31, 2006 5:13 PM

Subject:

VYNPS License Renewal Amendment 19

Jonathan, Attached is Amendment 19 to VY's License Renewal Application. This letter contains; responses for Section 3.5, Structures and Supports, responses to teleconferences on 09/25 and 09/27, VYNPS License Renewal Commitment List, Rev. 4.

<<BVY 06-097 - VYNPS LRA Amendment 19.PDF>>

Please contact me if you have any questions.

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

<dmannai@entergy.com>, "YOUNG, GARRY G" <GYOUNG4@entergy.com>, "Lach, David J"

<DLach@entergy.com>, "COX, ALAN B" <ACOX@entergy.com>, "McCann, John (ENNE Licensing Director)" <jmccanl @entergy.com>, "Faison, Charlene D" <CFaison@entergy.com>, "Metell, Mike"

<hmetell@entergy.com>, "Gill, Jeanne" <jgill2@entergy.com>

11 c-\\temI:ý,GWJ00001.TMP Pa7q-6-fl c:\\temp~GW}OOOQ1.TMP lii Mail Envelope Properties (4547CA67.315 :10: 25365)

Subject:

Creation Date From:

Created By:

VYNPS License Renewal Amendment 19 Tue, Oct 31, 2006 5:12 PM "Hamer, Mike" <mhamer@entergy.com>

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

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

ACOX CC (ALAN B COX)

DLach CC (David J Lach)

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

WMagui 1 CC (William F Maguire)

TSULLI2 CC (Theodore A Sullivan)

Post Office TWGWPO03.HQGWDOO1 Files Size Date & I MESSAGE 475

Tuesday, TEXT.htm 3768 BVY 06-097 - VYNPS LRA Amendment 19.PDF 1270352 Mime.822 1

Route nrc.gov entergy.com rime October 31, 2006 5:12 PM Options Expiration Date:

Priority:

ReplyRequested:

Return Notification:

Concealed

Subject:

Security:

None Standard No None No Standard

ILic:em p\\GW}O0001.TMP P~a*ge._2*

Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled

ntergy Entergy Nuclear Operations, Inc.

Vermont Yankee P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 257 5271 October 31, 2006 Docket No. 50-271 BVY 06-097 TAC No. MC 9668 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

1.

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

2.

Letter, USNRC to VYNPS, "Requests for Additional Information for the Review of Vermont Yankee Nuclear Power Station License Renewal Application", NVY 06-127, dated September 28, 2006.

Subject:

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

License Renewal Application. Amendment 19 On January 25, 2006, Entergy Nuclear Operations, Inc. and Entergy Nuclear Vermont Yankee, LLC (Entergy) submitted the License Renewal Application (LRA) for the Vermont Yankee Nuclear Power Station (VYNPS) as indicated by Reference 1. The following attachments are provided to address NRC requests for additional information (RAls).

" Attachment 1: RAI Responses - Section 3.5; Structures and Supports.

" Attachment 2: RAI 3.3.1-68-K Amended Response from 09/27/06 Teleconference.

• : RAI 2.3.3.8-1.- NRC Additional Information Request from 09/25/06 Teleconference.

• : VYNPS License Renewal Commitment List, Revision 4 - Commitment No. 33 has been revised to incorporate changes resulting from the response to RAI 3.5-7.

Should you have any questions concerning this letter, please contact Mr. David Mannai at (802) 451-3304.

I declare under penalty of perjury that the foregoing is true and correct, executed on October 30, 2006.

Sincerely,/

/fe~d 6; ent Site Vice President Vermont Yankee Nuclear Power Station Attachments 1, 2, 3 and 4 cc: See next page

BVY 06-097 Docket No. 50-271 Page 2 of 2 cc:

Mr. James Dyer, Director U.S. Nuclear Regulatory Commission Office 05E7 Washington, DC 20555-00001 Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Jack Strosnider, Director U.S. Nuclear Regulatory Commission Office T8A23 Washington, DC 20555-00001 Mr. Jonathan Rowley, Senior Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike MS-O-11F1 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 Diane Curran, Esq.

Harmon, Curran, Spielberg & Eisenberg, LLP 1726 M Street, N.W., Suite 600.

Washington, D.C. 20036

BVY 06-097 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 19 Section 3.5 Structures and Supports RAI 3.5-2 RAI 3.5-5 RAI 3.5-6 RAI 3.5-7 RAI 3.5-9

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 1 RAI 3.5-2 Table 3.5.2-1 of the Vermont Yankee Nuclear Power Station (VYNPS) license renewal application (LRA) does not list downcomers as a component. However, downcomers are listed in Table 3.5.1 under line item 3.5.1-13. The applicant is requested to explain why there is neither an aging management plan (AMP) nor an aging management review provided for downcomers in Table 3.5.2-1.

RAI 3.5-2 Response Downcomers are included in LRA Table 3.5.2-1, line item "Drywell to torus vent system."

with aging management programs ClI-IWE and Containment Leak Rate.

RAI 3.5-5 VYNPS AMP B.1.1 5, Inservice Inspection, states that "For containment inservice inspection, general visual and detailed visual examinations are used in addition to VT

[visual testing] examinations as allowed by 10 CFR 50.55a to include applicable relief requests." The applicant is requested to describe the difference between the general visual, detailed visual, and VT examinations. In addition, the applicant is requested to state the relief requests referenced in AMP B.1.15.

RAI 3.5-5 Response General visual examinations are performed either directly or remotely with sufficient illumination and resolution to assess the general condition of the accessible containment surfaces (inside and outside).

Detailed visual examinations are VT-I visual examinations.

VT-1 visual examinations are conducted with sufficient illumination and access to the containment surface to detect discontinuities and imperfections including such conditions as cracks, wear, corrosion, erosion, or physical damage. As specified in 10CFR50.55a, dated September 26, 2002, VT-1 examinations will be conducted in lieu of "detailed visual" examinations of ASME Code Section Xl, IWE-2310(c) for Examination Category E-C Item E4.11 (augmented examinations).

VT-3 visual examinations are conducted to determine the general mechanical and structural condition of components and their supports, such as verification of clearances, settings, physical displacements, loosed or missing parts, debris, corrosion, wear, erosion, or the loss of integrity at bolted or welded connections. As specified in 1 OCFR50.55a, dated September 26, 2002, VT-3 inspections are conducted in lieu of the "general visual" examinations of ASME Code Section XI, IWE-2310 (b) for Examination Category E-A Items El.12 (torus below water level) and E1.20 (vent system) and the bolting of Item E1.11 (drywell and torus above water level).

Presently, no relief requests have been implemented for the VYNPS CII Program. Since ASME code relief requests have their own process under 10 CFR 50.55a, reference to Page 1 of 3 BVY 06-097 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 1 relief requests in the LRA is unnecessary. References to relief requests are hereby deleted from LRA Section B.1.15.

RAI 3.5-6 B.1.15, inservice Inspection and A.2.1.16 Inservice Inspection - Containment Inservice Inspection Program states that "The program includes augmented ultrasonic exams to measure wall thickness of the containment structure." Explain the difference between the augmented portion of the ultrasonic exams performed in the two programs mentioned and that of the American Society of Mechanical EngineersSection XI Inservice Inspection program.

RAI 3.5-6 Response ASME Code Section XI, IWE-1240 "Surface Areas Requiring Augmented Examination" establishes criteria for determining the need for augmented examinations. This sentence was included in the description of the Inservice Inspection - Containment Inservice Inspection Program in LRA Sections A.2.1.16 and B.1.15.2 to indicate that the option for augmented examination exists if necessary. There is no difference between the augmented portion of the ultrasonic exams performed in the VYNPS Containment Inservice Inspection Program mentioned and that of the American Society of Mechanical EngineersSection XI Inservice Inspection Program. As of May 2006, no surface areas have been determined subject to the requirements of Paragraph IWE-1240. This determination was also provided in letter number BVY 06-043, dated May 15, 2006, from Entergy to USNRC, "Vermont Yankee Nuclear Power Station, Ucense No. DPR-28, License Renewal Application".

RAI 3.5-7 Section 3.5.2.2.1.1 of the VYNPS LRA states that the below-grade environment is not aggressive. The staff requests that the applicant provide actual values of pH, chlorides, and sulfates in the groundwater/soil adjacent to structures in order to verify the claim of a non-aggressive below-grade environment.

RAI 3.5-7 Response The results of samples in April 2006 are as follows.

Well Well Parameter 3301 3401 pH 6.2 6.6 chloride (ppm) 322 145 Values for sulfate are not available. Ucense renewal commitment 33 ensures that groundwater samples will continue to be evaluated on a periodic basis to assess aggressiveness of groundwater to concrete. This commitment is revised as follows and stated below (bold words added) to specify that future samples will be monitored for sulfates along with pH and chlorides.

Page 2 of 3 BVY 06-097 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 1 Include within the Structures Monitoring Program provisions that will ensure an engineering evaluation is made on a periodic basis (at least once every five years) of groundwater samples to assess aggressiveness of groundwater to concrete. Samples will be monitored for sulfates, pH and chlorides.

RAI 3.5-9 The applicant is requested to confirm whether or not the aggregates used for the concrete base mat that supports the steel containment have been tested for reactivity in accordance with American Society for Testing and Materials C-289 and C-295.

RAI 3.5-9 Response Aggregates used for the concrete foundation that support VYNPS steel containment (drywell) have been tested for reactivity in accordance with American Society for Testing and Material (ASTM) C-289 and C-295.

Page 3 of 3 BVY 06-097 Docket 50-271

BVY 06-097 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 19 09/27/2006 Conference Call Clarification Item RAI 3.3.1-68-K-03 Amended Response

I VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 2 09127/2006 CONFERENCE CALL CLARIFICATION ITEM RAI 3.3.1-68-K-03 Amended Response The response to RAI 3.3.1-68-K-03 ' included a paragraph about carbon steel components in the potable water system. This portion of the response is amended as follows (bold words added, strike-outs deleted).

The "untreated water" environment for the carbon steel potable water system components in LRA Table 3.3.2-13-29 is not "raw water"; it is actually treated water.

Water for this system comes from onsite wells and is monitored and treated to meet the regulations of the state of Vermont. It was labeled "untreated water" because conductivity and dissolved oxygen are not monitored. Carbon steel is not expected to experience significant aging effects in this treated water environment. A-i ndi*ated in NUREG 1801, a one time iinepoction may alco bo usroed to pFov-de addfitional assuranco t.ha

..-..aging is so insignificant that an agiRg manag-mnt Prg*r*. a i*.

t waRan*t-d. AS indcatr.;d 4

the 4 A, a One l"imo Ir*nspoRtn of rcarbo.n steel potable wat, cy6,etm compononte oxpocoed to uteadwtr"wl be peoformod to confirmA the abeonco of sign~ificant aging cffccts. if the One Time Inspection Pro~gram identifies afignificant aging otffaots, the cerrecti'.e action programA Will onsro..

tha proiaefolw up actions are i mplemented including periodic inApetiGn*,

if necessar..

Nevertheless, the aging management program is changed from One-Time Inspection to Periodic Surveillance and Preventive Maintenance for managing loss of material of carbon steel components in the potable water system exposed to untreated water.

LRA Table 3.3.2-13-29 is revised to replace the aging management program of One-Time Inspection with Periodic Surveillance and Preventive Maintenance for carbon steel piping with an environment of untreated water.

LRA Section A.2.1.23 list of one-time inspection activities is revised, deleting the bullet for "internal surfaces of carbon steel and copper alloy components in the potable water and radwaste systems containing untreated water."

LRA Section A.2.1.24 list of periodic inspections Is revised, adding bullets for "internal surfaces of carbon steel components in the potable water system containing untreated water" and "internal surfaces of carbon steel and copper alloy components in the radwaste system containing untreated water."

LRA Section B.1.21 list of one-time Inspection activities Is revised, deleting the activity for "Internal surfaces of carbon steel and copper alloy components in the potable water and radwaste systems containing untreated water."

LRA Section B.1.22 list of activities is revised, adding activities to "Perform visual or other non-destructive examination to manage loss of material for Internal surfaces of carbon steel potable water system components in the A diesel generator room due to potential spatial interaction" and "Perform visual or other non-destructive examination to manage loss of material for internal surfaces of Letter, Entergy to USNRC, "Vermont Yankee Nuclear Power Station, License No. DPR-28, License Renewal Application, Amendment 12," BVY-06-083, dated September 5, 2006.

Page 1 of 2 BVY 06-097 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 2 carbon steel and copper alloy radwaste system components in the CST valve and instrument enclosure, service water pump area of the intake structure, plant stack, primary containment, and reactor building due to potential spatial interaction."

Page 2 of 2 BVY 06-097 Docket 50-271

BVY 06-097 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 19 09/25/2006 Conference Call Item Additional Information in response to RAI 2.3.3.8-1

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 Conference Call -09/25/06 Additional Information in Response to RAI 2.3.3.8-1 Requested during Staff Position on RAI 2.3.3.8-1 Response (transmitted to VYNPS via e-mail time-stamped 9-25-2006 11:35 AM ET)

In RAI 2.3.3.8-1, dated August 15,2006, the staff stated that LRA drawing LRA-G-1 91163-SH-02-0, "Fire Protection System Inner Loop," shows the yard fire hydrants as out of scope (i.e., not colored in purple). Verify whether the yard fire hydrants are in scope of license renewal in accordance with Title 10 Code of Federal Regulations Part 54.4(a) (10 CFR 54.4(a)) and subject to an aging management review (AMR) in accordance with 10 CFR 54.21 (a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, please provide justification for the exclusion.

In its response, by letter dated September 20, 2006, the applicant stated:

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

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

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

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

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

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

Therefore, the fire protection system is in scope for license renewal.

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

Staff Position NRC fire protection safety evaluation report, dated January 17,1978, approving the VYNPS fire protection program states that, "All yard fire hydrants, automatic and manual water suppression systems and interior fire hose lines are supplied by the fire loop..."

The applicant indicated in the RAI response that the yard fire hydrants in question are within the Page 1 of 6 BVY 06-097 Docket 05-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 scope of license renewal and not subject to an AMR because the yard fire hydrants are isolable from the outer loop such that their failure would not impact the support of vital areas. Yard fire hydrants are not required to extinguish fire in vital areas of the plant and their failure cannot impact safety-related components. Therefore, the yard fire hydrants perform no intended function in support of the system intended functions.

A fire hydrant is a device that is connected to the water main for the purpose of supplying water to fire hose or other fire protection apparatus for interior and exterior firefighting. For example when a fire occurs inside plant area, fire brigade operations should supplement sprinkler systems while automatic sprinklers over the fire discharge water into the fire area. Fire hydrants are also required for exterior structural firefighting, e.g., large turbine building fire, transformer fire and explosion or fire in emergency diesel generator fuel oil tanks. In addition, fire hydrant flow testing is the most important and practical method to determined water flow available for a sprinkler system at a given location. Therefore, the yard fire hydrants in question should not be excluded from an AMR of license renewal on the basis that yard fire hydrants can isolate from the outer loop.

The exclusion of yard fire hydrants casing from an AMR, on the basis that it is not required to maintain pressure boundaries is not acceptable since the pressure boundary loss may prevent water from being supplied to the required areas in an event of sprinkler system actuation. In the staff view that 10 CFR 50.48 goes beyond safe-shutdown and GDC 3.

10 CFR 50.48 requires that each operating nuclear power plant have a fire protection plan that satisfies 10 CFR Part 50, Appendix A, General Design Criteria (GDC) 3, "Fire Protection." GDC 3 states that fire fighting systems shall be provided to minimize the effects of a fire. To implement this program, licensees need an operable fire water-supply system and operable fire hydrants.

The SSC's discussed by the staff can be tied back to Appendix A to Branch Technical Position (BTP) APCSB 9.5-1 requirements and GDC 3, by first looking at the VYNPS license condition.

The VYNPS fire protection license condition states that:..... shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated January 13, 1978, and Supplemental SERs dated..... )

In accordance with the standard fire protection license condition which has been adopted by most licensees, the NRC-approved fire protection program1 (required for compliance to 10 CFR

'The NRC-approved FP program, is defined in GL 88-12 as including the fire protection and post-fire safe shutdown systems necessary to satisfy NRC guidelines and requirements; administrative and technical controls; the fire brigade and fire protection related technical staff; and other related olant features which Page 2 of 6 BVY 06-097 Docket 05-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 50.48) is documented in the FSAR. In addition, the staff approved VYNPS to implement changes to the Technical Specifications, in accordance with the guidance contained in Generic Letter (GL) 86-10 "Implementation of Fire Protection Requirements" and GL 88-12, "Removal of Fire Protection Requirements From Technical Specifications".

10 CFR 50, Appendix A, General Design Criterion 3, Fire Protection, states in part, "Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety'. Furthermore, the general requirements provided in GDC 3 to "minimize the adverse effects of fires on SSC's important to safety" are stated to provide a general level of protection which is afforded to all systems, not only where required to prevent a loss of safe shutdown capability. 10 CFR 50.48(a) states, "Each operating nuclear power plant must have a fire protection plan that satisfies Criterion 3 of Appendix A of this part". The term "important to safety" encompasses a broader scope of equipment then safety-related and safe shutdown equipment." Though there is a focus on the protection of safety-related equipment or safe shutdown equipment, this does not imply that there is an exclusion of any equipment which protects non-safety related equipment.

The overall objectives of Appendix A that are mentioned with respect to the fire protection program are aimed at achieving an adequate balance in "defense-in-depth" for the public health and safety through:

1. Reducing the likelihood of occurrence of fires;

2. Promptly detecting and extinguishing fires if they occur;

3. Maintain the capability to safely shutdown the plant if fires occur and

4. Prevent the release of a significant amount of radioactive material if fires occur.

No one of these echelons can be complete or perfect by itself.

For example, in accordance with 10 CFR 50.48, some portions of suppression systems may be required in plant areas where a fire could result in the release of radioactive materials to the environment, even if no safety-related or safe shutdown equipment is located in that particular fire area. In addition, commitments made by the licensee to satisfy Appendix A to BTP APCSB 9.5-1 by providing certain equipment for the fire protection program are also considered "important to safety."

have been described by the licensee in the FSAR. fire hazards analysis, responses to staff requests for additional information, comparisons of plant designs to applicable NRC fire protection guidelines and requirements, and descriptions of the methodology for assuring safe plant shutdown following a fire.

Page 3 of 6 BVY 06-097 Docket 05-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 In fact, the NRC staff documented this position consistently on page 2-46 of NUREG-1 743 (Safety Evaluation Report Related to the License Renewal of Arkansas Nuclear One, Unit 1, issued on May 2001)2 and on page 2-107 of NUREG-1772 (Safety Evaluation Report Related to the License Renewal of McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2, issued March 2002).

2Excerpt from NUREG-1743: 'The exclusion of any FP SSC on the basis that its intended function is not required for the protection of safe-shutdown equipment is not acceptable to the staff, In itself. Compliance with 10 CFR 50.48 requires a FP program that goes beyond safe shutdown, and includes such requirements as a means to limit fire damage to SSCs that are important to safety so that the capability to safely shutdown the plant is ensured as described in BTP APSCB 9.5-1. In the event that these components are determined to be required for compliance with 10 CFR 50.48, they will need to subject to an AMR in accordance with 10 CFR 54.21 (a)."

Page 4 of 6 BVY 06-097 Docket 05-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 Additional Information in response to RAI 2.3.3.8-1 The fire protection system was originally provided to satisfy the requirements of BTP APCSB 9.5-1, Appendix A. The following VYNPS documents detail compliance with the branch technical position and with later requirements, such as, 10 CFR 50 Appendix R.

" Updated Final Safety Analysis Report (UFSAR) Section 10.11

" Fire Protection and Appendix R Program (PP 7011)

" Fire Hazards Analysis (FHA)

" Fire Protection Commitment Reference Manual (FPCRM)

" Safe Shutdown Capability Analysis (SSCA)

• Technical Requirements Manual (TRM)

A detailed review of these documents, as well as the NRC fire protection safety evaluation report dated January 13, 1978, was completed to determine the system intended functions performed in support of 1 OCFR50.48 requirements. Although early versions of the UFSAR listed all fire protection equipment installed at VYNPS, it was revised to identify the specific equipment required for compliance with 10 CFR 50.48. Section 10.11.3 of the UFSAR clearly identifies fire protection system components required for compliance with 10 CFR 50.48 under the current licensing basis. The portions of the fire protection system that support these intended functions were identified in license renewal project documents and indicated on license renewal drawings LRA-G-1 91163 Sheets 1, 2, 3, and 4, and LRA-G-1 91159 Sheet 1.

Yard fire hydrants are shown on LRA-G-1 91163 Sheet 2 at various points along the outer loop.

These hydrants were not identified during the fire protection document review as providing any support for 10 CFR 50.48 requirements.

Three points were suggested in the draft Staff position on RAI 2.3.3.8-1. VYNPS site information pertaining to these points is provided below.

1) "Fire hydrants are also required for exterior structural firefighting, e.g., large turbine building fire, transformer fire and explosion or fire in emergency diesel generator fuel oil tanks."

VYNPS site information: The yard fire hydrants are not credited for this purpose in the VYNPS documents which designate equipment required to meet 1 0CFR50.48 requirements.

2) "Fire hydrant flow testing is the most important and practical method to determine water flow available for a sprinkler system at a given location."

VYNPS site information: The yard fire hydrants are not credited for this purpose in the VYNPS documents which designate equipment required to meet 10CFR50.48 requirements. The VYNPS fire loop flow test uses a manifold capable of passing the required flow, not the hydrant.

In addition, the license renewal intended functions identified in 10 CFR 54.4 do not include the function of providing a means to test a system or component.

3) "The exclusion of yard fire hydrants casing from an AMR, on the basis that it is not required to maintain pressure boundaries is not acceptable since the pressure boundary loss may prevent water from being supplied to the required areas in an event of sprinkler system actuation."

Page 5 of 6 BVY 06-097 Docket 05-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 VYNPS site information: The yard fire hydrants are isolable from the outer loop. In the event of a failure of the yard fire hydrant pressure boundary, the isolation valves would be closed by the fire brigade as described in UFSAR Section 10.11.3.

The points suggested in the draft Staff position on RAI 2.3.3.8-1 do not constitute requirements for the yard fire hydrants under 10 CFR 50.48.

Page 6 of 6 BVY 06-097 Docket 05-271

BVY 06-097 Docket No. 50-271 Vermont Yankee Nuclear Power Station License Renewal Application Supplement Amendment 19 License Renewal Commitment List Revision 4

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 During the development and review of the Vermont Yankee Nuclear Power Station License Renewal Application, Entergy made commitments to provide aging management programs to manage the effects of aging on structures and components during the extended period of operation. The following table lists these license renewal commitments, along with the implementation schedule and the source of the commitment.

ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 1

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

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

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

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

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

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

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

Page 1 of 6

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 8

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

152, 153 and 159 9

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

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

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

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

This sampling will be repeated every 10 years.

11 The Fire Water System Program will be enhanced to specify that wall March 21, 2012 B3VY 06-009 B.1.12.2/Audit thickness evaluations of fire protection piping will be performed on system Items 37 & 41 components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections will be performed before the end of the current operating term and during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function......

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

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

14 Implement the Non-EQ Instrumentation Circuits Test Review Program as March 21, 2012 BVY 06-009 B1.1,18 described in LRA Section B.1.18.

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

Page 2 of 6

VERMONT YANKEE NUCLEAR POWER STATION UCENSE RENEWAL COMMITMENT LIST REVISION 4 j

ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE.

Section NoJ Comments 16 Implement the One-Time Inspection Program as described in LRA Section March 21,2012 BVY 06-009 B.1.21 B.1.21. Include destructive or non-destructive examination of one (1)

Audit Items socket welded connection using techniques proven by past industry 239, 240, 330, experience to be effective for the identification of cracking in small bore 331 socket welds. Should an inspection opportunity not occur (e.g., socket weld failure or socket weld replacement), a susceptible small-bore socket weld will be examined either destructively or non-destructively prior to entering the period of extended operation.

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

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

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

20 Enhance the Structures Monitoring Program to specify that process facility March 21, 2012 BVY 06-009 B.1.27.2 crane rails and girders, condensate storage tank (CST) enclosure, CO2 Audit Item 377 tank enclosure, N2 tank enclosure and restraining wall, CST pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man-way seals and gaskets, and hatch seals and gaskets are included in the program.

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

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

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

Page 3 of 6

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 a

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

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

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

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

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

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

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

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 a

ITEM COMMITMENT IMPLEMENTATION

SOURCE, Related LRA SCHEDULE Section NoJ Comments 29 VYNPS will perform one of the following:

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

1. Install core plate wedges, or, Item 9

2. Complete a plant-specific analysis to determine acceptance criteria for continued inspection of core plate hold down bolting in accordance with BWRVIP-25 and submit the inspection plan to the NRC two years prior to the period of extended operation for NRC review and approval.

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

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

Audit Items 39

& 40 32 Implement the Metal Enclosed Bus Program.

March 21,2012 BVY 06-058 Audit Item 97 (Details to be provided in a LRA Amendment) 33 Include within the Structures Monitoring Program provisions that will ensure March 21, 2012 BVY 06-009 B.1.27 an engineering evaluation is made on a periodic basis (at least once every Audit Item 77 five years) of groundwater samples to assess aggressiveness of groundwater to concrete. Samples will be monitored for sulfates, pH and RAI 3.5-7 chlorides.

34 Implement the Bolting Integrity Program.

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

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

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

Page 5 of 6

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 37 Continue inspections in accordance with the Steam Dryer Monitoring March 21, 2010 BVY 06-079 Audit Item 204 Program, Revision 3 in the event that the BWRVIP-139 is not approved prior to the period of extended operation.

38

'The BWRVIP-1 16 report which was approved by the Staff will be March 21, 2012 BVY 06-088 Response to implemented at VYNPS with the conditions documented in Sections 3 and RAI B.1.24-1 4 of the Staff's final SE dated March 1, 2006, for the BWRVI P-116 report."

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

40 If the Vernon Tie ever becomes unavailable, due to unavailability of the March 21, 2012 BVY 06-096 Response to VHS or other reasons, the reactor must be shut down within 15 days unless RAI 3.6.2.2-N-the Vernon Tie is returned to service or a basis for maintaining continued 08-2 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 10CFR50.4 outlining the reason for the unavailability, corrective actions in place to provide AC power for Appendix R alternate shutdown fire scenarios, and the time required to make the Vernon Tie available.

41 VYNPS will monitor the availability of the VHS to ensure continued March 21, 2012 BVY 06-096 Response to capability to perform its license renewal intended function, that is, RAI 3.6.2.2-N-conformance with the availability specified in NUMARC 87-00 for meeting 08-2 the requirements of the SBO Rule. 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.

Page 6 of 6