ML070240204
| ML070240204 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/10/2007 |
| From: | Hamer M Entergy Corp |
| To: | Rowley J NRC/NRR/ADRO |
| References | |
| PA-LR, TAC MD2297 | |
| Download: ML070240204 (20) | |
Text
'ard Emch -RE: other WORD file Paae 1 11 Emch - RE: other WORD file Paoe 1 II
.. P A - L R, S
From:
To:
Date:
Subject:
"Hamer, Mike" <mhamer@entergy.com>
"Jonathan Rowley" <JGR@nrc.gov>
Wed, Jan 10, 2007 9:45 AM RE: other WORD file From: Jonathan Rowley [1]
Sent: Wednesday, January 10, 2007 9:14 AM To: 7429369@cvcpaging.com; Hamer, Mike
Subject:
other WORD file Mike Thanks for sending the WORD files I requested on Tuesday so quickly. I need one other file to fulfill my need. That would be the WORD version of Amendment 19. Just sending the attachments as before will be perfect.
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Subject:
Creation Date From:
Created By:
RE: other WORD file Wed, Jan 10, 2007 9:44 AM "Hamer, Mike" <mhamer@entergy.com>
mhamer@entergy.com Recipients nrc.gov TWGWPO03.HQGWDO01 JGR (Jonathan Rowley)
Post Office TWGWPO03.HQGWDO01 Route nrc.gov Files Size Date & Time MESSAGE 424 Wednesday, January 10, 2007 9:44 AM TEXT.htm 3085 Att. 1 - Section 3.5 RAI responses.doc 44544 Att. 2 - RAI Response Clarification for Potable Water.doc 29696 Att. 3 - Response to Staff Position on RAI 2.3.3.8-1.doc 59904 Att. 4 - VYNPS LR Commitment List Rev4.doc 105472 Mime.822 1
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. Pagel 111 IfRichard~Emch
- Att. 1 - Section 3.5 RAI responses.doc Page iii 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 CII-IWE and Containment Leak Rate.
RAI 3.5-5 VYNPS AMP B.1.15, 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-1 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 relief requests in the LRA is unnecessary. References to relief requests Page 1 of 3 BVY 06-097 Docket 50-271
I Richard Emch - Aft. 1 - Section 3.5 RAI responses.doc Page 2 11 IRichard Emch - Aft. 1 - Section 3.5 RAI responses.doc Page 2~I VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 1 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 Xl, 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-1 240. This determination was also provided in letter number BVY 06-043, dated May 15, 2006, from Entergy to USNRC, "Vermont Yankee Nuclear Power Station, License 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. 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 and stated below (bold words added) to specify that future samples will be monitored for sulfates along with pH and chlorides.
Include within the Structures Monitoring Program provisions that will ensure an Page 2 of 3 BVY 06-097 Docket 50-271
I Richarb Emch - Att. 1 - Section 3.5 RAI responses.doc R
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VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 1 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 0-295.
Page 3 of 3 BVY 06-097 Docket 50-271
11IRichard Emch - Aft. 2 - RAI ResDonse Clarification for Potable Water.doc Page 111l I*Rca mc A.2 AIRsone lriiato-frPoaleWte-ocPoe1Ii VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 2 09/27/2006 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. indicatod in NilUREG-1801, a ono t*mo Oinspetion may also be used to. pododitnAl asura;nc that...
.aging is so insignific-ant that an aging m~anagement program is not warne.6As
÷ndhic,-atodin tho LRA, a One Time InSpcctiOh Of carbon steol potable wator sySteFm components cxpescd to "untreated water" will be podrmonid to conefir~m the abhse-nco of significant aging offrctS. If the On*eTimo InspetioRn Program identifies igRnificant aging, effoctG, the c~rroctivo action program will onSUro) that appropriate follow-up actions, are implemented iluding perFidic i,.nspections,, if necessary. 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
'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
I Richard Emch - Aft. 2 - RAI Response Clarification for Potable Water.doc Paae 2 11 I
Richarti Emch - Aft. 2 - RAI Response Clarification for Potable Water.doc Paae 211 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 2 non-destructive examination to manage loss of material for internal surfaces of 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
R Richard Emch - Aft. 3 - Resi)onse to Staff Position on RAI 2.3.3.8-l.doc Paae 1 11 Richard Emch - Aff. 3 - ResDonse to Staff Position on RAI 2.3.3.8-1.doc Pacie 1 II
'-'I 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-191163-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..."
Page 1 of 6 BVY 06-097 Docket 05-271
[Rjichard Emch - Att. 3 - Response to Staff Position on RAI 2.3.3.8-1.doc Page 21 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 The applicant indicated in the RAI response that the yard fire hydrants in question are within the 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 50.48) is documented in the FSAR. In addition, the staff approved VYNPS to implement 1The 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 plant features which 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 2 of 6 BVY 06-097 Docket 05-271
ill Richard Emch - Att. 3 - Response to Staff Position on RAI 2.3.3.8-l.doc Paae 3 11
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Richard Emch - Att. 3 - Response to Staff Position on RAI 2.3.3.8-1.doc Paae 311 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATrACHMENT 3 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."
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 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 3 of 6 BVY 06-097 Docket 05-271
Jji.R~ichard Em'.ch - Att. 3 - R e-spons-e to Staff Pos-ithonm on RI23381 dcPg4 Page 4 1 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION ATTACHMENT 3 the License Renewal of McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2, issued March 2002).
Page 4 of 6 BVY 06-097 Docket 05-271
l1CRchard-Emch-Att. 3-- Response to Staff Position on RAI 2.3.3.8-1.doc
-1Pag-e-_Q 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 0CFR50.48 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 10CFR50.48 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 1 OCFR50.48 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."
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.
Page 5 of 6 BVY 06-097 Docket 05-271
I Richard Emch - Aft. 3 - Response to Staff Position on RAI 2.3.3.8-l.doc Page 6 11 Richard Emch - Att. 3 - Response to Staff Position on RAI 2.3.3.8-1.doc Page 6~I VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION A'TACHMENT 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
Wcad-Emch - Att. 4 - VYNPS LR Cornitmnent List Rev4.doc Page 1 11 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 DOMMITMENT IMPLEMENTATION SOURCE Related LRA SCHEDULE Section NoJ Comments 1
3uidance for performing examinations of buried piping will be enhanced to March 21, 2012 BVY 06-009 B.1.1/Audit
_ pecify that coating degradation and corrosion are attributes to be evaluated.
Items 5 & 130 2
- ifteen (15) percent of the top guide locations will be inspected using As stated in the BVY 06-009 B.1.7/Audit anhanced visual inspection technique, EVT-1, within the first 18 years of the commitment Item 14
)eriod of extended operation, with at least one-third of the inspections to be
,ompleted within the first 6 years and at least two-thirds within the first 12 jears of the period of extended operation. Locations selected for
__xamination 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 hickness measurement of the fuel oil storage tank bottom surface will be erformed 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 of March 21, 2012 BVY 06-009 B.1.11
- umulative fatigue usage factors (CUFs), or to require update of CUFs if the iumber of accumulated cycles approaches the number assumed in the design calculation.
6 A computerized monitoring program (e.g., FatiguePro) will be used to directly March 21, 2012 BVY 06-009 B.1.11 determine cumulative fatigue usage factors (CUFs) for locations of interest.
1_
7 Fhe allowable number of effective transients will be established for monitored March 21, 2012 BVY 06-009 B.1.11 transients. This will allow quantitative proiection of future margin.
8 Procedures will be enhanced to specify that fire damper frames in fire March 21, 2012 BVY 06-009 B.1.12.1/Audit arriers will be inspected for corrosion. Acceptance criteria will be enhanced Items 35, 151, o verify no significant corrosion.
152,153 and I_
1-159 Page 1 of 6
III Richard Emch - Att. 4 - VYNPS LR Commitment List Rev4.doc Paae 2 11 IlLII Richard Emch - Att. 4 - VYNPS LR Commitment List Rev4.doc Paae 2(1 C
ý VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 9
Procedures will be enhanced to state that the diesel engine sub-systems (including the fuel supply line) will be observed while the pump is running.
Acceptance criteria will be enhanced to verify that the diesel engine did not exhibit signs of degradation while it was running; such as fuel oil, lube oil,
- oolant, or exhaust oas leakace.
March 21, 2012 BVY 06-009 B.1.12.1/Audit Items 33, 150
& 155 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
,ave been in place for 50 years a representative sample of sprinkler heads Nill 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 BVY 06-009 B.1.12.2/Audit hickness evaluations of fire protection piping will be performed on system Items 37 & 41
,omponents using non-intrusive techniques (e.g., volumetric testing) to dentify evidence of loss of material due to corrosion. These inspections will De performed before the end of the current operating term and during the 3eriod of extended operation. Results of the initial evaluations will be used to Jetermine the appropriate inspection interval to ensure aging effects are dentified prior to loss of intended function.
12 mplement the Heat Exchanger Monitoring Program as described in LRA March 21, 2012 BVY 06-009 B.1.14 Section B.1.14.
13 mplement the Non-EQ Inaccessible Medium-Voltage Cable Program as March 21, 2012 BVY 06-009 B.1.17 Jescribed in LRA Section B.1.17.
14 Implement the Non-EQ Instrumentation Circuits Test Review Program as March 21, 2012 BVY 06-009 B.1.18 Jescribed in LRA Section B.1.18.
15 mplement the Non-EQ Insulated Cables and Connections Program as March 21, 2012 BVY 06-009 B.1.19 Jescribed in LRA Section B.1.19.
1 16 mplement the One-Time Inspection Program as described in LRA Section March 21, 2012 BVY 06-009 B.1.21 3.1.21. Include destructive or non-destructive examination of one (1) socket Audit Items Nelded connection using techniques proven by past industry experience to be 239, 240, 330, effective for the identification of cracking in small bore socket welds. Should 331 in inspection opportunity not occur (e.g., socket weld failure or socket weld "eplacement), a susceptible small-bore socket weld will be examined either estructively or non-destructively prior to entering the period of extended
_ peration.
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Richard Emch - Att. 4 - VYNPS LR Commitment List Rev4.doc e
R a66-3-11 _
J, VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 17 Enhance the Periodic Surveillance and Preventive Maintenance Program to assure that the effects of aging will be managed as described in LRA Section B.1.22.
March 21, 2012 BVY 06-009 B.1.22 Audit Item 377 18 Enhance the Reactor Vessel Surveillance Program to proceduralize the data March 21, 2012 BVY 06-009 B.1.24 analysis, acceptance criteria, and corrective actions described in the program description in LRA Section B.1.24.
19 mplement the Selective Leaching Program as described in LRA Section March 21, 2012 BVY 06-009 B.1.25 3.1.25.
20 Enhance the Structures Monitoring Program to specify that process facility March 21, 2012 BVY 06-009 B.1.27.2 rane rails and girders, condensate storage tank (CST) enclosure, C02 tank Audit Item 377 nclosure, N2 tank enclosure and restraining wall, CST pipe trench, diesel enerator cable trench, fuel oil pump house, service water pipe trench, man-Nay 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
)rocedure.
23 Guidance for performing structural examinations of PVC cooling tower fill to March 21, 2012 BVY 06-009 B.1.27.2 dentify cracking and change in material properties will be added to the Structures Monitoring Program procedure.
24 System walkdown guidance documents will be enhanced to perform periodic March 21, 2012 BVY 06-009 B.1.28 3ystem engineer inspections of systems in scope and subject to aging Audit Items management review for license renewal in accordance with 10 CFR 54.4 187, 188 & 190
- a)(1) and (a)(3). Inspections shall include areas surrounding the subject 3ystems to identify hazards to those systems. Inspections of nearby systems
- hat could impact the subject system will include SSCs that are in scope and ubject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(2).
1 25 mplement the Thermal Aging and Neutron Irradiation Embrittlement of Cast March 21, 2012 BVY 06-009 B.1.29 ustenitic Stainless Steel (CASS) Program as described in LRA Section 11".1.29.
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Richard Emch - Att. 4 - VYNPS LR Commitment List Rev4.doc Pa-e- -11 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 26
- rocedures will be enhanced to flush the John Deere Diesel Generator
,ooling water system and replace the coolant and coolant conditioner every
- hree years.
March 21, 2012 BVY 06-009 B.1.30.1 Audit Items 84
& 164 27
- or each location that may exceed a CUF of 1.0 when considering March 21, 2012 BVY-06-058 4.3.3
?nvironmental 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 ess than 1.0; performing a fatigue
'2) management of fatigue at the affected locations by an inspection program analysis that
ýhat has been reviewed and approved by the NRC (e.g., periodic non-addresses the effects estructive examination of the affected locations at inspection intervals to be of reactor coolant etermined by a method acceptable to the NRC);
environment on
- 3) repair or replacement of the affected locations, fatigue (in accordance with an NRC 3hould VYNPS select the option to manage environmental-assisted fatigue approved version of luring the period of extended operation, details of the aging management the ASME Code)
)rogram such as scope, qualification, method, and frequency will be provided o the NRC two years prior to the period of extended operation for review and
_ pproval.
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 Audit Item 47 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 every March 21, 2012 BVY 06-009 B.1.28 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)
I Page 4 of 6
Ric-hard.Emc-m Att-. -4VY-NPS LR Commitment List Rev4.doc Page VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 33 nclude within the Structures Monitoring Program provisions that will ensure March 21, 2012 BVY 06-009 B.1.27 in engineering evaluation is made on a periodic basis (at least once every Audit Item 77
ýive years) of groundwater samples to assess aggressiveness of groundwater
- o concrete. Samples will be monitored for sulfates, pH and chlorides.
RAI 3.5-7 34 mplement 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 LRA 198, 216, 218, referenced.
237, 331 & 333 35 Provide within the System Walkdown Training Program a process to March 21, 2012 BVY 06-058 Audit Item Jocument biennial refresher training of Engineers to demonstrate inclusion of 384
- he methodology for aging management of plant equipment as described in PRI Aging Assessment Field Guide or comparable instructional guide.
36 f technology to inspect the hidden jet pump thermal sleeve and core spray March 21, 2010 BVY06-058 Audit Item 12 fhermal sleeve welds has not been developed and approved by the NRC at east two years prior to the period of extended operation, VYNPS will initiate 31ant-specific action to resolve this issue. That plant specific action may be ustification that the welds do not require inspection.
37 3ontinue 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-116 report which was approved by the Staff will be March 21, 2012 BVY 06-088 Response to mplemented at VYNPS with the conditions documented in Sections 3 and 4 RAI B.1.24-1
39
'If the VYNPS standby capsule is removed form the reactor vessel without March 21, 2012 BVY 06-088 Response to
'he intent to test it, the capsule will be stored in a manner which maintains it RAI B.1.24-2 n a condition which would permit its future use, including during the period of
ýxtended operation, if necessary."
40 f the Vernon Tie ever becomes unavailable, due to unavailability of the VHS March 21, 2012 BVY 06-096 Response to Dr other reasons, the reactor must be shut down within 15 days unless the RAI 3.6.2.2-N-Vernon Tie is returned to service or a basis for maintaining continued 08-2
)peration 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 o the NRC in accordance with 10CFR50.4 outlining the reason for the navailability, corrective actions in place to provide AC power for Appendix R Iternate shutdown fire scenarios, and the time required to make the Vernon
_ ie available.
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1 11 111.1 1.1 11 Richard Emch - Att. 4 - VYNPS LR Commitment Lisf-F46V4.-d-oc Vade 6 11 Richard Emch - Mt. W-~VYNPS LR Commitment List Rev4.doc Pa q'
I V VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 4 41 VYNPS will monitor the availability of the VHS to ensure continued capability March 21, 2012 BVY 06-096 Response to fto perform its license renewal intended function, that is, conformance with the RAI 3.6.2.2-N-availability specified in NUMARC 87-00 for meeting the requirements of the 08-2 3SBO Rule. If availability falls below the acceptable level, VYNPS will respond
- o the condition through the corrective action program. The corrective action Program requires evaluation and appropriate corrective action to correct the pnonconforming condition.
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