ML063420178

2006/12/04-Vermont Yankee Nuclear Power Station, License Renewal Application, Amendment 22, Clarification of Aging Management Program and Environmental Report Items

ML063420178
Person / Time
Site:	Vermont Yankee
Issue date:	12/04/2006
From:	Ted Sullivan Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
%dam200702, BVY-06-100, TAC MC9670
Download: ML063420178 (12)

Text

Entergy Nuclear Operations, Inc.Vermont Yankee P.O. Box 0500 Brattleboro, VT 05302-0500 Tel 802 257 5271 December 4, 2006 Docket No. 50-271 BVY 06-100 TAC No. MC 9670 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 22 Clarification of Aging Management Program and Environmental Report Items 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. Teleconferences were conducted with the Entergy License Renewal Team On November 6, 2006 with the Nuclear Regulatory Commission (NRC)Environmental Auditors and on November 8, 2006 with the NRC Aging Management Program Audit Team. The following attachments are provided to address the items discussed;

• Attachment 1: RAI 2.3.3.8-1 revised response." Attachment 2: Vernon Pool Stratification Information" Attachment 3: Environmental maps, Figure 3-2 and 3-3* Attachment 4: RAI 3.5-7 revised response, well sample results and evaluation, Audit Item 350 Clarification This submittal does not contain new regulatory commitments.

Should you have any questions, please contact Mr. Dave Mannai at (802) 451-3304.

I declare under penalty of perjury that the foregoing is true and correct, executed on December 4, 2006.Sincerely, Site Vice Vermont 'nke Nuclear Power Station Attachments 1 to 4 cc: See next page BVY 06-100 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-11 F1 Rockville, MD 20853 Mr. Richard Emch 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 mai# 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 06-100 Docket No. 50-271 Attachment 1 Vermont Yankee Nuclear Power Station License Renewal Application Amendment 22 RAI 2.3.3.8-1, Revised Response VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ATTACHMENT 1 Section 2.3.3.8: Fire Protection System -Water RAI 2.3.3.8-1 LRA drawing LRA-G-191163-SH-01

-0, "Fire Protection System Inner Loop" show 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 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21 (a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.

RAI 2.3.3.8-1 Revised Response The yard fire hydrants are in scope and subject to aging management review. The hydrants are identified as component type "valve body" in LRA Table 2.3.3-8. Results of the aging management review are provided in LRA Table 3.3.2-8 for line items "valve body" with carbon steel as the material and raw water as the environment.

Additional Information The revised response to RAI 2.3.3.8-1 supersedes the response in Attachment 1 of LRA Amendment 14 and the additional information in Attachment 3 of LRA Amendment 19.Page 1 of 1 BVY 06-100 Docket No. 50-271 BVY 06-100 Docket No. 50-271 Attachment 2 Vermont Yankee Nuclear Power Station License Renewal Application Amendment 22 Vernon Pool Stratification Information VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 2 During review of Vermont Yankee's Environmental Report, a 2004 Clean Water Act 316(a) Demonstration, and in discussions with team members from Argonne National Laboratory, it has been determined that a correction to Vermont Yankee Nuclear Power Station's (VYNPS) Environmental Report is appropriate.

Specifically, Section 2.2;"Aquatic and Riparian Ecological Communities", the last paragraph of page 2-2 shall be changed as follows: Water temperatures as measured near VYNPS vary from 32°F to 84°F with daily variations rarely exceeding 2 0 F. From December through March the water temperature averages 350F, and from July through September it averages between 70°F to 77°F [Reference 2-2,Section II.E.2]. Based on a 316(a)Demonstration conducted in support of a request for increased discharge temperature limits between May 15 and October 14 annually, it was determined that the River water was thoroughly mixed below Vernon Dam and therefore thermal stratification was highly unlikely [Reference 2-15, Section 3.2.4]. Thermal stratification is observed in the portion of the Connecticut River known as lower Vernon pool due to the contribution of solar input and Vermont Yankee's thermal discharge.

Thermal stratification from solar input alone is also observed upstream of and outside of the influence of Vermont Yankee's thermal discharge.

Page 1 of 1 BVY 06-100 Docket No. 50-271 BVY 06-100 Docket No. 50-271 J Attachment 3 Vermont Yankee Nuclear Power Station Ucense Renewal Application Amendment 22 Maps -Figure 3-2 and 3-3 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 Figure 3-2 Chestnut Hill 11 5-Kv Transmission Line Page 1 of 2 BVY 06-100 Docket No. 50-271 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 Figure 3-3 Coolidge 115/345-Kv Transmission Line Page 2 of 2 BVY 06-100 Docket No. 50-271 BVY 06-100 Docket No. 50-271 Attachment 4 Vermont Yankee Nuclear Power Station License Renewal Application Amendment 22 RAI 3.5-7 Revision Audit Item 350, Revision to Amend. 5 Response VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ATTACHMENT 4 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 Revised Resoonse This response supersedes the response to RAI 3.5-7 provided in Amendment 19, dated October 31,2006.Sample data from April 2002 through April 2006 is provided below.April 2002 October 2002 April 2003 October 2003 Parameter Well Well Well Well Well Well Well Well 3301 3401 3301 3401 3301 3401 3301 3401 pH 6.4 6.0 6.6 6.0 6.7 6.0 6.8 6.8 chloride (ppm) 237 54.30 237 57.30 225 70.30 260 111 April 2004 October 2004 April 2005 October 2005 Parameter Well Well Well Well Well Well Well Well 3301 3401 3301 3401 3301 3401 3301 3401 pH 6.4 6 6.7 6.9 7.1 7.5 6.6 17.3 chloride (ppm) 399 118 410 78.1 325 92.2 388 103 April 2006 Parameter Well Well 3301 3401 pH 6.2 6.6 chloride (ppm) 322 1145 Values for sulfate are not available because the station's indirect discharge permit does not require measurement of sulfate levels. License 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 (bold words added) to specify that future samples will be monitored for sulfates along with pH and chlorides.

Included within the Structures Monitoring Program are 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 evaluated for sulfate, pH and chloride levels.The Vermont Agency of Natural Resources has attributed the difference in chloride levels between Well 3301 and Well 3401 to road salt influence given the close proximity of Well 3301 to a roadway within the plant boundaries.

Page 1 of 2 BVY 06-100 Docket 50-271 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ATTACHMENT 4 Additional Clarification Audit item 350 NRC question states;B.1.27.3-E-01 Please clarify the FERC provisions under which the Vernon Dam is inspected.

The dam is now exempt from Provisions of Title 18, Part 12, Subpart D, (Inspection by Independent Consultant).

Clarification:

Audit item 350 (provided in LRA Amendment 5, dated July 14, 2006, addressing"LRA Section A.2.1.31, Structures Monitoring

-Vernon Dam FERC Program"), has been revised to state 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 inspection frequency for licensed and exempt low hazard potential dams is biennial.

As indicated in NUREG-1801 for water control structures, NRC has found that FERC / US Army Corp of Engineers dam inspections and maintenance programs are acceptable for aging management." Page 2 of 2 BVY 06-100 Docket 50-271