ML062480082

Email: (PA) VY Lrd - Base 98-99

ML062480082
Person / Time
Site:	Vermont Yankee
Issue date:	06/06/2006
From:	Hamer M Entergy Corp
To:	Rowley J NRC/NRR/ADRO
References
%dam200611, TAC MD2297
Download: ML062480082 (27)

Text

Kent Howard - VY LR D-Base 98-199 _ age1 From: "Hamer, Mike" <mhamer@entergy.com>

To: <jgr@nrc.gov>

Date: 6/6/2006 2:10:04 PM

Subject:

VY LR D-Base 98-199

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c:\temp\GW}OOOO1 .TMP Mail Envelope Properties (4485C4E7.90C :20:10508)

Subject:

VY LR D-Base 98-199 Creation Date 6/6/2006 2:09:05 PM From: "Hamer, Mike" <mhamer@entergy.com>

Created By: mhamer@entergy.com Recipients nrc.gov TWGWPO03.HQGWDO01 JGR (Jonathan Rowley)

Post Office Route TWGWPO03.HQGWDOO1 nrc.gov Files Size Date & Time VY LR D-Base 98-199 on 06-06-2006.pdf 1487275 Mime.822 2036874 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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98 Category Open Request 3.6.2.2-N-08 10 CFR 54.4 (a)(3) requires, In part, that all systems, structures, and components (SSCs) relied on In safety analyses or plant evaluation to perform a function that demonstrates compliance with the commission's regulations for station black out (10 CFR 50.63) are within the scope of license renewal. Vernon Hydroelectric Station has been designated as the Station Blackout (SBO) alternate ac (AAC) source and Is used to meet SBO requirements 10 CFR 50.63. Are all SSCs (including electrical components) associated with Vernon Hydroelectric Station Included In the scope of licensee renewal? Ifthey are not, explain why not. Ifthey are, provide an AMR for long-lived, passive SSCs associated with the hydro station.

Response The long-lived, passive components from the Vernon dam switchyard to the plant are Inscope and subject to AMR. The underground cables and connections are Included In E2. The Vernon Dam Is regulated by FERC and Inspected per FERC regulations.

99 Category Closed Request B.1.27.3-W-03 Are there any other license renewal Intended functions other than SBO, associated with the Vernon Dam?

Response Vernon Dam Is used for hydro-electric generation and is the alternate AC source of power for VYNPS. The deep basin beneath the west cooling tower Is a safety-related, reinforced concrete structure constructed on bedrock. The basin acts as a reservoir to replace the evaporative and other losses occurring during alternate cooling system (ACS) operation, providing a one-week supply of makeup for the alternate cooling cell Inthe event of a loss of Vernon Dam. The Vernon dam has no other Intended functions for (10CFR54.4(a)(1) or (a)(2). The Vernon dam Is credited for station blackout (IOCFR50.63), Intended function.

e 100 Cate-orv Closed Reauest The NRC requested additional Information on Ilcenslng renewal, specifically on how aging management applied to passive components In the Vernon Hydroelectric Station.

Response The requested Information was provided to the NRC during the onsite review. In addition a FERC Inspection r~port was provided for the dam and NPCC Document A-3, Emergency Operational Criteria. The NRC requested additional Information on underground cables, buried piping and support systems.

101 Category Closed Request B.1.30.3.M.04 GALL X1.M21 discusses pump and heat exchanger testing In the parameters monitored / Inspected attribute. Is this testing part of the Water Chemistry Control -

Closed Cooling Water Program?

Response LRA Section B.1.30.3 includes an exception to the performance and functional testing discussed In the detection of aging effects attribute. This exception and its justification are equally applicable to the parameters monitored I trended attribute.

102 Category Closed Request B.1.9-K-11 Please provide a copy of QA Surveillance 99-010 and more recent QA surveiliance of Diesel Fuel Monitoring Program.

Response Provided QA Surveillance 99-010, OA Audit Report QA-2-2005-VY-1 and CR-VTY-2005-00196.

......................................... ~...*..............

103 Category Closed Request B.1.9-K-12 Please Identify sample point locations on John Deere diesel and diesel fire pump oil storage tanks. (Diesel Fuel Monitoring Program)

Response Provided Section 5 of OP2106 Rev. 18, App. DJD Diesel day tank sample location Is at the bottom of this tank. Fire pump diesel fuel supply &sample point are 2 Inches from the bottom of the diesel fire pump fuel tank.

104 Category Closed Request B.1.9-K-13 Please provide 2000 and 2003 sample results spreadsheet. Also sample lab results for main storage tank and EDG day tanks are desired. (Diesel Fuel Monitoring Program)

Response This Information has been provided via spreadsheet of monthly analysis data for the Main Fuel Oil Storage Tank for 2000 and 2003. Also, provided example analysis results for samples from the Walpole NH supplier tank, the John Deere diesel storage tank, the diesel fire pump storage tank, and the EDG day tanks 105 Category Closed Request B.1.30.3-M-05 Please provide a copy of recent third party assessment of the water chemistry control - closed cooling water program.

Response Third party assessment of 'Chemistry' on May 6, 2003 provided for review. Summary states that closed cooling water systems are monitored and treated to provide a chemical environment that minimizes corrosion rates.

106 Category Closed Request 5.1.2.3-M-04 The Reactor Vessel Stud Program takes exception to GALL based on relief request ISI-03. The NRC does not believe this should be an exception.

Review the relief request and ASME code. Ifthis is not an exception, revise the program document.

Response The existing examinations for the reactor vessel closure studs (Category B-G-2) are based on ASME Code Case N-652. Code Case N-652 has been endorsed by the NRC per Table 1 of Regulatory Guide 1.147, Revision 14. As this Code Case Is now endorsed, this Inspection is no longer an exception to GALL. The LRA Supplement Letter will revoke this GALL exception.

107 Category Accepted Request The commitment to manage locations CUF>1.0 should be on a numbered commitment list.

The commitment to analyze the limiting location for environmentally assisted fatigue should be on a numbered commitment list.

NOTE: The commitment Is In section 4 (4.3.3.?) not In App. B Response License renewal commitment #27 has been prepared, to address the above items.

108 Category Closed Request Identify the site specific calculations for core plate hold down bolt preload.

Response No site specific calculation Was found Inthe VYNPS current licensing basis for the number I preload of the core plate hold-down bolts required to prevent lateral motion of the core plate.

109 Category Closed Request Accurately state / describe the Inrformation / documentation requested. Be as specific as possible. The NRC requested a copy of the Vernon hydro-drawing.

Not an NRC question. Close Item.

Response This Information was provided during the onsite review.

110 Category Closed Request The NRC Inspector had a one-line diagram and asked Ifbus duct was used for the Immediate access source or the delayed access source. The inspector was Interested Ifan AMR applied to either source for segregated or non-segregated bus, if used.

Not an NRC question. Close item.

Response Immediate assess: The cables are used from the startup transformers to the 4 KV buses and overhead 115 KV bare cable Is used to supply the transformers with bus above the transformers.

Delayed Access: there Is Isophase bus duct used on the back-feed for the 22 KV system and It connects to the auxiliary transformer.

111 Category Closed Request. Please provide results of the last Inspection of the welds between the rerouted CRD return line and the RWCU system. (BWR CRD Return Une Nozzle Program)

Response Provided results of 1985 Inspection 112 CategOry Closed Request Please provide documentation related to resolution of vessel clad cracking.

Response Provided documentation as requested during NRC interview.

113 Cate-gory Closed Request The BWR penetrations program second exception allows a smaller Inspection than the code (1/2" vs. 1/2" vessel wall thickness). What Is the basis for this?

Response The Inspection of the vessel penetrations tol/2! versus 1/2T was approved via Relief Request ISI-09. This relief request Is Inturn based on ASME Code Case N-613-1. Code case N-613-1 has been endorsed by the NRC per Table 1 of Regulatory Guide 1.147, Revision 14, August 2005..

This Is conservatively Identified in the BWR Penetrations Program descrIption as an exception to GALL because Itrequired relief to the existing code requirements.

114 Category Closed Request Do the VY penetration nozzles have a bored (cold worked) safe end extension?

Ifyes, they require additional Inspection.

Response This question was erroneously applied to the vessel Instrumentation nozzles. BWRVIP-49-A requires no additional Inspection requirements for cold worked safe ends for the Instrumentation nozzles.

The question should have been directed at the SLC/DP nozzle, for which the discussion of cold worked safe ends Is found In the BWRVIP-27-A Inspection guideline 3.4.1. Per drawing 5920-52666 RO Implementing the Inspection guidelines of BWRVIP-27-A as applicable to VY, but that does not Include the entire safe end extension examination required of those plants with cold worked safe ends.

115 Cateaorv Closed Request Accurately state I describe the Information / documentation requested. Be as specific as possible.

LRPD-05 section 4.4.1 second paragraph states that the BWR CRD Return Line Nozzle program provides reasonable assurance. Should this have been the Buried Piping Inspection Program?

Response Yes, this Is a typographical error and Itshould have said that the Buried Piping Inspection Program provides reasonable assurance that the effects of aging will be managed such that the current licensing basis for the period of extended operation. This Item has been addressed through revision of LRPD-05.

116 Categorv Closed Request B.1.17-N-04 GALL X1.E3 under program description states, in part, that periodic actions such as Inspecting for water collection In cable manholes, and draining water, as needed to prevent cables from being exposed to significant moisture. The above actions are not sufficient to assure water Is not trapped elsewhere in the raceways. In addition to the above periodic actions, In scope, medium voltage cables are tested to provide an Indication of the condition of the conductor Insulation. VYNPS AMP B.1.17 under same element states that periodic actions will be taken to prevent cables from being exposed to significant moisture, such as Inspecting for water collection in cable manholes and draining water, as needed. In-scope medium-voltage exposed to significant moisture and voltage will be tested to provide an Indication of the condition of the conductor Insulation. It Is not clear to the NRC Ifyou Intend to use these periodic actions to preclude cable testing. Ifthis is the case, provide a technical justification of why removing water In the cable manholes will provide assurance that water Is not present elsewhere In the conduits or duct banks. Ifthis Is not the case, revise your AMP as appropriate to requires both testing and Inspecting water accumulation In the Response The Intent of the VY AMP B.1.17 Is to Inspect for water In manholes and to test the In-scope medium-voltage cables.

117 Category Closed Request B.l.17-N-05 GALL XI.E3 recommends testing all In-scope Inaccessible medium-voltage cables. Are all Inaccessible medium-voltage cables within the scope of license renewal tested?

Response Yes, all of the In-scope medium-voltage cables will be subject to testing per the program requirements.

1ý.. 7.

118 Cateiory Accepted Request B.1.17-N-06 GALL X1..E3 under parameters monitored/Inspected states that the specific type of test 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 such as power factor, partial discharge test, or polarization Index, as described In EPRI TR-103834-PI-2, or other testing that is state-of-the-art at the time the test Is performed. VYNPS B.1.17 under the same attribute only states that the specific type of test performed will be determined prior to Initial test. Revise your AMP to be consistent with GALL or explain how do you ensure that the test to be performed will be In accordance with Industrial guideline or that Is the state-of-the-art at the time the test is performed.

Response LRA Appendix B.1.17 will be revised to state that 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-PI-2, or other testing that Is state-of-the-art at the time the test Is performed.

This requires an amendment to the LRA.

119 Category Closed Request B.1.17-N-07 Do you currently Inspect water In the man holes. Are there any existing procedures for Inspecting man holes. Provide a copy of these procedures.

Response Yes, the manholes are Inspected on an annual basis. An example was provided during the onsite Inspection 120 Category Accepted Request B.1.17-N-08 GALL X1.E3 defines medium-voltage cable Is the voltage level from 2kV to 35kV VYNPS AMP B.1.17 defines medium-voltage cable Is the voltage level from 2kV to 15kV. Revise the scope of the Inaccessible medium - voltage level to be consistent with GALL or provide a technical Justification that why the water tree phenomenon Is not applicable to voltage level greater than 15kV. Are there any Inaccessible medium - voltage cables within the scope of licensee that are greater than 15kV. Are there any Inaccessible medium - voltage cables within the scope of licensee that are Response VY does not have any medium-voltage cable In-scope that Is greater than 15KV. LRA Appendix B.1.17 will define medium-voltage cable as voltage level from 2kV to 35kV.

This requires an amendment to the LRA.

121 Category Closed Request B.1.18-N-03 GALL XI.E2 under corrective actions states that such an evaluation Is to consider the significance of the test results, the operability of the component, the reportability of the event, the extend of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective actions required, and likelihood of recurrence In addition to 10 CFR Part 50, Appendix B. VYNPSB.1.18 under the same element only refers to 10 CFR Part 50 Appendix B to address corrective actions. Revise your AMP corrective actions to be consistent with GALL or provide a justification of why such specific corrective actions are not Response VYNPS B.1.18 AMP under corrective actions states that 'an engineering evaluation will be performed when the test acceptance criteria are not met Inorder to ensure that the Intended functions of the electrical cables can be maintained consistent with the current ilcensing basis. This evaluation Is performed in accordance with the Entergy corrective action process per procedure EN-LI-1 02. This procedure provides the stated elements to consider Including the extent of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective actions required, and likelihood of recurrence. See procedure details below:.

Adverse Condition - An event, defect, characteristic, state or activity that prohibits or detracts from safe, efficient nuclear plant operation or a condition that could credibly Impact nuclear safety, personnel safety, plant reliability or non-conformance with federal, state, or local regulations. Adverse conditions Include non-conformances, conditions adverse to quality and plant reliability concerns Operability Evaluation - A written evaluation of a Condition Report, to determine Impact of the Identified condition on the operability of structures, systems or components. The operability evaluation Includes a determination for reportability.

Extent of Condition - An evaluation to Identify the total population of Items that have or may have the same problem as Identified Inthe original CR problem statement The Intent of the Extent of Condition review focuses on a determination of any potential Impact to the operability/functionality of similar components, equipment, systems, human performance traps/Issues, or organizational processes/programs.

Root Cause - The most basic cause(s) for a failure or a condition that, Ifcorrected or eliminated, will preclude repetition of the event or condition.

Corrective Action - Corrective actions Include actions Intended to preclude repetition of significant conditions and those Intended to correct adverse conditions.

Corrective Actions to Preclude Repetition - Atype of corrective action intended to correct the root cause of a condition and thereby preclude repetition.

A copy of EN-L-1i 02 had been provided to the onsite review team.

122 Category Closed Request B.1.18-N-04 Why Is the high range radiation monitor cable Is not considered inscope of XI.E2.

Response VYNPS electrical AMR, AMRE-01, states that "Cables and connections Inthe high-range reactor building area monitoring System, support a license renewal Intended function. However, the entire length of these cables are EQ and do not require aging management since they are subject to replacement based on a 123 Category Closed Request B.1.19-N-03 For all new AMP prpvide a commitment number and the Implementation period for this new program.

Response Commitments numbers are being supplied In a table for all commitments.

..... :I. . . .. V... . ...

124 Cate-gory Accepted Request B.I.19-N-04 GALL XI.E1 under scope of program states that this Inspection program applies to accessible electrical cables and connections within the scope of license renewal that are Installed Inadverse localized environments caused by heat or radiation Inthe presence of oxygen. VYNPS AMP B.1.19 under the same element you have stated that this program will Include accessible Insulated cables and connections Installed Instructures within the scope of license renewal and prone to adverse localized environments. Clarify Ifthe scope of this program Include only Insulated cables and connections Installed In structures which (structures) are Inscope of license renewal and prone to adverse localized environments or Insulated cables and connections within the scope of license renewal that are Installed In adverse localized environments. ; Why are structures Included Inthe scope of the AMP. Modify the scope of the program as appropriate to remove the Response 'In a structurea means Inside the plant not outside. The VYNPS B.1.19 will be revised to state that the program applies to accessible electrical cables and connections within the scope of license renewal that are Installed Inadverse localized environments caused by heat or radiation Inthe presence of oxygen.

This requires an amendment to the LRA.

125 Category Closed Request B.1.19-N-05 Explain why the GALL X.E1, EQ. Is Included Inthe basic document for non-EQ Insulated cables and connections program.

Response Arevised copy of GALL for XI.E1 was provided.

126 Category Closed Request 3.6.2.2-N-09 GALL XI.E5 states that the fuse holder (not part of a larger assembly) metallic portions are subject to fatigue due ohmic heating, thermal cycling, electrical transients, frequent manipulation, vibration, chemical contamination, corrosion, and oxidation. In the LRA Table 3.6.1 item 3.6.1-6, you have stated that NUREG-1 801 aging effect Is not applicable to VYPNS. In AMRE-01 Revision 0 Page 14 of 108, you have stated that VYNPS employs two general types of fuse holders. The first type Is the bolt-mount fuse holder that uses either a lug or cap-screw to secure the fuse between the clamps. The second type of fuse holder Is the metallic clamp fuse holder, which uses the spring tension. Installation data for cables and connections Indicated that the only fuse holders Installed at VYNPS that utilize metallic clamps to secure the fuse are either part of active assembly or are located Incircuits that perform no license renewal indented functions. Are there any bolt-mount fuse holders Inscope of licensee renewal that are not part an active assembly. Ifthere are, explain why aging effects as Response No, the two types of fuse holders are all located In active devices.

127 Category Closed Request B.1.1-L-06 Program Description Item. The LRA says 'Buried components are Inspected when excavated during maintenance". Is maintenance performed on an as needed basis or Is it on a scheduled frequency?

Response The maintenance Inspections being credited are Inspections that are being performed on an as needed basis since there are no routine scheduled maintenance Inspections of buried piping.

128 Category Closed Request B;1.1-L-07 Program Description Item. The LRA says *Afocused Inspection will be performed within the first 10 years of the period of extended operation....' The LRA seems to address Inspections that occur both before and during the period of extended operation; the Appendix A reference does not clarify this confusion. When does VY plan to perform these focused Inspections?

Response The focused Inspection will be performed within the first 10 years of the period of extended operation, unless an opportunistic Inspection occurs within this ten-year period as stated In LRPD-02 section 4.1 .B.4.b of the Buried Piping Inspection Program and InAppendix B.1.1 of the LRA. The first sentence In the third paragraph of the program description in the LRA describes a review of operating experience (if available) for examinations of buried piping for relevant Information and Is not a required Inspection.

Inspections of buried carbon steel piping were performed In 2003 which Is within the 10 years prior to the period of extended operation. These Inspections revealed no coating or piping degradation.

129 Category Closed Request B.1.1-L-07 Program Description item. Depending on the response to the above question, please clarify the Appendix A reference, as needed.

Response Appendix A Is correct as written. The focused Inspection is specified for the ten years Immediately after entering the period of extended operation. This Is consistent with the SER for Brunswick dated March 2006.

130 Category Closed Request B.1.1-L-08 Acceptance Criteria item. The GALL Report says 'Any coating and wrapping degradations are reported and evaluated according to site corrective actions procedures.' The LRA says 'Coating and wrapping degradation, or loss of material due to corrosion, Is evaluated In accordance with the site corrective action program.' PP 7030, Section 4.8, Is very general, e.g., 'signs of degradation," 'areas of degradation.' Does VY Intend to enhance this guidance, as well as that addressed In question B.1.1-L-04?

Response Itwas the Intent of the enhancement specified In B.1.1 to revise appropriate sections of procedure PP 7030 to Include attributes of coating damage and evidence of corrosion. This would Include updating sections 4.3 &4.8.

This Item will be captured In Ucense Renewal Commitment 01.

131 Category Closed Request B.l.1-L-09 Operating Experience item., Why does LRDP-05, Section 4.4.1 reference the BWR CRD Retum Line Nozzle Program?

Response Yes, this is a typographical error and It should have saId that the Buried Piping Inspection Program provides reasonable assurance that the effects of aging will be managed such that the current licensing basis for the period of extended operation. This item was addressed In revision to LRPD-05.

132 Cate-gory Closed Request B.1.30.2-M-03 An exception to BWRVIP - 130 critera for feedwater copper was noted. Please provide related Information. (Water Chemistry Control - BWR Program)

Response Provided Revision 1.of Technical Justification for Continued Operation of Entergy Northeast Vermont Yankee (ENVY) with Feedwater Copper> 0.2 ppb.

133 Category Closed Request B.1.30.2-M-04 Please provide a copy of recent third party assessments of the Water Chemical Control - BWR Program.

Response Third party assessment of BWR Water Chemistry control from March 2001, May 2003 and April 2005 were provided for review.

134 Category Closed Request B.1.8-L-02 Detection of Aging Effects Item. PP 7006, Section 4.4.4, refers to a Type A Test, which will be developed. Please explain.

Response Type A testing) and due to the expectations of VY on maintaining operating procedures current, OP 4029 (test procedure) was retired. By retiring the procedure that Is conducted once every 10 to 15 years, forces the test engineer to develop a Type A Test lAW Tech Specs 6.7.C &PP 7006, Section 4.4.4 that adopts the latest test equipment, processes, software programs, and testing philosophies into the Infrequent*y conducted evolution (SOER 91-01). thereby ensuring that the complex Type Atesting process Is thoroughly understood by the test engineer. With the Inception of 10CFR50 Option B, containment Integrity Is adequately monitored between Type Atests.

135 Category Closed Request B.1.8-L-03 Monitoring and Trending Item. The GALL Report says "Thefrequency of these tests depends on which option (Aor B)Is selected. With Option A,testing is performed on a regular fixed time Interval as defined In 10 CFR Part 50, Appendix J." The LRA says "The first Type Atest after the April 1995 Type A test shall be performed no later than April 2010. This is a one-time extension of the NEI 94-01, 10 year Type Atest interval to 15 years. NRC approved Amendment 227 to Facility Operating License DPR-28 for VYNPS to extend the primary containment Integrated leak rate testing Interval from 10 years to no longer than 15 years on a one-time basis." Amendment 227 refers to Its being a one-time extension, so Itwould not appear to extend Into the period of extended operation. Please clarify.

Response Under current regulations and NEI guidance, the one time change does not affect the Type Atest Interval or number of tests to be conducted during the period of extended operation.

136 Category Closed Request B.1.8-L-04 Monitoring and Trending item. Does VY take any exception to the testing guidance of RG 1.163 or NEI 94-01?

Response At present, VY does not take direct exception to any provision In RG 1.163. VY does take exception to NEI 94-01. Specifically, with the adoption of License Amendment 223 of the Alternative Source Term (AST), the Main Steam Line Pathways were determined to be separate radiological (consequences) release paths exclusive of the Primary-Secondary Containment System radiological (consequences) release path. This pathway Is subject to the 10CFR50 Appendix J Type C testing methodologies but the calculation methods, leakage-rate summations, and acceptance criteria were determined to be Independent of the Primary Containment allowable leakage rate (La). NEI 94-01 does not address the effects AST adoption on a primary containment leakage rate testing program; therefore, an exception 137 Cate-gory Closed Request B.1.8-L-05 Acceptance Criteria Item. LRPD-02 Identifies the following as an exception that the LRA did not. The GALL Report says "Acceptance criteria for leakage rates are defined in plant Technical Specifications. These acceptance criteria meet the requirements In 10 CFR Part 50, Appendix J, and are part of each plant's current licensing basis. The current licensing basis carries forward to the period of extended operation." The LRA says "VYNPS acceptance criteria are defined Inplant technical specifications." Please expand on why the acceptance criteria are not consistent with the GALL Report.

Response See B.1.8-L-04 exception basis for response.

138 Category Closed Request B.1.8-L-06 Operating Experience Item. Does VYNPS monitor Industry Issues/events and assess these for applicability to its own program?

Response VYNPS Incorporates, as necessary, lessons learned Into the Containment Leak Rate Program from operating experiences Identified at VYNPS and Industry operating experiences. The incorporation of the lessons learned follows a process of an understanding of the operating experience, an assessment of the current program to determine applicability, and the document development to affect the change.

139 Category Closed Request B.1.14.K-O1 Requested operating experience Information on a sample of the heat exchangers included In the Heat Exchanger Monitoring Program Ifany Is available.

Response Operating History search was performed on the following components:

HPCI gland Seal condenser (E-1 8-1A)

HPCI Lube oil coolers (E-1 9-1A)

RCIC lube oil coolers (E-21-1A)

CST aluminum steam reheat coil (E-HB-1)

Drywall atmospheric cooling units (RRU 1, 2, 3, 4)

Drywall equipment drain cooler (E-ESC-1 A)

Reactor Recirculation pump seal water coolers (P-1 8-1A/B Hx-3)

Reactor Recirculation pump motor upper &lower bearings oil coolers (P-18-1AB Hx-2)

Reactor Recirculatlon pump motor air coolers (P-18-1AMB Hx-1)

Keywords used In PCRS:

Fouling Eddy Current Tube replacement Tube plugging Plugging Tube blockage No information was found on the heat exchanger or coolers for any of the above components In PCRS.

EMPAC search on components:

WO 2001-5153 performed 10/04/2002- E-18-lA HPCI Gland Seal condenser Cleaning and Inspection WO 1997-8128 performed 04/02/1998- E-19-1A Inspect lube oil side of HPCI lube oil cooler RRU-1 through 4 are Inspected and lubricated during refueling outages-External Inspections only Attachments provided to the NRC during the onsite review:

WO 2001-5153 WO 1997-8128 NRC has these attachments.

140 Cate-gory Closed Request B.1.14-K-02 What Isthe proposed frequency of Inspection and basis of the frequency selected for the heat exchangers Included Inthe Heat Exchanger Monitoring Program.

Response The development of the non Service Water (SW) cooled heat exchanger Inspection and monitoring plan would be similar to the process which was used for the SW heat exchangers.

The scope of this plan would Include, but not be limited to, the following heat exchangers and coolers:

Drywall Coolers, RRU-i through 4 HPCI Gland Seal Condenser, E-18-1A HPCI Lube Oil Cooler, E-19-1A RCIC Lube Oil Cooler, E-21-1A CST Reheat Coll, E-HB-1 Drywall Equipment Drain Cooler, E-ESC-1A Reactor Recirculation Pump Seal Water Coolers, P-18-1A HX-3 &P-18-IB HX-3 Recirculation Pump Motor Upper &Lower Bearing Oil Coolers, P-18-1A HX-2 &P-18-1B HX-2 Recirculation Pump Motor Air Coolers, P-18-1A HX-1 &P-1 8-1B HX-1 The following Is an example of the steps which would be used to develop the plan:

1. An Initial visual Inspection would be performed of the Inscope heat exchangers. This Inspection would document the "as-found* conditions. Additional examination methods may be used if "as-found" conditions warrant, (i.e. ultrasonic thickness measurements or radiography). The results of these Inspections would be used to establish the frequency of future Inspections.

2. Where physically accessible, baseline eddy current data would be obtained. The number of tubes sampled would be determined based on Industry best practices and EPRI recommendations. The results of these tests would be used to determine the frequency of future Inspections and the number of tubes to be sampled.

3. Future Inspections and eddy current examinations would be scheduled via the Preventive Maintenance process.

4. Performance monitoring and trending would be performed In accordance with established fleet procedures.

Once developed the plan would be administered by the onsite engineering organization, 141 Cate-gory Closed Request B.1.12.1-L-07 Scope of Program Item. The GALL Report has requirements Innumerous program elements that are on a six-month frequency. The LRA states that these are on a refueling (twenty-month) frequency. Please discuss and justify the Inspection frequency differential for the C02 .system.

Response System walkdown every 6 months, starting prior to period of extended operations.

The vY AMP B.1.17 will state that 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 InEPRI TR-1 03834-P1-2, or other testing that Is state-of-the-art at the time the test Isperformed.

142 Category Closed Request B.l.18-N-04 Why Is high range radiation monitor cable not considered In scope of XL.E2 Response VYNPS Electrical AMR, AMRE-01 states that 'Cables and connections Inthe high-range reactor building area monitoring system, support a license renewal Intended function. However, the entire length of these cables are EQ and do not require aging management since they are subject to replacement based on a qualified life.

143 Category Closed Request B.1.18-N-05 GALL XI.E2 under parameter monitored/inspected states that the parameter monitored are determined from the specific calibration, surveillance or testing performed and are based on the specific Instrumentation under surveillance or being calibrated, as documented In plant procedures. VY AMP B.1.18 under same attribute states that results from the calibrations or surveillance of components within the scope of license renewal will be reviewed. The parameters reviewed will be based on the specific Instrumentation circuit under surveillance or being calibrated, as document Inthe plant calibration or surveillance procedures.

a Why does the review of calibration results belong to parameter monitored/inspected attribute?

b. The parameter monitored/inspected for cable testing was not mentioned. What Is the parameter for cable testing. Confirm that cable testing will be perform on cables In-scope of XI.E2 that are disconnected during Instrumentation calibration.

Response a) 8.1.18 will be revised under parameter monitored/Inspected to'state that the parameters monitored are determined from the specific calibration, surveillances or testing performed and are based on the specific Instrumentation circuit under surveillance or being calibrated, as documented In plant procedures.

LRPD-02, Rev 2 Incorporated this change.

(b) B.1.18 under parameter monitored/finspected will state that the parameters monitored are determined from tire specific calibration, surveillances or testing performed. The parameter for cable testing is determined from the plant procedures. Cable testing Isperformed by plant procedures on cables in-scope of XLE2 that are disconnected during Instrument calibration.

144 Category Closed Request B.1.18-N-06 VY B.1.18 under acceptance criteria address the acceptance criteria for calibration. However, it silences on the acceptance criteria for cable testing. What is the acceptance criteria for cable testing?

Response B.1.18 will be revised under acceptance criteria to state that calibration results or findings of surveillance and cable system testing results are to be within the acceptance criteria.

LRPD-02, Rev 2 Incorporated this change.

145 Category Closed Request B.1.20-K-03 Please provide QA Surveillance and self-assessment referenced in operating experience for Oil Analysis Program.

Response CA Surveillance SRVY 2002-025 and 2003 self-assessment provided during the onsite audit 146 Category Closed Request B.1.12.1-L-07 Scope of program item. The GALL Report has requirements Innumerous program elements that are on a six-month frequency. The LRA states that these are on a refueling (twenty-month) frequency. Please discuss and Justify the Inspection frequency differential for the C02 system.

Response The TRM frequencies are based on those that were previously Inthe Technical Specifications. Entergy VT will re-examine the ability to performing these surveillances at a 6 month or higher frequency, provided that they can be safely performed online. This effort will be started 6 months prior to the period of extended operation and Is tracked as Ucense Renewal Commitment #30.

147 Category Closed Request B.1.12.1-L-08 Preventive Actions item. The GALL Report says "For operating plants, the fire hazard analysis assesses the fire potential and fire hazard In all plant areas...." The LRA says "The NUREG-1801 Preventive Actions do not specify any measures for preventing aging effects of fire protection structures, systems or components."

Has VY performed a fire hazard analysis?

Response The VY Fire Hazards Analysis was provided during the onsite Inspection 148 Category Closed Request B.1.12.1-L-09 Parameters Monitored/Inspected Item. The GALL Report says 'Visual Inspection of the fire barrier walls, ceilings, and floors examines any sign of degradation such as cracking, spalling, and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates." The LRA says "Procedures will be enhanced to specify that fire damper frames In fire barriers shall be Inspected for corrosion." What Is the material and environment of the damper frames?

Response These dampers are In ventilation ducts; therefore, the conditions would be similar to other ambient conditions In the plant. The duct material is carbon steel. The environment Is Indoor air.

149 Category Closed Reauest B.1.12.1-L-10 Parameters Monitored/inspected Item. What examination technique will be used?

Response Visual exam, consistent with ANSI 45.2.6 150 Category Accepted Request B.1.12.1-L-11 Parameters Monitored/Inspected Item. The GALL Report says "The diesel-driven fire pump Is under observation during performance tests such as flow and discharge tests, sequential starting capability tests, and controller function tests for detection of any degradation of the fuel supply line." The LRA says

• Procedures will be enhanced to state that the diesel engine sub-systems (including the fuel supply line) shall be observed while the pump is running." Is there a

'VYNPS commitment associated with this enhancement?

Response Yes. This Item Is being tracked by License Renewal Commitment #9.

151 Category Closed Request B.1.12.1-L-12 Acceptance Criteria Item. The GALL Report says "Inspection results arb acceptable If there are no visual Indications (outside those allowed by approved penetration seal configurations) of cracking, separation of seals from walls and components, separation of layers of material, or ruptures or punctures of seals; no visual Indications of concrete cracking, spaeling and loss of material of fire barrier walls, ceilings, and floors; no visual indications of missing parts, holes, and wear and no deficiencies In the functional tests of fire doors." The LRA says "Acceptance criteria will be enhanced to verify no significant corrosion.' How much Is Response This Item Is being addressed by Ucense Renewal Commitment #8

152 Category Closed Request B.1.12.1-L-13 Acceptance Criteria item. What actions are taken, either with or without significant corrosion?

Response This Item Is being addressed by License Renewal Commitment #8 153 Category Closed Request B.1.12.1-L-14 Acceptance Criteria item. Is there a VYNPS commitment associated with this enhancement?

Response This Item is being addressed by License Renewal Commitment #8 154 Category Closed Request B.1.12.1-L-15 Acceptance Criteria Item. The GALL Report says 'No corrosion Is acceptable In the fuel supply line for the dlesel-driven fire pump.* The LRA says *Acceptance criteria will be enhanced to verify that the diesel engine did not exhibit signs of degradation while ItWas running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.* Does the enhancement include corrosion Inthe fuel supply line of the diesel-ddven fire pump?

Response Evidence of corrosion Inside the fuel line would appear as corrosion products Inthe fuel filter. Evidence of corrosion in the fuel filter would result Ina Condition Report and an evaluation. Evidence of corrosion would be an Inspection criterion for fuel filters removed from service. Inaddition, the Intemals of the fuel line are managed by the diesel fuel oil monitoring program.

155 Category Accepted Request B.1.12.1-L-16 Acceptance Criteria Item. Is there a VYNPS commitment associated with this enhancement?

Response Yes. This Item Is being tracked by License Renewal Commitment # 9 156 Category Closed Request B.1.12.1-L-17 Operating Experience Item. Has VY experienced any fire-protection-related operating experience? Please describe.

Response During the onsite Inspection, the OE Coordinator provided the requested Information.

157 Category Closed Request B.1.12.1-L-18 Operating Experience item. Has VY reviewed and applied the Industry operating experience that relates to fire protection?

Response VY routinely reviews Industry OE in accordance with fleet procedure, EN-OE-100. The VY OE coordinator routes OE to affected line organization groups, and enters action Items Into the corrective action process to ensure that timely review is completed and documented.

158 Category Closed Request B.l.12.1-L.19 Operating Experience item. Is any VY plant-specific operating experience not bounded by Industry operating experience?

Response No 159 Category Closed Request B.1.12.1.L-20 Program Description item. Does VY Inspect the fire dampers?

Response Yes. Surveillance Test #7134 Is the Operating Cycle Test of Fire Barrier Dampers, using procedure OP 4019. VY will add Fire Dampers to the program description.

160 Category Closed Request B.1.12.1-L-21

• Program Description Item. Does VY have an electric fire pump?

Response Yes. The pump end Is Identical to the diesel fire pump. ItIs located Inthe Intake Structure. Component IDIs P-40-1 B. Iti1Managed by Fire Water Program via Test Procedure # OP 4105.

161 Cate-gory Closed Request B.1.12.1-L-22 Program Description item. How does VY Inspect/test Appendix R-required equipment?

Response Test Procedures for Inspecting and testing Appendix R required equipment are:

PROC. # TITLE AP 0042 Plant Fire Prevention and Fire Protection OP 0046 Installation and Repair of Fire Barriers, Penetration Seals, Fire Breaks and Flood Seals.

• OP 2186 Fire Suppression Systems OP 3020 Fire Emergency Response Procedure AP 3700 Fire Training OP 4001 Plant Fire Extinguisher Service and Issue OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems OP 4019 Surveillance of Plant Fire Barriers and Fire Rated Assemblies OP 4103 Fire Protection Equipment Surveillance OP 4104 Fire Hose Hydro Test Surveillance OP 4105 Fire Protection Systems Surveillance OP 4221 Surveillance of Gas Fire Extinguishing Systems OP 4339 Surveillance of Fire Protection Detectors/instruments OP 4392 Trip Test of Fire System Water Flow Alarms OP 4393 Test of the Cable Vault, Switchgear Room, and Intake Structure C02 Systems OP 4395 Check of Computer/Heating Ventilation Air Conditioning (HVAC) Shutdown Circuits/Computer Room Halon Act System OP 4602 Sampling of Fire Fighting Foam for Annual Analysis OP 4800 General Safety Surveillance OP 5327 Calibration of Plant Fire Protection System Instruments AP 6024 Plant Housekeeping and Foreign Material Exclusion/Cleanliness Control PP 7011 Vermoht Yankee Fire Protection and Appendix R Program

162 Category Accepted Request B.1.12.1-L-23 Detection of Aging Effects item. The GALL Report says "Vlsual Inspection by fire protection qualified Inspectors....; Of what does this consist, at VY?

Response At VY, the program Is being developed and will Include training, acceptance criteria, and qualification as a "fire protection qualified Individual" ANSI 45.2.6 The Injection program, EN-MA-102, will be used.

163 Category Closed Request B.1.12.1-L-24 Acceptance Criteria Item. The GALL Report says "Inspection results are acceptable if there are no visual Indications (outside those allowed by approved penetration seal configurations) of cracking,..." OP 4019, Appendix B, allows cracks In poured concrete barriers, fire barriers, concrete block walls, drywall, plaster, silicone foam, pyrocrete, and smoke/gas seals.

Response OP 4019 acceptance criteria will be revised to require that any recordable 'outside those allowed by approved penetration seal configurations" visual Indication be Identified and entered Into the corrective action process for evaluation.

The CA number to complete this action by 12/31/06 Is CR.VTY-2006-112. CA-02; CA-03.

164 Category Closed Request B.1.30.1-M-02 Is the Identified enhancement to AMP B.1.30, Water Chemistry Control- Auxiliary Systems, necessary and appropriate for this program Response The Identified enhancement to AMP B.1.30, Water Chemistry Control - Auxiliary Systems Is to enhance procedures to flush the John Deere diesel cooling water system and replace the coolant and coolant conditioner every three years.

A program Is necessary to manage loss of material and fouling of carbon steel and copper alloy components In the John Deere diesel cooling water system for the period of extended operation. Due to the size and configuration of the system, periodic sampling of the coolant was deemed unrealistic and the decisionr was made to flush the coollng water and replace the coolant and coolant conditioner every three years. While this task could have been Included In the Periodic Surveillance and Preventive Maintenance program, It was Included In the Water Chemistry Control - Auxiiiary Systems program to be consistent with other components exposed to treated water, which are managed by water chemistry control programs.

As stated In LRA Section B.1.30.1, rather than sampling, procedures will be enhanced to flush the John Deere diesel cooling water system and replace the coolant and coolant conditioner every three years. (License Renewal Commitment 26)

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165 Category Closed Request B.1.30.1-M-03 Confirm that there are no other In-scope systems that rely on this AMP for managing'the effects of aging.

Response The following LRA tables credit the Water Chemistry Control - Auxiliary Systems Program for managing the effects of aging.

3.2.2-5, Reactor Core Isolation Cooling (RCIC) System - Summary of Aging Management Evaluation 3.3.2-10, Heating, Ventilation and Air Conditioning (HVAC) Systems - Summary of Aging Management Evaluation 3.3.2-12, John Deere Diesel (JDD) - Summary of Aging Management Evaluation 3.3.2-13-18, House Heating Boiler (HB) System, Non Safety-Related Components Affecting Safety-Related Systems - Summary of Aging Management Evaluation 3.3.2-13-39, Stator Cooling (SC) System, Non Safety-Related Components Affecting Safety-Related Systems - Summary of Aging Management Evaluation The component in the RCIC system that credits this program Is a steam heater which Issupplied by the house heating boiler system. Similarly, the components In the HVAC systems that credit this program are supplied by the house heating boiler system. Thus, there are no In-scope systems (other than the house heating boiler, stator cooling, and John Deere diesel systems) that rely on this AMP for managing the effects of aging. All other In-scope treated water systems rely on either the Water Chemistry Control - BWR program or the Water Chemistry Control - Closed Cooling Water program for managing the effects of aging.

Items 3.3.1 -50 and 3.3.1-51 in LRA Table 3.3.1 will be updated to reflect that the de-mineralized water system Is managed by the Water Chemistry Control - BWR Program, as Indicated In LRA Table 3.3.2-13-12, aging of components.

This requires an amendment to the LRA.

166 Catecgory Accepted Request B.1.21-K-04 LRA Section 3 Table 2's do not list the One-Time Inspection Program with the water chemistry control programs for components for which GALL recommends One-Time Inspection to verify effectiveness of the Water Chemistry Control Program.

Response LRA'Section 3 Table l's discussions provide the link between the One-Time Inspection and Water Chemistry Control Program for these components.

To provide further clarification, the effectiveness of the Water Chemistry Control - Auxiliary Systems, BWR, and Closed Cooling Water programs is confirmed by the One-Time Inspection program. This requires an amendment to the license renewal application to change the Appendix A,SAR supplement descriptions for the Water Chemistry Control -Auxiliary Systems, BWR and Closed Cooling Water programs to explicitly state One-Time Inspection Program activities will confirm the effectiveness of these programs.

167 Cateqory Closed Request B.1.21.-K-05 Please provide sample selection criteria for the small -bore piping one-time Inspection program.

Response Inspection locations will be based on physical accessibility exposure levels, NDE techniques, and locations Identified In NRC Information Notice 97-46, Un-isolable Crack In High-Pressure Injection Piping. The Initial populatibn will Include all Class 1 small - bore piping.

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168 Cate-gory Closed Request Bi.15.2-P-01 Please explain why the AMP for IS1(IWB, IWC, & IWD) Is not consistent with the GALL AMP XI.M1 Response Entergy chose to describe the Inservice Inspection and Containment InservIce Inspection Programs as plant-specific programs rather than comparing to the corresponding NUREG-1801 programs because the NUREG-1801 programs contain many ASME Section XI table and section numbers which change with different versions of the code. Because of this, comparison with the NUREG-1 801 programs generates many exceptions and explanations which detract from the objective of the comparison. What Is really needed Is that VYNPS follow the version of ASME Section XI that Is approved for use at VYNPS and accepted by law In 10CFRSO.55(a). As this Is the case, the Inservice Inspection and Containment Inservice Inspection Programs are presented as plant-specific programs so they can be judged on their own merit without the distraction of numerous explanations of code revision.

169 Cate-gory Closed Request B.1.15.2-P-02 The AMP for ISI (IWB, IWC, & IWD) makes no mention of any risk-Informed program. Please confirm whether or not there are current or future plans for the Implementation of risk-informed 1SI.

Response Risk-informed ISI Is being Implemented during the Fourth Ten-Year Interval (9/1/2003 - 8/31(2013). Surface examination of ASME Section Xl, Class I, Examination Categories B-F, C-F-i, and C-F-2 (4' NPS and larger) are conducted In accordance with Code Case N-663. All areas of the subject welds Identified as susceptible to outside surface attack shall be surface examined during the Fourth Ten-Year Interval In accordance with Code Case N-663. Code Case N-663 Incorporates lessons learned for risk-informed Initiatives and Industry examination experience by requiring that an evaluation be conducted to Identify locations, Ifany, where a surface examination would be of benefit from a generic piping degradation perspective. The results of the evaluation Identify where O.D. degradation Is most likely to occur by reviewing plant-specific programs and practices, and operating experience. Ifthe potential for degradation Is Identified, Code Case N-663 defines examination techniques, volumes, and frequencies. As such, Implementing Code Case N-663 Identifies appropriate locations for surface examination and eliminates unnecessary examinations.

VYNPS plans to continue surface examination of ASME Section XI, Class I, Examination Categories B-F, C-F-i, and C-F-2 (4" NPS and larger) In accordance with Code Case N-663 In subsequent Inspection Intervals. IfCode Case N-663 Is not Incorporated Into the ASME Section Xl code edition and addendum approved by the Nuclear Regulatory Commission In 10 CFR 50.55a for the subsequent Interval, a relief request will be submitted as was done for the Fourth Inspection Interval.

170 Cate-gory Closed Request Provide the basis for determining the Inspections required for BWRVIP-48. Particularly address whether VYNPS has any furnace sensitized material or Alloy 182 material that requires EVTI.

Response PP7027, Appendix B states clearly that these brackets are examined as Ifthey are fumace sensitized, I A W VIP 48-A.

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171 Category Closed Request B.1.27.1-W-04 Provide the last two Inspection reports for one un-reinforced Masonry Wall without bracing, one reinforced Masonry Wall without bracing and one steel braced Masonry Wall.

Response The following Block Wall Inspection Reports and drawings were provided during the onsite Inspection:

-Masonry Wall Routine Surveillance Walkdown Sheet for Wall G-1 91145-9 dated 10/16/02 (un-reinforced wall)

-Drawing B-191600 Sheet 8 Rev 0 (from walkdown)

Attachment C VYP-007 Ri Masonry Wall Routine Surveillance Walkdown Sheet for Wall G-191145-9 dated 9/1/93 (un-reInforced wall)

• Drawing B-1 91600 Sheet 8 Rev 0 (from walkdown)

-Attachment C VYP-007 R1 Masonry Wall Routine Surveillance Walkdown Sheet for Wall G-191145-4 dated 9/28/93 (steel braced wall) tAttachment C VYP-007 RO Masonry Wall Routine Surveillance Walkdown Sheet for Wall G-191145-4 dated 9/10/87 (steel braced wall)

'Drawing B-1 91600"Sheet 7 Rev 1 (from 1993 walkdown)

• Masonry Wall Routine Surveillance Walkdown Sheet for Wall G-191627-4 dated 10/16/02 (reinforced wall)

-Attachment C VYP-007 RI Masonry Wall Routine Surveillance Walkdown Sheet for Wall G-191627-4 dated 9/1/93 (reinforced masonry wall)

'*Drawing B-191600 Sheet 105 Rev 0 (reinforced masonry wall, from walkdown)

'Drawing B-1 91600 Sheet 105 Rev I (reinforced masonry wall) 172 Category Closed Request Please provide copies of OP4339 and EN-OE-100, procedures related to the Fire Water System Program.

Response 0P4339 and EN-OE-1 00 were provided during the onsite Inspection.

173 Category Closed Request InSection 2b Preventive actions of LRPD-02 and ItIs stated that there are no preventive actions. GALL says that monitoring of water chemistry to control pH and concentration of corrosive contaminants and treatment with hydrazine are effective In reducing selective leaching. Do any of the systems that have selective leaching as an AMP have a treated water environment that performs any of these treatments to control selective leaching?

ReSponse Yes, The Water Chemistry Control - Closed Cooling Water and BWR prbgrams at VYNPS control PH and corrosive contaminants and could be effective In controlling selective leaching. Therefore any system and components with both the selective leaching and the water chemistry programs as aging management programs are Included measures that could be effective In controlling the aging effect of selective leaching.

174 Category Closed Request What Is the flaw evaluation calculation for the jet pump diffuser welds? Is thls calculatlon considered a TLAA?

Response The jet pump diffuser welds calculations are contained In: GE-NE-B13-01935, Rev. 2, Jet Pump Assetnbly Welds Flaw Evaluation Handbook for Vermont Yankee, July 1999.

This Is not a TLAA.

175 Cateqory Closed Request Will UT of the flawed jet pump diffuser welds continue?

Please Identify any change to the exception identified In LRA.

Ifyes, please provide the exact wording in LRA supplement.

(Note: EVT-1 does not provide flow propagation verification.)

Response These welds are scheduled for UT examination during RFO 26.

Following RFO -26, Ifthere are no changes to the observed Indications, the Inspections will revert to EVT-1 Inspections lAW BWRVIP-4.

176 Category Closed Request Will VYNPS continue to Inspect 10% of CRD guide tubes every 12 years?

Additional question: PP-1 027 stated that 2VT-3 Inspections were performed. BWRVIP stated that 4 CRD Guide tube weld locations were recommended to be Inspected 2 locations (VT-3) 2 locations (EVT-1)

Please describe the Inspection for all 4 locations.

Does applicant Inspect all 4 welds or only 2 welds?

Response VYNPS Inspects guide tubes lAW BWRVIP-47-A and.plans to continue to do so.

EVT-1 Inspections are conducted on CRGT-2 and CRGT-3.

VT-3 Inspections are conducted on CRGT-1 and FS?GT-APRIN-1 177 Category Closed Request Will VYNPS continue to Inspect the top guide at the rate of 10% every 12 years?

Response This question has been addressed InQuestion # 14. The BWR Vessel Internals Program at VYNPS Is consistent with the program described In NUREG-1801,Section XI.M9, BWR Vessel Internals with the exceptions and enhancement noted In LRA Section B.1.7. As stated In NUREG-1 801, the extent of the examination and Its frequency will be based on a ten percent sample of the total population, which Includes all grid beam and beam-to-beam crevice slots.

178 Category Closed Request What Isthe exam hlstory, results, schedule and current status of shroud HB and H9 welds?

Response In RFO 19 (1996) Vermont Yankee performed an Inspection of welds H8 and H9 which meets the requirements of BWRVIP-38 for a baseline examination. The following describes the rationale for this statement The baseline strategies for welds H8 and H9 are shown InFigures 3-4 and 3-5 of BWRVIP-38. The load multiplier Is determined from Figures 5-1. InVermont Yankee's case this Isa 0.41. The flaw tolerance Is determined from figures 5-1 (for H8) and 5-2 (for H9) for plants with support legs. For both welds the flaw tolerance of 100 %. The minimum examination coverage for a flaw tolerance of 100% Is 10% for both H8 and H9.

The coverage was 25% for weld H8 and 22% for weld H9 during the RFO 19 (1996) examination. No flaws were found. Therefore an adequate baseline of welds H8 and H9 was performed.

No welds other than H8 and H9 require examination Is accordance with BWRVIP-38 for a plant with Vermont Yankee's core shroud support configuration. The NRC requires Inspection tooling and methodologies be developed that allow the welds Inthe lower plenum to be made accessible. This requirement applies to the VYNPS shroud support leg welds. This Inspection remains an open Item with the NRC per response to BWRVIP-38.

The re-inspection Interval Is established In BRWVIP-38, Paragraph 3.3.2, that states "ifno flaws were found during the previous Inspection, re-Inspections are performed on ten-year Intervals IfUT techniques were used...O The RFO 19 (1996) H8 and H9 examination was an ultrasonic test augmented with eddy current and no flaws were found. Therefore the re-Inspection Interval Is ten years IfUT techniques are used, and six years IfEVT-1 techniques are used (but see below).

Accordingly, re-Inspection of H8 and H9 were re-Inspected In RFO 25(2005), by EVT-1 nine years following the baseline exam.

179 Category Closed Request B.1.22-M-03 Please provide a recent third party assessment of the preventive maintenance program.

Response WANO Assessment Report will be available for on-site review during return audit (week of 5115106).

180 Category Closed Request B.i.22.M-04 Following the proposed enhancement to the Periodic Surveillance and Preventive Maintenance Program, will Itbe apparent that these tasks contain an aging management element?

Response The Periodic Surveillance and Preventive Maintenance program Includes two types of tasks, Inspections and surveillances.

Inspections Include various visual or other non-destructive examinations to manage loss of material, cracking, and fouling of components. Following the proposed enhancements, Itwill be apparent that these tasks contain an aging management element. To properly Inspect for evidence of loss of material, cracking, or fouling, the Inspector must be aware that he Is looking for these aging effects and as such new guidance to Identify these aging effects will be Included as required.

Surveillances Include the secondary containment capability check, which will confirm the absence of aging effects for reactor building exterior concrete walls during the period of extended operation; leakage testing on the equipment lock doors, which will confirm the absence of aging effects for the rubber door seals during the period of extended operation; and temperature monitoring during operability testing of diesel generators to confirm the absence of fouling of diesel heat exchangers during the period of extended operation. To perform these tests, the performer does not need to be aware that he Is confirming the absence of aging effects. If the applidable acceptance criterion Is not met, the performerwiII Initiate a condition report. In accordance with the corrective action program, causes for the condition will be evaluated, Including those that are due to aging of components.

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181 Category Closed Request B.1.22-L-01 Program Description Item. The GALL Report says 'The External Surfaces Monitoring program Is based on system Inspections and walkdowns. This program consists of periodic visual Inspections of steel components such as piping, piping components, ducting, and other components within the scope of license renewal and subject to AMR In order to manage aging effects. The program manages aging effects through visual Inspection of external surfaces for evidence of material loss. Loss of material due to boric acid corrosion is managed by the Boric Acid Corrosion Program." The LRA says 'This program entails Inspections of external surfaces of components subject to aging management review. The program Is also credited with managing loss of material from internal surfaces, for situations In which Internal and extemal material and environment combinations are the same such that external surface condition is representative of Internal surface condition." What materials are within the scope of this AMP?

Response The Walkdown program Is not exclusive of any system material condition. It should be noted that the walkdown process may find signs of external piping degradation that would be evaluated for potential Impact to Interior piping surfaces. The walkdown program Is not Intended to Inspect Interior piping and component surface unless they have been revealed for Inspection during maintenance and repairs. As Indicated In the tables In Section 3 of the LRA, the System Walkdown program manages aging for external surfaces of carbon steel, stainless steel, cast Iron, low alloy steel, aluminum, and copper alloy components. The program also manages loss of material from Internal surfaces In situations in which Internal and external material and environment combinations are the same such that external surface condition Is representative of Internal surface condition.

182 Cate-gory Closed Request B.1.22-L-02 Program Description Item. What examination methods are used?

Response For current term operation, system waikdowns use ' eye contact" examination. System Engineers are not qualified Invisual examination methods such as those used to qualify welding. The Entergy walkdown procedure provides a listing and a checklist of examinations to be performed during the walkdown. Plant Issues ranging from standard housekeeping to equipment problems are documented and acted upon accordingly through work planning and the condition reporting system. For the License Renewal term, under the System Walkdown program, visual Inspection activities are performed and associated personnel are qualified In accordance with site controlled procedures and processes.

183 Category Closed Request B.1.22-L-03 Operating Experience Item.. Has VY experienced any external surfaces-related operating experience? Please describe.

Response System Walkdowns , both online and during refueling outages, have found corrosion on piping and component surfaces. For Instance, each refueling, the Interior of the condenser hotwell and waterboxes are Inspected. Repairs and or more detailed Inspections are Implemented as required. In Refueling Outage 24 (November 2005) examinatton'of spring cans supporting service water piping revealed rust and the need for recoating. Corrective actions driven by condition reporting and work order planning has resulted inscheduling repair for the 2006 outage.

184 Category Closed Recuest B.1.22-L-04 Operating Experience item: Has VY reviewed and applied the Industry operating experience that relates to external surfacps?

Response Vermont Yankee System Engineers have received training Inthe EPRI Aging Management Field guide, which Ineffect Is a' collection of OE from many nuclear plant systems, both mechanical and electrical, as well as buildings and structures Intended to provide specific details of corrosion and degradation throughout the plant. Review of OE Is an ongoing activity for Vermont Yankee System Engineers Intended to ensure latest Issues are known and to continue to develop background related to assigned systems.

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185 Category Closed Request B.1.22-L-05 Operating Experience item: Is any VY plant-specific operating experience not bounded by Industry operating experience?

Response Through Its condition reporting system, Vermont Yankee will contribute to Industry OE as Its Condition Reporting Committee directs. Aging related Issues with Vermont Yankee are typical of Industry based OE.

186 Categorv Closed Request B.1.22-L-06 Program Description Item. Is boric acid leakage that falls/sprays on VY components managed by the Boric Acid Corrosion Program?

Response Vermont Yankee Is a Boiling Water Reactor and therefore does not have a Boric Acid Corrosion Prevention program. The Standby Liquid Control system, which contains Sodium Pentaborate, and Is maintained In a clean condition. Rare cases of leakage from standby liquid control system valve packing or other system components have occurred, but were promptly corrected prior to Impacting the Intended function of components subject to aging management review for license renewal. The extemal surfaces of SLC components and components In the area are managed by the System Walkdown program.

187 Cateciory Closed Request B.1.22-L-07 Scope of Program Item. Please expand the explanation of the enhancement Identified In LRPD-02, page 218.

Response The enhancement In LRPD-02, page 218 was identified after the LRA was submitted to NRC for review. Entergy decided that the System Walkdown program Implementing procedure should be enhanced to specify that systems In scope and subject to aging management review for license renewal In accordance with 10 CFR 50.54 (a)(1) and (a)(3) shall be walked down. Guidance as to what systems are walked-down Is currently Included In less formal plant guidelines. Also, although the System Walkdown program Implementing procedure currently provides guidance to Inspect nearby systems that could Impact the system being walked down, Entergy decided that this guidance should be clarified. The enhancement In LRPD-02, page 218 Is commitment # 24 on the list of commitments for license renewal.

188 Cate-gory Closed Request B.1.22-L-08 Scope of Program Item. Enhancements will need specific commitments.

Response Vermont Yankee commits to those Items related to Aging Management'and will update the Entergy walkdown procedure accordingly commensurate with the License Renewal schedule. Training Inthe EPRI Field Guide Is ongoing at this time. The enhancement In LRPD-02, page 218 Is commitment # 24 on the list of commitments for license renewal.

189 Category Closed Request B.1.22.L.09 Parameters Monitored/inspected Item. The LRA does not specify the same examples that the GALL Report does, e.g., material wastage, leakage, Insulation condition, eto..What Is the Justification for not addressing these parameters?

Response These Items are documented on a monthly basis, as found during walkdowns, In walkdown reports. Any material condition Is assessed at the time discovered and acted upon according to Its conditions. All system conditions, Including those found In walkdowns, plant monitoring and daily operations are summarized In Quarterly System Health reports.

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190 Cate-gory Closed Request B.1.22-L-10 Parameters Monitored/Inspected item. Several of these parameters are not addressed In EN-DC-178. Should this procedure be enhanced?

Response Specifically discussed during Ucense Renewal program reviews were Insulation and the need to visually examine it for signs of leakage, corrosion beneath and missing Insulation. Ucense Renewal Commitment # 24 addresses the Waikdown procedure.

191 Cate-gory Closed Request B.1.22-L-1I Detection of Aging Effects Item. GALL focuses on the pertinent surfaces. LRPD-02, page 215, says that the program will manage the loss of material for Internal and external surfaces by visual inspection of external surfaces. How Is this accomplished?

Response Walkdowns may find signs of piping external surface degradation and will assess any potential Impact on Interior surfaces.

Consistent with GALL Section XI.M36, External Surfaces Monitoring, the VYNPS System Walkdown program will manage loss of material for Internal surfaces exposed to the same environment as the external surfaces. External surface condition on components exposed to the same Internal and external environments is Indicative of Internal surface condition. Components with signs of external surface degradation will be assessed for potential Impact on interior surfaces Impact.

192 Category Closed Request B.1.22-L-12 Operating Experience Item: Has VYNPS experienced any external surfaces-related operating experience? Please describe.

Response In addition to the service water piping spring cans noted in Question 183 and a few other examples are:

1. Cooling Tower wood structural member splitting (normal aging and checking of wood). VY's preventative maintenance program drives Inspection and replacement as required.

2. Switchyard tower base age related cracking. Evaluated for structural Impact, found satisfactory, future work to coat bases.

193 Category Closed Request B.1.22-L-13 Operating Experience item. Has VYNPS reviewed and applied the Industry operating experience that relates to external surfaces?

Response Yes, the OE has helped Identify specific causes and *best practice" repairs. The EPRI Aging Management Field Guide has been particularly useful.

194 Category Closed Request B.1.22-L-14 Operating Experience Item. Is any VY plant-specific operating experience not bounded by Industry operating experience?

Response Review of Aging Related OE to date has not found such OE.

195 Category Closed Request B.1.22-L-15 Operating Experience Item. Several findings are Identified under the OE tab. Are these the total findings that were made or are they simply representative?

Response These examples are representative. VYNPS can supply others on specific systems as requested.

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196 Category Closed Request Regarding the UT Indication at 215 degrees on the RPV cladding adjacent to a dryer support log: Does VYNPS plan to re-Inspect this Indication by UT?

Response VYNPS performed enhanced UT's In accordance with commitment described In BVY 92-055 and BVY 93-112. These UT's were performed from the RPV OD and determined that the cracks do not penetrate to the RPV base metal. The steam dryer lugs will be re-Inspected In accordance with BWRVIP-48 by VT-1.

197 Category Closed Request 3.1.1-01-P-01 On page 3.1-55, the component type 'supports stabilizer padssupport skirt' Is managed using TLAA - metal fatigue. In all cases where the LRA lists 'Cracking -

fatigue" as the AERM, change It to 'Fatigue damage' (applies to multiple Table I Items but Is asked only once).

Response Cumulative fatigue damage Is a generic term. However, only when fatigue damage accumulates to the point that the component cracks Is the function of the component In jeopardy. VYNPS uses the aging effect of cracking due to fatigue to represent the physical result of cumulative fatigue damage. The meaning of

'Cracking - fatigue' Is consistent with the Intent of Cumulative Fatigue Damage'.

198 Category Accepted Request 3.1.1-02-P-01 On page 3.1-36, the component type 'closure flange studs, nuts, washers and bushings' and the component type 'other pressure boundary bolting, flange bolts and nuts (N6A, N6B, N7), CRD flange cap-screws and washers' are managed using TLAA -*metal fatigue. Please confirm that aging of these components will be managed using the new *Bolting Integrity' AMP.

Email Edit 5/1112006 - 3.1.1-02-P-01 Generic question 2: When bolting Integrity AMP Is added, many AMR Table 2 items need to be revised. Will VYNPS provide bolting Integrity program to manage bolts?

Response Revised Answer to 5/11/2006 email A Bolting Integrity Program Is In development that will address the aging management of bolting In the scope of license renewal. The Bolting Integrity Program will be implemented prior to the period of extended operation In accordance with commitment number #34.

The identification of TLAA - metal fatigue In the aging management program column Is provided as a convenient means to Indicate that these components are susceptible to cracking due to fatigue which Is addressed In Section 4.3.1 of the LRA as a TLAA. It Is not Implying that TLAA - metal fatigue Is an aging management program. An aging management program Is one of the three resolutions for the evaluation of a TLAA.

The component type closure flange studs, nuts, washers and bushings are for the reactor head and are managed by the Reactor Head Closure Studs Program described In Section B.1.23 of the LRAwhichls comparable with the NUREG-1801 Xl.M3 program. This approach Is consistent with the GALL Bolting Integrity program XI.M18 which states that the aging management of reactor head closure studs Is addressed by XI.M3, and Is not Included In this program. A Bolting Integrity Program Is In development that will address the aging management of other bolting In the scope of license renewal.

199 Category Closed Request 3.1.1-02-P-02 On page 3.1-54, the component type 'intemal attachments shroud support ring pad (1) shroud support feet (14) jet pump riser pads (20) core spray brackets (4) guide rod brackets (2) steam dryer brackets (4)dryer hold-down brackets (4* surveillance specimen holder brackets feedwater sparger brackets (8)' is managed using TLAA - metal fatigue. Please explain why these components are not managed in accordance with GALL v2 Item IV.B1-14.

Response Many NUREG-1 801, Volume 2 Items are very similar In terms of materials, environment, aging effect and aging management program. Where a NUREG-1 801 item lists the same component, the choice Is straightforward. Where NUREG-1 801 does not match the specific component, the selection of the Item to compare to the aging management review results Is somewhat arbitrary. Item IV.B1-14 would certainly have been an acceptable choice for the comparison. However, in this particular case, the components were considered a subset of the reactor vessel (hence the listing within the reactor vessel table) and the comparison was made to the fatigue Item within the NUREG-1 801 BWR reactor vessel table. The aging management review results in NUREG-1801 are the same for item IV.A1 -7 as for IV.B1-14.