ML071350551
| ML071350551 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/08/2007 |
| From: | Ted Sullivan Entergy Nuclear Operations |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| BVY 07-035, TAC MC9668 | |
| Download: ML071350551 (37) | |
Text
Entergy Nuclear Operations, Inc.
Vermont Yankee P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 257 5271 May 8, 2007 Docket No. 50-271 BVY 07-035 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, USNCR to Entergy, "Safety Evaluation Report with Confirmatory Items Related to the License Renewal of Vermont Yankee Nuclear Power Station" NVY 07-036, dated March 30, 2007.
Subject:
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
License Renewal Safety Evaluation Report Comments
Dear Sir or Madam,
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. After the completion of the LRA audit, application review and requests for additional information process, the NRC developed and transmitted the "Safety Evaluation Report with Confirmatory Items Related to the License Renewal of VYNPS" as indicated by Reference 2, hereinafter referred to as the Safety Evaluation Report (SER). Entergy has completed a review of the SER to verify accuracy. Reviewer comments are provided as Attachment 1 to this letter.
This letter contains no commitments.
Should you have any questions concerning this letter, please contact Mr. Dave Mannai at (802) 258-5422.
I declare under penalty of perjury that the foregoing is true and correct, executed on May 8, 2007.
Sincerely,
)Site Vice President Vermont Yankee Nuclear Power Station cc: See next page enc: Attachment 1
BVY 07-035 Docket No. 50-271 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-1 1 F1 Rockville, MD 20853 Mr. Mike Modes USNRC RI 475 Allendale Rd, King of Prussia, PA 19406 Mr. James S. Kim, Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0 8 C2A 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 07-035 Docket No. 50-271 Draft SER Review Comments
I VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Note: The section number(s) and page number(s) cited in the following listing correspond to the section number(s) and page number(s) as identified in the draft Safety Evaluation Report. Strikethroughs = delete, underlines = add.
Comment Section Page Comment Number Number(s)
Number(s) 1 Abstract iii Abstract states, "By letter dated January 27, 2006, Entergy Nuclear Operations, Inc.
(ENO or the applicant) submitted the LRA...." However, transmittal letter BVY 06-009 is dated January 25, 2006.
2 TOC v
Change first letter in page number of Abstract to lower case.
3 TOC v
Change section 1.7 title from "Sumary" to "Summary."
4 TOC viii Section 3.0.4 is indented too far.
5 TOC x
Title for Section 4.5 should not be underlined.
6 TOC xi Capitalize all letters of VYNPS in appendix A title.
7 Abbreviations xiii In definition of AWWA, change "Americal" to "American."
8 Abbreviations xiii Definition of BAF should be lower case.
9 Abbreviations xiii Remove CAC from the list and change where used in text. The acronym is PCAC -
primary containment atmosphere control.
10 Abbreviations xiv In definitibn of EIC, change "instrumental" to "instrumentation."
11 Abbreviations xv Add definition "inservice testing" for acronym IST.
12 Abbreviations xv Delete IWE. This is not an acronym; it is a sub-section of ASME Section Xl.
13 Abbreviations xvi Change definition of MG from "motor gear" to "motor generator."
14 Abbreviations xvi Change definition of MIC to "microbiologically influenced corrosion."
15 Abbreviations xvi In definition of PCAC, change "atmospheric" to "atmosphere."
Page 1 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page I
Number Number(s)
Number(s)
Comment 16 Abbreviations xvii Delete "liquid and solid" from definition of RDW.
17 Abbreviations xvii Delete "unit" from definition of RWCU.
18 Abbreviations xvii Add definition "safety evaluation" for acronym SE.
19 1.2.2 1-4 Change; "GepetiG Environmental Impact Statement" to; "Generic Environmental Impact Statement" 20 CI 1-8 First sentence: change, "LRA Section 2.3.3.12.indicts," to LRA Section 2.3.3.12 2.3.3.12-1 indicates..."
21 2.1.3.1.2 2-5 First full paragraph, sixth line, remove "and" in
"...the NRC staff afd concluded" 22 2.1.4.1.1 2-7 The specific list of CLB references used for scoping is confusing.
The SER states: 'With respect to the safety-related criteria, the applicant stated that at VYNPS, the safety-related SSCs are initially identified based on descriptions and analyses in the UFSAR, or on DBDs such as enqineeringq drawinqs, evaluations, or calculatidns."
From section 2.1.1.1 of the LRA, the relevant statements seems to be: "For VYNPS, system safety functions are identified in safety classification documents, the maintenance rule SSC basis documents for each system, and in design basis documents (DBDs) for those systems for which a DBD was written. Consideration was given to the safety objectives included in the UFSAR system descriptions,..."
These don't match too well. Particularly confusing is the reference to calculations, and the description of DBDs as a class of documents rather than a specific document type.
Revise the SER text to match the reference list in the LRA.
Page 2 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 23 2.1.4.1.1 2-8 First full paragraph on page: "The VYNPS CLB definition of safety-related SSCs is not identical to the definition provided in the Rule. As a result, the applicant performed an evaluation of the differences between its CLB definition of safety-related and the Rule definition. The evaluation was documented in LRA Section 2.1.3.2, "Identification of Safety-related Systems and Structures."
There is no LRA Section 2.1.3.2 nor any LRA section with the listed title. Minor differences in the definition of safety-related, especially with respect to offsite dose limits, were described in section 2.1.1.1. Revise paragraph to note differences were minor.
24 2.1.4.1.2 2-10 2 nd full paragraph:
Change: 10 CFR 54.3(a)
To: 10CFR 54.4(a).
25 2.1.4.1.2 2-10 First full paragraph, first sentence: "To help facilitate the identification of SSCs in-scope in accordance with the 10 CFR 54.4(a) criteria, the applicant developed a license renewal information system (LRIS) which contained detailed design description information about each plant system and structure and the relevant functions of those systems and structures."
LRIS was not used for the scoping of systems and structures. Suggest rewording to the following:
To docurnent the identification of SSCs in-scope in accordance with the 10 CFR 54.4(a) criteria, the applicant developed a scoping report (one of the LRPDs) which contained design description information about each plant system and structure and the relevant functions of those systems and structures.
26 2.1.4.1.2 2-10 Second paragraph, sixth line, "LRPGs" should be "LRPDs" Page 3 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) Comment 27 2.1.4.2.1(3) 2-12 First paragraph under "Physical Impact" is very difficult to understand. Suggest rewordinl as follows:
The applicant evaluated nonsafety-related structures and components to identify features that protect safety-related equipment from physical impact, or features whose structural failure could result in physical impact to safety-related equipment. Nonsafety-related features that protect safety-related equipment from missiles were included within the scope of license renewal. The structural failure of equipment such as overhead handling systems could directly damage safety-related equipment. Nonsafety-related equipmeht, the structural failure of which could damage a system and possibly prevent the acconplishment of a safety function was included within the scope of license renewal.
28 2.1.4.2.1 (3) 2-13 Second paragraph under "Fluid Leakage, Spray and Flooding" last sentence. In regards to (a)(2) in the context of the paragraph, the sentence should say "systems containing only air or gas were not included within the scope of license renewal based on the potential for spray or leakage."
29 2.1.4.2.1(3) 2-13 The SER groups "Fluid leakage, Spray, and Flooding" together in the description of the 2.1.4.2.2 2-15 applicant's review for spatial interaction. This is not correct. Flooding was considered along with physical impact in LRA 2.1.1.2.2(2) as a situation which can be protected against using missile shields, walls, curbs, dikes, and doors.
30 2.1.4.2.2 2-14 Fifth line from bottom of page is: "structures that, as required by analysis, physically restrain forces and movements in three" In this line, the word "movements" should be "moments" 31 2.1.4.2.2 2-15 First full paragraph on page, fifth line. RAI 2.1-1 should be RAI 2.1-2.
32 2.1.4.2.2 2-17 Second line at top of page, second half of line. Delete the incomplete sentence.
33 2.1.4.3.2 2-19 Middle of ATWS paragraph, "CDR" should be "CRD" Page 4 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 34 2.1.4.4.1 2-20 The last two sentences on the page should be recombined in the draft SER. Splitting the sentences to make them more readable, lost the meaning of the second sentence.
Recombine to read as follows (strike-through is deleted, bold text is added):
The LRPGs specify that the personnel performing license renewal scoping use CLB documents,. Tho, LRP2GC also describe the system or structure, and *l*'"U4g a list the of functions that the system or structure is required to accomplish.
35 2.1.4.4.2 2-22 First paragraph under Staff Evaluation. Middle of paragraph, sentence beginning; "Specifically, the LRPGs identified the systems... "
The LRPGs are guidelines for scoping but do not document the scoping results.
Suggest revising the sentence to read:
SpeGif"GaUy As specified in the LRPGs, the applicant identified the systems and structures that are subject to 10 CFR 54.4 review, described the processes for capturing the results of the review, and weFe-used to determined if the system or structure performed intended functions consistent with the criteria of 10 CFR 54.4(a).
36 2.1.4.5.2 2-24 First sentence under Staff Evaluation. "accident management (AM) reports" should be "aging management (AM) reports" or preferably, to be consistent with other references to these documents in the SER (see very bottom of page 2-30), "aging management review (AMR) reports" Change here and in list of acronyms (abbreviations). If switching to AMR reports, change all places used.
37 2.1.5.2.2 2-31 First paragraph on page. Change AM to AMR to be consistent with ending paragraph of previous page. Also, "valuation" in fourth line should be "evaluation" and "LRPDs" in the fifth line Would better be "LRPGs."
38 2.1.5.3.2 2-32 2 nd paragraph: suggest adding a comma after the word "component" in the third sentence.
Page 5 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 ComIment Section Page Comment Number Number(s)
Number(s) 39 2.3.1.1 2-40 The SEFR states that Table 2.3.3-13-25 identifies the NB system components within the scope of license renewal and subject to AMR. Table 2.3.3-13-25 identifies only the NON-SAFETY related components of NB that are subject to AMR for 10 CFR 54.4(a)(2). The safety-related components are in Tables 2.3.1-1 and Table 2.3.1-3.
40 2.3.1.1 2-41 The SER states that Table 2.3.3-13-5 identifies the CRD system components within the scope of license renewal and subject to AMR. Table 2.3.3-13-5 identifies only the NON-SAFETY, related components of NB that are subject to AMR for 10 CFR 54.4(a)(2).
Safety related CRD system components are listed in Table 2.3.1-3. Unique components (drive, etc.) are marked as belonging to CRD, but common items (i.e. valve bodies) are included with other items of the same component type.
41 2.3.1.1 2-41 The SEFR states that Table 2.3.3-13-19 identifies the HCU system components within the scope of license renewal and subject to AMR. Table 2.3.3-13-19 identifies only the NON-SAFETY related components of NB that are subject to AMR for 10 CFR 54.4(a)(2).
Note the HCU system is included in Table 2.3.1-3 as a subsystem of the CRD system.
42 2.3.1.2.1 2-44 There are vessel internals listed in the paragraph that are not listed in Table 2.3.1-2.
43 2.3.1.2.1 2-44 First paragraph, last sentence, last vessel internal listed is "Vessel Head Spray Line".
This has been removed at VY. There is still a penetration in the vessel head for this function but the flange is blanked off and the internal piping has been removed.
44 2.3.1.2.1 2-44 The first bullet in the second paragraph states "flow distribution or spray pattern".
Clarify whether this applies to Core Spray.
45 2.3.2 2-47 In the list of systems, the system abbreviation of CS needs to be spelled out as "core spray" to be consistent with the other system names.
46 2.3.2.1 2-47 1 st sentence under 2.3.2.1:
Remove "in accordance with" and replace with "during" as follows; "... from the reactor in AcGcodAnco with during both operational and accident conditions."
Page 6 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 47 2.3.2.1 2-48 2 nd paragraph states "... the failure of nonsafety-related SSCs in the RHR system potentially could prevent the satisfactory accomplishment of a safety-related function.
The RHR system is SC-2, and has interface components that isolate from NNS components.
Generic Comment - This statement is not clear, and is repeated for each system throughout the SER.
48 2.3.3.2.1 2-59 The SW headers are normally cross connected. This is not apparent in this section.
49 2.3.3.3.2 2-65 In the next to last paragraph the first sentence states;
"... the applicant stated that the RBCCW return to the 2 shown on This should state;
"... the applicant stated that the RBCCW return to the ACS shown on..
50 2.3.3.8.2 and 2-85 and In the sixth paragraph at the end there is a sentence which contains the words "active 2.3.3.9.2 2-90 (short-lived components)". This needs to be changed to "active or short lived components" since the way it is currently written implies that active and short lived mean the same thing which is not true. Alternatively, delete the entire sentence as it is ambiguous and appears redundant to the last sentence of the paragraph...Last sentence of the paragraph should be changed to say, "...components are active or replaced, on a specified frequency..
Page 7 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 51 2.3.3.13M. 1 2-112 Reactor Water Clean-Up:
The following is contained within the document. As written, it does not make sense.
Limiting impurities does not activate a neutron flux. However, impurities can become activated under a neutron flux.
"The RWCU system maintains high reactor water purity to limit chemical and corrosive action, to remove corrosion products, and to limit impurities that would activate neutron flux."
Suggested wording change underlined:
"The R\\VVCU system maintains high reactor water purity to limit chemical and corrosive action, to remove corrosion products, and to limit impurities that could activate under a neutron flux."
52 2.3.4.1.1, 2-116 Table 2.3.4.1 does not identify the component types in the systems. It is identifying the 2.3.4.2.1, component types in the MSIV leakage pathway. Not all of these component types are 2.3.4.3.1, included in each of these systems. Table 2.3.4-1 includes the component types from all 2.3.4.4.1 of the systems constituting the MSIV leakage pathway.
53 2.4.2.1 2-124 Typo in first paragraph. CDR should be CRD.
Page 8 of 34 BVY 07-035 Docket 50-271
I VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 54 2.5.1 2-136 The intended functions listed in the SER are not the same as those in the LRA. These slight differences should be reviewed for possible changes.
To describe intended functions within the scope of LR, the SER provides the following "The EIC systems component intended functions within the scope of license renewal include the following:
- electrical connections to deliver voltage, current, or signals
- electrical conductor insulation and support" To designate the intended functions for 2.5.1 component types, the following abbreviations are provided within the LRA:
Abbreviation CE Function: Conducts electricity Definition: Provide electrical connections to specified sections of an electrical circuit to deliver voltage, current or signals.
Abbreviation IN Function: Insulation (electrical)
Definition: Insulate and support an electrical conductor.
55 2.5.2 2-137 Discussion of RAI2.5-2 (middle of page) - Editorial Comment: It should either read "provide details of Vernon Hydroelectric Station used as an Alternate AC Source for Vermont Yankee" or "provide details of Vermont Yankee Nuclear Power Station's Alternate AC Source".
Page 9 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 56 2.5.2 2-139 The last paragraph on page 2-139 discusses a commitment to a "Bolted Cable Connections Program" with no reference to that commitment. Additionally, the "One-Time Inspection" mentioned is consistent with the NEI agreement. To improve this paragraph, add in the following; SubsequIent to above response, on November 30, 2006, NEI held a meeting with NRC.
Based on this meeting, XI.E6 program was revised to be a one-time inspection of a representative sample of cable connections subject to aging management review, and therefore consistent with the NEI agreement. In its letter dated January 4, 2007,, the applicant agreed to plant-specific, Bolted Cable Connection Program.
Commitrhent 42 was initiated to ensure implementation of this program prior to the period of extended operation.
57 2.6 2-140 In second paragraph list of confirmatory items, "2.3.3.2-1" should be "2.3.3.2a-1" and "2.3.3.2-2" should be "2.3.3.2a-2" to be consistent with the Cl numbers in Section 1.6.
58 3.0 3-2 The last paragraph in this section states; 'The applicant can respond to questions and, the staff can readily evaluate the applicant's responses, the need for formal correspondence between the staff and the applicant is reduced, and the result is an improvement in review efficiency."
Revise as follows:
"The applicant can respond to questions, the staff can readily evaluate the applicant's responses, and the need for formal correspondence between the staff and the applicant is reduced, resulting in an improvement in review efficiency."
59 3.0.1.2 3-4 In Item 6, sentence reads, "If there are no corresponding items in the GALL Report, the applicant leaves the column blank in order to identify the AMR results in the LRA tables corresponding to the items in the GALL Report tables." Since leaving the column blank provides no correlation, the last part of this sentence should be a separate sentence that comes first, such as, "In this way, the applicant identified the AMR results in the LRA tables corresponding to the items in the GALL Report tables. If there are no corresponding items in the GALL Report, the applicant leaves the column blank."
Page 10 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Com~ment Section Page Comment Number Number(s)
Number(s) 60 3.0.3 3-7 Since SER Table 3.0.3-1 includes three programs that were not described in LRA Appendix B, it is assumed that this table and subsequent lists of programs are meant to reflect LRA Appendix B as amended by RAI responses. Suggest appending "and subsequent RAI responses" to the end of the first sentence of Section 3.0.3.
61 3.0.3 3-7 For consistency with other entries in the GALL Report Comparison column of Table through 3-3.0.3-1, "enhancement" should be plural for the Buried Piping Inspection Program and 10 the BWR Vessel Internals Program and should be singular for the Bolting Integrity Program. Also, "exception" should be plural for the Containment Leak Rate Program 62 3.0.3 3-7 The list of LRA systems or structures that credit the Buried Piping Inspection Program should not include "steam and power conversion systems." As indicated in LRA table 3.4.1, item 3.4.1-11, this program is not applicable because there are no steel components exposed to soil in the steam and power conversion systems.
63 3.0.3 3-8 The list of LRA systems or structures that credit the Periodic Surveillance and PreventiVe Maintenance Program should not include "steam and power conversion systems." This program is not listed in LRA Section 3.4.2.1.1 or Table 3.4.2-1. LRA Table 3.4-1 line items 3.4.1-31 and 3.4.1-32, which mention this program, are referenced only in LRA auxiliary systems Table 3.3.2.13-9.
64 3.0.3 3-8 In Amendment 26, letter BVY 07-018, dated March 23, 2007 (page 10 of attachment 3),
an enhancement was added to the Service Water Integrity Program (Commitment 45).
Thereforb, this program should be listed as "Consistent with exceptions and enhancement."
65 3.0.3 3-9 The list of LRA systems or structures that credit the Water Chemistry Control - BWR Program should include "SC supports." LRA sections 3.5.2.1.2 and 3.5.2.1.6 indicate that this brogram is credited for reactor building and bulk commodity components. Also, this program (along with the ISI program) manages aging of portions of the carbon steel vent header supports below the water level in the torus (Amendment 12, BVY 06-083, dated September 5, 2006, attachment 1).
Page 11 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 66 3.0.3-1 3-10 The Bolting Integrity Program is included in the list of "New AMPs" for VY. The program is an existing program with enhancements to match GALL and should be included in the upper section of Table 3.0.3-1 67 3.0.3 3-10 The list of LRA systems or structures that credit the One-Time Inspection Program should include, "reactor vessel, internals, and reactor coolant system" and "steam and power conversion systems." Small bore piping, main steam flow restrictors and RB flange leak-off line are in the reactor coolant system. Also, the reactor coolant system and steam and power conversion systems credit the One-Time Inspection Program since thdy credit water chemistry control programs.
68 3.0.3.1 3-10 In Amendment 5, letter BVY 06-064, dated July 14, 2006 (response to audit item 64 on page 3 of attachment 1); the exception was deleted from the Reactor Head Closure Studs Program. Therefore, this program should be listed as "Consistent."
69 3.0.3.1 3-12 Last paragraph, 1st sentence, capitalize "Environmental".
70 3.0.3.1.1 3-14 In final paragraph of Operating Experience, change "...satisfies there..." to "...satisfies the...."
71 3.0.3.1 3-14 4 th paragraph, change "there" to "their".
72 3.0.3.1.3 3-19 Third paragraph, beginning "The staff noted that GALL..." is redundant to the second paragralJh on page 3-18, beginning "In addition, the staff noted that GALL...." One of the paragraphs should be deleted.
73 3.0.3.1.3 3-21 UFSAR supplement and conclusion discussions do not mention the commitment (#13) to implement this program. For consistency with other program discussions, this information should be included.
74 3.0.3.1.4 3-23 Ist paragraph is incomplete, should read;
_"environmentally qualified" vs. Environmental Qualification" Page 12 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 75 3.0.3.1.4 3-24 1st indented paragraph, 3rd line should state; "plant specific operating procedures" vs. "operating".
76 3.0.3.1.6 3-30 The bulleted list of items for which the One-Time Inspection program will verify AMP effectiveness and confirm the absence of aging effects should be revised as follows.
- Add diesel fuel monitoring program (Amendment 16, BVY 06-091, dated October 17, 2006, attachment 1)
" Add oil analysis program. (Amendment 16, BVY 06-091, dated October 17, 2006, attachment 1)
" Add non-piping components without metal fatigue analysis; specifically, RHR hbat exchanger shell, RHR pump casing, HPCI turbine casing, and RCIC turbine casing. (Amendment 16, BVY 06-091, dated October 17, 2006, attachment 1)
Delete internal surfaces of carbon steel and copper alloy components in the potable water and radwaste systems containing untreated water. (Amendment 16, BVY 06-091, dated October 17, 2006, attachment 1 and Amendment 19, BVY 06-097, dated October 31, 2006, attachment 2) 77 3.0.3.1.6 3-30 Delete Pg 3-30 last paragraph and 1st paragraph on pg 3-31. This discussion is 3-31 confusing. Start 2 nd paragraph with; "The staff and licensee discussed socket welded connection needs."
78 3.0.3.1.6 3-31 In the third paragraph, change "In its letter, dated March 12,... " to "In its letter dated March 12, 2007.
79 3.0.3.1.6 3-32 In the second paragraph of UFSAR Supplement discussion, remove the first "that" from the first line, "In addition, the applicant stated that-, in a letter dated January 4, 2007, that a one-time..."
Page 13 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 80 3.0.3.1.8 3-34 In second paragraph, change "Included components are masonry walls required by 10 CFR 50.48, radiation-shielding masonry walls, masonry walls with the potential to affect safety-related components, and the torus compartment water trough." to "Included walls are the 10CFR50.48-required walls and masonry walls in the reactor building, intake structure, control room building, and turbine building." The existing words are not from the VYNPS LRA.
81 3.0.3.1.9 3-37 Last paragraph state; "SER Section 3.0.3.2.11 C02 Systems" 82 3.0.3.1.11 3-40 In the first sentence of the first paragraph, delete the second occurrence of "levels of contaminants" as it is redundant.
83 3.0.3.1.11 3-40 In the second sentence of the first paragraph, delete, "for the reduction of dissolved oxygen in the treated water" as it is redundant.
84 3.0.3.1.11 3-41 In second paragraph of UFSAR Supplement discussion, change "will conform the effectiveness" to "will confirm the effectiveness."
85 3.0.3.2 3-41 In Amendment 5, letter BVY 06-064, dated July 14, 2006 (response to audit item 64 on page 3 of attachment 1); the exception was deleted from the Reactor Head Closure Studs Program. Therefore, this program should not be listed as 'With Exceptions and/or Enhancements."
86 3.0.3.2 3-41 Delete "Metal" from bullet for Bolting Integrity Program.
87 3.0.3.2.1 3-42 In the second paragraph of Summary of Technical Information in the Application, change "(b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, stainless steel, and titanium components" to "(b) inspection's to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, stainless steel, and gray cast iron components."
Page 14 of 34 BVY 07-035 Docket 50-271
VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Numiber Number(s)
Number(s) 88 3.0.3.2.1 3-44 First paragraph states, "The applicant made a commitment (Commitment #1) to enhance this plant procedure to provide additional guidelines for the examination of buried piping,....and instructions to notify engineering to perform an opportunistic examination of any buried structure uncovered during the excavation of piping."
Commitment 1 does not mention buried structures. Also, the bottom of SER page 3-95 states, "The applicant stated that VYNPS will take advantage of inspection opportunities for underground structures that become accessible by excavation. This inspection is already part of the Structures Monitoring Program." Therefore, the end of the statement should be deleted.
89 3.0.3.2.1 3-44 and of Amendment 26, BVY 07-018, dated March 23, 2007 contains 3-45 Commitment 44 which states, 'Guidance for performing examinations of buried piping will be revised to include the following. "A focused inspection will be performed within the first 10 years of the period of extended operation, unless an opportunistic inspection (or an inspection via a method that allows an assessment of pipe condition without excavation) occurs within this ten-year period."' This commitment is not mentioned.
90 3.0.3.2.2 3-47 In the Conclusion paragraph, change "the staff reviewed the exception and their justifications" to "the staff reviewed the exception and its justification." Comment also applies to other programs with one exception.
91 3.0.3.2.3 3-48 In the paragraph below the exception, change "have performed system modifications to mitigate cracking" to "has performed... "
92 3.0.3.2.3 3-48 Last sentence on page states, "Data from the bypass leakage detection system continues to be used appropriately to ensure adequate conservatism in modeling the aging of the interference-fit thermal sleeve." This was not stated in the LRA or subsequent amendments. If this statement is needed, perhaps it should be included in the following paragraph which discusses staff interviews.
93 3.0.3.2 3-48 Pg 3-48 6 th paragraph - Should be past tense ("determines" should be "determined")
94 3.0.3.2 3-49 Conclusion paragraph - Verb tenses mixed - Should be past tense Page 15 of 34 BVY 07-035 Docket 50-271
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Number Number(s)
Number(s)
Comment 95 3.0.3.2.4 3-51 In the first paragraph of the Operating Experience discussion, delete "are evaluated" from the final sentence.
96 3.0.3.2.7 3-56 The end of the second paragraph of the Staff Evaluation discussion states, "The applicant also committed to evaluate BWRVIP-139 upon approval by the staff and either include its recommendations in the BWR Vessel Internals Program or inform the staff of exceptions to that document." While it is true that this will occur, it is not listed as a license renewal commitment, because it will occur in accordance with existing procedures. Therefore, suggest rewording to state, "In accordance with existing procedures, the applicant will evaluate BWRVIP-39... "
97 3.0.3.2.7 3-56 Change the 4 th paragraph, 3 rd sentence of Section 3.0.3.2.7 as follows:
"In a letter dated August 22, 2006, the applicant committed (Commitment #37) to continue inspections in accordance with the VYNPS Steam Dryer Monitoring Pregram Plan, Revision 3, which incorporates the guidelines of GE-SIL-644, Revision 1."
98 3.0.3.2 3-57 Pg 3-57 Paragraph 2 should read "the exception stated "since the exception no longer exists.
99 3.0.3.2.7 3-57 At the beginning of exceptions 2 through 6 and the enhancement, change "LRA Section through 3-B.1.57" to "LRA Section B.1.7."
62 100 3.0.3.2.7 3-60 In final paragraph, change (TSs) to (TS) since the acronym for technical specifications is TS.
101 3.0.3.2.7 3-63 Change tlie 4 th paragraph, of Section 3.0.3.2.7 as follows:
"The applicant committed (Commitment #37) to continue inspections in accordance with the Steam Dryer Monitoring Pregram Plan, Revision 3, in the event that the BWRVIP-139 is not approved prior to the period of extended operation; by March 21, 2012."
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Number(s) 102 3.0.3.2.8 3-64 of Amendment 26, BVY 07-018, dated March 23, 2007 contains an additional exception, Acceptance Criteria (number 2), to the Containment Leak Rate Program. Consider incorporating this exception into section 3.0.3.2.8 as stated below:
"Main steam leakage pathway contributions (leakage through all four main steam lines and the main steam drain line) are excluded from the overall integrated leakage rate Type A test measurement and from the sum of the leakage rates from Type B and Type C tests" 103 3.0.3.2.8 3-65 Delete the 1st paragraph on the page as it is redundant to the previous paragraph.
104 3.0.3.2.9 3-68 of Amendment 26, BVY 07-018, dated March 23, 2007 revised commitments 3 and 4 and the enhancements discussed in this section to include UT measurements of the fire pump diesel storage (day) tank in addition to the fuel oil storage tank.
105 3.0.3.2.9 3-68 of Amendment 26, BVY 07-018, dated March 23, 2007 added commitments 46 and 47 as enhancements to this program.
106 3.0.3.1.11 3-74 In second paragraph of Section, change "included" to "includes."
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Number(s) 107 3.0.3.1.11 3-74 Final paragraph on page states, "The staff reviewed the applicant's procedure acceptance criteria and noted that they allow cracks in poured concrete barriers, fire barriers, doncrete block walls, drywall, plaster, silicone foam, pyrocrete, and smoke/gas seals. The staff asked the applicant to justify the plant-specific acceptance criteria's variance from that recommended by the GALL Report. The applicant responded that this acceptance criteria procedure would be revised to require that any recordable indication be identified and entered into the CAP for evaluation and subsequent action, as described below in Enhancement 1." Enhancement 1 (SER page 3-77) does not contain these words.
Actually, the procedure (OP 4019) does not allow cracks in these components. Rather, the acceptance criteria in the procedure are two-fold.
- 1. If a major crack (degradation or missing component in a fire barrier or fire rated assembly that requires supplemental evaluation to determine its functional imbact) exists, it is entered into the CAP for evaluation and subsequent action.
- 2. If a minor crack (degradation in a fire barrier or fire rated assembly that should be corrected even though the component is considered functional) exists, corrective action is taken directly through a work order, without entering the CAP.
Although minor cracks are not entered in the CAP, they are repaired. Therefore, the procedure acceptance criteria are consistent with that recommended by the GALL report without enhancement since they do not allow cracks.
108 1
3.0.3.2 3-75 J 6 th paragraph. The last 2 sentences of the paragraph do not make sense.
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Number(s) 109 3.0.3.2 3-76 Last line "determined" vs. "determines."
110 3.0.3.2.12 3-83 The footnote states, "NFPA 25 requires that sprinkler heads be replaced or representative samples from one or more sample areas be submitted to a recognized testing latoratory for field services testing. In the VYNPS program a representative sample of sprinkler heads will be submitted to a recognized testing laboratory for services testing. The Staff notes that the VYNPS sprinkler heads inspection program appears to eliminate the option to just replace a sprinkler head after 50 years service unless it first undergoes laboratory testing. This implies that, if a sprinkler head is obviously corroded and requires replacement, the VYNPS may first have to send that sprinkler Hiead to a testing laboratory before replacing it, a seemingly unnecessary burden."
This footnbte does not appear necessary, or logical. The reason for testing a sample of sprinkler heads is to provide assurance that the heads are suitable for continued service. This testing does not preclude replacement of an obviously corroded sprinkler head. Testing would not be necessary unless the head is to be returned to service.
The footnote should be deleted.
111 3.0.3.2 3-85 Last paragraph "determined" vs. "determines."
112 3.0.3.2 3-89 Ist and 2 nd paragraphs. Indent is not needed 113 3.0.3.2 3-90 2 nd paragraph, last sentence, change to:
"....... evaluation section. The applicant" 114 3.0.3.2 3-90 6 th +7th paragraph, - Mixing presence tense with past tense (e.g. determines vs. determined)
Page 19 of 34 BVY 07-035 Docket 50-271
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Number(s) 115 3.0.3.2 3-90 The proposed license condition does not seem appropriate. The license condition states that changes to storage requirements be approved by the staff as required by 10 CFR Part 50, Appendix H. Appendix H does not mention storage. The reason given for the license condition is to ensure that changes to the capsule withdrawal schedule will be submitted for staff review and approval, which is already required by Appendix H.
There is no apparent need for a license condition to require a licensee to follow a regulation that must be followed without the license condition. This license condition is different than the related license condition for Oyster Creek, which is different from the related license condition for Nine Mile Point.
116 3.0.3.2.16 3-91 In Amendment 26, letter BVY 07-018, dated March 23, 2007 (page 10 of attachment 3),
through 3-an enhancement was added to the Service Water Integrity Program (Commitment 45).
94 This enhancement to visually inspect internal surfaces of the RHRSW pump motor cooling coils for loss of material should be mentioned in this discussion. (Commitment
- 45) 117 3.0.3.2.16 3-91 Last sentence should read "Components are lined and coated on a limited basis." The current sentence implies that any susceptible base mater is coated. This is not the case.
118 3.0.3.2.17 3-99 In last paragraph of Enhancement 1 discussion, change "(Commitments #20)" to
"(Commitment #20)."
119 3.0.3.2.17 3-100 The last sentence of the Enhancement 3 discussion states, "The drywell floor liner seal is to be removed by the applicant as discussed in SER Section 3.0.3.2.17.2." This sounds like the seal is actually going to be removed from the plant. Perhaps the paragraph about removing the drywell floor liner seal from the scope of the program that was used in the Enhancement 1 discussion could be repeated here.
120 3.0.3.2.17 3-101 In discussion of Commitment #22, change "elastomers, seals, and gaskets)" to "elastomers (seals and gaskets)."
Page 20 of 34 BVY 07-035 Docket 50-271
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Number(s) 121 3.0.3.3.1 3-112 The first paragraph on this page states, "As documented in the Audit and Review Report, the applicant clarified that all heat exchangers in the program are inspected."
The second paragraph also states, "All of the heat exchangers in the program are to be inspected...." These statements are inconsistent with Attachment 4 of Amendment 26, letter BVY 07-018, dated March 23, 2007 which revised attribute 4 of the Heat Exchanger Monitoring program to state, "At least one heat exchanger of each type, material and environmental combination will be included in the sample population."
Additional wording about sample population and testing frequency was also added in Amendment 26.
122 3.0.3.3.1 3-112 Attribute (6) states, "...the minimum acceptable tube wall thickness for each heat exchanger to be eddy current inspected will be established based upon a component-specific engineering evaluation." The words "that considers industry best practices and EPRI recommendations" were added at the end of this sentence in Attachment 4 of Amendment 26, letter BVY 07-018, dated March 23, 2007.
123 3.0.3.3 3-116 1st paragraph - "strainers" vs. "stainers" 124 3.0.3.3.2 3-117 In Amendment 5, letter BVY 06-064, dated July 14, 2006, element (4) of the CII program was revised to include the following sentence. "The CII Program manages cracking and change in material properties for the drywell shell to floor liner seal (moisture barrier) elastomer." This should be included in the discussion of element 4.
125 3.0.3.3.2 3-119 In first line of Operating Experience, change "finds" to "found."
126 3.0.3.3.3 3-122 In ISI program attribute (1), "and relief requests" was deleted in Amendment 19 (BVY 06-097, dated October 31, 2006) response to RAI 3.5-5.
127 3.0.3.3.3 3-123 In second paragraph of ISI program attribute (4), the SER states, "The applicant also stated that its Inservice Inspection Program manages cracking, loss of preload, loss of material, a~hd reduction of fracture toughness, as applicable, of reactor coolant system components...." However, this was not stated by the applicant. As discussed in SER section 3.0.3.2.19, loss of preload is managed by the Bolting Integrity Program, not the ISI program.
Page 21 of 34 BVY 07-035 Docket 50-271
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Number(s) 128 3.0.3.3.4 3-128 In discussion of acceptance criteria, SER states, "dew point less than 400C. However, LRA Section B. 1.16 states, "dew point < -400C.
129 3.0.3.3.4 3-128 In discussion of acceptance criteria, SER states, "hydrocarbon content less than 1 parts per million (ppm)." However, LRA Section B.1.16 states, "hydrocarbon content < lppm.
130 3.0.3.3.4 3-129 Revise second paragraph as shown. The applicant committed (Commitment #28) in to revise the program procedure by March 21, 2012 to indicate that the Instrument Air Program will.-
tMiiain maintains IA quality in accordance with ISA S7.3 by MaFrh 24, 2042.
131 3.0.3.3.4 3-129 In third paragraph, change "Commitments #28" to Commitment #28."
132 3.0.3.3.5 3-129 In second paragraph of Summary of Technical Information in the Application, change the acronym for primary containment atmosphere control from "(CAC)" to "(PCAC)."
133 3.0.3.3.5 3-129 In first paragraph of Staff Evaluation, change "LRA Section B.1.7" to LRA Section B.1.22."
134 3.0.3.3 3-132 6 th paragraph-The last sentence repeats (e.g. On this basis........ )
135 3.0.3.3.6 3-134 Change the first sentence of section 3.0.3.3.6 as follows:
LRA Section B.1.27.3 initially described dee-,rbes the Vernon Dam FERC Inspection as an existing, plant-specific program.
136 3.0.3.3 3-134 Last paragraph almost repeats again on Pg 135, paragraph 3. Could resolve by stating 3-135 that "The applicant stated in the LRA and the staff verified that.
137 3.0.3.3.7 3-136 Insert space before this section title.
138 3.0.3.3.7 3-140 Paragraph 4, change the following:
In addition, in a letter dated January 14, 2007, the applicant provided an amendment to its LRA to explicitly state, "One-Time Inspection Program," activities will confo4rm confirm the effectiveness of 'Water Chemistry Control - Auxiliary Systems Program."
Page 22 of 34 BVY 07-035 Docket 50-271
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Number(s) 139 3.0.3.3.7 3-140 In last paragraph of UFSAR Supplement discussion, change "Commitments #26" to "Commitment #26."
140 3.0.3.3 3-141 2 paragraph, last sentence - discusses QA, but should be summarizing bolting program.
141 3.0.4.1 3-146 Last paragraph of Section 3.0.4.1 states, "LRA Section B.1, "Aging Management Review Results," provided an AMR summary...." However, LRA Section 3.0 contains the AMR summary.
142 3.0.3.3 3-147 The 3 rTd paragraph is difficult to clearly understand - provided below:
"During the review of the LRA and AMP evaluation reports, the staff identified inconsistencies associated with corrective action, confirmation, and administrative control processes regarding the AMP for the VHS structural components. LRA Section B.1.27 and the AMP evaluation reports stated that the AMP was consistent with NUREG-1801 in that the applicants CAP was applicable to the VHS. When discussing this AMP with the applicant, the applicant stated that it did not own the VHS and that its CAP did not apply to VHS as indicated in the LRA and AMP evaluation reports.
Additionally, the staff found that AMP evaluation reports did not consistently describe the application of the 10 CFR Part 50, Appendix B, QA Program for the corrective action, confirmation process, and administrative control attributes for each AMP."
Suggest deleting the 3 rd paragraph and adding the following statement to the beginning of paragraph 4:
"During the review of the LRA and AMP evaluation reports, the staff determined that the licensee's CAP and10 CFR Part 50, Appendix B, QA Program could not be applied to the VHS, due to the VHS being owned by a third Party and regulated by FERC."
143 Table 3.1-1 3-152 Entry 3.1.1-13 is misleading as written as it implies VY has an isolation condenser, which it does not. VY only referenced this line item as it was the closest match for other components with the same material and environment. An entry similar to 3.1.1-20 and 3.1.1-26 would be better.
Page 23 of 34 BVY 07-035 Docket 50-271
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Number(s) 144 Table 3.1-1 3-160 Entry 3.1.1-46 implies VY has mechanical (bolted) core shroud access covers; which in fact they don't. Suggest using words from LRA discussion column for this item, that is, "Not applicable. The VYNPS access hole covers are welded, not mechanical (bolted)."
145 3.1.2.2.11 3-189 Change the last paragraph, 2 nd sentence on page 3-189 as follows:
"In addition, in a letter dated August 22, 2006, the applicant committed (Commitment
- 37) to continue inspections in accordance with the Steam Dryer Monitoring Pregram Plan, Revision 3, in the event that BWRVIP-139 is not approved prior to the period of extended operation."
146 3.2.2 3-201 In the fourth column of the second row in Table 3.2-1, provide lower border for cell.
147 3.2.2 3-206 In the second row, Fire Protection Program and Fire Water System Program are listed as AMPs identified in the LRA to manage loss of material due to corrosion for components in ESF systems. However, these programs are not credited for ESF components (Tables 3.2.2-1 through 3.2.2-7). The programs are credited in auxiliary system tables with reference to GALL Report Item number 3.2.1-32.
148 3.2.2 3-209 In the bottom row, change "9 See SER Section 3.2.2.1)" to "(See SER Section 3.2.2.1)."
149 3.2.2.1 3-211 The Bolting Integrity Program should be included in the list of programs that manage aging effects for ESF system components.
150 3.2.2.1.9 3-216 Final paragraph includes the Inservice Inspection program for managing cracking due to SCC and IGSCC for ESF components. The foregoing discussion does not mention this program, so it should be deleted from this paragraph.
151 3.2.2.1.13 3-218 In the second paragraph, Fire Protection Program and Fire Water System Program are listed as AMPs identified in the LRA to manage loss of material due to corrosion for components in ESF systems. However, these programs are not credited for ESF components (Tables 3.2.2-1 through 3.2.2-7). The programs are credited in auxiliary system tables with reference to GALL Report Item number 3.2.1-32.
152 3.2.2.3 3-232 Last two paragraphs on this page are redundant. Delete last paragraph.
Page 24 of 34 BVY 07-035 Docket 50-271
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Number(s) 153 3.2.2.3.1 3-233 In last paragraph on this page, change sentence as shown. "The staff's evaluation of the applicant's System Walkdown Program and Bolting Integrity Program in are documented in SER Sections 3.0.3.1.9 and in 3.0.3.2.19, respectively."
154 3.2.2.3.2 3-234 In third paragraph of this section, change sentence as shown. 'The staff's evaluation of the applicant's System Walkdown Program and Bolting Integrity Program i4 are documented in SER Sections 3.0.3.1.9 and in 3.0.3.2.19, respectively."
155 3.2.2.3.3 3-234 In 2nd sentence of 3 rd paragraph, "XI.M181" should read simply "XI.M18" NOTE: This error appears several times.
156 3.2.2.3.3 3-235 In top paragraph on this page, change sentence as shown. "The staff's evaluation of the applicant's System Walkdown Program and Bolting Integrity Program iA are documented in SER Sections 3.0.3.1.9 and in 3.0.3.2.19, respectively."
157 3.2.2.3.4 3-235 SER states, "In LRA Table 3.2.2-4, the applicant proposed to manage loss of material wear of copper alloy and stainless steel materials for component types of heat exchanger tubes and orifice exposed to lube oil and treated water environments using the Heat Exchanger Monitoring Program." However, LRA Table 3.2.2-4 does not propose usihg the Heat Exchanger Monitoring Program for stainless steel materials or for component type orifice. Sentence should be revised as follows. In LRA Table 3.2.2-4, the applicant proposed to manage loss of material wear of copper alloy and st-anless, stee4 materials for component type psof heat exchanger tubes an4deGrf*ee exposed to lube oil and treated water environments using the Heat Exchanger Monitoring Program.
158 3.2.2.3.4 3-235 SER states, "In LRA Table 3.2.2-4, the applicant proposed to manage cracking of stainless steel material for component types of valve body exposed to lube oil environments using the Oil Analysis Program." However, Table 3.2.2-4 proposes using this program for cracking of stainless steel orifices, tubing and valve bodies. Sentence should be revised as follows. In LRA Table 3.2.2-4, the applicant proposed to manage cracking of stainless steel material for component types of orifice, tubing and valve body exposed to lube oil environments using the Oil Analysis Program.
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Number(s) 159 3.2.2.3.4 3-236 In second paragraph on this page, change sentence as shown. 'The staff's evaluation of the applicant's System Walkdown Program and Bolting Integrity Program in are documented in SER Sections 3.0.3.1.9 and in 3.0.3.2.19, respectively."
160 3.2.2.3.5 3-236 For consistency with LRA Table 3.2.2-5, change sentence as shown. "In LRA Table 3.2.2-5, the applicant proposed to manage crackinQ and loss of material wear of copper alloy and aluminum materials for component types of heat exchanger tubes and steam headers heaters exposed to steam, treated water and a lube oil environment using the Heat Exchanger Monitoring Program." Also, conclusion in the following paragraph should address cracking along with loss of material.
161 3.2.2.3.5 3-237 In third and iinal paragraphs on this page, change sentence as shown. 'The staff's 3.2.2.3.6 evaluation of the applicant's System Walkdown Program and Bolting Integrity Program i4 are documiented in SER Sections 3.0.3.1.9 and in 3.0.3.2.19, respectively."
162 3.2.2.3.7 3-239 In top sentence on this page, change sentence as shown. 'The staff's evaluation of the applicant's System Walkdown Program and Bolting Integrity Program in are documented in SER Sections 3.0.3.1.9 and in 3.0.3.2.19, respectively."
163 3.2.2.3.9 3-241 and Section does not discuss stainless steel components exposed to gas, or glass 3-242 components exposed to air indoor (external), lube oil, or treated water. LRA Tables 3.2.2-1 through 3.2.2-7 identify these additional AMR line items with no aging effects.
164 3.3 3-243 The bulleted item at the end "Miscellaneous systems in scope for' needs to be the heading at the top of the page and not a bulleted item since all of these systems on this page are the (a)(2) systems in the LRA list. Also the augmented off gas system on page 3-242 needs to be under this listing. All of the systems listed after John Deere diesel should be deleted and replaced with one bullet titled "miscellaneous systems in scope for 10FR54.4(a)(2)". Listing all of these systems is confusing as many are listed in the first part of the list already.
165 Table 3.3-1 3-250 Line Item 3.3.1-29; Last two columns are incorrect. Change SER reference from 3.3.2.1.1.16 to 3.3.2.1.17 and Buried Piping Inspection Program Page 26 of 34 BVY 07-035 Docket 50-271
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Number(s) 166 3.3 3-251 Line item 3.3.1-33 needs to include One Time Inspection in LRA program along with Oil analysis 167 Table 3.3-1 3-253 Line item 3.3.1-45 says that the Bolting Integrity Program was the LRA program for managing loss of preload. In the LRA this line item is identified as not applicable. The Bolting Integrity program includes all bolting in scope but loss of preload is not an aging effect requiring management at VYNPS. This line item is inconsistent with the conclusion in the SER on page 3-348 which says it is not an AERM. Suggest making table agree with conclusion on 3-348 and mark this as None in AMP in LRA column.
Also does commitment #34 need to be included by all the Bolting Integrity entries or removed? It only shows on one.
168 Table 3.3-1 3-253 Line Item 3.3.1-44; Last two columns should be the same as 3.3.1-42.
169 3.3.2.1.1 3-266 The generic statement; "The One-Time Inspection Program was not explicitly identified 3.3.2.1.2 3-267 in system Tble (Table 2)", is not correct for the sections as listed in the second column from the left in this table.
3.3.2.1.7 3-270 3.3.2.1.11 3-272 3.3.2.1.12 3-273 3.3.2.1.18 3-278 3.3.2.1.19 3-278 Page 27 of 34 BVY 07-035 Docket 50-271
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Number(s) 170 3.3.2.1.32 3-287 In the next to last paragraph it is stated that "In a letter dated July 14, 2006, the applicant revised its LRA. The applicant stated that the LRA is revised to state the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control
- Closed Cobling Water Program." These sentences should be deleted or moved since they are in the middle of a discussion of an exception related to a different subject.
The next to laIst sentence states; "The staff determines that the applicant would select".
This should ýtate; "The staff determined that the applicant".
171 3.3.2.1.38 3-294 In the first paragraph third sentence add; "EDG stainless steel expansion filters" are called out. The word expansion needs to be deleted to adree with other descriptions of these components which are just filters.
172 3.3.2.3.5 3-325 3.3.2.3.5 discusses Fuel tank management not Fuel Pool Cooling System. This section is repeated below under the proper title, the write-up for Fuel Pool Cooling is apparently missing.
173 3.3.2.3.5 3-325 In this sectioh the 2 nd and 3 rd paragraphs document the review of stainless steel flex hoses in a fuel oil environment in Table 3.3.2-5. There are no stainless steel flex hoses or any components containing fuel oil in this table.
174 3.3.2.3.6 3-326 In the third paragraph last sentence it states "... the staff finds the loss of material from carbon-steel tanks". This paragraph is referring to cracking in stainless steel flex hoses.
175 3.3.2.3.8 3-327 and In first, third, and fourth paragraphs, the program name should be Fire Protection not 328 Fire Protection-Fire Protection.
176 3.3.2.3.8 3-329 In first paragraph the following sentence appears to be missing something; "The System Walkdown Program is consistent with the staff team determines the loss of material from stainless steel bolting" Page 28 of 34 BVY 07-035 Docket 50-271
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Number(s) 177 3.3.2.3.23 3-337 This s6ction incorrectly refers to Table 3.3.2-13-12 as being for the Diesel Lube Oil System in the second paragraph. Should be LRA table 3.3.2-13-11.
178 3.3.2.3.25 3-338 Need to remove the following words in 1st paragraph "are either not applicable to VYNPS" 179 Various 3-367 The SER staies in several places; 3-368 (2 "During the audit and review, the staff noted that for this aging effect, the One-Time places)
Inspection Program was not credited in the system tables (Table 2s), only the Water 3-369 (2 Chemistry Control-BWR Program was credited."
places)
This is a mischaracterization of the LRA. The One-Time Inspection Program was credited in the system tables through a reference to a line item in the 'Table 1 Item" column. The Table 1 line item referenced in the Table 2s, explicitly stated that each chemistry program is augmented by the One-Time Inspection Program to verify program effectiveness. It would be correct to say that the Table 2s did not explicitly list the One-Time Inspection Program although the corresponding Table 1 item states that the One-Time Inspection Program is credited.
Also, the last sentence of the associated paragraph should be revised to state:
"The applicant Fev4se4-larified its Water Chemistry Control-BWR Program description to explicitly state that includo the sentence: "The One-Time Inspection Program will confirm the effectiveness of the program." No changes were required to the programs since the One-Time Inspection Program was credited."
In other sectibns, the SER uses slightly different words. The most correct phrase is the statement that the One-Time Inspection Program was not; "explicitly identified in the system tables (Table 2s)".
Other locations (Pages 282, 283, 284-twice, 285, 286, and 287) state:
... will be explicitly identified in the system tables...".
This excerpt is also incorrect fir reasons/examples provided above.
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VERMONT YANKEE NUCLEAR POWER STATION DRAFT SER REVIEW COMMENTS ATTACHMENT 1 Comment Section Page Comment Number Number(s)
Number(s) 180 3.4.2.1.3 3-368 In the 1st paragraph change; RCICSs To; RCIC or RCIC systems 181 3.4.2.1.5 3-369 In the first paragraph first sentence need to delete aluminum. The discussion column for Item 3.4.1-15 did not include aluminum.
182 3.4.2.1.6 3-370 In the fourth paragraph it says the applicant provided clarification on loss of preload as an aging effe6t in a letter dated January 4, 2007. This letter does not discuss loss of preload but only the scope of bolting included in the Bolting Integrity program. The statements in this paragraph are inconsistent with the referenced letter. The paragraph should be revised to read as follows; In its October 17, 2006 letter, the applicant also stated that this program applies to all bolting exposed to air with aging effects requiring management. The applicant was asked to confirm if the program applied to all bolting. By letter dated January 4, 2007, the applicant clarified that the Bolting Integrity Program applies to bolting and torqueing practices of safety-related and nonsafety-related bolting for pressure retaining components, NSSS support components, and structural joints regardless of bolting size.
On the basis of its review, the staff finds the applicant clarification acceptable.
183 3.4.2.1.12 3-373 The first sentence in the 2 nd paragraph "During the audit and review, the staff noted that for this aging effect, the GALL Report's recommended Water Chemistry Control Program was not explicitly identified in the system tables (Table 2s)" is not correct since water chemistry is identified. Need to delete this sentence or reword it. Also applies on page 3-374 for water chemistry control auxiliary program. This appears to be a carry over from earlier one time inspection discussions in 3.3.2 where OTI was not specifically called out in Table 2s.
184 3.4.2.2.3 3-376 First sentence in second paragraph is confusing and appears to be missing something 185 3.5.2.2.2 3-438 4 th paragraph, 2 nd sentence - A space is needed for the "5percent" (i.e. 5 percent)
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Comment Section Page Comment Number Number(s)
Number(s) 186 Table 3.6-1 3-473 The aging effect/mechanism listed for Item 3.6.1-8 in this table does not match Item 8 of NUREG-1801, Vol. 1, Table 6. The aging effect/mechanism should be; "Reduced insulation resistance and electrical failure due to various physical, thermal, radiolytic, photolytic, and chemical mechanisms."
187 3.6.2.2.3 3-479 3 rd line from b~ottom, change; "pro-load" to; "pre-load".
188 3.6.2.2.3 3-480 Middle of first full paragraph, around 9 th line-should state; "Except for connections associated with normally enclosed transformer connections..."
Routing thermography is effective and will be used for all transformer connections which are visible to the camera. Those not visible would be the low voltage connections to the GSU, the connections for the UAT. The high voltage connections to the GSU and the startup transformer connections can be trended using thermography.
189 3.6.2.3 3-486 Typos, 7th line from bottom - "cap-screws" and 6th line from bottom "Installation data" 190 3.6.2.3.2 3-488 3 rd paragraph, next to last sentence clarification; "The underground cables and connections are included in E2."
This should state "E3" instead of "E2". Suggest providing the VY program name since E3 refers to the NUREG-1 801 section.
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Comment Section Page Comment Number Number(s)
Number(s) 191 3.6.2.3.2 3-488 Second paragraph begins with the following; "In a letter dated October 17, 2006, the applicant revised its LRA. The applicant added LRA Appendices A.2.1.38 and B.1.32 describing its Metal Enclosed Bus Inspection Program."
Suggest changing LRA appendices to LRA sections as Sections were added to the existing appendices.
192 3.6.2.3.2 3-500 Change "the applicant argued" to "the applicant stated".
193 3.6.2.3.2 3-500 The fourth pai'agraph states, 'The SOC to 10 CFR Part 54 states that required redundancy can not be used to preclude aging effects of in-scope passive long-lived electrical components." It would be appropriate to indicate that the SBO rule does not REQUIRE redundancy for an alternate AC source.
194 4.1.1 4-2 Reword the first paragraph on the page so it doesn't state that VYNPS didn't identify exemptions as required by 10 CFR 54.3 as follows The regulations in 10 CFR 54.21(c)(2) require identification of exemptions granted pursuant to 10 CFR 50.12 that are based on TLAA. The applicant stated that there were no VYNPS exemptions dependent on time-limited aging analyses.
195 4-23 Suggest the last sentence of the first paragraph on this page be edited. Cracking because of fatigue is not an aging effect requiring management if the analysis is valid for the period of extended operation.
If the TLAA does not remain valid and cannot be projected, then cracking due to fatigue is an aging effect requiring management in accordance with 10 CFR 54.21 (c)(1 )(iii).
196 4.3.1.3.1 4-29 The last sentence in the first paragraph is missing a verb.
These analyses were based on a number of cycles not expected to be exceeded in 40-years and as such are treated as TLAAs.
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Number(s)
Comment 197 4.3.1.3.3 4-30 Seems odd to have environmentally assisted fatigue (EAF) discussed in the conclusion section for 4.3.1 when EAF is not discussed until-section 4.3.3. If the staff needs to I
address EAF here, perhaps a reference to Section 4.3.3 would be appropriate.
198 4.3.3.2 4-34 The last sentence of the first paragraph on this page should be revised.
199 200 201 202 4.7.1.1 Commitment 3
Commitment 4
Commitment 16 4-42 A-3 A-3 A-5 The staff finds that CUFs for these four locations are required to address the effects of reactor boolant environment on fatigue as mentioned above.
The first paragraph mixes flux and fluence. It should read as follows.
To show that VYNPS remains bounded for the period of extended operation, it is adequate to show that shroud fluence for 54 EFPY remains below 2.7 x 1020 n/cm2.
The peak shroud flux was calculated for the extended power uprate at 9.67 x 1010 n/cm2 -sec. Integration of this flux and the pre-uprate flux indicates an end of life shroud fluence of 1.5 x 1020 n/cm2. of Amendment 26, BVY 07-018, dated March 23, 2007 revised this commitment to include the fire pump diesel storage (day) tank. It should now read as follows.
The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonic thickness measurement of the fuel oil storage and fire pump diesel storage (day) tank bottom surfaces will bIe performed every 10 years during tank cleaning and inspection. of Amendment 26, BVY 07-018, dated March 23, 2007 revised this commitment to include the fire pump diesel storage (day) tank. It should now read as follows.
The Diesel Fuel Monitoring Program will be enhanced to specify UT measurements of the fuel oil storage and fire pump diesel storage (day) tank bottom surfaces will have acceptance criterion > 60% Tnom. of Amendment 24, BVY 07-009, dated March 12, 2007 revised this commitment to remove socket weld examinations. It should now read as follows.
Implement the One-Time Inspection Program as described in LRA Section B.1.21.
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Comment ISection 1Page] Comment Number jNumber(s) JNumber(s) 203 204 Commitment 39 LRA 2.1.1.1 A-12 2.1-3 Change the following:
"If the VYNPS standby capsule is removed fer-m from the License Renewal Application Change To coincide with correct statements for 10 CFR 50.34(a)(1) in the SER, a change to the LRA is necessary; On LRA Pg 2.1-3, paragraph 3, delete the second sentence that states; "Section 50.34(a)(1) is not applicable to VYNPS as it concerns applicants for a construction permit who apply on or after January 10, 1997."
Specifically, the Entergy staff acknowledges that 50.34(a)(1)(ii) is not applicable to VYNPS as stated in the last paragraph of SER pg 2-10.
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