BVY 10-050, License Renewal Application Supplemental Information: Difference between revisions

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{{#Wiki_filter:**~Entergy Entergy Nuclear Operations, Inc.
September 3, 2010 BVY 10-050 ATTN: Document Control Desk U.S.Nuclear Regulatory Commission Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.Vermont Yankee 320 Governor Hunt Rd Vernon.VT 05354 Tel 802 257 7711 Michael J Colomb Site Vice President
Vermont Yankee 320 Governor Hunt Rd Vernon. VT 05354 Tel 802 257 7711 Michael J Colomb Site Vice President September 3, 2010 BVY 10-050 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001


==SUBJECT:==
==SUBJECT:==
License Renewal Application Supplemental Information Vermont Yankee Nuclear Power Station Docket No.50-271 License No.DPR-28  
License Renewal Application Supplemental Information Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28


==REFERENCES:==
==REFERENCES:==
: 1. Letter, Entergy to USNRC, ''Vermont Yankee Nuclear Power Station, License No. DPR-28, License Renewal Application," BVY 06-09, dated January 25, 2006.


==Dear Sir or Madam:==
==Dear Sir or Madam:==
1.Letter, Entergy to USNRC,''Vermont Yankee Nuclear Power Station, License No.DPR-28, License Renewal Application," BVY 06-09, dated January 25, 2006.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.This letter provides supplemental information to the LRA to address issues that have been discussed in industry correspondence concerning the possibility of non-EO inaccessible cables failing in the presence of water intrusion.
Entergy has completed a review of relevant operating experience and addressed it as discussed in Attachment 1 of this letter.New regulatory commitments to implement related aging management activities have been entered into the VYNPS License Renewal Commitment List, Revision 10 (Attachment 2).Should you have any questions or require additional information concerning this submittal, please contact Mr.Robert Wanczyk at 802-451-3166.
I declare under penalty of perjury, that the foregoing is true and correct.Executed on September 3, 2010.Sincerely,[MJC/PLC)
BVY 10-050 / Page 2 of 2Attachments: 1. License Renewal Application Supplemental Information  2. License Renewal Commitment List, Revision 10 cc:  Mr. Eric J. Leeds, Director Office of Nuclear Reactor Regulation  U.S. Nuclear Regulatory Commission One White Flint North 13H16M


11555 Rockville Pike
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.
This letter provides supplemental information to the LRA to address issues that have been discussed in industry correspondence concerning the possibility of non-EO inaccessible cables failing in the presence of water intrusion. Entergy has completed a review of relevant operating experience and addressed it as discussed in Attachment 1 of this letter.
New regulatory commitments to implement related aging management activities have been entered into the VYNPS License Renewal Commitment List, Revision 10 (Attachment 2).
Should you have any questions or require additional information concerning this submittal, please contact Mr. Robert Wanczyk at 802-451-3166.
I declare under penalty of perjury, that the foregoing is true and correct.
Executed on September 3, 2010.
Sincerely,
[MJC/PLC)


Rockville, MD 20852-2738 Mr. William Dean, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Robert Kuntz, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11F1  
BVY 10-050 / Page 2 of 2 Attachments: 1. License Renewal Application Supplemental Information
: 2. License Renewal Commitment List, Revision 10 cc:    Mr. Eric J. Leeds, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 Mr. William Dean, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Robert Kuntz, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11F1 11555 Rockville Pike Rockville, MD 20852-2738 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. David OBrien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601


11555 Rockville Pike
BVY 10-050 Attachment 1 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
License Renewal Application Supplemental Information


Rockville, MD 20852-2738  Mr. James S. Kim, Project Manager  Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 USNRC Resident Inspector  Entergy Nuclear Vermont Yankee, LLC  320 Governor Hunt Road  Vernon, Vermont 05354 Mr. David O'Brien, Commissioner  VT Department of Public Service  112 State Street - Drawer 20  Montpelier, Vermont 05620-2601 BVY 10-050        Attachment 1 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
BVY 10-0xx / Attachment 1 / Page 1 of 3 Vermont Yankee Nuclear Power Station License Renewal Application - Supplemental Information
License Renewal Application Supplemental Information BVY 10-0xx / Attachment 1 / Page 1 of 3 Vermont Yankee Nuclear Power Station License Renewal Application - Supplemental Information BackgroundDue to industry correspondence regarding inaccessible cables, Vermont Yankee Nuclear Power Station (VYNPS) is providing the following information enhancing its aging management program for non-EQ inaccessible medium-voltage cables to include low-voltage (480 V to 2 kV) cables.The NRC staff has concluded that inaccessible low-voltage cables (480 V to 2 kV cables that are subject to aging management review for license renewal) potentially exposed to significant moisture should be included in an aging management program (AMP) specifically to address the effects of moisture on the cables. VYNPS responded to Generic Letter (GL) 2007-01, "Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients" in a letter dated April 30, 2007 (ADAMS Accession Number ML071290055). In the letter, VYNPS reported that no failures were found during a review of plant operating experience involving low-voltage inaccessible cables. VYNPS operating experience since the response to GL 2007-01 on April 30, 2007 until August 25, 2010 was researched in the Corrective Action Program database. VYNPS has experienced no age-related failures of inaccessible low-voltage cables that are subject to aging management review subsequent to the response to GL 2007-01. VYNPS has also reviewed the information provided in the industry responses to GL 2007-01, recent NRC and Electric Power Research Institute guidance documents, and recent industry/NRC meetings on this topic. In light of the NRC Staff's conclusion, VYNPS is expanding the scope of the B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) aging management program to include in-scope, inaccessible, low-voltage cables. VYNPS Revision to Inaccessible Cable ProgramVYNPS will expand the scope of the program described in License Renewal Application (LRA) Section B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) to include inaccessible low-voltage (480 V to 2kV) cables that are subject to aging management review. The parameters monitored or inspected, as required by the program, are changed to include inaccessible low-


voltage cables that are subject to aging management review. Inaccessible low-voltage (480 V to 2kV) cables will be tested for degradation of the cable insulation at least once every 10 years. Inspections for water in manholes containing in-scope inaccessible low-voltage (480 V to 2kV) cables will be performed at least once every two years. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables (480 V to 2 kV) potentially exposed to significant moisture. In addition, LRA Sections A.2.1.19 (Non-EQ Inaccessible Medium-Voltage Cable Program) and B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) are revised to delete the criterion of "exposure to significant voltage" (system voltage for more than 25% of the time) associated with in-scope inaccessible medium-voltage (2 kV to 35 kV) cables. Section B.1.17 is revised to note that the VYNPS Non-EQ Inaccessible Medium-Voltage Cable Program will be based on and consistent with the program described in NUREG-1801, Section XI.E3.
===Background===
BVY 10-050 / Attachment 1 / Page 2 of 3 The changes are presented as strikeout text deleted, and underlined text added. A.2.1.19 Non-EQ Inaccessible Medium-Voltage Cable Program In the Non-EQ Inaccessible Medium-Voltage Cable Program, in-scope medium-voltage cables, not designed for, but exposed to significant moisture and voltage are tested at least once every ten years to provide an indication of the condition of the conductor insulation. The specific test performed is a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, polarization index, or other testing that is state-of-the-art at the time the test is performed. Significant moisture is defined as periodic exposures that last more than a few days.
Due to industry correspondence regarding inaccessible cables, Vermont Yankee Nuclear Power Station (VYNPS) is providing the following information enhancing its aging management program for non-EQ inaccessible medium-voltage cables to include low-voltage (480 V to 2 kV) cables.
Significant voltage exposure is defined as being subjected to system voltage for more than 25% of the time.Inspections for water collection in cable manholes and conduit containing in-scope inaccessible low-voltage and medium-voltage cables will occur at least once every two years.Inaccessible low-voltage cables (cables with operating voltage from 480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables potentially exposed to significant moisture.B.1.17 Non-EQ Inaccessible Medium-Voltage Cable Program DescriptionThe Non-EQ Inaccessible Medium-Voltage Cable Program at VYNPS will be based on and consistent with comparable to the program described in NUREG-1801, Section XI.E3, Inaccessible Medium-voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. VYNPS inspection for water accumulation in manholes is conducted in accordance with a plant procedure. An evaluation per the Corrective Action Process will be used to determine the need to revise manhole inspection frequency based on inspection results. Medium voltage cables include cables with operating voltage level from 2kV to 35kV. Low-voltage cables include cables with operating voltage ranging from 480 V to 2 kV.In this program, periodic actions will be taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. In scope medium-voltage cables exposed to significant moisture and voltage will be tested to provide an indication of the condition of the conductor insulation. The specific type of test to be performed will be determined prior to the initial test and is to be a proven test for detecting deterioration of the insulation system due to wetting as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed. Inaccessible low-voltage cables (cables with operating voltage from 480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended BVY 10-0xx / Attachment 1 / Page 3 of 3 operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables potentially exposed to significant moisture.The program will be initiated prior to the period of extended operation. NUREG-1801 ConsistencyThe program attributes of the Non-EQ Inaccessible Medium-Voltage Cable Program at VYNPS will be consistent with the program attributes described in NUREG-1801, Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements. Exceptions to NUREG-1801 None.
The NRC staff has concluded that inaccessible low-voltage cables (480 V to 2 kV cables that are subject to aging management review for license renewal) potentially exposed to significant moisture should be included in an aging management program (AMP) specifically to address the effects of moisture on the cables.
VYNPS responded to Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients in a letter dated April 30, 2007 (ADAMS Accession Number ML071290055). In the letter, VYNPS reported that no failures were found during a review of plant operating experience involving low-voltage inaccessible cables.
VYNPS operating experience since the response to GL 2007-01 on April 30, 2007 until August 25, 2010 was researched in the Corrective Action Program database. VYNPS has experienced no age-related failures of inaccessible low-voltage cables that are subject to aging management review subsequent to the response to GL 2007-01.
VYNPS has also reviewed the information provided in the industry responses to GL 2007-01, recent NRC and Electric Power Research Institute guidance documents, and recent industry/NRC meetings on this topic. In light of the NRC Staffs conclusion, VYNPS is expanding the scope of the B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) aging management program to include in-scope, inaccessible, low-voltage cables.
VYNPS Revision to Inaccessible Cable Program VYNPS will expand the scope of the program described in License Renewal Application (LRA)
Section B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) to include inaccessible low-voltage (480 V to 2kV) cables that are subject to aging management review. The parameters monitored or inspected, as required by the program, are changed to include inaccessible low-voltage cables that are subject to aging management review. Inaccessible low-voltage (480 V to 2kV) cables will be tested for degradation of the cable insulation at least once every 10 years.
Inspections for water in manholes containing in-scope inaccessible low-voltage (480 V to 2kV) cables will be performed at least once every two years. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables (480 V to 2 kV) potentially exposed to significant moisture.
In addition, LRA Sections A.2.1.19 (Non-EQ Inaccessible Medium-Voltage Cable Program) and B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) are revised to delete the criterion of exposure to significant voltage (system voltage for more than 25% of the time) associated with in-scope inaccessible medium-voltage (2 kV to 35 kV) cables. Section B.1.17 is revised to note that the VYNPS Non-EQ Inaccessible Medium-Voltage Cable Program will be based on and consistent with the program described in NUREG-1801, Section XI.E3.
 
BVY 10-050 / Attachment 1 / Page 2 of 3 The changes are presented as strikeout text deleted, and underlined text added.
A.2.1.19 Non-EQ Inaccessible Medium-Voltage Cable Program In the Non-EQ Inaccessible Medium-Voltage Cable Program, in-scope medium-voltage cables, not designed for, but exposed to significant moisture and voltage are tested at least once every ten years to provide an indication of the condition of the conductor insulation. The specific test performed is a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, polarization index, or other testing that is state-of-the-art at the time the test is performed.
Significant moisture is defined as periodic exposures that last more than a few days.
Significant voltage exposure is defined as being subjected to system voltage for more than 25% of the time.
Inspections for water collection in cable manholes and conduit containing in-scope inaccessible low-voltage and medium-voltage cables will occur at least once every two years.
Inaccessible low-voltage cables (cables with operating voltage from 480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables potentially exposed to significant moisture.
B.1.17 Non-EQ Inaccessible Medium-Voltage Cable Program Description The Non-EQ Inaccessible Medium-Voltage Cable Program at VYNPS will be based on and consistent with comparable to the program described in NUREG-1801, Section XI.E3, Inaccessible Medium-voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
VYNPS inspection for water accumulation in manholes is conducted in accordance with a plant procedure. An evaluation per the Corrective Action Process will be used to determine the need to revise manhole inspection frequency based on inspection results.
Medium voltage cables include cables with operating voltage level from 2kV to 35kV. Low-voltage cables include cables with operating voltage ranging from 480 V to 2 kV.
In this program, periodic actions will be taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. In scope medium-voltage cables exposed to significant moisture and voltage will be tested to provide an indication of the condition of the conductor insulation. The specific type of test to be performed will be determined prior to the initial test and is to be a proven test for detecting deterioration of the insulation system due to wetting as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed.
Inaccessible low-voltage cables (cables with operating voltage from 480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended
 
BVY 10-0xx / Attachment 1 / Page 3 of 3 operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables potentially exposed to significant moisture.
The program will be initiated prior to the period of extended operation.
NUREG-1801 Consistency The program attributes of the Non-EQ Inaccessible Medium-Voltage Cable Program at VYNPS will be consistent with the program attributes described in NUREG-1801, Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.
Exceptions to NUREG-1801 None.
Enhancements None This program includes inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review.
Enhancements None This program includes inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review.
Operating Experience This The program is a new aging management program based on the program description in NUREG-1801, which in turn is based on relevant industry operating experience. As such, this program will provide reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation. As additional operating experience is obtained, lessons learned can be used to adjust the program, as needed. CommitmentLicense renewal commitment #13 is revised to augment the aging management program for Non-EQ Inaccessible Medium-Voltage Cables (underlined text is added): Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.17. Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables will be performed at least once every two years.Inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.
Operating Experience This The program is a new aging management program based on the program description in NUREG-1801, which in turn is based on relevant industry operating experience. As such, this program will provide reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation. As additional operating experience is obtained, lessons learned can be used to adjust the program, as needed.
BVY 10-050        Attachment 2 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Commitment License renewal commitment #13 is revised to augment the aging management program for Non-EQ Inaccessible Medium-Voltage Cables (underlined text is added):
License Renewal Application License Renewal Commitment List Revision 10 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 1 of 12 BVY 10-050 Docket 50-271 During the development and review of the Vermont Yankee Nuclear Power Station License Renewal Application, Entergy made commitm ents 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 commitmen
Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.17.
: t. ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE  Related LRA Section No./
Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables will be performed at least once every two years.
Comments1 Guidance for performing examinations of buried piping will be enhanced to specify that coating degradation and corrosion are attributes to be evaluated. March 21, 2012 BVY 06-009B.1.1 Audit Items 5 &
Inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.
130 2 Fifteen (15) percent of the top guide locations will be inspected using enhanced visual inspection technique, EVT-1, within the first 18 years of the period of extended operation, with at least one-third of the inspections to be completed within the first 6 years and at least two-thirds within the first 12 years of the period of extended operation. Locations selected for examination will be areas that have exceeded the neutron fluence threshold. As stated in the commitment BVY 06-009B.1.7 Audit Item 14 3 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 be performed every 10 years during tank cleaning and inspection. March 21, 2012 BVY 06-009 BVY 07-018 B.1.9 and


regional inspection 4 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 March 21, 2012 BVY 06-009 BVY 07-018 B.1.9 and
BVY 10-050 Attachment 2 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
License Renewal Application License Renewal Commitment List Revision 10


regional inspection VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 2 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Related LRA Section No./
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 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.
Comments5 The Fatigue Monitoring Program will be modified to require periodic update of cumulative fatigue usage factors (CUFs), or to require update of CUFs if the number of accumulated cycles approaches the number assumed in the design calculation. March 21, 2012 BVY 06-009B.1.11 6 A computerized monitoring program (e.g., FatiguePro) will be used to directly determine cumulative fatigue usage factors (CUFs) for locations of interest. March 21, 2012 BVY 06-009B.1.11 7 The allowable number of effective transients will be established for monitored transients. This will allow quantitative projection of future
ITEM   COMMITMENT                                                                         IMPLEMENTATION     SOURCE       Related LRA Section No./
SCHEDULE Comments 1    Guidance for performing examinations of buried piping will be enhanced to           March 21, 2012    BVY 06-009  B.1.1 specify that coating degradation and corrosion are attributes to be Audit Items 5 &
evaluated.
130 2    Fifteen (15) percent of the top guide locations will be inspected using          As stated in the    BVY 06-009  B.1.7 enhanced visual inspection technique, EVT-1, within the first 18 years of        commitment Audit Item 14 the period of extended operation, with at least one-third of the inspections to be completed within the first 6 years and at least two-thirds within the first 12 years of the period of extended operation. Locations selected for examination will be areas that have exceeded the neutron fluence threshold.
3    The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonic            March 21, 2012   BVY 06-009  B.1.9 and thickness measurement of the fuel oil storage and fire pump diesel storage                            BVY 07-018  regional (day) tank bottom surfaces will be performed every 10 years during tank                                            inspection cleaning and inspection.
4    The Diesel Fuel Monitoring Program will be enhanced to specify UT                    March 21, 2012   BVY 06-009  B.1.9 and measurements of the fuel oil storage and fire pump diesel storage (day)                                BVY 07-018  regional tank bottom surfaces will have acceptance criterion  60% Tnom.                                                     inspection Page 1 of 12 BVY 10-050 Attachment 2 Docket 50-271


margin. March 21, 2012 BVY 06-009B.1.11 8 Procedures will be enhanced to specify that fire damper frames in fire barriers will be inspected for corrosion. Acceptance criteria will be enhanced to verify no significant corrosion. March 21, 2012 BVY 06-009B.1.12.1 Audit Items 35, 151, 152, 153
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                    IMPLEMENTATION  SOURCE      Related LRA Section No./
SCHEDULE Comments 5  The Fatigue Monitoring Program will be modified to require periodic update      March 21, 2012 BVY 06-009 B.1.11 of cumulative fatigue usage factors (CUFs), or to require update of CUFs if the number of accumulated cycles approaches the number assumed in the design calculation.
6  A computerized monitoring program (e.g., FatiguePro) will be used to            March 21, 2012 BVY 06-009 B.1.11 directly determine cumulative fatigue usage factors (CUFs) for locations of interest.
7  The allowable number of effective transients will be established for            March 21, 2012 BVY 06-009 B.1.11 monitored transients. This will allow quantitative projection of future margin.
8 Procedures will be enhanced to specify that fire damper frames in fire           March 21, 2012 BVY 06-009 B.1.12.1 barriers will be inspected for corrosion. Acceptance criteria will be Audit Items 35, enhanced to verify no significant corrosion.
151, 152, 153 and 159 9  Procedures will be enhanced to state that the diesel engine sub-systems          March 21, 2012 BVY 06-009 B.1.12.1 (including the fuel supply line) will be observed while the pump is running.
Audit Items 33, Acceptance criteria will be enhanced to verify that the diesel engine did not 150 & 155 exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.
Page 2 of 12 BVY 10-050 Attachment 2 Docket 50-271


and 159 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, coolant, or exhaust gas leakage. March 21, 2012 BVY 06-009B.1.12.1 Audit Items 33, 150 & 155 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 3 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Related LRA Section No./
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                     IMPLEMENTATION   SOURCE     Related LRA Section No./
Comments10 Fire Water System Program procedures will be enhanced to specify that in accordance with NFPA 25 (2002 edition), Section 5.3.1.1.1, when sprinklers have been in place for 50 years a representative sample of sprinkler heads will be submitted to a recognized testing laboratory for field service testing. This sampling will be repeated every 10 years. March 21, 2012 BVY 06-009B.1.12.2 11 The Fire Water System Program will be enhanced to specify that wall thickness evaluations of fire protection piping will be performed on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections will be performed before the end of the current operating term and during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function. March 21, 2012 BVY 06-009 B.1.12.2 A udit Items 37 &
SCHEDULE Comments 10 Fire Water System Program procedures will be enhanced to specify that in         March 21, 2012 BVY 06-009 B.1.12.2 accordance with NFPA 25 (2002 edition), Section 5.3.1.1.1, when sprinklers have been in place for 50 years a representative sample of sprinkler heads will be submitted to a recognized testing laboratory for field service testing.
41 12 Implement the Heat Exchanger Monitoring Program as described in LRA Section B.1.14. March 21, 2012 BVY 06-009B.1.14 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 4 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Related LRA Section No./
This sampling will be repeated every 10 years.
Comments13 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.17. Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables will be performed at least once every two years.
11 The Fire Water System Program will be enhanced to specify that wall              March 21, 2012 BVY 06-009 B.1.12.2 thickness evaluations of fire protection piping will be performed on system Audit Items 37 &
components using non-intrusive techniques (e.g., volumetric testing) to 41 identify evidence of loss of material due to corrosion. These inspections will be performed before the end of the current operating term and during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.
12 Implement the Heat Exchanger Monitoring Program as described in LRA               March 21, 2012 BVY 06-009 B.1.14 Section B.1.14.
Page 3 of 12 BVY 10-050 Attachment 2 Docket 50-271
 
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                   IMPLEMENTATION   SOURCE     Related LRA Section No./
SCHEDULE Comments 13 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as             March 21, 2012 BVY 06-009 B.1.17 described in LRA Section B.1.17.
BVY 10-050 Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables will be performed at least once every two years.
Inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.
Inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.
March 21, 2012 BVY 06-009 BVY 10-050 B.1.17 14 Implement the Non-EQ Instrumentation Circuits Test Review Program as described in LRA Section B.1.18. March 21, 2012 BVY 06-009B.1.18 15 Implement the Non-EQ Insulated Cables and Connections Program as described in LRA Section B.1.19. March 21, 2012 BVY 06-009B.1.19 16 Implement the One-Time Inspection Program as described in LRA Section B.1.21. March 21, 2012 BVY 06-009 BVY 07-009 B.1.21 Audit Items 239, 240, 330, 331 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 06-009B.1.22 Audit Item 377 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 5 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE  Related LRA Section No./
14 Implement the Non-EQ Instrumentation Circuits Test Review Program as           March 21, 2012 BVY 06-009 B.1.18 described in LRA Section B.1.18.
Comments18 Enhance the Reactor Vessel Surveillance Program to proceduralize the data analysis, acceptance criteria, and corrective actions described in the program description in LRA Section B.1.24. March 21, 2012 BVY 06-009B.1.24 19 Implement the Selective Leaching Program as described in LRA Section B.1.25. March 21, 2012 BVY 06-009B.1.25 20 Enhance the Structures Monitoring Program to specify that process facility crane rails and girders, condensate storage tank (CST) enclosure, CO 2 tank enclosure, N 2 tank enclosure and restraining wall, CST pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man-way seals and gaskets, and hatch seals and gaskets are included in the program. March 21, 2012 BVY 06-009B.1.27.2 Audit Item 377 21 Guidance for performing structural examinations of wood to identify loss of material, cracking, and change in material properties will be added to the Structures Monitoring Program. March 21, 2012 BVY 06-009B.1.27.2 22 Guidance for performing structural examinations of elastomers (seals and gaskets) to identify cracking and change in material properties (cracking when manually flexed) will be enhanced in the Structures Monitoring Program procedure. March 21, 2012 BVY 06-009B.1.27.2 23 Guidance for performing structural examinations of PVC cooling tower fill to identify cracking and change in material properties will be added to the Structures Monitoring Program procedure. March 21, 2012 BVY 06-009B.1.27.2 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 6 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE  Related LRA Section No./
15 Implement the Non-EQ Insulated Cables and Connections Program as               March 21, 2012 BVY 06-009 B.1.19 described in LRA Section B.1.19.
Comments24 System walkdown guidance documents will be enhanced to perform periodic system engineer inspections of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject system will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(2). March 21, 2012 BVY 06-009B.1.28 A udit Items 187, 188 & 190 25 Implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in LRA Section
16 Implement the One-Time Inspection Program as described in LRA Section         March 21, 2012 BVY 06-009 B.1.21 B.1.21.
BVY 07-009 Audit Items 239, 240, 330, 331 17 Enhance the Periodic Surveillance and Preventive Maintenance Program to       March 21, 2012 BVY 06-009 B.1.22 assure that the effects of aging will be managed as described in LRA Audit Item 377 Section B.1.22.
Page 4 of 12 BVY 10-050 Attachment 2 Docket 50-271


B.1.29. March 21, 2012 BVY 06-009B.1.29 26 Procedures will be enhanced to flush the John Deere Diesel Generator cooling water system and replace the coolant and coolant conditioner every
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                  IMPLEMENTATION  SOURCE      Related LRA Section No./
SCHEDULE Comments 18 Enhance the Reactor Vessel Surveillance Program to proceduralize the          March 21, 2012 BVY 06-009 B.1.24 data analysis, acceptance criteria, and corrective actions described in the program description in LRA Section B.1.24.
19 Implement the Selective Leaching Program as described in LRA Section          March 21, 2012 BVY 06-009 B.1.25 B.1.25.
20 Enhance the Structures Monitoring Program to specify that process facility    March 21, 2012 BVY 06-009 B.1.27.2 crane rails and girders, condensate storage tank (CST) enclosure, CO2 Audit Item 377 tank enclosure, N2 tank enclosure and restraining wall, CST pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man-way seals and gaskets, and hatch seals and gaskets are included in the program.
21 Guidance for performing structural examinations of wood to identify loss of    March 21, 2012 BVY 06-009 B.1.27.2 material, cracking, and change in material properties will be added to the Structures Monitoring Program.
22 Guidance for performing structural examinations of elastomers (seals and      March 21, 2012 BVY 06-009 B.1.27.2 gaskets) to identify cracking and change in material properties (cracking when manually flexed) will be enhanced in the Structures Monitoring Program procedure.
23 Guidance for performing structural examinations of PVC cooling tower fill to  March 21, 2012 BVY 06-009 B.1.27.2 identify cracking and change in material properties will be added to the Structures Monitoring Program procedure.
Page 5 of 12 BVY 10-050 Attachment 2 Docket 50-271


three years. March 21, 2012 BVY 06-009B.1.30.1 A udit Items 84 &
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                 IMPLEMENTATION   SOURCE     Related LRA Section No./
164 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 7 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Related LRA Section No./
SCHEDULE Comments 24 System walkdown guidance documents will be enhanced to perform              March 21, 2012 BVY 06-009 B.1.28 periodic system engineer inspections of systems in scope and subject to Audit Items 187, aging management review for license renewal in accordance with 10 CFR 188 & 190 54.4 (a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject system will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(2).
Comments 27 At least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR-6260 for BWRs of the VY vintage, VY will refine our current fatigue analyses to include the effects of reactor water environment and verify that the cumulative usage factors (CUFs) are less than 1. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following: 1. For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the
25 Implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast    March 21, 2012 BVY 06-009 B.1.29 Austenitic Stainless Steel (CASS) Program as described in LRA Section B.1.29.
26 Procedures will be enhanced to flush the John Deere Diesel Generator        March 21, 2012 BVY 06-009 B.1.30.1 cooling water system and replace the coolant and coolant conditioner every Audit Items 84 &
three years.
164 Page 6 of 12 BVY 10-050 Attachment 2 Docket 50-271


existing CUF to determine the environmentally adjusted CUF. 2. More limiting VY-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations. 3. Representative CUF values from other plants, adjusted to or enveloping the VY plant specific external loads may be used if demonstrated applicable to VY. 4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                      IMPLEMENTATION        SOURCE    Related LRA Section No./
SCHEDULE Comments At least 2 years prior to entering the period of extended operation, for the 27                                                                                    March 21, 2012    BVY-06-058 4.3.3 locations identified in NUREG/CR-6260 for BWRs of the VY vintage, VY will refine our current fatigue analyses to include the effects of reactor water                                      Audit Items 29, environment and verify that the cumulative usage factors (CUFs) are less                                        107 & 318 March 21, 2010 for than 1. This includes applying the appropriate Fen factors to valid CUFs      performing a fatigue determined in accordance with one of the following:                            analysis that
: 1. For locations, including NUREG/CR-6260 locations, with existing          addresses the effects fatigue analysis valid for the period of extended operation, use the      of reactor coolant existing CUF to determine the environmentally adjusted CUF.               environment on
: 2. More limiting VY-specific locations with a valid CUF may be added in     fatigue (in accordance addition to the NUREG/CR-6260 locations.                                 with an NRC
: 3. Representative CUF values from other plants, adjusted to or               approved version of enveloping the VY plant specific external loads may be used if           the ASME Code) demonstrated applicable to VY.
: 4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.
During the period of extended operation, VY may also use one of the following options for fatigue management if ongoing monitoring indicates a potential for a condition outside the analysis bounds noted above:
During the period of extended operation, VY may also use one of the following options for fatigue management if ongoing monitoring indicates a potential for a condition outside the analysis bounds noted above:
: 1) Update and/or refine the affected analyses described above.
: 1) Update and/or refine the affected analyses described above.
: 2) Implement an inspection program that has been reviewed and approved by the NRC (e.g., periodic nondestructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC). 3) Repair or replace the affected locations before exceeding a CUF of 1.0. March 21, 2012 March 21, 2010 for performing a fatigue analysis that addresses the effects of reactor coolant environment on fatigue (in accordance with an NRC approved version of the ASME Code)  BVY-06-0584.3.3 Audit Items 29, 107 & 318 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 8 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE  Related LRA Section No./
: 2) Implement an inspection program that has been reviewed and approved by the NRC (e.g., periodic nondestructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC).
Comments28 Revise program procedures to indicate that the Instrument Air Program will maintain instrument air quality in accordance with ISA S7.3  March 21, 2012 BVY 06-009B.1.16 Audit Item 47 29 VYNPS will perform one of the following: 1. Install core plate wedges, or, 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 and analysis to the NRC two years prior to the period of extended operation for NRC review and approval. March 21, 2012 BVY 06-009B.1.7 Audit Item 9 30 Revise System Walkdown Program to specify CO2 system inspections every 6 months. March 21, 2012 BVY 06-009B.1.28 Audit Items 30, 141, 146 & 298 31 Revise Fire Water System Program to specify annual fire hydrant gasket inspections and flow tests. March 21, 2012 BVY 06-009B.1.12.2 A udit Items 39 &
: 3) Repair or replace the affected locations before exceeding a CUF of 1.0.
40 32 Implement the Metal Enclosed Bus Program. Details are provided in a LRA Amendment 16, Attachment 3 and LRA Amendment 23, 7. March 21, 2012 BVY 06-058 BVY 07-003 BVY 06-091 Audit Item 97 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 9 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE  Related LRA Section No./
Page 7 of 12 BVY 10-050 Attachment 2 Docket 50-271
Comments33 Include within the Structures Monitoring Program provisions that will ensure an engineering evaluation is made on a periodic basis (at least once every five years) of groundwater samples to assess aggressiveness of groundwater to concrete. Samples will be monitored for sulfates, pH and chlorides. March 21, 2012 BVY 06-009B.1.27 Audit Item 77 RAI 3.5-7 34 Implement the Bolting Integrity Program. Details are provided in a LRA Amendment 16, Attachment 2 and LRA Amendment 23, Attachment 5. March 21, 2012 BVY 06-058 BVY 07-003 BVY 06-091 A udit Items 198, 216, 218, 237, 331 & 333 35 Provide within the System Walkdown Training Program a process to document biennial refresher training of Engineers to demonstrate inclusion of the methodology for aging management of plant equipment as described in EPRI Aging Assessment Field Guide or comparable instructional guide. March 21, 2012 BVY 06-058Audit Item 384 36 If technology to inspect the hidden jet pump thermal sleeve and core spray thermal sleeve welds has not been developed and approved by the NRC at least two years prior to the period of extended operation, VYNPS will initiate plant-specific action to resolve this issue. That plant specific action may be justification that the welds do not require inspection. March 21, 2010 BVY06-058 Audit Item 12 37 Continue inspections in accordance with the Steam Dryer Monitoring Program, Revision 3 in the event that the BWRVIP-139 is not approved prior to the period of extended operation. March 21, 2010 BVY 06-079Audit Item 204 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 10 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE  Related LRA Section No./
Comments38 The BWRVIP-116 report which was approved by the Staff will be implemented at VYNPS with the conditions documented in Sections 3 and 4 of the Staffs final SE dated March 1, 2006, for the BWRVIP-116 report. March 21, 2012 BVY 06-088 Response to
 
RAI B.1.24-1 39 If the VYNPS standby capsule is removed form the reactor vessel without the intent to test it, the capsule will be stored in a manner which maintains it in a condition which would permit its future use, including during the period of extended operation, if necessary.
March 21, 2012 BVY 06-088 Response to


RAI B.1.24-2 40 This Commitment has been deleted and replaced with Commitment 43.
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                IMPLEMENTATION  SOURCE      Related LRA Section No./
N/A BVY 07-018N/A 41 This Commitment has been deleted and replaced with Commitment 43.
SCHEDULE Comments 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
N/A BVY 07-018N/A 42 Implement the Bolted Cable Connections Program. Details are provided in LRA Amendment 23, attachment 7. March 21, 2012 BVY 07-003 BVY 07-018 Response to:
: 1. Install core plate wedges, or,                                                                  Audit Item 9
RAI 3.6.2.2-N-01
: 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 and analysis to the NRC two years prior to the period of extended operation for NRC review and approval.
30 Revise System Walkdown Program to specify CO2 system inspections            March 21, 2012 BVY 06-009 B.1.28 every 6 months.
Audit Items 30, 141, 146 & 298 31 Revise Fire Water System Program to specify annual fire hydrant gasket      March 21, 2012 BVY 06-009 B.1.12.2 inspections and flow tests.
Audit Items 39 &
40 32 Implement the Metal Enclosed Bus Program.                                   March 21, 2012 BVY 06-058 Audit Item 97 Details are provided in a LRA Amendment 16, Attachment 3 and LRA                            BVY 07-003 Amendment 23, 7.
BVY 06-091 Page 8 of 12 BVY 10-050 Attachment 2 Docket 50-271


LRA Sections:
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                    IMPLEMENTATION  SOURCE      Related LRA Section No./
3.6.2.1 A.2.1.39
SCHEDULE Comments 33 Include within the Structures Monitoring Program provisions that will ensure    March 21, 2012 BVY 06-009 B.1.27 an engineering evaluation is made on a periodic basis (at least once every Audit Item 77 five years) of groundwater samples to assess aggressiveness of groundwater to concrete. Samples will be monitored for sulfates, pH and                                    RAI 3.5-7 chlorides.
34 Implement the Bolting Integrity Program.                                         March 21, 2012 BVY 06-058 Audit Items 198, 216, 218, 237, Details are provided in a LRA Amendment 16, Attachment 2 and LRA                                BVY 07-003 331 & 333 Amendment 23, Attachment 5.
BVY 06-091 35 Provide within the System Walkdown Training Program a process to                March 21, 2012 BVY 06-058 Audit Item 384 document biennial refresher training of Engineers to demonstrate inclusion of the methodology for aging management of plant equipment as described in EPRI Aging Assessment Field Guide or comparable instructional guide.
36 If technology to inspect the hidden jet pump thermal sleeve and core spray      March 21, 2010 BVY06-058 Audit Item 12 thermal sleeve welds has not been developed and approved by the NRC at least two years prior to the period of extended operation, VYNPS will initiate plant-specific action to resolve this issue. That plant specific action may be justification that the welds do not require inspection.
37 Continue inspections in accordance with the Steam Dryer Monitoring              March 21, 2010 BVY 06-079 Audit Item 204 Program, Revision 3 in the event that the BWRVIP-139 is not approved prior to the period of extended operation.
Page 9 of 12 BVY 10-050 Attachment 2 Docket 50-271


B.1.33 Table 3.6.1 Table 3.6.2-1 43 Establish and implement a program that will require testing of the two 13.8 kV cables from the two Vernon Hydro Station 13.8 kV switchgear buses to the 13.8 kV / 69 kV step up transformers before the period of extended operation and at least once every 10 years after the initial test.
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                      IMPLEMENTATION  SOURCE      Related LRA Section No./
March 21, 2012 BVY 07-009 BVY 07-018 Am. 24 Response to:
SCHEDULE Comments 38 The BWRVIP-116 report which was approved by the Staff will be                      March 21, 2012 BVY 06-088 Response to implemented at VYNPS with the conditions documented in Sections 3 and                                        RAI B.1.24-1 4 of the Staffs final SE dated March 1, 2006, for the BWRVIP-116 report.
39 If the VYNPS standby capsule is removed form the reactor vessel without            March 21, 2012 BVY 06-088 Response to the intent to test it, the capsule will be stored in a manner which maintains it                            RAI B.1.24-2 in a condition which would permit its future use, including during the period of extended operation, if necessary.
40 This Commitment has been deleted and replaced with Commitment 43.                      N/A      BVY 07-018        N/A 41 This Commitment has been deleted and replaced with Commitment 43.                      N/A      BVY 07-018        N/A 42 Implement the Bolted Cable Connections Program.                                    March 21, 2012 BVY 07-003 Response to:
RAI 3.6.2.2-N-01 Details are provided in LRA Amendment 23, attachment 7.                                          BVY 07-018 LRA Sections:
3.6.2.1 A.2.1.39 B.1.33 Table 3.6.1 Table 3.6.2-1 43 Establish and implement a program that will require testing of the two 13.8       March 21, 2012 BVY 07-009 Am. 24 kV cables from the two Vernon Hydro Station 13.8 kV switchgear buses to                                     Response to:
BVY 07-018 the 13.8 kV / 69 kV step up transformers before the period of extended                                       RAIs operation and at least once every 10 years after the initial test.
3.6.2.2-N-08-2 3.6.2.2-N-08-4 Page 10 of 12 BVY 10-050 Attachment 2 Docket 50-271


RAIs  3.6.2.2-N-08-2 3.6.2.2-N-08-4 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 11 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Related LRA Section No./
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                                 IMPLEMENTATION   SOURCE     Related LRA Section No./
Comments44 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. March 21, 2012 BVY 07-018Regional inspection 45 Enhance the Service Water Integrity Program to require a periodic visual inspection of the RHRSW pump motor cooling coil internal surface for loss of material. March 21, 2012 BVY 07-018Regional inspection 46 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the fire pump diesel storage (day) tank will be analyzed according to ASTM D975-02 and for particulates per ASTM D2276. Also, fuel oil in the John Deere diesel storage tank will be analyzed for particulates per ASTM D2276. March 21, 2012 BVY 07-018Regional inspection 47 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the common portable fuel oil storage tank will be analyzed according to ASTM D975-02, per ASTM D2276 for particulates, and ASTM D1796 for water  
SCHEDULE Comments 44 Guidance for performing examinations of buried piping will be revised to     March 21, 2012 BVY 07-018 Regional include the following. A focused inspection will be performed within the                               inspection 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.
45 Enhance the Service Water Integrity Program to require a periodic visual     March 21, 2012 BVY 07-018 Regional inspection of the RHRSW pump motor cooling coil internal surface for loss                               inspection of material.
46 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the   March 21, 2012 BVY 07-018 Regional fire pump diesel storage (day) tank will be analyzed according to ASTM                                 inspection D975-02 and for particulates per ASTM D2276. Also, fuel oil in the John Deere diesel storage tank will be analyzed for particulates per ASTM D2276.
47 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the   March 21, 2012 BVY 07-018 Regional common portable fuel oil storage tank will be analyzed according to ASTM                               inspection D975-02, per ASTM D2276 for particulates, and ASTM D1796 for water and sediment.
48 Perform an internal inspection of the underground Service Water piping        March 21, 2012 BVY 07-018 Regional before entering the period of extended operation.                                                      inspection 49 Revise station procedures to specify fire hydrant hose testing, inspection,  March 21, 2012 BVY 07-009 Audit Item 38 and replacement, if necessary, in accordance with NFPA code specifications for fire hydrant hoses.
Page 11 of 12 BVY 10-050 Attachment 2 Docket 50-271


and sediment. March 21, 2012 BVY 07-018Regional inspection 48 Perform an internal inspection of the underground Service Water piping before entering the period of extended operation.
VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT                                                               IMPLEMENTATION   SOURCE     Related LRA Section No./
March 21, 2012 BVY 07-018Regional inspection 49 Revise station procedures to specify fire hydrant hose testing, inspection, and replacement, if necessary, in accordance with NFPA code specifications for fire hydrant hoses. March 21, 2012 BVY 07-009Audit Item 38 VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 Page 12 of 12 BVY 10-050 Docket 50-271 ITEM COMMITMENT IMPLEMENTATION SCHEDULE SOURCE Related LRA Section No./
SCHEDULE Comments 50 During the period of extended operation, review the Vernon Dam owner       March 21, 2012 BVY 06-009 RAI FERC required report(s) at a minimum of every five years to confirm that BVY 07-047 3.6.2.2.N-08-1 the Vernon Dam owner is performing the required FERC inspections.
Comments50 During the period of extended operation, review the Vernon Dam owner FERC required report(s) at a minimum of every five years to confirm that the Vernon Dam owner is performing the required FERC inspections. Document deficiencies in the Entergy Corrective Actions Program and evaluate operability as described in BVY 96-043 and BVY 97-043 if it is determined that the required inspections are not being performed. March 21, 2012 BVY 06-009 BVY 07-047 RAI 3.6.2.2.N-08-1 51 Entergy will perform an evaluation of operating experience at extended power uprate (EPU) levels prior to the period of extended operation to ensure that operating experience at EPU levels is properly addressed by the aging management programs. The evaluation will include Vermont Yankee (VY) and other BWR plants operating at EPU levels.
Document deficiencies in the Entergy Corrective Actions Program and evaluate operability as described in BVY 96-043 and BVY 97-043 if it is determined that the required inspections are not being performed.
March 21, 2012 BVY 08-008 N/A}}
Entergy will perform an evaluation of operating experience at extended 51 power uprate (EPU) levels prior to the period of extended operation to     March 21, 2012 BVY 08-008      N/A ensure that operating experience at EPU levels is properly addressed by the aging management programs. The evaluation will include Vermont Yankee (VY) and other BWR plants operating at EPU levels.
Page 12 of 12 BVY 10-050 Attachment 2 Docket 50-271}}

Latest revision as of 14:40, 13 November 2019

License Renewal Application Supplemental Information
ML102500065
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 09/03/2010
From: Michael Colomb
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 10-050
Download: ML102500065 (19)
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    • ~Entergy Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd Vernon. VT 05354 Tel 802 257 7711 Michael J Colomb Site Vice President September 3, 2010 BVY 10-050 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

License Renewal Application Supplemental Information Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. Letter, Entergy to USNRC, Vermont Yankee Nuclear Power Station, License No. DPR-28, License Renewal Application," BVY 06-09, dated January 25, 2006.

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.

This letter provides supplemental information to the LRA to address issues that have been discussed in industry correspondence concerning the possibility of non-EO inaccessible cables failing in the presence of water intrusion. Entergy has completed a review of relevant operating experience and addressed it as discussed in Attachment 1 of this letter.

New regulatory commitments to implement related aging management activities have been entered into the VYNPS License Renewal Commitment List, Revision 10 (Attachment 2).

Should you have any questions or require additional information concerning this submittal, please contact Mr. Robert Wanczyk at 802-451-3166.

I declare under penalty of perjury, that the foregoing is true and correct.

Executed on September 3, 2010.

Sincerely,

[MJC/PLC)

BVY 10-050 / Page 2 of 2 Attachments: 1. License Renewal Application Supplemental Information

2. License Renewal Commitment List, Revision 10 cc: Mr. Eric J. Leeds, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 Mr. William Dean, Regional Administrator U.S. Nuclear Regulatory Commission, Region 1 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Robert Kuntz, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11F1 11555 Rockville Pike Rockville, MD 20852-2738 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. David OBrien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 10-050 Attachment 1 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

License Renewal Application Supplemental Information

BVY 10-0xx / Attachment 1 / Page 1 of 3 Vermont Yankee Nuclear Power Station License Renewal Application - Supplemental Information

Background

Due to industry correspondence regarding inaccessible cables, Vermont Yankee Nuclear Power Station (VYNPS) is providing the following information enhancing its aging management program for non-EQ inaccessible medium-voltage cables to include low-voltage (480 V to 2 kV) cables.

The NRC staff has concluded that inaccessible low-voltage cables (480 V to 2 kV cables that are subject to aging management review for license renewal) potentially exposed to significant moisture should be included in an aging management program (AMP) specifically to address the effects of moisture on the cables.

VYNPS responded to Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients in a letter dated April 30, 2007 (ADAMS Accession Number ML071290055). In the letter, VYNPS reported that no failures were found during a review of plant operating experience involving low-voltage inaccessible cables.

VYNPS operating experience since the response to GL 2007-01 on April 30, 2007 until August 25, 2010 was researched in the Corrective Action Program database. VYNPS has experienced no age-related failures of inaccessible low-voltage cables that are subject to aging management review subsequent to the response to GL 2007-01.

VYNPS has also reviewed the information provided in the industry responses to GL 2007-01, recent NRC and Electric Power Research Institute guidance documents, and recent industry/NRC meetings on this topic. In light of the NRC Staffs conclusion, VYNPS is expanding the scope of the B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) aging management program to include in-scope, inaccessible, low-voltage cables.

VYNPS Revision to Inaccessible Cable Program VYNPS will expand the scope of the program described in License Renewal Application (LRA)

Section B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) to include inaccessible low-voltage (480 V to 2kV) cables that are subject to aging management review. The parameters monitored or inspected, as required by the program, are changed to include inaccessible low-voltage cables that are subject to aging management review. Inaccessible low-voltage (480 V to 2kV) cables will be tested for degradation of the cable insulation at least once every 10 years.

Inspections for water in manholes containing in-scope inaccessible low-voltage (480 V to 2kV) cables will be performed at least once every two years. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables (480 V to 2 kV) potentially exposed to significant moisture.

In addition, LRA Sections A.2.1.19 (Non-EQ Inaccessible Medium-Voltage Cable Program) and B.1.17 (Non-EQ Inaccessible Medium-Voltage Cable) are revised to delete the criterion of exposure to significant voltage (system voltage for more than 25% of the time) associated with in-scope inaccessible medium-voltage (2 kV to 35 kV) cables. Section B.1.17 is revised to note that the VYNPS Non-EQ Inaccessible Medium-Voltage Cable Program will be based on and consistent with the program described in NUREG-1801,Section XI.E3.

BVY 10-050 / Attachment 1 / Page 2 of 3 The changes are presented as strikeout text deleted, and underlined text added.

A.2.1.19 Non-EQ Inaccessible Medium-Voltage Cable Program In the Non-EQ Inaccessible Medium-Voltage Cable Program, in-scope medium-voltage cables, not designed for, but exposed to significant moisture and voltage are tested at least once every ten years to provide an indication of the condition of the conductor insulation. The specific test performed is a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, polarization index, or other testing that is state-of-the-art at the time the test is performed.

Significant moisture is defined as periodic exposures that last more than a few days.

Significant voltage exposure is defined as being subjected to system voltage for more than 25% of the time.

Inspections for water collection in cable manholes and conduit containing in-scope inaccessible low-voltage and medium-voltage cables will occur at least once every two years.

Inaccessible low-voltage cables (cables with operating voltage from 480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables potentially exposed to significant moisture.

B.1.17 Non-EQ Inaccessible Medium-Voltage Cable Program Description The Non-EQ Inaccessible Medium-Voltage Cable Program at VYNPS will be based on and consistent with comparable to the program described in NUREG-1801,Section XI.E3, Inaccessible Medium-voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

VYNPS inspection for water accumulation in manholes is conducted in accordance with a plant procedure. An evaluation per the Corrective Action Process will be used to determine the need to revise manhole inspection frequency based on inspection results.

Medium voltage cables include cables with operating voltage level from 2kV to 35kV. Low-voltage cables include cables with operating voltage ranging from 480 V to 2 kV.

In this program, periodic actions will be taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. In scope medium-voltage cables exposed to significant moisture and voltage will be tested to provide an indication of the condition of the conductor insulation. The specific type of test to be performed will be determined prior to the initial test and is to be a proven test for detecting deterioration of the insulation system due to wetting as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed.

Inaccessible low-voltage cables (cables with operating voltage from 480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended

BVY 10-0xx / Attachment 1 / Page 3 of 3 operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration of the insulation system for inaccessible low-voltage cables potentially exposed to significant moisture.

The program will be initiated prior to the period of extended operation.

NUREG-1801 Consistency The program attributes of the Non-EQ Inaccessible Medium-Voltage Cable Program at VYNPS will be consistent with the program attributes described in NUREG-1801,Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

Exceptions to NUREG-1801 None.

Enhancements None This program includes inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review.

Operating Experience This The program is a new aging management program based on the program description in NUREG-1801, which in turn is based on relevant industry operating experience. As such, this program will provide reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation. As additional operating experience is obtained, lessons learned can be used to adjust the program, as needed.

Commitment License renewal commitment #13 is revised to augment the aging management program for Non-EQ Inaccessible Medium-Voltage Cables (underlined text is added):

Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.17.

Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables will be performed at least once every two years.

Inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.

BVY 10-050 Attachment 2 Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

License Renewal Application License Renewal Commitment List Revision 10

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 During the development and review of the Vermont Yankee Nuclear Power Station License Renewal Application, Entergy made commitments to provide aging management programs to manage the effects of aging on structures and components during the extended period of operation. The following table lists these license renewal commitments, along with the implementation schedule and the source of the commitment.

ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE Comments 1 Guidance for performing examinations of buried piping will be enhanced to March 21, 2012 BVY 06-009 B.1.1 specify that coating degradation and corrosion are attributes to be Audit Items 5 &

evaluated.

130 2 Fifteen (15) percent of the top guide locations will be inspected using As stated in the BVY 06-009 B.1.7 enhanced visual inspection technique, EVT-1, within the first 18 years of commitment Audit Item 14 the period of extended operation, with at least one-third of the inspections to be completed within the first 6 years and at least two-thirds within the first 12 years of the period of extended operation. Locations selected for examination will be areas that have exceeded the neutron fluence threshold.

3 The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonic March 21, 2012 BVY 06-009 B.1.9 and thickness measurement of the fuel oil storage and fire pump diesel storage BVY 07-018 regional (day) tank bottom surfaces will be performed every 10 years during tank inspection cleaning and inspection.

4 The Diesel Fuel Monitoring Program will be enhanced to specify UT March 21, 2012 BVY 06-009 B.1.9 and measurements of the fuel oil storage and fire pump diesel storage (day) BVY 07-018 regional tank bottom surfaces will have acceptance criterion  60% Tnom. inspection Page 1 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

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

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

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

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

151, 152, 153 and 159 9 Procedures will be enhanced to state that the diesel engine sub-systems March 21, 2012 BVY 06-009 B.1.12.1 (including the fuel supply line) will be observed while the pump is running.

Audit Items 33, Acceptance criteria will be enhanced to verify that the diesel engine did not 150 & 155 exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.

Page 2 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

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

This sampling will be repeated every 10 years.

11 The Fire Water System Program will be enhanced to specify that wall March 21, 2012 BVY 06-009 B.1.12.2 thickness evaluations of fire protection piping will be performed on system Audit Items 37 &

components using non-intrusive techniques (e.g., volumetric testing) to 41 identify evidence of loss of material due to corrosion. These inspections will be performed before the end of the current operating term and during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

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

Page 3 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

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

BVY 10-050 Inspections for water accumulation in manholes containing in-scope inaccessible low-voltage and medium-voltage cables will be performed at least once every two years.

Inaccessible low-voltage cables (480 V to 2 kV) that are subject to aging management review are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every 10 years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.

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

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

16 Implement the One-Time Inspection Program as described in LRA Section March 21, 2012 BVY 06-009 B.1.21 B.1.21.

BVY 07-009 Audit Items 239, 240, 330, 331 17 Enhance the Periodic Surveillance and Preventive Maintenance Program to March 21, 2012 BVY 06-009 B.1.22 assure that the effects of aging will be managed as described in LRA Audit Item 377 Section B.1.22.

Page 4 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

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

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

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

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

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

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

Page 5 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

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

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

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

three years.

164 Page 6 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE Comments At least 2 years prior to entering the period of extended operation, for the 27 March 21, 2012 BVY-06-058 4.3.3 locations identified in NUREG/CR-6260 for BWRs of the VY vintage, VY will refine our current fatigue analyses to include the effects of reactor water Audit Items 29, environment and verify that the cumulative usage factors (CUFs) are less 107 & 318 March 21, 2010 for than 1. This includes applying the appropriate Fen factors to valid CUFs performing a fatigue determined in accordance with one of the following: analysis that

1. For locations, including NUREG/CR-6260 locations, with existing addresses the effects fatigue analysis valid for the period of extended operation, use the of reactor coolant existing CUF to determine the environmentally adjusted CUF. environment on
2. More limiting VY-specific locations with a valid CUF may be added in fatigue (in accordance addition to the NUREG/CR-6260 locations. with an NRC
3. Representative CUF values from other plants, adjusted to or approved version of enveloping the VY plant specific external loads may be used if the ASME Code) demonstrated applicable to VY.
4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.

During the period of extended operation, VY may also use one of the following options for fatigue management if ongoing monitoring indicates a potential for a condition outside the analysis bounds noted above:

1) Update and/or refine the affected analyses described above.
2) Implement an inspection program that has been reviewed and approved by the NRC (e.g., periodic nondestructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC).
3) Repair or replace the affected locations before exceeding a CUF of 1.0.

Page 7 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE Comments 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

1. Install core plate wedges, or, Audit 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 and analysis to the NRC two years prior to the period of extended operation for NRC review and approval.

30 Revise System Walkdown Program to specify CO2 system inspections March 21, 2012 BVY 06-009 B.1.28 every 6 months.

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

Audit Items 39 &

40 32 Implement the Metal Enclosed Bus Program. March 21, 2012 BVY 06-058 Audit Item 97 Details are provided in a LRA Amendment 16, Attachment 3 and LRA BVY 07-003 Amendment 23, 7.

BVY 06-091 Page 8 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

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

34 Implement the Bolting Integrity Program. March 21, 2012 BVY 06-058 Audit Items 198, 216, 218, 237, Details are provided in a LRA Amendment 16, Attachment 2 and LRA BVY 07-003 331 & 333 Amendment 23, Attachment 5.

BVY 06-091 35 Provide within the System Walkdown Training Program a process to March 21, 2012 BVY 06-058 Audit Item 384 document biennial refresher training of Engineers to demonstrate inclusion of the methodology for aging management of plant equipment as described in EPRI Aging Assessment Field Guide or comparable instructional guide.

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

37 Continue inspections in accordance with the Steam Dryer Monitoring March 21, 2010 BVY 06-079 Audit Item 204 Program, Revision 3 in the event that the BWRVIP-139 is not approved prior to the period of extended operation.

Page 9 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE Comments 38 The BWRVIP-116 report which was approved by the Staff will be March 21, 2012 BVY 06-088 Response to implemented at VYNPS with the conditions documented in Sections 3 and RAI B.1.24-1 4 of the Staffs final SE dated March 1, 2006, for the BWRVIP-116 report.

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

40 This Commitment has been deleted and replaced with Commitment 43. N/A BVY 07-018 N/A 41 This Commitment has been deleted and replaced with Commitment 43. N/A BVY 07-018 N/A 42 Implement the Bolted Cable Connections Program. March 21, 2012 BVY 07-003 Response to:

RAI 3.6.2.2-N-01 Details are provided in LRA Amendment 23, attachment 7. BVY 07-018 LRA Sections:

3.6.2.1 A.2.1.39 B.1.33 Table 3.6.1 Table 3.6.2-1 43 Establish and implement a program that will require testing of the two 13.8 March 21, 2012 BVY 07-009 Am. 24 kV cables from the two Vernon Hydro Station 13.8 kV switchgear buses to Response to:

BVY 07-018 the 13.8 kV / 69 kV step up transformers before the period of extended RAIs operation and at least once every 10 years after the initial test.

3.6.2.2-N-08-2 3.6.2.2-N-08-4 Page 10 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE Comments 44 Guidance for performing examinations of buried piping will be revised to March 21, 2012 BVY 07-018 Regional include the following. A focused inspection will be performed within the inspection 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.

45 Enhance the Service Water Integrity Program to require a periodic visual March 21, 2012 BVY 07-018 Regional inspection of the RHRSW pump motor cooling coil internal surface for loss inspection of material.

46 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the March 21, 2012 BVY 07-018 Regional fire pump diesel storage (day) tank will be analyzed according to ASTM inspection D975-02 and for particulates per ASTM D2276. Also, fuel oil in the John Deere diesel storage tank will be analyzed for particulates per ASTM D2276.

47 Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the March 21, 2012 BVY 07-018 Regional common portable fuel oil storage tank will be analyzed according to ASTM inspection D975-02, per ASTM D2276 for particulates, and ASTM D1796 for water and sediment.

48 Perform an internal inspection of the underground Service Water piping March 21, 2012 BVY 07-018 Regional before entering the period of extended operation. inspection 49 Revise station procedures to specify fire hydrant hose testing, inspection, March 21, 2012 BVY 07-009 Audit Item 38 and replacement, if necessary, in accordance with NFPA code specifications for fire hydrant hoses.

Page 11 of 12 BVY 10-050 Attachment 2 Docket 50-271

VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL COMMITMENT LIST REVISION 10 ITEM COMMITMENT IMPLEMENTATION SOURCE Related LRA Section No./

SCHEDULE Comments 50 During the period of extended operation, review the Vernon Dam owner March 21, 2012 BVY 06-009 RAI FERC required report(s) at a minimum of every five years to confirm that BVY 07-047 3.6.2.2.N-08-1 the Vernon Dam owner is performing the required FERC inspections.

Document deficiencies in the Entergy Corrective Actions Program and evaluate operability as described in BVY 96-043 and BVY 97-043 if it is determined that the required inspections are not being performed.

Entergy will perform an evaluation of operating experience at extended 51 power uprate (EPU) levels prior to the period of extended operation to March 21, 2012 BVY 08-008 N/A ensure that operating experience at EPU levels is properly addressed by the aging management programs. The evaluation will include Vermont Yankee (VY) and other BWR plants operating at EPU levels.

Page 12 of 12 BVY 10-050 Attachment 2 Docket 50-271

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