ML062480276

Email: (PA) Printout of the VYNPS LRA Question Responses

ML062480276
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/28/2006
From:	Kennedy M Information Systems Labs, ISL
To:	Kaihwa Hsu, Mark Lintz, Morgan J, Dang Nguyen, Rowley J Office of Nuclear Reactor Regulation
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Download: ML062480276 (81)

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Kent Howard - Printout of the VYNPS LRA Question Responses Page 11*

Page...

From: Mike Kennedy <mkennedy@islinc.com>

To: "Michael Morgan" <MJM2@nrc.gov>, <mpl2@nrc.gov>, <krh2@nrc.gov>,

<dtnl @nrc.gov>, <jgr@nrc.gov>

Date: 4/26/2006 2:39:48 PM

Subject:

Printout of the VYNPS LRA Question Responses To NRC.Project Team Members:

Attached is a printout of the VY responses to the Project Team AMP questions. This was printed on Friday (4/21) before we left the plant site. This is for your use as you draft the evaluation paragraphs for your AMP write-ups. Ifyou have any questions, please let me know.

Regards, Mike CCO: Colleen Amoruso <camoruso @infosyslabs.com>, <tpfiester@ islinc.com>

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Printout of the VYNPS LRA Question Responses Creation Date 4/26/2006 2:16:55 PM From: Mike Kennedy <mkennedy@islinc.com>

Created By: mkennedy@islinc.com Recipients nrc.gov TWGWPOO1.HQGWDOO1 JGR (Jonathan Rowley)

DTN1 (Duc Nguyen)

MPL2 (Mark Lintz) islinc.com tpfiester CC infosyslabs.com camoruso CC (Colleen Amoruso) nrc.gov OWGWPOO2.HQGWDOO1 KRH2 (Kaihwa Hsu) nrc.gov ATLPO.ATLDO MJM2 (Michael Morgan)

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VY LRA - All Items Item Request Response Lead .Support Status Inspector:

I A-K-01 The LRA, Appendix B identifies the J im Devincentis Accepted Mike Morgan Please explain where the commitments for the various commitments for AMP enhancements.

AMP enhancements to bring the particular AMP in Consistent with how other NRC conformance to the GALL Report recommendations commitments are tracked VYs will enter are made? How are these commitments tracked to the commitments associated with License closure? Renewal into PCRS corrective action database as Work Tracking (WT) items.

We will do this when requested by the LR Project Manager who has a tracking item to define how all planned actions are tracked.

2 B.1.1-L-01 Yes, gray cast iron components subject to Steve Vekasy Lori Potts Accepted Lintz, Mark Program Description Item - The GALL states, "Gray aging management review are included in cast iron, which is included under the definition of the VYNPS selective leaching program.

steel, is also subject to a loss of material due to Reference LRA Section B.1.25 and Table selective leaching, which is an aging effect managed 3.3.2-8. [LAP 4/12106]

under Chapter XI.M33, 'Selective Leaching of Materials'." The LRA states, "This program includes (a) preventive measures to mitigate corrosion and (b) inspections to manage effects of corrosion on the pressure-retaining capability of buried carbon steel, stainless steel, and gray cast iron components." Are gray cast iron components included in the VYNPS selective leaching program?

3 B.1.1-L-02 Ifa focused inspection is required during Steve Vekasy Lori Potts Open Lintz, Mark Program Description Item - The LRA states, "A the first 10 years of the period of extended focused inspection will be performed within the first 10 operation, it will be conducted in years of the period of extended operation...." What is accordance with the criteria of NUREG-the extent of the focused inspection at the start of the 1801,Section XI.M34, Buried Piping and period of extended operation? Tanks Inspection. [LAP 4/12/06]

Modified Question: Program Description Item -The In section 4 of XI.M34 it states that any LRA states, "A focused inspection will be performed credited inspection should be performed within the first 10 years of extended operation... "On in areas with the highest likelihood of what areas will the "focused inspection" be focused? corrosion problems, and in areas with a history of corrosion problems. This defines the focused inspection that will be performed at VYNPS which will also include buried piping that has experienced external corrosion problems and areas that have conditions such as exposure to groundwater that could increase the likelihood of corrosion of buried piping.

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Item Request Response Lead Support Status Inspector:

4 B.1.1-L.-03 The basis for exclusion of tanks from the Steve Vekasy Ivy, Ted Accepted Lintz, Mark Scope of Program Element - The GALL Report states, Buried Piping Inspection Program is that "The program relies on preventive measures such as none of the metal tanks subject to aging coating, wrapping and periodic inspection for loss of management review are buried.

material caused by corrosion of the external surface Therefore, aging of tanks is managed by of buried steel piping and tanks." The LRA states, other programs. Reference LRA Sections "The VYNPS program does not inspect tanks. There 3.2.2.2.9 and 3.4.2.2.5, and Section 3.3 are no buried steel tanks subject to aging Tables (The only buried tank in the management review." What is the basis for including auxiliary systems is fiberglass.) [LAP piping but excluding tanks? 4/12106]

These were discussed in interview. When were responses written?

5 B.1.1-L-04 This is commitment #1 Steve Vekasy Ivy, Ted Open Lintz, Mark Parameters Monitored/Inspected Element - The GALL Vermont Yankee will enhance PP 7030, Report states, "Coatings and wrappings are inspected Structures Monitoring Program Procedure, by visual techniques." The LRA states, "Guidance for to provide additional guidelines for performing examinations of buried piping will be inspections of buried pipe and enhanced to specify that coating degradation and underground structures. Attributes to be corrosion are attributes to be evaluated." What is the considered will include:

VYNPS commitment number associated with this enhancement? 1. improved definition of the

. Buried piping is visually examined for evidence of scope of underground piping inspections corrosion damage or coating defects." A review of PP 2. define the condition of 7030, Section 4.3, does not identify the parameters coatings to be inspected, including that pertain to corrosion damage or coating defects. Is adhesion and discontinuities.

this the guidance that VY intends to enhance? 3. define the need to inspect piping underneath failed coatings

4. provide acceptance criteria, including removal of rust and an evaluation of remaining wall thickness against the minimum wall thickness requirements

5. provide instructions to notify Engineering for an inspection of any underground structures unearthed during excavation of piping.

See the master license renewal commitment list for tracking of this commitment.

Page 2 of 78 4/21/2006 1:46:04 PM 412112006 1:46:04 PM Page 2 of 78

Item Request Response Lead Support Status Inspector:

6 B.1.1-L-05 Buried components are inspected when Steve Vekasy Ivy, Ted Accepted Untz, Mark Detection of Aging Effects Element - The GALL excavated during maintenance. The Report states, "Inspections substituted for inspections exception merely states that alternate requiring excavation solely for the purpose of methods may be used to inspect buried inspection. Methods such as phased array UT components. Reference LRA Section technology provide indication of wall thickness for B.1.1. [LAP 4/12106]

buried piping without excavation. Use of such methods to identify the effects of aging is preferable to excavation for visual inspection, which could result in damage to coatings or wrappings." How are buried components that cannot be examined by UT, due to, e.g., either material or size, examined?

7 1B.1.2-P-1 B.1.2-P-1 DExceptions granted under the Dave King Finnin, Ron&Potts,L Closed Patterson, Malcol Exceptions granted under the current license are not current license are not assumed to apply assumed to apply to period of extended operation. to period of extended operation. Please Please confirm that the excepted weld is outside the confirm that the excepted weld is outside scope of license renewal. Also, explain why it need the scope of license renewal. As indicated not be inspected at least once in each inspection in LRA Tables 3.3.2-13-5 and 3.3.2-13-36, interval. the excepted welded connection is subject to aging management review for potential spatial interaction in accordance with 10 CFR 50.54 (a)(2). As stated in LRA Section B.1.2, exception Note 1, the welded connection need not be inspected at least once in each inspection interval because it is in a section of piping that is Safety Class 0 and has no license renewal function in accordance with 10 CFR 54.4 (a)(1) or (a)(3). [LAP 4/16/06]

Page 3 of 78 1:46:04 PM 4/21/2006 1:46:04 412112006 PM Page3 of 78

Item Request Response Lead Support Status Inspector:

I 8 B.1.7-H-01 'The BWR Vessel Internals Program Larry Lukens Finnin, Ron & Potts, Closed Hsu, Robert BWRVIP utilities have made a commitment that the includes provisions to notify the NRC if NRC will be notified by a BWRVIP licensee of their VYNPS does not implement a BWRVIP decision to not fully implement a BWRVIP report, as recommendation. Exceptions to the approved by the NRC staff, within 45 days of the NUREG-1 801 programs that invoke report approval. Please clarify the exceptions for not specific BWRVIP reports are identified in fully implementing BWRVIP report by VYNPS. Did Appendix B of the LRA. Reference LRA VYNPS define any new cases of not fully Section B.1.7 and LRPD-02 (AMPER) implementing BWRVIP in the VYNPS LRA? Section 4.7. [LAP 4/12/06]. The IWI program procedure is ENN-DC-135, and current revision includes the requirements of BWRVIP 94 Revision 1. VY has prepared a technical justification to defer the jet pump beam examinations to align with the refueling outage schedule as allowed by BWRVIP-94 (Revision in place at time of deviation). The BWRVIP requirements are based on 24 month cycles while VY is on a 18 month cycle.

The UT examinations of the Jet Pump beams are scheduled for the next refueling outage RFO 26 (2007).

BWRVIP 94 Revision 1, Section 3.5 provides guidance on the reporting requirements. A BWRVIP letter dated 12/20/2005 requires implementation by 8/112006. This is also addressed in the latest revision of EN N-DC-135.

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Item Request Response Lead Support Status Inspector:

I 9 B.1.7-H-02 This exception came from TJ-2004-01 in Larry Lukens Finnin, Ron &Potts, Accepted Hsu, Robert In the VYNPS LRA, pages B-28 & C-5, an exception PP 7027. BWRVIP owner to address to BWRVIP-25 is taken. UT & Enhanced VT-1 question. [LAP 4/12106] The BWR Core examinations are used to detect cracking and verify Plate Inspection and Flaw Evalaution the integrity of a critical number of rim hold-down Guideline (BWRVIP-25) recommend a UT bolts. VT-3 examination is used to detect general or EVT-1 examinations of core plate rim condition. Please provide further justification for the hold-down bolts for all plants that have not aging management of the cracking, since VT-3 cannot intalled core plate wedges. These bolts detect cracking. If EVT-1 cannot be performed, are the only location in the core plate please provide alternative for review and approval. requiring inspection. Utilities have determined the EVT-1 examinations are extremely difficult to perform and are of limited value. The Inspection committee of the BWRVIP has attempted to develop a UT technique, and has had limited success. However, the UT examination can only be performed on a limited number of existing bolt configurations and delivery hardware for the inspection equipment has not been developed. A screening tool presented to the BWRVIP Assessment Committee shows that VY has sufficient preload through 60 years of operating life to ensure the bolting will not be degraded and remain functional.

VY will either install core plate wedges or complete an analysis, including TLAA, to support continued inspection in accordance with BWRVIP- 25.

This is commitment # 29.

10 B.1.7-H-03 Same as previous question. [LAP Larry Lukens Finnin, Ron & Potts, Closed Hsu, Robert In the VYNPS LRA, page B-29, the applicant 4/12106] This question ties into the above identified a VT-3 examination as a baseline. The and the same answer would apply, i.e. the baseline inspection described in BWRVIP is the first BWRVIP is working developing an inspection that satisfies the guidelines in BWRVIP. inspection method.

Since VT-3 does not satisfy the BWRVIP guidelines, the inspection cited does not provide a baseline.

Please explain how the BWRVIP guideline will be met.

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Item Request Response Lead Support Status Inspector:

11 B.1.7-H-04 Portions of the Core Shroud horizontal Larry Lukens Finnin, Ron & Potts, Accepted Hsu, Robert In the VYNPS LRA, page B-27, (BWRVIP-76) Recent welds HI, H2 and H3 are scheduled for industry experience indicates that partial through-wall UT examination in RFO-26 (2007). The cracks from the inside diameter are possible. (They shroud tie rod repair was installed to have been detected at Plant Hatch.) How will replace the structural integrity of the cracking initiated from the inside surface of VYNPS's shroud horizontal welds. The tie rod core shroud welds H1, H2, and H3 be managed? repair does not replace vertical welds and relies on the H2/H3 support ring blocks to transfer loads to the tie rod radial seismic supports. Because of interferences the support ring block welds and vertical welds inside surface between H1 and H2 cannot be inspected. Portions of horizontal welds H1, H2, and H3 can be inspected in lieu of these welds and as such are characterized as "design reliant". Analysis performed by the shroud repair designer MPR Associates has determined the minimum design reliant weld lengths for H1, H2, and H3 required to ensure the tie rod repair and shroud functions as designed. This is consistent with the BWRVIP-76 requirement that the shroud tie rod repair designer provide the inspection requirements 12 B.1.7-H-05 Deferral of inspection of the inaccessible Larry Lukens Finnin, Ron & Potts, Open Hsu, Robert In the VYNPS LRA, page B-28 (BWRVIP-18 and welds is justified based on the following:

BWRVIP-41) BWRVIP-18 states that inspection The hidden jet pump welds are far enough technique development needed for the thermal sleeve into the nozzle that failure at these welds welds is being addressed by the BWRVIP inspection would not result in the thermal sleeve committee as a high priority item (since 1996). The disengaging from the nozzle before the Final License Renewal SER for BWRVIP-41 states riser contacted the shroud. Ifthe jet pump that aging management review of the nozzle thermal thermal sleeve or riser piping severed, it sleeve (jet pump inaccessible welds) will be provided would be detected through jet pump by individual applicants. Please provide plant-specific monitoring, which alarms if the riser pipe justification/commitment to demonstrate that these moves more than 10% while at or above a inaccessible welds will be adequately managed during core flow of 42 Mlbthr. . Reference LRA the period of extended operation. page B-30. [LAP 4/12/06].

The response still does not address the inspection requirement. Further discussion required.

(KRH) 4/2112006 1:46:04 PM Page 6 of 78

Item PRflLIPst Response Lead SuonOrt Status Inspector:

-te

-Rwet Rs-ns 13 B.1.7-H--06 TE-2003-0021 from Appendix.C of PP Larry Lukens Finnin, Ron & Potts, Closed Hsu, Robert In the VYNPS LRA, page B-28 (BWRVIP-41) The 7027 will be provided during on-site audit.

VYNPS LRA states that flaws were identified through References used to prepare TE-2003-UT examinations. Please provide detailed inspection 0021 will be available for on-site review evaluation, scope expansion and corrective action upon request. [LAP 4/11/06]

information for the staff's review. Flaw evaluations were performed for the jet pump diffuser welds, jet pump riser welds, and the core spray collar welds.

The jet pump riser flaw evaluation calculation number is VYC-2400. The core spray collar weld flaw evaluation report number is VY-RPT-05-00015 and should be available in Curator/Merlin.

100% of the JP diffuser welds were inspected by UT in RFO 21 (1999). The flawed diffuser welds were reinspected by UT in RFO 23 (2002) with little change in flaw sizes. 26 of 30 JP riser welds were UT inspected in RFO 20 (1998) and 4 welds were inspected by VT-1 with cleaning. The flawed riser welds were re-inspected by UT in RFO 22 (2001) with no crack growth on 2 welds and two previous indications were determined to be due to UT transducer liftoff. 100 % of the core spray collar welds were examined by UT in 1996. The flawed collar welds were reinspected by UT in RFO 22 (2001) with no change in flaw sizes. The flawed Jet Pump diffuser/riser welds and the Core Spray collar welds are scheduled to be inspected by UT during RFO 26 (2007).

Future re-inspections will be performed in accordance with BWRVIP requirements.

14 B.1.7-H-07 The BWR Vessel Internals Program at Larry Lukens Finnin, Ron & Potts, Accepted Hsu, Robert In the VYNPS LRA, page B-31 (BWRVIP-26) The VYNPS is consistent with the program VYNPS LRA states that an inspection will be described in NUREG-1801, Section performed for the first 12 years of the period of XI.M9, BWR Vessel Internals with the extended operation (PEO). Please clarify what exceptions and enhancement noted in inspections (if any) will be performed for the remaining LRA Section B.1.7. As stated in NUREG-PEO. 1801, 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. [LAP 4/12/06]

412112006 1:46:04 PM Page 7 of 78

Item Request Response Lead Support Status Inspector:

15 B.1.8-L-01 The term latent in this context means: not Ted Underkoffler Ahrabli, Reza Accepted Lintz, Mark Operating Experience Element - The LRA states, "A currently affecting program effectiveness, QA audit in 2001 revealed latent noncompliance with but with the potential for affecting program station administrative and Appendix J implementing effectiveness if not corrected. While procedures." Please clarify the meaning of 'latent" in technical details were followed, this context. administrative details within procedures were not always followed. This procedural Added:Scope of Program item. Are any other noncompliance, if not corrected, could examinations/tests performed, in addition to the have diminished the effectiveness of the integrated leakage rate and the local leakage rate program. Reference Audit Report VY-tests? 2001-26. [LAP 4/12/06]

There are no additional tests or examinations are performed under the Containment Leak Rate Program. As a support to the Type A testing, examinations of the accessible interior and exterior surfaces of the containment system are conducted in accordance with the Containment Inservice Inspection Program at the periodicity specified in RG 1.163.

Revised Response:

The term latent in this context means: not currently affecting program effectiveness, but with the potential for affecting program effictiveness if not corrected. While technical details were followed, administrative processes, associated with test record retention, were impletmented outside the established requirements. This procedural noncompliance, if not corrected, could have diminished the effectiveness of the program. Reference Audit Report VT-2001-26 (FTU 4/19/06) vtrfl.r. ~ -flrv -.- *-t-r.rrvt-r--.-v ~ - Page 8 of 78 1:46:04 PM 4/21/2006 1:46:04 412112006 PM Page 8 of 78

Item Request Response Lead Support Status Inspector:

16 B.1.9-K-01 Rick Gerdus Lod Potts Accepted Kennedy, Mike Please demonstrate that the guidelines provided in D2276 are consistent with or more stringent than the ASTM D 2276 provides guidance on guidelines provided in D6217 to justify the use of determining particulate contamination D2276 only. using a field monitor. It provides for rapid assessment of changes in contamination level without the time delay required for rigorous laboratory procedures. It also provides a laboratory filtration method using a 0.8 micron filter. ASTM D 6217 provides guidance on determining particulate contamination by sample filtration at an off-site laboratory. The acceptance criterion of D 2276 is 10 mg/liter while that of D 6217 is 24 mg/liter. Therefore, D 2276 is more stringent than D 6217. Since ASTM D2276 is an accepted method of determining particulates and is a method recommended by ASTM D975, to which VYNPS is committed by Technical Specifications, the D 2276 method is used at VYNPS. [LAP 4/18/06]

17 B.1.9-K-02 As stated in the program description in Rick Gerdus Lori Potts Accepted Kennedy, Mike Are the guidelines provided in D4057 addressed in LRA Section B.1.9, sampling and analysis this program? Ifnot, please justify excluding this activities are in accordance with technical standard as an exception to the GALL Report specifications on fuel oil purity and the recommendations. guidelines of ASTM standards D4057-88 and D975-02 (or later revisions of these standards). Reference LRA Section B.1.9, Program Description. [LAP 4/12/06]

18 B.1.9-K-03 Vermont Yankee purchases un-dyed, low Rick Gerdus Lori Potts Accepted Kennedy, Mike Please indicate what additives, if any, are provided by sulfur #2 diesel fuel for use in safety-the fuel oil supplier. Please provide a copy of a recent related systems. Additives are not used fuel oil procurement specification or supplier by Vermont Yankee or the fuel supplier.

declaration which indicates what fuel oil additives are The diesel fuel currently comes from included as well as any tests that may have been Ultramar (a Canadian refinery) to a local performed by the fuel oil supplier or by VYNPS. supplier. The refinery blends fuel to meet a given specification and may use some additives such as cetane enhancers.

Refinery use of additives is not described in their specification and is outside the control of the end user. Biocides have never been added to the onsite fuel supply. [Rick Gerdus 4/18106 4/21/2006 1:46:04 PM Page 9 of 78

Item Request Response Lead Support Status Inspector:

19 B.1.9-K-04 As stated in LRA Section B.1.9, exception Rick Gerdus Lori Potts Accepted Kennedy, Mike Please provide the technical justification for not note 2, plant operating experience has not adding fuel oil additives. indicated a need for additives. Reference LRA Section B.1.9, exception note 2. [LAP 4/12106]

Fuel additives are generally required for three reasons. These are to maintain the stability of the fuel oil, change the properties of the fuel oil (e.g. increase the ignition quality) or to prevent bacterial or mold growth in the fuel oil. The addition of biocides may degrade some of the other fuel oil properties such as increasing the filterable solids loading.

For the past 10 years, Vermont Yankee has been buying high quality fuel oil from Ultramar in Canada. Our deliveries are timed to the arrival of new rail cars in Vermont from this refinery. We specify very high quality fuel oil and ensure that it and the delivery trucks do not contain any contaminants. Monthly analyses of diesel fuel oil from the top, middle and bottom of the Main Fuel Oil Storage Tank have not produced any indications of fuel oil deterioration or the presence of water or sediment. Since mold and bacteria grow in the water fuel oil interface, we have no need for biocides.

There have been no diesel performance issues associated with the quality of the diesel fuel oil. Thus there is no need for fuel oil additives.

4/21/2006 1:46:04 PM Page 10 of 78

Item Request Response Lead Support Status Inspector:

20 B.1.9-K-05

• The Diesel Fuel Monitoring Program Rick Gerdus Lori Potts Accepted Kennedy, Mike Please describe what parameters are monitored or monitors fuel quality and levels of water in inspected and indicate what guidance is used for fuel the fuel oil. ASTM D4057-88 (or a later oil sampling. Please provide a copy of a revision of this standard), Standard representative plant procedure for fuel oil sampling. Practice for Manual Sampling of Petroleum and Petroleum Products, is used for guidance on oil sampling. Safety-related diesel fuel oil is analyzed according to ASTM D975-02 (or a later revision of this standard). ASTM D1796 is used to check for water and sediment.

Determination of particulates is according to ASTM Standard D2276. Reference LRPD-02 (AMPER) Section 4.9.

Exceptions to NU REG-1 801 Section XI.M30 parameters monitored/inspected are described in LRA Section B.1.9.

Procedure OP-4613 is available for on-site review in the program basis document.

[LAP 4/12106]

21 B.1.9-K-06 As stated in LRASection B.1.9, the Diesel Rick Gerdus Lori Potts Accepted Kennedy, Mike Is multi-level sampling used to detect the presence of Fuel Monitoring Program is consistent with contaminants in the fuel oil and, if not, please provide NUREG-1801,Section XI.M30 for the the technical justification for the approach used at the detection of aging effects attribute. As plant? described in NUREG-1801, periodic multi-level sampling is used to provide assurance that fuel oil contaminants are below unacceptable levels. Reference LRA Section B.1.9 and LRPD-02 (AMPER) Section 4.9. [LAP 4/12106 Page '11 of 78 Page 11 of 78 4/2112006 1:46:04 PM 412112006 1:46;04 PM

Item Request Response Lead Support Status Inspector:

22 B.1.9-K-07 As stated in LRA Section B.11.9, the Diesel Rick Gerdus Lori Potts Accepted Kennedy, Mike Are the interior surfaces of the fuel oil tanks visually Fuel Monitoring Program is consistent with inspected and, if so, provide a copy of a NUREG-1 801,Section XI.M30 for the representative plant procedure used for the tank detection of aging effects attribute. As inspection? described in NUREG-11801, the fuel oil storage tank is periodically drained, cleaned and visually inspected to detect potential degradation. Reference LRA Section B.11.9 and LRPD-02 (AMPER)

Section 4.9. PM Activity 3 of PM Basis MI 18 is available for on-site review in the program basis document. [LAP 4/12/06]

The diesel day tanks are 800 gallon tanks located above ground and adjacent to the emergency diesels in separate rooms.

The design of the tanks does not provide access for cleaning. The fuel oil for these tanks is supplied from the Main Fuel Oil Storage Tank. The suction for the transfer pumps is located 4" off of the bottom of the tank. Chemistry samples both the Main Tank and the Day tanks from the bottom of the tanks. Any water or sediment in the Main Storage Tank would be detected prior to it being transferred to the Day Tanks.

Each of the emergency diesels is run for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> monthly with each diesel using approximately 200 gallons of fuel oil per hour. This ensures that the fuel oil is turned over every month and that there are no stability issues. There have been no indications of water and sediment in the quarterly analyses from these tanks.

Since Vermont Yankee is sampling from the bottom of these tanks,and if we are not detecting problems with the fuel oil, there is no reason to crain and clean the tanks.

The John Deere diesel is run under load monthly for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The diesel uses 10 gallons per hour and the surveillance requires verification of auto feed. The fire pump diesel is operated during monthly and quarterly surveillance tests. Thus the fuel in the metal tanks associated with the John Deere and fire pump diesels is turned over frequently.

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Page 12 of 78

Item Request Response Lead Support Status Inspector:

23 B.1.9-K-08 A 1996 ultrasonic thickness measurement Rick Gerdus Lori Potts Accepted Kennedy, Mike Are UT measurements conducted on the fuel oil tank of the fuel oil storage tank bottom surface bottoms? How often are these measurements taken revealed no significant degradation. The and provide a copy of a representative plant Diesel Fuel Monitoring Program includes procedure which governs these measurements? an enhancement to perform UT measurements of the fuel oil storage tank bottom surface every 10 years during the period of extended operation. Reference LRA Section B.1.9. WO 94-08951, with the results of the 1996 UT measurement, is available for on-site review in the program basis document. [LAP 4/12/06]

24 B.1.9-K-09 The Diesel Fuel Monitoring Program is Rick Gerdus Lori Potts Accepted Kennedy, Mike How often is the fuel oil in the tanks sampled? Is this consistent with NUREG-1 801, Section data trended and what criteria is used to initiate XI.M30 for the monitoring and trending corrective actions? attribute. As described in NUREG-1801, monitoring (sampling) and trending occurs at least quarterly, and in accordance with plant technical specifications (monthly).

Reference LRA Section B.1.9 and technical specification 4.10.C.2. Filterable solids acceptance criterion is = 10 mg/I.

Water and sediment acceptance criterion is = 0.05%, UT acceptance criterion will be = 60% Tnom. Reference LRA Section B.1.9 and LRPD-02 (AMPER) Section 4.9.

[LAP 4/12/06]

25 B.1.9-K-10 The review of plant operating experience Rick Gerdus Lori Potts Accepted Kennedy, Mike Have there been any component failures related to did not reveal any component failures the quality of the fuel oil which led to the loss of related to the quality of the fuel oil which intended function? led to the loss of intended function.

Reference LRA Section B.1.9 and LRPD-05 (OE Report). [LAP 4/12/06]

ýC- --. -.- "ý- ". t 4/21/2006 1:46:04 PM Page 13 of 78

Item Request Response Lead Support Status Inspector:

26 B.1.10-N-01  : VYNPS may perform reanalysis of an Al Haumann Stroud, Mike Accepted Nguyen, Duc The results of the EQ of electrical equipment in LRA aging evaluation in order to extend the Section 4.4. indicate equipment identified in the qualification of electrical components TLAA. The important attributes of a re-analysis are under 10 CFR 50.49E on a routine basis the analytical methods, the data collection, the as part of the plant's EQ program.

reduction methods, the underlying assumptions, the Important attributes for the reanalysis of acceptance criteria, and corrective actions. Provide an aging evaluation include analytical information on these important attributes of re- methods, data collection and reduction analysis of an aging evaluation of electrical equipment methods, underlying assumptions, identified in the TLAA to extend the qualification under acceptance criteria, and corrective 10 CFR 50.49(e) actions.

VYNPS may apply this reanalysis program to EQ components now qualified for the current operating term.

A reanalysis program, which meets the conditions defined in the GALL report for important attributes, is an acceptable AMP for license renewal under option 10 CFR 54.21(c)(1)(iii).

27 B.1.10-N-02 The EQ program (10 CFR 50.49) does Al Haumann Stroud, Mike Accepted Nguyen, Duc GALL X.E1, Environment Qualification (EQ) of Electric not require environmental monitoring, Components, under "Parameter Monitored/Inspected" because the EQ components are qualified states that EQ component qualified life is not based based on conservative bounding plant on condition or performance monitoring. However, environments.

pursuant to Regulatory Guide 1.89, Rev. 1, such The VYNPS EQ program, consistent with monitoring programs are an acceptable basis to GALL X.EI, ensures that the components modify a qualified life through analysis. Monitoring or covered by the program are replaced at inspection of certain environmental conditions or the end of the qualified life or the qualified component parameters may be used to ensure that life is modified by analysis in accordance the component is within the bounds of its qualified with the applicable regulations governing basis, or as a means to modify the qualified life. the program.

Provide a detailed description of a monitoring program to modify the qualified life of EQ components through re-analysis and how the actual operating environment is determined.

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Item Request Response Lead Support Status Inspector:

28 B. .10-N-0 28 B.1.10-N-03 The EQ program is a qualification Al Haumann Stroud, Mike Accepted Nguyen, Duc Discuss operating experience of the existing EQ program that assures SSCs are replaced program. Show where an existing program has prior to exceeding qualified life beyond succeeded and where it has failed in identifying aging which unacceptable aging degradation degradation in a timely manner. may occur. The review of OE identified no conditions in which the program failed to identify unacceptable aging degradation. License Event Report (LER) 97-20 notified the NRC staff of significant program deficiencies including non-conservative analytical methods.

Supplementary and confirmatory analyses were completed because conditions in the EQ analyses were determined to be non-conservative.

This OE demonstrates that the corrective action process is used to document program deficiencies and track corrective actions when necessary.

QA audits in 2000 and 2002 identified deficiencies related to maintenance and content of program documentation.

A 2004 QA audit and engineering program health report determined the program is effective and being administered and maintained in a manner that meets regulatory requirements and commitments.

Revised: 4/20/06 MDS

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Item Request Response Lead Support Status Inspector:

29 B.1.11-P-1 The impact of environmental factors on Jim Fitzpatrick Finnin, Ron &Potts, Accepted Patterson, Malcol Please clarify the basis for excluding the impact of fatigue at critical locations during the environmental factors for critical locations during the period of extended operation will be period of extended operation. addressed as stated in the following commitment.

Prior to entering the period of extended operation, for each of the seven location that may exceed a CUF of 1.0 when considering environmental effects, VYNPS will implement one or more of the following: (1) further refinement of the fatigue analyses to lower the predicted CUFs to less than 1.0; (2) management of fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC (e.g.,

periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC); (3) repair or replacement of the affected locations.

Should VYNPS select the option to manage environmental-assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method, and frequency will be provided to the NRC prior to the period of extended operation.

Reference LRA Section 4.3.3. [LAP 4/12/06]

(See License Renewal Commitment No.

27)

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Item Request Response Lead Support Status Inspector:

30 B.1.12.1-L-01 The Halon 1301 suppression system Larry Lukens Ivy, Ted Open Lintz, Mark Program Description Item - The GALL states, "The provides fire suppression only for the AMP also includes periodic inspection and testing of computer room. There are no Appendix the halon/carbon dioxide (C02) fire suppression A, SER commitments or Appendix R system." The LRA does not address the halon/carbon commitments requiring the Halon 1301 dioxide (C02) fire suppression system. On what suppression system. Therefore, it is not basis does the LRA not address the halon/carbon subject to aging management review.

dioxide (C02) fire suppression system? Aging effects for components in the C02 system are managed by the System Walkdown Program. Reference LRA Section B.1.12.1, exception note 1; LRA Table 3.3.2-9; and AMRM-17 (Aging Management Review of the Fire Protection -Water System). [LAP 4/12/06]

VY will perform C02 system walkdowms every 6 months starting no later than the period of extended operation.

31 B.1.12.1-L-02 The computer room fire suppression is Larry Lukens Ivy, Ted Accepted Lintz, Mark Scope of Program Element - The GALL states, "The provided by a Halon 1301 suppression AMP also includes management of the aging effects system. There are no Appendix A, SER on the intended function of the halonICO2 fire commitments or Appendix R suppression system." The LRA states, "This program commitments requiring the Halon 1301 is not necessary to manage aging effects for halon suppression system. Therefore, it is not fire protection system components." What program subject to aging management review.

will manage aging effects on halon system Reference AMRM-1 7 (Aging Management components? Review of the Fire Protection - Water System). [LAP 4/1 2106]

32 B.1.12.1-L-03 The computer room fire suppression is Larry Lukens Ivy, Ted Accepted Lintz, Mark The LRA states "the Halon 1301 suppression system provided by a Halon 1301 suppression is not subject to aging management review. Aging system. There are no Appendix A, SER effects for components in the C02 system are commitments or Appendix R managed by the System Walkdown Program." commitments requiring the Halon 1301 Explain rational for why the Halon 1301 suppression suppression system. Therefore, it is not system is not subject to review. subject to aging management review.

Reference AMRM-17 (Aging Management Review of the Fire Protection - Water System). [LAP 4/1 21061 Page 17of78 412112006 1:46:04 PM 4/21/2006 1:46:04 Page 17 of 78

Ite*m Request Response Lead SuoDort Status Inspector:

33 B.1.12.1-L-04 Need a commitment to revise the Larry Lukens Ivy, Ted Open Lintz, Mark Parameters Monitored/Inspected Element - The GALL procedure to examine the fuel line.

Report states, "The diesel-driven fire pump is under observation during performance tests such as flow This is commitment # 9.

and discharge tests, sequential starting capability tests, and controller function tests for detection of any degradation of the fuel supply line." The LRA states, "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 number associated with this enhancement?

34 B.1.12.1-L-05 The environment to which inaccessible Larry Lukens Ivy, Ted Accepted Lintz, Mark Detection of Aging Effects Element - The GALL seals are exposed is very similar, if not Report states, "Visual inspection by fire protection the same, as the environment for qualified inspectors of approximately 10% of each accessible seals such that the condition of type of seal in walkdowns is performed at least once accessible seals is representative of the every refueling cycle." The LRA states, "The NUREG- condition of inaccessible seals. [TSI 1801 program states that 10% of each type of 4/13/061 penetration seal should be visually inspected at least once every refueling outage. The VYNPS program specifies inspection of approximately 25% of the seals (regardless of seal type) each operating cycle, with all accessible fire barrier penetration seals being inspected at least once every four (4) operating cycles. Since aging effects are typically manifested over several years, this variation in inspection frequency is insignificant." How are inaccessible seals addressed?

35 B.1.12.1-L-06 Need a commitment to revise acception Larry Lukens Ivy, Ted Open Lintz, Mark Acceptance Criteria Element - The GALL states, criteria.

"Inspection results are acceptable if there are no visual indications (outside those allowed by approved Any recordable indication is extended into penetration seal configurations) of cracking, the corrective action program for separation of seals from walls and components, evaluation.

separation of layers of material, or ruptures or punctures of seals; no visual indications of concrete This is commitment # 8.

cracking, spalling 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 states, "Acceptance criteria will be enhanced to verify no significant corrosion." How much corrosion is considered "significant?" What actions are taken, either with or without "significant corrosion"? Is there a VYNPS commitment number associated with this enhancement?

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Item Request Response Lead Support Status !nspector:

36 B.1.12.2-L-01 No, VYNPS does not have fire water Larry Lukens Ivy, Ted Accepted Lintz, Mark Program Description Item - The GALL states, "This storage tanks. Reference UFSAR Section aging management program (AMP) applies to water- 10.11. [LAP 4/12106]

based fire protection systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, water storage tanks, and aboveground and underground piping and components that are tested in accordance with the applicable National Fire Protection Association (NFPA) codes and standards." The LRA states, "This aging management program applies to water-based fire protection systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, and aboveground and underground piping and components that are tested in accordance with applicable National Fire Protection Association (NFPA) codes and standards." Does VYNPS have fire water storage tanks?

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37 B.1.12.2-L-02 This paragraph comes from NUREG- Larry Lukens Ivy, Ted Open Lintz, Mark Program Description Item - The GALL states, "The 1801,Section XI.M27 program fire protection system piping is to be subjected to description. The recommendation for flow required flow testing in accordance with guidance in testing is included in the NUREG-1801 NFPA 25 to verify design pressure or evaluated for technical basis for the parameters wall thickness (e.g., non-intrusive volumetric testing or monitored/inspected attribute. As stated plant maintenance visual inspections) to ensure that in LRA Section B>11.1 2.2, the VYNPS Fire aging effects are managed and that wall thickness is Water System Program is consistent with within acceptable limits. These inspections are this attribute. Every fire main segment is performed before the end of the current operating full flow tested using the guidelines of term and at plant-specific intervals thereafter during NFPA 25 at least once every 3 years.

the period of extended operation. The plant-specific Reference LRPD-02 (AMPER) Section inspection intervals are to be determined by 4.12.2.

engineering evaluation of the fire protection piping to ensure that degradation will be detected before the loss of intended function. The purpose of the full flow The recommendation for wall thinning testing and wall thickness evaluations is to ensure monitoring is included in the NUREG-1 801 that corrosion, MIC, or biofouling is managed such technical basis for the detection of aging that the system function is maintained." The LRA effects attribute. As indicated in LRA does not address this item. How does VYNPS intend Section B.1.12.2, the Fire Water System to address these NFPA and GALL recommendations? program includes an enhancement to this attribute to perform wall thickness evaluations of fire protection piping 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 at intervals thereafter. Results of the Initial evaluations will be used to determine the appropriate inspection interval. [LAP 4/16/06]

Commitment # 11 38 B.1.12.2-L-03 Per NUREG-1 800, Table 2.1-3, fire hoses Larry Lujkens Ivy, Ted Accepted Lintz, Mark Detection of Aging Effects Element - The GALL are consumables not subject to aging Report states, "Fire hydrant hose hydrostatic tests, management review. Therefore, the gasket inspections, and fire hydrant flow tests, exception to the Fire Water System performed annually, ensure that fire hydrants can program related to fire hydrant hose perform their intended function and provide hydrostatic tests is not necessary. [LAP opportunities for degradation to be detected before a 4/12/06] An aging management program loss of intended function can occur." The LRA states, is not required to address components "NUREG-1801 specifies annual fire hydrant hose that are not subject to aging management hydrostatic tests. Under the VYNPS program, review. [ABC 4/13/06]

hydrostatic test of outside hoses occurs once per 24 months; and hydrostatic test of inside hoses occurs Agree to annual.

once per 3 years." Provide justification for relaxing the test frequency.

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Item Reauest Response Lead Support Status Inspector:

39 B.1.12.2-L-04 Since aging effects are typically Larry Lukens Ivy, Ted Open Lintz, Mark Detection of Aging Effects Element - The GALL manifested over several years, differences states, "Fire hydrant hose hydrostatic tests, gasket in inspection and testing frequencies are inspections, and fire hydrant flow tests, performed insignificant. The review of operating annually, ensure that fire hydrants can perform their experience did not reveal age-related intended function and provide opportunities for failures of fire water system components degradation to be detected before a loss of intended that led to loss of intended function.

function can occur." The LRA states, "NUREG-1801 Reference LRA Section B.1.12.2, specifies annual gasket inspections. Under the exception note 1 and LRPD-05 (OE VYNPS program, visual inspection, re-racking and Report). [LAP 4/12/06]

replacement of gaskets in couplings is to occur at least once per 18 months." Provide justification for relaxing the test frequency.

40 B.1.12.2-L-05 As stated in LRA Section B.1.12.2, Larry Lukens Ivy, Ted Open Lintz, Mark Detection of Aging Effects Element - The GALL exception note 1, since aging effects are states, "Fire hydrant hose hydrostatic tests, gasket typically manifested over several years, inspections, and fire hydrant flow tests, performed differences in inspection and testing annually, ensure that fire hydrants can perform their frequencies are insignificant. The review intended function and provide opportunities for of operating experience did not reveal age-degradation to be detected before a loss of intended related failures of fire water system function can occur." The LRA states, "NUREG-1801 components that led to loss of intended specifies annual fire hydrant flow tests. Under the function. Reference LRPD-05 (OE VYNPS program, verification of operability and no Report). [LAP 4/16/06]

flow blockage occurs at least once every 3 years."

Provide justification for relaxing the test frequency. Agree to annual.

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Item Request Response Lead Support Status Inspector:

41 B.1.12.2-L-06 This is commitment #11. Larry Lukens - John Cox, Alan Open Lintz, Mark Detection of Aging Effects Element - The GALL Report states, "Fire protection system testing is performed to assure that the system functions by maintaining required operating pressures. Wall thickness evaluations of fire protection piping are performed on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections are performed before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation."

The VYNPS LRA identified the following enhancement, "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 at intervals thereafter 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." What is the VYNPS commitment number associated with this enhancement?

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Item Recquest Response Lead Support - Status Inspector:

I 42 B.1.15.1-W-01 Portions of drawings G-191150, G- ' Ted Underkoffler Ahrabli, Reza Closed Woodfield, Jon Provide drawings for the sand pocket region of the 191277, & G-1 91481 have been provided Drywell. Provide drawings for the refueling bellows to the NRC for the Sand pocket region of detailing how they are stored, installed, connected the Drywell; Refueling Bellows and sealed. Provide procedures for how the refueling assemblies, and the General Arrangement bellows are used. Provide drawings of the Drywell of the Reactor Building including the showing the gap and fill material between the Primary Containment.

secondary concrete shield wall from the refueling bellows/cavity seal connection down to the sand The Refueling Bellows (to RPV) and the pocket region. Provide the VYNPS response to Drywell to Reactor Cavity Seal assemblies Generic Letter 87-05. are permanently installed by full penetrant welds. The bellows allow the Refueling Cavity to be flooded during refueling operations to allow for spent fuel transfer to the Spent Fuel Pool for storage. No procedures are required for the operation of the bellow assemblies since they are static. Operation of the drain line isolation valves are controlled by plant operating procedures used for flood-up and drain-down of the cavity.

There is no fill material in the gap located between the Drywell Shell and the Secondary Concrete Shield.

VYNPS response to GL 87-05 has been provided to the NRC.

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Item Reauest Response Lead Support Status Inspector:

I 43 B.1.15.1-W-02 VY does have a service level I coating Ted Underkoffler Ahrabli, Reza & Pott Closed Woodfield, Jon It is stated in the VYNPS UFSAR that all interior and program, however it is not relied on for exterior drywell surfaces which are exposed to the managing the aging effects for licensing atmosphere are protected from corrosion by renewal.

application of a corrosion resistant coating material.

However, in the VYNPS LRA itis stated that VYNPS The VY UFSAR states: "No material within does not rely on protective coating to manage the primary containment will fail by effects of aging. The VYNPS LRA Appendix B does decomposition or corrosion and affect vital not have a Protective Coating Monitoring and systems." The examination of the coated Maintenance Program section. However, there is a surfaces is performed as a part of the GALL AMP XI.S8 called Protective Coating Monitoring Containment Inservice Inspection and Maintenance Program which states the following: Program (IWE) to assure that the paint Proper maintenance of protective coatings inside and base metal has not degraded (TS containment (defined as Service Level I)is essential Section 4.7.A). VY has an active and to ensure operability of post-accident safety systems effective Service Level I Coatings that rely on water recycled through the containment Program to prevent degradation to the sump/drain system. Explain why VYNPS does not primary containment structure.

have a Service Level I Protective Coating Monitoring and Maintenance Program to prevent coating failure VY response to GL 98-04 includes our that could adversely affect the operation of post- commitment to EPRI TR-1 09937 accident fluid systems and thereby impair safe "Guideline on Nuclear Safety-Related shutdown. Provide a copy of the VYNPS response to Coatings (renumbered 1003102). The GL GL 98-04 and discuss if VYNPS considers the also discusses the impact of debris maintenance programs described acceptable coatings loading on the ECCS strainers. These AMPs for license renewal. strainers were designed to accept 100%

of the coatings within the LOCA zone of influence. The approach velocity of materials entrained in the torus water is extremely low due to the sizing of the ECCS strainers. Conservative design assumptions ensures VY compliance with 10CFR50.46(b)(5).

A copy of VY response to GL 98-04 has been provided.

[FTU 4/20106]

412112006 1:46:05PM ~~'~~~r.-&~~ag 24~rrtrrnrr'rttr of 7

Item Request Response Lead Support Status Inspector:

44 B.1.15.1-W-03 Entergy chose to describe the Inservice Ted Underkoffler Ahrabli, Reza Closed Woodfield, Jon Explain why the Containment Inservice Inspection Inspection and Containment Inservice Program is a plant-specific program instead of a Inspection Programs as plant-specific ASME Section XI, subsection IWE program with programs rather than comparing to the exceptions. Explain why the scope of the corresponding NUREG-1801 programs Containment Inservice Inspection Program does not because the NUREG-1 801 programs include containment seals, gaskets and pressure contain many ASME Section XI table and retaining bolts. Explain under what VYNPS AMPs the section numbers which change with inspection of these components are performed. It is different versions of the code. Because of stated in the VYNPS LRA that the Containment this, comparison with the NUREG-1 801 Inservice Inspection Program is an existing program. programs generates many exceptions and Explain if this program has been in compliance with explanations which detract from the ASME Section XI, subsection IWE since the final objective of the comparison. What is rulemaking to require IWE inspections was made by really needed is that VYNPS follow the the NRC in 1996. Provide a copy of the VYNPS version of ASME Section XI that is notification of commitment to IWE inspections. approved for use at VYNPS and accepted by law in 10CFR50.55(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.

[LAP 4/13/06]

The Containment Inservice Inspection Program does not include containment seals or gaskets because they have been removed from the scope of Subsection IWE in the 1998 Edition of ASME Section Xl with 2000 Addenda. These components are inspected under the Structures Monitoring Program as indicated in Table 3.5.2.1 of the LRA.

[LAP 4/13/06] Pressure retaining bolts are considered and included as integral part of the structural components. [AA]

The Containment Inspection Program does not include containment seals or gaskets because they have been removed from the scope of Subsection IWE in the 1998 Edition of ASME Section XI with 2000 Addenda. These components are seal tested under the Containment Leak Rate Program.

Pressure retaining bolts are considered and included as Containment Inservice Inspection Program. (FTU 4/20/06)

VY has been incompliance

,~v. ~

PM

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Item Request Response Lead Support Status Inspector:

withi10CFR50.55a (b)(2)(vi) and (b)(2)(ix) since at least September 9, 2001. No notification of commitment to the IWE examinations was required by 10CFR50.55a. In 2003, VY submitted a notification of the intent to use ASME Section XI -1998 Edition with 2000 Addenda as the .Codeof Record for all ISI programs. A copy of the submittal has been provided. [FTU 4/20/06]

45 B.1.15.1-W-04 Examinations are performed in Ted Underkoffler Ahrabli, Reza Closed Woodfield, Jon Explain how inspections are performed in the torus accordance with the Code of Record suppression pool above and below the waterline. which requires that all accessible interior Explain historically what inspection findings have lead and exterior surfaces areas be examined.

to the need for augmented inspections. Explain if any In 1998, the interior surface, slightly above augmented inspections are currently being and fully below the water line, was performed. The LRA states that VYNPS uses stripped and coated. During RFO-24 inspection program B for containment inservice (2004), the Suppression Pool exterior inspection. Provide the Inspection interval dates surface was General Visual examined.

through the current license and also through a Though normally inaccessible, the possible license extension period. Suppression Pool interior was made accessible and the surface above the water-line was General Visual examined.

During the General Visual examination of the interior surface, the water clarity permitted observation of nearly 100% of the submerged surface area. Three small areas (at the water line) in BAY 3 were identified to have a loss of coating and primer. These areas were UT (ultrasonic tested) from the exterior, in 2 gridded areas. No result approached the nominal wall thickness of 0.533" with the lowest reading being 0.597.* Based on the results, these areas were excluded from augmented examination. In RFO-27 (2008), the VT-3 of the wetted areas is presently planned to be executed by divers without dewatering the Suppression Pool. The current examination schedule is contained in Program Bases Document (4.14.2) inthe PP 7024 tables. The projected schedule through the possible license extension period will be developed in accordance with the Code in effect but should be 6 inspection periods in 20 years. [FTU 4/20/06]

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Item Reauest Response Lead Support Status Inspector:

I 46 B.1.15.1-W-05 Reference to drywell moisture barrier in Ted Underkoffler Closed Woodfield, Jon VYNPS lists several Containment Inservice Inspection section B.1.15.1, operating experience is findings under operating experience for AMP B.1.15.1 intended to provide relative location of the in the LRA. Explain why the operating experience inspection area only. Drywell moisture discusses the drywell moisture barrier when the barrier is inspected under structures inspection of it does not appear to be in the scope of monitoring program (B.1.27.2). (Site to the VYNPS Containment Inservice Inspection provide the rest, including QA surveillance Program. Provide the documentation for any report referenced in RFO 24 containment containment inspection findings from the most recent inservice inspection report).

RFO if beyond 24. Explain if water leakage has ever been discovered between the drywell and concrete Revised Response:

secondary shield wall or in the sand pocket area.

Explain what VYNPS does to inspect for water Drywell moisture barrier is examined leakage in these two areas or to verify that loss of under the Containment Inservice material is not occurring on the backside of the Inspection Program. Table IWE-2500-1 Drywell. Provide the documentation for the RFO 24 Item E1.30 of ASME Section XI-1 998 issues identified by QA surveillance that are Edition with 2000 Addenda is contained in discussed in the operating experience. Provide the the Program Bases Document (4.14.2) in latest engineering system health report for the the PP 7024 tables. The Program Based containment inservice inspection program. Document (4.14.2) in Section B.1.1 5.1.10, describes the area examined and replaced during RFO-21 (2001). LRA Table 3.5.2.6 shows the drywell moisture barrier to be inspected under the structural monitoring program; this will be changed to the Containment Inservice Inspection Program. IWE examinations during RFO-25 (2005) produced no findings.

In 1991, an Auxiliary Operator (AO) observed water running from a crack in the Drywell pedestal concrete onto the Torus Room floor. The investigation revealed leakage from a steam valve was condensing on and traveling along the Primary Containment Air Conditioning piping to the Drywell shell. From the Drywell shell, the water found a crack or cold-joint which directed itto the Torus Room floor. To ensure the Drywell shell integrity, the sand-cushion drains were examined and found to be functional; the exterior 47 B.1.16-P-1 Commitment # 28 ensures that instrument Jay Anvari Accepted Patterson, Malcol Please identify the standard(s) to which instrument air air is maintained in accordance with ISA is maintained, and document this commitment in S7.3.

Appendix A if appropriate.

- K'-'i27

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Item Request Response Lead Support Status Inspector:

48 B.1.17-N-01 VYNPS inspection for water accumulation Al Haumann Open Nguyen, Duc GALL XI.E3 under "Detection of Aging Effects" in manholes is conducted by a plant recommends that the inspection for water collection procedure. An engineering evaluation will should be performed based on actual plant be used per EN-LI-102 to document and experience with water accumulation in the manhole. determine the plant experience that is However, the inspection frequency should be at least considered in manhole inspection once every two years. VYNPS AMP B.1.17 under the frequency. An action plan and corrective same attribute requires inspection for water collection actions will be used to modify the in cable manholes and conduit occurs at least once inspection frequency...

every two years. Explain how actual plant experience is considered in the manhole inspection frequency to be consistent with GALL's XI.E3.

49 B.1.17-N-02 Al Haumann Lori Potts Accepted Nguyen, Duo In AMP B.1.17 under the "Operating Experience" Operating Experience at VYNPS is element, you have stated that the "Non-EQ controlled by procedure EN-OP-1 00, Inaccessible Medium-Voltage Cable Program" at Operating Experience Program. The VYNPS is a new program for which there is no program includes the following operating experience. GALL XI.E3 under the same components:

element states that operating experience has shown Operating Experience - Information that cross linked polyethylene (XLPE) or high received from various industry sources molecular weight polyethylene (HMWPE) insulation that describe events, issues,equipment materials are most susceptible to water tree failures, that may represent opportunities formation. The formation and growth of water trees to apply lessons learned to avoid negative varies directly with operating voltage. Water treeing is consequences or to recreate positive much less prevalent in 4kV cables than those experiences as applicable.

operated at 13 or 33kV. Also, minimizing exposure to Internal Operating Experience - Operating moisture minimizes the potential for the development experience that originates as a condition of water treeing. As additional operating experience is report or request from plant personnel obtained, lessons learned can be used to adjust the which warrants consideration for possible program, as needed. NUREG-1800, Rev. 1, Appendix Entergy-wide distribution. Internal OE can A, Branch Technical Position RLSB-1 states that an originate from any Entergy plant or applicant may have to commit to providing operating headquarters.

experience in the future for new programs to confirm Impact Evaluation - Analysis of an OE their effectiveness. Describe how operating event or problem that requires additional experience is captured at VYNPS to confirm program information and research to determine effectiveness or how it is to be used to adjust the impact or potential impact, as it relates to program as needed. plant condition and/or configuration.

Impact evaluations are typically documented with a condition report.

Condition report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed. _

T Ris-ORt 0- ;;

412112006 1:46:05PM Page 28 of 78

Item Request Response Lead Support Status Inspector:

50 B.1.17-N-03 Yes, the underground power lines that run Al Haumann Stroud, Mike Open Nguyen, Duc As stated in FSAR Section 8.3.3 (Page 8.3-5 of 8), from Vernon Dam to VYNPS safety the underground power lines - which run from the buses, are included in program B.1.17.

adjacent Vernon Hydroelectric Station to station switchgear - have been designated as the Station Backout alternate ac source. Thus; they are used to meet Station Blackout requirements 10 CFR 50.63.

Are these cables included in the scope of AMP B.1.17? Ifnot, provide an explanation.

51 B.1.18-N-01  :-An engineering evaluation will be Al Haumann Lori Potts Open Nguyen, Duc In AMP B.1.18, you have stated that for neutron flux performed per EN-LI-1 02 to document monitoring system cables that are disconnected and determine the plant experience that is during instrument calibration, testing is performed at considered for neutron flux monitoring least once every 10 years. GALL XI.E2 recommends system cables that are disconnected that the test frequency shall be determined by the during instrument calibration in inspection applicant based on engineering evaluation, but the frequency. An action plan and corrective test frequency shall be at least once every ten years. actions will be used to modify the Explain how engineering evaluation is considered in inspection frequency.

the test frequency; in order to be consistent with GALL XI.E2.

52 B.1.18-N-02 Yes, the B.1.18 program includes both Al Haumann Stroud, Mike Closed Nguyen, Duc Confirm that the test includes both cables and cables and connections for the instrument connections. circuits that are in scope for license renewal.

53 B.1.19-N-01 The VY AMP B.1.19 program description Al Haumann Stroud, Mike Accepted Nguyen, Duc In AMP B.1.19 you have stated that the a will be changed to read as follows:

representative sample of accessible insulated cables This program addresses cables and and connections, within the scope of license renewal, connections at plants whose configuration will be visually inspected for cable and connection is such that most cables and connections jacket surface anomalies such as embrittlement, installed in adverse localized discoloration, cracking or surface contamination. The environments are accessible. This technical basis for sampling will be determined using program can be thought of as a sampling EPRI document TR-1 09619, "Guideline for the program.

Management of Adverse Localized Equipment Selected cables and connections from Environments". Explain the technical basis for cable accessible areas will be inspected and sampling. represent, with reasonable assurance, all cables and connections in the adverse localized environments. Ifan unacceptable condition or situation is identified for a cable or connection in the inspection sample, a determination will be made as to whether the same condition or situation is applicable to other accessible cables or connections. The sample size will be increased based on an evaluation per EN-LI-1 02 - Corrective Action Process.

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54 B1.19-N-02 Al Haumann Stroud, Mike Accepted Nguyen, Duc In AMP B.1.19 under the "Operating Experience" Operating Experience at VYNPS is element, you have stated that the Non-EQ Insulated controlled by procedure EN-OP-1 00, Cables and Connection Program at VYNPS is a new Operating Experience Program.

program for which there is no operating experience. The program includes the following GALL XI.E1 under same element states that operating components:

experience has shown that adverse localized Operating Experience - Information environments caused by heat or radiation for electrical received from various industry sources cables and connections may exist next to or above that describe events, issues,equipment (within three feet of) steam generators, pressurizers failures, that may represent opportunities or hot process pipes, such as feedwater lines. These to apply lessons learned to avoid negative adverse localized environments have been found to consequences or to recreate positive cause degradation of the insulating materials on experiences as applicable.

electrical cables and connections that is visually Internal Operating Experience - Operating observable, such as color changes or surface experience that originates as a condition cracking. NUREG-1800, Rev. 1, Appendix A, Branch report or request from plant personnel Technical Position RLS B-1 under operating which warrants consideration for possible experience states that an applicant may have to Entergy-wide distribution. Internal OE can commit to providing operating experience in the future originate from any Entergy plant or for a new program to confirm its effectiveness. headquarters.

Describe how operating experience will be captured Impact Evaluation -Analysis of an OE by VYNPS. event or problem that requires additional information and research to determine impact or potential impact, as it relates to plant condition and/or configuration.

Impact evaluations are typically documented with a condition report.

Condition report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed.

55 B.1.20-K-01 As stated in LRA Section B.1.20, Ron Scherman Lori Potts Accepted Kennedy, Mike For those components that do not have regular oil exception note 1, flash point is not changes, please provide the basis for Note 1 (not determined for sampled oil because determining the flash point for the sampled oil). analyses of filter residue or particle count, viscosity, total acid/base (neutralization number), water content, and metals content provide sufficient information to verify the oil does not contain water or contaminants that would permit the onset of aging effects. [LAP 4/16/06]

Added Response: Fuel dilution is measured on EDG lube oil, rather than determing flash point.

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56 B.1.20-K-02 As indicated in LRA Section B.1.20, the Ron Scherman Lori Potts Accepted Kennedy, Mike How are the alert levels or action limits established? Oil Analysis Program is consistent with How is the data trended and what criteria are used to NUREG-1801,Section XI.M39 for the determine if the trends are unusual? acceptance criteria attribute. As recommended in NUREG-1801, action limits were established in accordance with industry standard ISO 4406 and manufacturer's recommendations. See DP 0213 (available for on-site review in the program basis document) for trending and criteria. [LAP 4/16/06]

57 B.1.21-K-01 Attachment 2 of LRPD-02 (AMPER), Hoffman / Lach Lori Potts Open Kennedy, Mike Please provide a table outlining the inspection which is available for on-site review in the methods used for each aging effect and parameter program basis document, is a table similar monitored or inspected. This should be consistent to the table provided in the GALL report.

with the table provided in GALL Report AMP XI.M32. Attachment 2 identifies the inspection If not, provide a justification for any exceptions to this method and parameters monitored for table. applicable aging effects. As indicated in LRA Section B.1.21, Attachment 2 of LRPD-02 (AMPER) is consistent with the table provided in NUREG-1801,Section XI.M32. (LAP 4/16/061 58 B.1.21-K-02 Combinations of nondestructive Hoffman / Lach Finnin, Ron Accepted Kennedy, Mike The table provided in the program description in examinations including visual, ultrasonic, section B.1.21 indicates that the one-time inspection and surface techniques will monitor activity will confirm that the loss of fracture toughness cracking of CASS valve bodies in piping is not occurring or is so insignificant that an aging <4" NPS to confirm that reduction of management program is not warranted. What fracture toughness is not occurring or is inspection method is used to detect this aging effect so insignificant that an aging management and what parameter is monitored? program is not warranted. Reference Attachment 2 of LRPD-02 (AMPER). [LAP 4/12/06

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59 B.1.21-K-03 The review of plant operating experience Hoffman / Lach Finnin, Ron & Potts, Accepted Kennedy, Mike What is Vermont Yankee's operating experience with (1998 to 2005) did not reveal instances of Class 1 piping less than 4 Inches NPS in terms of cracking of Class I piping less than cracking? 4"NPS. Site to confirm and address experience prior to 1998. [LAP 4/13106]

In the early years of plant operation Vermont Yankee (VY) experienced occurrences of intergranular stress corrosion cracking (IGSCC) in some stainless steel piping systems. In the period of approximately 1980 through 1986 VY embarked on a major IGSCC mitigation program, replacing the susceptible stainless steel piping with IGSCC resistant materials. Since then there have been no instances of IGSCC or other pipe cracking events at VY. See report "YAEC-1247, Rev. 1" and Letter FVY 88-62.

60 B.1.22-M-01 This information is included in Attachment Rich Rusin Ivy, Ted Accepted Mike Morgan As stated by the applicant, "...prior to the period of 3 of LRPD-02 (AMPER) which is available extended operation, program activity implementing for on-site review in the program basis documents will be enhanced as necessary to assure document. [LAP 4/13/06]

that the effects of aging will be managed...." The applicant is asked to provide a listing of which specific PSPM plant implementing documents will be enhanced and why such an enhancement is necessary for each implementing document.

61 B.1.22-M-02 Yes. Reference LRA Table B-2 and Rich Rusin Lori Potts Accepted Mike Morgan In the statement for the "operating experience' Section B.1.22 Program Description.

element of the AMP, the applicant, notes that "...the [LAP 4/16/06]

material condition of cranes was consistent with inspection acceptance criteria..", and "... ECCS corner room recirculation units had no significant corrosion..". By the appearance of these statements in the "operating experience" of the PSPM, is the staff to understand that thepplicant intends to use the applicants PSPM AMP in lieu of the GALL-recommended programs - XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems", and XI.M38, "Inspection of Intemal Surfaces in Miscellaneous Piping and Ducting Components"- during the period of extended operation?

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62 B.1.23-M-01 VY meets the 1998 edition through 2000 Dave King Finnin, Ron Closed Rowley, Jonathan As noted in the GALL, [Section XI.M3, Element addenda of the ASME Section XI Code, Number four (4) - "Detection of Aging Effects"]; GALL- Sub Section IWB 2500-1 Examination recommended programs use visual, surface, and Category B-G-1," Pressure Retaining volumetric examinations, to indicate the presence of Bolting Greater than Z' in Diameter" Items surface discontinuities/flaws and other BG .20 and BG .30 which specifies a discontinuities/flaws throughout the volume of surface or volumetric examination method.

material. The applicant's proposed exception states that cracking initiates on the outside surfaces of the bolts/studs, and by meeting acceptance standards of IWB-3515, this "surface-type" examination will

"...provide at least the sensitivity of flaw detection that an end shot ultrasonic examination provides on bolts/studs...". The applicant is asked to provide further evidence that such a "qualified surface examination" provides the stated level of sensitivity with the thoroughness of other GALL-recommended programs.

63 B.1.23-M-02 As stated in LRA Section B.1.23, the Dave King Finnin, Ron Closed Rowley, Jonathan Some replacement stud bolts use a manganese Reactor Head Closure Studs Program is phosphate surface treatment in combination MoS2 to consistent with NUREG-1801, XI.M3 for prevent bolt degradation due to corrosion or hydrogen the preventive actions attribute. As embrittlement. The applicant's AMP notes that described in NUREG-1801, threaded Vermont Yankee's existing program includes surfaces of studs, nuts and washers have preventive measures, such as "appropriate materials", a phosphate coating to act as a rust to mitigate cracking and loss of material. GALL inhibitor and lubricant. Also, a stable Section XI.M2, [Element Number two (2) - lubricant compatible with the bolting and "Preventive Actions'] states that the use of this type of vessel materials is applied to the stud surface treatment is acceptable and effective. Does threads, the mating surfaces of the the applicant use similar bolting with a similar type of washers and the nut threads during surface treatment? assembly. Reference LRPD-02 (AMPER)

Section 4.18. [LAP 4/16/06]

64 B.1.23-M-03 Relief Request ISI-03 duration began on Dave King Finnin, Ron Closed Rowley, Jonathan As noted in GALL,Section XI.M3, [Element Number September 1, 2003, so the 2004 ten (10) -"Operating Experience"]; GALL- examinations were visual only. The 2002 recommended programs should have provisions examinations included visual and regarding inspection techniques and evaluation. The ultrasonic inspections. Reference ISI-03, applicant states, in its explanation of their existing PP 7015, Rev. 05, LPCOO and 2002 RPV program, that "...recent (2002 and 2004) visual and stud inspection results. [LAP 4/16/06]

ultrasonic inspections.., revealed no recordable indications..". The applicant is asked to compare examinations performed in 2002 and 2004 with the "exception-stated" examination technique proposed for future examinations and to provide to the staff the results of this comparison.

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65 B.1.26-W-01 Procedures OP 5265, Service Water Harry Breite Ivy, Ted Closed Woodfield, Jon Provide examples of VYNPS plant procedures used to Component Inspection and Acceptance implement the requirements of GL 89-13/Service Criteria; PP 7021, Service Water Water Integrity AMP for routine inspection and Program; and PP 7601, Service Water maintenance of the service water systems. Include Chemical Treatment and Monitoring examples of actual visual and NDE testing. Explain Program are available for on-site review in any differences between the GL 89-13 program scope the program basis document.

and the Service Water Integrity Program scope for license renewal. As stated in LRA Section B.1.26, the Service Water Integrity Program is consistent with NUREG-1801, XI.M20 for the scope of program attribute. Therefore, there are no differences between the GL 89-13 program scope and the Service Water Integrity Program scope for license renewal. [LAP 4116106 66 B.1.26-W:02 Provided a copy of the original site piping Harry Breite Ivy, Ted Closed Woodfield, Jon Provide the original (or current if pipe has been specification QC-10 which shows the replaced) material and lining specification for the piping for the service water and alternate buried piping which is part of the service water cooling water systems piping is carbon system, including the alternate cooling system. steel material and are not coated.

67 B.1.26-W-03 Linings and coatings are not credited. Harry Breite Ivy, Ted Closed Woodfield, Jon VYNPS takes exception to GALL AMP XI.M20 Piping that is lined or coated will be element 2 by stating that not all VYNPS service water inspected with the same techniques used system components are lined or coated. Components for unlined piping. Itemized listing of are lined or coated only where necessary to protect which piping is lined or coated was not the underlying metal surfaces. Provide an itemized necessary for the aging management list of the piping in the service water system where it review. [ABC 4/17106]

is lined or coated to protect the underlying metal surfaces. Provide the type of lining or coating for In accordance with the piping specification each item on the list. QC-10 there is no coated piping in the service water system. The only coated components are a few valve body internals and heat exchanger heads that are currently and will continue to be inspected as part of the service water program.

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Item Request Response Lead Support Status Inspector:

68 B.1.26-W-04 The only section of the Service Water Harry Breite Ivy, Ted Closed Woodfield, Jon Explain if there any portions of the service water (SW) system which are flushed on a system that are infrequently used and are periodically regular basis are instrumentation tubing flushed. Ifso, describe these portions and how often lines (3/8" stainless steel tubing).A list of they are flushed. Explain the criteria used to initiate the specific line has been provided. These the flushing. Explain if any other flushing of the lines are flushed onj a 12 or 18 month system is done and how the strainers are cleaned. basis as identified inthe Preventive Discuss the historic inspection results of the gravity Maintenance program. The SW strainers portion of the ACS piping coming from the deep water are self cleaning and are not opened and basin and if this has been a problem area with flow cleaned on a regular basis. The suction blockage. line from the deep basin to the RHRSW pumps is opened and inspected every other outage (3 years). The results of the inspection have shown the line to be free of tuberlication and silt. The line is treated with a biocide before being closed after inspection. No issues with flow blockage have been identified in the past six years.

The line was found to be fouled in the early 1990's and was subsequently cleaned and the addition of biocide was started. This appears to be very successful based on the recent inspections.

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69 B.1.26-W-05 PP7021 provides information related to Harry Breite Ivy, Ted Closed Woodfield, Jon VYNPS takes exception to GALL AMP XI.M20 Vermont Yankee's compliance with GL89-element 5 by stating that the VYNPS program 13 requirements. A copy of this procedure requires tests and inspections each refueling outage, was provided. GL 89-13 provides for the but not annually. Provide documentation that this options of performing either thermal frequency is in agreement with the commitments performance testing or periodic cleaning.

made by VYNPS under GL 89-13. Provide the VY has chosen to perform cleaning for frequency of heat transfer testing for each heat most of the SW supplied heat exchanger exchanger in the service water system. The applicant and coolers. The exceptions are the Stand-is requested to state which VYNPS group is by Fuel Pool Cooling (SBFPC) Heat responsible for reviewing the test data and to provide Exchangers, the Emergency Diesel through a plant procedure an example of how this Generator Coolers (3 each) and the process is Implemented. Explain the type of heat Corner Room RRU's #7 & 8. The SBFPC transfer testing which is done on the service water heat exchangers are thermal performance system heat exchangers. tested every 18 months. Based on the satisfactory results of the tests VY is preparing a change to perform cleaning instead of testing. The coolers have been internally examined and found to be very clean and free for silt, sludge and tuberlication. The frequency of cleaning has yet to be determined but is anticipated to be in the every 3 to 6 year range. The Emergency Diesel Generator Coolers ate tested every month and the results are trended by System Engineering. No adverse trends have been identified. A copy of the trends for the "B"Diesel has been provided. Copies of the test data sheets for the entire year 2004 have been provided.. The RRU's are tested quarterly by measuring the DP across the units.

This will detect any fouling which would decrease thermal performance. No performance issues have been identified.

All performance data and inspection results are monitored and trended by the System Engineering Department and the Service Water System Engineer.

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70 B.1.26-W-06 A copy of NRC Report, NW 02-61 was Harry Breite Ivy, Ted Closed Woodfield, Jon Provide the NRC inspection report written in 2002 for provided. CR-VTY-2003-02344 was the service water system. Characterize the 20 service provided. This CR document the water system leaks and how they were repaired under investigation into the adverse trend the VYNPS corrective action program. Provide the created by approximately 20 through wall VYNPS self-assessment and independent evaluation leaks in the SW system. The result of this which was completed on 12/20/2002. Provide an investigation identified several causes.

example of the documents which provide the One of these being the use of carbon protocols for the use of biocides to mitigate MIC and steel components which bare susceptible any other procedure changes made after the self- to Microbiological Influenced Corrosion assessment. Provide a sampling of the different (MIC). Another cause was determined to performance testing and inspection results for 2004 be ineffective chemical treatment of the that are discussed in the LRA operating experience system. The ineffectiveness of the with acceptance criteria. If more recent performance chemical treatment was reinforced by a testing and inspection results are available, provide a follow up assessment (DR Lutey Report).

sampling of them. This assessment was also provided, Changes were made to the sampling program and chemical treatment process.

New chemical addition pumps were installed and sampling was implemented for SW components during inspections. It should be noted that the plant is limited by the NPDES permit to no more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> a day of treatment to the SW system. This reduces the effectiveness of the treatments. VY also began treatment of lines which are not normally inservice, I.e. supply line to the Diesel Generator Cooler. These lines are treated when the diesels are run to insure that the lines are full of treated water when they are secured. Copies of the inspection database detailing the results of internal inspections have been provided.

71 B.1.26-W-06 Duplicate entry. Close to # 70. Harry Breite Ivy, Ted Closed Woodfield, Jon Provide the NRC inspection report written in 2002 for the service water system. Characterize the 20 service water system leaks and how they were repaired under the VYNPS corrective action program. Provide the VYNPS self-assessment and independent evaluation which was completed on 12/20/2002. Provide an example of the documents which provide the protocols for the use of biocides to mitigate MIC and any other procedure changes made after the self-assessment. Provide a sampling of the different performance testing and inspection results for 2004 that are discussed inthe LRA operating experience with acceptance criteria. Ifmore recent performance testing and inspection results are available, provide a sampling of them.

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72 B.1.27.1-W-01 Inspection Report for Masonry wall G- Steve Vekasy Ahrabli, Reza Closed Woodfield, Jon Provide a masonry wall inspection report for an 191513-51 provided in Drawing B-191600 unreinforced masonry wall. Sheet 96 for an unreinforced masonry wall was provided..

73 B.1.27.1-W-02 Site procedure PP-7026 will be in the Steve Vekasy Ahrabli, Reza Closed Woodfield, Jon Explain how often masonry walls are inspected for program basis document cracking. Explain if the inspection frequency varies Additional Response (AA):

from wall to wall. If the frequency does vary, explain Inspection of masonary walls, in scope of the basis for the differences in frequency. Explain the license renewal, are performed each qualification and training that is required of the refueling outage. Upon completetion of six inspection personnel. Explain if inspectors use crack successive surveillance intervals during a maps during the inspections to help inthe detection of ten year period, the sequence of the changes. inspection is reverted back to the initial sequence interval. The inspections are performed by inspection team comprised of degreed engineers having understanding of structures, materials of masonry construction and masonry wall analysis techniques. The observed instances of cracking are detailed on as-built and considered in record analysis.

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74 B.1.27.1-W-03 PP 7026 Rev 1 requires that if during the Steve Vekasy Ahrabli, Reza Closed Woodfield, Jon Explain if Masonry Wall crack changes are turned course of inspection, a "significant finding" over to engineering for evaluation and documentation is encountered a Condition Report shall by procedure. Provide the procedure for performing be generated and the Civil Structural the Masonry Wall crack inspections. What Supervisor is notified (Section 4.4, PP engineering procedures are used to control and 7026). PP 7026 is provided for reference.

evaluate the attachment of new components to The Engineering Request process is used masonry walls evaluated under NRC IEB 80-11? to control the plants configuration. Walls Explain if there is a masonry wall log book or data affected via planned modifications are base to track new attachments to block walls and identified during the design process and evaluate the effects on the existing evaluations the analysis of record and design performed under 80-11? drawings reflecting I. E. B. 80-11 are updated accordingly. Administrative controls require that proposed new attachments are reviewed by the Civil Structural Department (Section 4.4.5, PP 7026). A log book is maintained by the Civil Structural Department with a summary findings memo and surveillance walkdown sheets (Form VYPPF 7026.01 and Section 4.4.7, PP 7026).

Attachments include the Vermont Yankee Masonry Wall Routine Surveillance for RFO 25 in which three corrective updates were performed for observed discrepancies. The CR generated for correcting the drawings is also attached along with a corrected drawing for example.

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75 B.1.27.2-W-01 Regulatory Guide (RG) 1.127, Inspection Steve Vekasy Ahrabli, Reza Open Woodfield, Jon The program description In the LRA for the Structures of Water-Control Structures associated Monitoring Program (B.1.27.2) makes no reference to with Nuclear Power Plants, is identified as GALL,Section XI.S7, RG 1.127, Inspection of Water- XI.S7 Program in GALL for managing Control Structures Associated With Nuclear Power aging effects associated with water control Plants. GALL XI.S7 states that for plants not structures, and Structures Monitoring committed to RG 1.127, Revision 1, aging Program, XI.S6, is identified as managing management of water-control structures may be aging effects associated with structures included in the Structures Monitoring Program. and structural components. The water-However, details pertaining to water-control structures control structure at VYNPS is the intake are to incorporate the attributes of GALL XI.S7. structure. Aging effects requiring Explain if VYNPS is committed to RG 1.127 Revision management for the intake structure and I for inspection of its water control structures (such as its structural components were Intake Structure). IfVYNPS is not committed to RG determined based on industry guidelines 1.127 Revision 1, explain how the 10 element and operating experience.

attributes of GALL X1.$7 are incorporated into the The attributes that are inthe GALL XI.S7 VYNPS Structures Monitoring Program. aging management program, but not in the VYNPS Structures Monitoring Program, are attributes dealing with earthen embankment water control structures. RG 1.127 proposes inspection parameters (e.g., settlement, depressions, sink holes, slope stability (e.g.,

irregularities in alignment and variances from originally constructed slopes),

seepage, proper functioning of drainage systems, and degradation of slope protection features) and frequency (not to exceed 5 years) for earthen embankment water control structures. These parameters are not applicable parameters for the intake structure. During the VYNPS aging management review, the aging effect requiring management for the intake structures was determined to be loss of material of the structural components and commodities. Loss of material is effectively managed by Structures Monitoring Program and the Fire Protection Program as indicated in LRA Table 3.5.2-3. Therefore, the attributes of the NUREG-1 801 XI.S7 aging management program regarding earthen structures are not necessary attributes for the WNPS Structures Monitoring Program for water control structures.

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76 B.1.27.2-W-02 Drywell moisture barrier is examined Ted Underkoffier &S Ahrabli, Reza Open Woodfield, Jon Explain why the drywell floor liner seal and other under the Containment Inservice components are not part of the ASME Section XI Inspection Program. LRA Table 3.5.2.6 subsection IWE inspection program. Justify this shows the drywell moisture barrier to be exclusion. Explain why the inspection of crane rails inspected under the structural monitoring and girders are not under an Inspection of Overhead program; this will be changed to the Heavy Load and Light Load Handling Systems AMP. Containment Inservice Inspection Explain if all the structures and components being Program.

added to the Scope of Program for this AMP by enhancement are currently inspected by another Crane rails and girders are covered under program, since the SMP is an existing program. the periodic surveillance and preventive maintenance program. Not all the structures and components added by the enhancement to SMP are currently inspected under another program.

77 B.1.27.2-W-03 No, VY does not have porous concrete Steve Vekasy Ahrabli, Reza Open Woodfield, Jon Explain if VYNPS has any porous concrete subfoundation. (AA) subfoundations and a site dewatering system. Explain if the Structures Monitoring Program requires periodic Revised Response:

sampling and testing of groundwater to determine and No, VY does not have porous concrete confirm that that the below grade water chemistry/soil subfoundation and does not rely on site is non-aggressive to concrete structures below grade. dewatering system or ground water Provide the results for the two most recent tests and monitoring. (AA) provide the scheduled frequency of groundwater monitoring. Explain if there is any seasonal consideration for groundwater monitoring.

78 B.1.27.2-W-04 Yes. VYNPS will take advantage of Steve Vekasy Ahrabli, Reza Closed Woodfield, Jon Will VYNPS take advantage of inspection inspection opportunities for underground opportunities for structures required for license structures that become accessible by renewal and identified as inaccessible? As excavation. As indicated in the response inaccessible areas become accessible by such means to Item 5 (B.1.1-L-04), VYNPS will as excavation or other reason, will additional enhance procedure PP 7030, Structures inspections of those areas be performed? Monitoring Program, to provide additional guidelines for inspection of underground strctures unearthed during excavation of piping {Commitment#l). (Ref. LRPD-02, Section 4.21..B.4b).

100. 1"4.05 .41. of.7.

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Item Request Response Lead Support Status Inspector:

79 B.1.27.2-W-05 Vermont Yankee's current structures Steve Vekasy Ahrabli, Reza Closed Woodfield, Jon Explain how the frequency of inspection for the monitoring program is performed by structures, buildings and components within the scope Design Structural Engineers in of this program are affected when aging effects are accordance with PP 7030, Structures discovered. Monitoring Program Procedure. Our surveillance tracking program ensures that this inspection is performed on a three year interval.

Any adverse condition discovered during inspections of buildings, structures and components would be entered into Entergy's corrective action process through the initiation of a Condition Report in the PCRS tracking system. The corrective action program defines further responses to the discovered condition.

Attributes considered through the corrective action will include, as applicable, apparent cause evaluation, root cause evaluation, extent of condition, consideration of Operating Experience, required corrective action and follow-up verification. Frequency of future inspections will also be considered through the corrective action process.

PM

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Item Reauest ResDonse Lead SuDport Status Inspector:

80 B.1.27.2-W-06 Although ACl 349.3-3R-96 is known and Steve Vekasy Ahrabli, Reza Open Woodfield, Jon Explain if the inspection acceptance criteria for the available to Vermont Yankee's structural Structures Monitoring Program is based on ACI monitoring team and is an option standard 349.3R-96, and if not, provide the industry codes, in Gall XI .S6 for monitoring parameters standards and guidelines that the acceptance criteria and acceptance criteria, Vermont Yankee is based on. Explain the basis of the acceptance performs its structural monitoring program

.criteria for crane rail/girder inspections and drywell (e.g. acceptance criteria) in accordance floor liner seal. with the standards listed in Sect. 5.2 of PP 7030, Structures Monitoring Program Procedure. These standards include:

5.2.1 10CFR50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 5.2.2 NEI 96-03, Nuclear Energy Institute, Industry Guideline for Monitoring the Condition of Structures at Nuclear Power Plants 5.2.3 NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 5.2.4 NRC Inspection Manual, Inspection Procedure 62002, Inspection of Structures, Passive Components and Civil Engineering Features at Nuclear Power Plants 5.2.5 NUREG-1522, Assessment of In Service Conditions of Safety Related Nuclear Power Plant Structures The acceptance criteria for crane rail/girder inspections are contained in the Preventative Maintenance tasks for the crane inspection.

The acceptance criteria for the drywell floor liner seal is covered under 4.14.2, Containment Inspection Program. LRDP-02 will be revised to indicate that this seal is covered in the Containment Inspection Program, not the Structures Monitoring Program as currently stated.

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Item Request .Response Lead Support Status Inspector:

81 B.1.27.2-W-07 Documentation of the operating Steve Vekasy Ahrabli, Reza Closed Woodfield, Jon VYNPS lists the following structure issues under experience with structural repairs was operating experience for this AMP. provided to the Inspection Team in the following format:

- Concrete pad above JD diesel generator day tank sinking and cracking Concrete pad above the JD diesel

- Degradation of Cooling Tower structural column generator day tank WO 99-1090-000 WO 99-9746-001 Provide the documentation for these issues showing when, where and how they were discovered. Also, Degradation of cooling tower structural provide the documentation on how these issues were columns WO 05-5158-000 evaluated and resolved with a discussion on the need WO 97-5357-004 for any followup inspections. WO 97-5327-00 WO 03-1243-009 Provide the most recent inspection results for the reactor building overhead crane rails/girders, reactor Intake structure floor concrete repair WO building (a few examples of areas where aging has 04-1745-000 been discovered), cooling towers, and intake structure (a few examples of areas where aging has been The concrete pad above the JD diesel discovered). Provide the last three inspection reports generator day tank is in a high traffic

• for the drywell floor liner seal. area. Degradation was identified by personnel transiting the area. The cracked concrete slab was replaced. This was essentially a design issue, in that the original pad was not designed to bear the weight of the fuel oil delivery truck. The

.reference WO replaced the pad and added bollard columns to prevent vehicles from driving over the pad. No further follow-up inspections are required.

Degradation of cooling tower structural columns was discovered during routine fall and spring structural inspection PMs.

These columns were replaced in kind.

Follow-up inspections are performed during the routine fall and spring structural inspection PMs.

The most recent inspection and repair results for the Turbine Building overhead crane were provided to the Inspection Team. Included were reports of two different inspections, repair information and monitoring plans. Both the Reactor and Turbine Building overhead cranes are in scope of the Maintenance Rule and are subject to the same inspection and corrective action programs. Recent Reactor Building overhead crane inspections have identified only mechanical and electrical deficiencies (i.e.

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trolley motors, brakes, etc.). The results for the Turbine Building overhead crane were provided in lieu of the Reactor Building overhead crane because the recent inspection results involve structural elements and show the effectiveness of the Maintenance Rule crane inspection program. The Structures Monitoring Program will be enhanced to describe how the program takes credit for the structural inspection program being performed through the Maintenance Rule crane inspection program.

Examples of inspections for cooling tower aging are included inthe referenced WOs above.

As stated inother responses, LRDP-02 will be revised to indicate that the drywell floor liner seal will be covered under the containment inspection program, not the structures monitoring program. The seal was replaced two refueling outages ago, and the seal inspection report for last outage has already been provided to the inspection team.

Degradation of intake structure floor concrete was discovered during routine diver PM inspections performed every refueling outage. The small washed out area was repaired with an underwater concrete repair product. Follow-up routine diver PM inspections will be performed.

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82 B.1.27.3-W-01 There has not been any need for site to Steve Vekasy Ahrabli, Reza Open Woodfield, Jon Explain which VYNPS individual is responsible for the coordinate or interface with Vernon Dam coordination of Vernon Dam FERC inspections. FERC inspection. VYNPS does not have Explain the process of VYNPS interfacing with FERC an individual responsible for coordinating, with respect to Vernon Dam and if there are any plant interfacing, collecting and reviewing FERC procedures for the interface. Ifthere are plant inspection report. There is no site procedures for dealing with FERC, provide a current procedure for dealing with FERC and copy. Explain if VYNPS has any influence on what obtaining a current copy. Reports are and when repairs are made on Vernon Dam from a normally received on site after each management or economic standpoint. Provide the inspection. And, VYNPS does not have most recent Vernon Dam assessment performed by any influence on what and when repairs FERC. Explain how VYNPS receives the report and if should be made from management or the report is independently reviewed by any VYNPS economics standpoint. As stated in LRA personnel such as insystems or design engineering. section 2.4.5, Vernon Dam is not part of the site structures owned by VYNPS. Dam inspectors are regulated by the Federal Ehergy Regulatory Commission (FERC),

which licenses the dam and associated power block.

A copy of FERC inspection report of Vernon dam, for the period October 28, 1998 to June 24, 2002 is attached to this response.

'Prior to period of extended operation, VYNPS will develop plans and process to ensure its involvement and interface with Vernon dam inspection, review of the inspection reports, and implementation of required maintenance and repairs."

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83 B.1.27.3-W-02 Steve Vekasy Ahrabli, Reza Open Woodfield, Jon The operating experience for this AMP states that As stated in LRA section 2.4.5, Vernon daily inspections are made of Vernon Dam and Dam is not part of the site structures periodic underwater inspections are made on the owned by VYNPS. Dam inspections are Dam. Explain what organization makes the daily regulated by the Federal Energy inspections and the underwater inspections. Explain Regulatory Commission (FERC), which how often the underwater inspections are performed licenses the dam and associated power and what determines the frequency. Explain if block. Daily inspections are performed by VYNPS has ever independently Inspected Vernon Licensee's (USGen New England, Inc.)

Dam. Explain if any flooding has occurred which maintenance personnel. And, underwater required additional FERC inspections beyond the inspections are performed by divers once normal 5 year. The operating experience states that every 5 years determined by FERC.

areas of degradation were found on Vernon Dam Independent inspection of Vernon Dam by during the 2002 FERC inspection and will continue to VYNPS neither has been necessary or be monitored. Explain if the continued monitoring is performed. No evidence of flooding to by FERC on a five year cycle or by VYNPS personnel require additional FERC inspections on a more frequent basis. Explain the type and beyond the normal 5 year. As stated in the number of staff that work at Vernon Dam on a daily inspection reports, maximum rise in stage basis to maintain it. Explain if and how any personnel cause by a breach will not exceed 1.7 feet at Vernon Dam have the ability to communicate under either 50 or 100 year flood immediately with responsible individuals at VYN PS condition. The areas of degradation, found should a problem develop at the Dam which could on Vernon Dam during the 2002 FERC affect the availability of plant cooling water. inspection, are monitored by FERC on a five year cycle. However, daily inspection by the licensee also supplements these inspections. Number and type of staff at Vermon Dam on daily basis is not known.

Although not procedurlized, any problem with dam is expected to be communicated to the site.

'Prior to period of extended operation, VYNPS will develop plans and process to ensure its involvement and interface with Vernon dam inspection, review of the inspection reports, and implementation of required maintenance and repairs."

84 B.1.30.1-M-01 No, as stated in LRA Section B.1.30.1, Steve Vekasy Accepted Mike Morgan Since the applicant is currently and periodically rather than sampling, procedures will be sampling and analyzing the cooling water of the other enhanced to flush the John Deere diesel systems "controlled" by VYNPS's existing cooling water system and replace the program--the stator cooling water and plant heating coolant and coolant conditioner every boiler systems--is it also the intent of the applicant to three years. [LAP 4/16/06]

periodically sample and analyze the John Deere Diesel cooling water system?

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85 B.1.30.2-M-01 Yes, the one-time inspection program Rick Gerdus Lori Potts Accepted Mike Morgan Section XI.M2 of the GALL notes that a "water described in LRA Section B.1.21 includes chemistry only" program may not be fully effective for inspections to verify the effectiveness of verification of corrosion or SCC in slow flow or the water chemistry control aging stagnant flow areas. The GALL further suggests that management programs by confirming that for some of these "susceptible locations" a one-time unacceptable cracking, loss of material, inspection verification program may be appropriate. and fouling is not occurring. [LAP 4/13106]

Do you intend to implement a "one-time inspection (or some other program) to verify existence of corrosion or SCC in these "susceptible locations"?

86 B.1.30.2-M-02 Yes, the one-time inspection program Rick Gerdus Lori Potts Accepted Mike Morgan Section XI.M2 - Element Number four (4) - of the described in LRA Section B.1.21 includes GALL notes that the staff considers a BWR water inspections to verify the effectiveness of chemistry program as a "...mitigation program and the water chemistry control aging (that it) does not provide detection of any aging management programs by confirming that effects...". The GALL further states that "...inspection unacceptable cracking, loss of material, of select components (should) be undertaken to verify and fouling is not occurring. [LAP 4/13/06 the effectiveness of the program..." The applicant's AMP does not present any other program - other than the indirect results of their existing water chemistry program - to verify effectiveness of the chemistry control program. Do you intend to perform "other' inspections, as suggested by the GALL, "...to ensure that significant degradation is not occurring and that intended functions of system components will be maintained during the extended period of operation..."?

87 B.1.30.3-M-01 This AMP does not ensure that a stagnant Rick Gerdus Lori Potts Closed Mike Morgan The applicant's exception for this AMP states that flow condition or crevice will not be

"...monitoring pump performance parameters is of periodically present in system piping little value in managing effects of aging on long-lived, during the period of extended operation.

passive CCW system components..". The associated Preventing stagnant flow conditions is not GALL for this AMP (XI.M21; Element 4) states that a recommended preventive action in

"...control of water chemistry does not preclude NUREG-1801,Section XI.M21. As stated corrosion or SCC at locations of stagnant flow in LRA Section B.1.20.3, passive intended conditions or crevices...". How does this AMP ensure functions of pumps, heat exchangers and that a stagnant flow condition or crevice will not be other components will be adequately periodically present in system piping during the period managed by the Water Chemistry of extended operation? Control - Closed Cooling Water Program through monitoring and control of water chemistry parameters. Also the one-time inspection program described in LRA Section B.1.21 includes inspections to verify the effectiveness of the water chemistry control aging management programs by confirming that unacceptable cracking, loss of material, and fouling is not occurring. [LAP 4/13/06].

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88 B.1.30.3-M-02 No, functional and performance testing Rick Gerdus Lori Potts Closed Mike Morgan The applicants exception for this AMP also states that are not aging management actions. They

"....in most cases, functional and performance testing are maintenance rule activities and not verifies that the component active functions can be part of the Water Chemistry Control -

accomplished and as such would be included as part Closed Cooling Water Program. As of the maintenance rule...". Does this AMP reference stated in LRA Section B.1.30.3, the Water or refer to "maintenance rule activities" as part of Chemistry Control - Closed Cooling Water planned aging management actions; i.e., actions Program takes exception to this which address GALL XI.M21 "parameters recommendation of NUREG 1801, monitored/inspected"? Section XI.M21. [LAP 4/16/06]

89 A-P-01 Section 13 includes all the systems that John Hoffman Ivy, Ted Closed Patterson, Malcol Please clarify the rationale for the unusual numbering have intended functions that meet 10 CFR system used for auxiliary systems after the first 12. 54.4(a)(2) for physical interaction. The (Note: This question is arbitrarily linked to the first aging management review of these item of Table 3.3.1-13-1) systems that have functions that met 10 CFR 54.4(a)(2) for physical interaction was done separately from the review of systems with intended functions that met 10 CFR 54.4 (a)(1) or (a)(3). The results of this review therefore needed to be presented separately so that they could be distinguished from the 10 CFR 54(a)(1) and (a)(3) review. Table 3.3.1-13 would be the next sequential table number after the remainder of the auxiliary system tables.

To indicate individual systems included in the aging management review for (a)(2),

Table 3.3.1-13 is subdivided by system.

For example, Table 3.3.1-13-1 is for the augmented off gas system, a system which only has components included for (a)(2). For the core spray system, Table 3.3.1-13-6 shows the components included for (a)(2) but since the system is also in scope for other reasons, Table 3.2.2-2 shows the components included for 54.4(a)(1) and (a)(3). This numbering system was chosen so that these systems and the components that had intended functions unique for 54.4(a)(2) could be uniquely identified and reviewed separately. This allows a reviewer to clearly distinguish which component types in a system were included for 10 CFR 54.4(a)(2) for physical interaction. Since most of these systems are auxiliary systems they were added as part of the auxiliary systems section. [TSi 4/13106]

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90 3.1.1-14-P-01 This response assumes that the question John Hoffman Lori Potts & Finnin,R Closed Patterson, Malcol "Support" is not listed as an intended function Please is referring to the tables in Section 3.3.2-clarify which IF(SNS, SRE, and/or SSR) is intended. 13 for components included for 10 CFR 54.4(a)(2). This function is described in Section 2.3.3.13 under "System Description (pg. 2.3-65) and in the definition in Table 2.0-1 for "Pressure boundary." As shown in the component type tables in Section 2.3.3-13, a footnote states "For component types included under 10 CFR54.4(a)(2), the intended function of pressure boundary includes providing structural/seismic support for components that are included for nonsafety-related SSCs directly connected to safety-related SSCs" when this function is appropriate. Pressure boundary was only used because there is no difference in the aging management review regardless of whether the component intended function is pressure boundary or structural support, and if the pressure boundary intended function of the component is maintained the structural support function will be maintained. This definition of providing structuraVseismic support would be equivalent to the intended function of SSR as defined in Table 2.0-1 .[TSI 4/13/06]

2tvz~t~tt-rrS.zzt7razn7svtI . . -n.v-_--r-.

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91 3.6.2.2-N-01 VYNPS electrical AMR AMRE-01 in Al Haumann Stroud, Mike Open Nguyen, Duc In LRA, Table 3.6.2-1, under Cable connections section 4.1.4.4 states for cable (metallic parts), you have stated that no aging effects connections (metallic parts) requiring management and no AMP is required. "An evaluation of thermal cycling, ohmic Further, in LRA, Table 3.6.1 under discussion of cable heating, electrical transients, vibration, connection metallic parts, you have stated that cable chemical contamination, corrosion, and connections outside of active devices are taped or oxidation stressors for the metallic parts of sleeved for protection and operating experience with electrical cable connections identified no metallic parts of electrical cable connections at aging effects requiring management.

VYNPS indicated no aging effects requiring *OMetallic parts of electrical cable management. Electrical cable connections (metallic connections potentially exposed to parts) are subject to the following aging stressors: thermal cycling and ohmic heating are thermal cycling, ohmic heating, electrical transients, those carrying significant current in power vibration, chemical contamination, corrosion, and supply circuits. Typically, power cables oxidation. NUREG-1801, Revision 1, AMP XI.E6, are in a continuous run from the supply to "Electrical Cable Connection not Subject to 10 CFR the load. Therefore, the connections are 50.49 Environmental Qualification Requirements," part of an active component that is specifies that connections associated with cables controlled by Maintenance Rule and is not within the scope of license renewal are part of this subject to aging management review.

program, regardless of their association with active or °UThe fast action of circuit protective passive components. Also, refer to pages 107, 256, devices at high currents mitigates and 257 of NUREG-1 833, "Technical Bases for stresses associated with electrical faults Revision to the License Renewal Guidance and transients. In addition, mechanical Documents," for additional information regarding AMP stress associated with electrical faults is XI.E6. Provide a basis document including an AMP not a credible aging mechanism because with the ten elements for cable connections or provide of the low frequency of occurrence for a justification for why an AMP is not necessary. such faults. Therefore, electrical transients are not applicable stressors.

0OMetallic parts of electrical cable connections exposed to vibration are those associated with active components that cause vibration. Since active components are controlled by Maintenance Rule, they are not subject to aging management review.

• lJCorrosive chemicals are not stored in most areas of the plant. Routine releases of corrosive chemicals to areas inside plant buildings do not occur during plant operation. Such a release, and its effects, would be an event, not an effect of aging.

The location of electrical connections inside active components protects the metallic parts from contamination.

Therefore, this stressor is not applicable.

• UOxidation and corrosion usually occur in the presence of moisture or contamination such as Industrial pollutants and salt deposits. Enclosures or splice materials protect metal connections from moisture or contamination. Therefore, oxidation and corrosion are not applicable stressors.

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Based on the evaluations of the stressors above, there are no aging effects requiring management for metallic components of connections and no AMP is required.

92 3.6.2.2-N-02 VYNPS electrical AMR Section 4.3.4 of Al Haumann Stroud, Mike Accepted Nguyen, Duc In LRA, Table 3.6.2-1, under switchyard bus AMRE-01.

(switchyard bus for SBO) and connections you have Connection surface oxidation for stated no aging effects requiring management and no aluminum switchyard bus is not applicable AMP is required. NUREG 1800, Rev. 1, Standard since all switchyard bus connections Review Plan for Review of License Renewal requiring AMR are welded connections.

Application for Nuclear Power Plants, Section No aging effects have been identified for 3,6.2.2.3 identifies loss of preload is an aging effect welded connections on switchyard busfor for switchyard bus connections. Torque relaxation for SBO.

bolted connection is a concern for switchyard bus connections. An electrical connection must be designed to remain tight and maintain good conductivity through a large temperature range.

Meeting this design requirement is difficult if the material specified for the bolt and the conductor are different and have different rates of thermal expansion. For example, copper or aluminum bus/conductor materials expand faster than most bolting materials. Ifthermal stress is added to stresses inherent at assembly, the joint members or fasteners can yield. If plastic deformation occurs during thermal loading (i.e., heatup) when the connection cools, the joint will be loose. EPRI document TR-1 04213, "Bolted Joint Maintenance &

Application Guide," recommends inspection of bolted joints for evidence of overheating, signs of burning or discoloration, and indication of loose bolds. Provide a discussion why torque relaxation for bolted connections of switchyard bus is not a concern for VYNPS.

93 3.6.2.2-N-03 Table 3.6.2-1 Component type - Al Haumann Stroud, Mike Open Nguyen, Duc Provide AMR line item for transmission conductor Transmission conductors will be revised to connections in Table 3.6.2-1. Address any aging be Transmission conductors and effects requiring management. connections.

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94 3.6.2.2-N-04 VYNPS electrical AMR Section 4.2 in Al Haumann Stroud, Mike Open Nguyen, Duo In LRA, Table 3.6.2-1, under Transmission AMRE-01.

conductors, you have stated that no aging effects The prevalent mechanism contributing to requiring management and no AMP is required. loss of conductor strength of an ACSR NUREG 1800, Rev. 1, Standard Review Plan for transmission conductor is corrosion, which Review of License Renewal Application for Nuclear includes corrosion of the steel core and Power Plants, Section 3.6.2.2.3 identifies loss of aluminum strand pitting. Corrosion in conductor strength due to corrosion is the aging effect ACSR conductors is a very slow acting of high voltage transmission conductor. The most mechanism, and the corrosion rates prevalent mechanism contributing to loss of conductor depend on air quality, which includes strength of aluminum core steel reinforce (ACSR) suspended particles chemistry, S02 transmission conductor is corrosion which includes concentration in air, precipitation, fog corrosion of steel core and aluminum strand pitting. chemistry and meteorological conditions.

Degradation begins as a loss of zinc from the Air quality in rural areas generally contains galvanized steel core wires. Corrosion rate depend low concentrations of suspended particles largely on air quality, which includes suspended and SO2, which keeps the corrosion rate particles chemistry, sulfur dioxide concentration in air, to a minimum.

precipitation, fog chemistry and meteorological Tests performed by Ontario Hydro showed conditions. Explain why loss of conductor strength a 30% loss of composite conductor due to corrosion is not an aging effect requirement strength of an 80-year old ACSR management for transmission conductors at VYNPS. conductor due to corrosion.

Aluminum conductor alloy reinforced (ACAR) conductors are used at WNPS as well as ACSR conductors.

ACAR conductors are more resistant to loss of conductor strength since the core of the conductor is an alloy of steel and corrosion resistant metals.

Conclusions for ACSR conductors conservatively bound ACAR conductors.

Therefore, corrosion of transmission conductors is not aging effect requiring management and an AMP is not required.

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95 3.6.2.2-N-05 :_ VYNPS electrical AMR Section 4.4 in Al Haumann Stroud, Mike Accepted Nguyen, Duc In LRA, Table 3.6.2-1, under high voltage insulators, AMRE-01.

you have indicated that no aging effects requiring Various airborne materials such as dust, management and no AMP is required. In LRA, salt and industrial effluents can Section 3.6.2.2.2, you have also stated that at contaminate insulator surfaces. The VYNPS surface contamination build-up on insulator is buildup of surface contamination is not a concern. NUREG 1800, Rev. 1, Standard gradual and in most areas, such Review Plan for Review of License Renewal contamination is washed away by rain; the Application for Nuclear Power Plants, Section glazed insulator surface aids this 3.6.2.2.3 identifies surface contamination is the aging contamination removal.

effect of high voltage insulators. Various airborne VYNPS is not located near the seacoast materials such as dust and industrial effluent can where salt spray is prevalent, or near contaminate insulator surfaces. The buildup of facilities that discharge soot.

surface contamination is gradual and in most areas At VYNPS, as in most areas of the New such contamination is washed away by rain; the England transmission system, glazed insulator surface aids this contamination contamination build up on insulators is not removal. However, a large buildup of contamination a problem. Therefore, surface enables the conductor voltage to track along the contamination is not an applicable aging surface more easily and can lead to insulator mechanism for the insulators at VYNPS.

flashover. Surface contamination can be a problem in areas where there are greater concentration of airborne particles such a near facilities that discharge" soot. Explain why surface contamination is not a concern at VYNPS.

96 3.6.2.2-N-06 Section 3.4.2 in AMRE-01. Al Haumann Stroud, Mike Accepted Nguyen, Duc Are all electrical and I&C containment penetrations EQ? If not, provide AMRs and AMPs for non-EQ FSAR Section 5.2.3.4.3 electrical and I&C containment penetrations. The AMRs should include both organic (XLPE, XLPO, :_ VYNPS electrical AMR Section 3.4.2 and SR internal conductor/pigtail insulation, etc.,) as in AMRE-01.

well as inorganic material (such as cable fillers, At VYNPS, electrical penetration epoxies, potting compounds, connector pins, plugs, assemblies are included in the EQ and facial grommets). program and are not subject to aging management review since they are short-lived.

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97 3.6.2.2-N-07 The VY UFSAR Section 8.3.3 Al Haumann Stroud, Mike Open Nguyen, Duc In LRA, Table 3.6.1 under metal enclosed bus, you describes three offsite power sources.

have stated that an evaluation of metal enclosed bus The immediate access circuit from the for VYNPS determined that VYNPS does not have 345kV yard through the 345/115kV any phase bus that support a license renewal autotransformer to the startup function. 10 CFR 54.4 (a)(3) requires, in part, that all transformers, the alternate immediate systems, structures, and components relied on in access circuit from the 115kV yard (Keene safety analyses or plant evaluation to perform a Line) through the startup transformers.

function that demonstrates compliance with the The delayed access circuit is available by commission's regulations for station black out (10 opening the generator no-load disconnect CFR 50.63) are within the scope of license renewal. switch and establishing a feed from the VYNPS FSAR Section 8.3.3 states that electric power 345kV switchyard through the main and supplied from the transmission network to the on-site aux transformers.

electric distribution system by two independent circuits, one immediate access and one delayed As stated in ISG-2, "For purposes of the access. The immediate access circuit is supplied license renewal rule, the staff has from the 345 kV transmission system through 345 determined that the plant system portion kV/1 15 kV auto-transformer. It feeds the on-site of the offsite power system that is used to electric distribution system through the two 115 kV to connect the plant to the offsite power 4160 V start up transformers and is available source should be included within the immediately following a loss of generating capability. scope of the rule." This guidance was The delay access circuit is available by opening the followed for the VY LRA. The guidance generator no-load disconnect switch and establish a statement in ISG-2 is, 'This path typically feed from the 345 kV switchyard through the main includes the switchyard circuit breakers generator step-up transformer and unit auxiliary that connect to the offsite system power transformer to the 4160 V safety buses. Answer the transformers (startup transformers), the following questions and support them with a main one transformers themselves, the intervening line diagram: overhead or underground circuits between circuit breaker and transformer and 3.6.2.2-7(a). In regard to the above, are non- transformer and onsite electrical segregated phase buses used to connect the start up distribution system, and the associated transformers (T-3A and T-3B) (lower sides) to 4.16 kV control circuits and structures." Based on safety buses? the guidance in ISG-2 and past applicants' SERs, VY added two sources of offsite 3.6.2.2-7(b). In regard to the above, are iso phase power for the SBO recovery path. The buses used to connect the delay access circuit from two offsite paths chosen were the two the 345 kV switchyard through the main generator immediate sources. Since the backfeed is step-up transformer and unit auxiliary transformer? a delayed source, and based on the recovery instructions in procedure OT 3.6.2.2-7(c). In regard to the above, are non- 3122, *Loss of Normal Power," the two segregated phase buses used to connect the unit immediate offsite sources were chosen for auxiliary transformer (lower sides) to 4.16 kV safety SBO recovery for license renewal.

buses? 3.6.2.2-N-07(a)

No, there is no non-segregated phase Ifthe answer to a, b, or c is yes, explain why metal buses in the path from the startup enclosed buses (iso phase and/or non-segregated transformers to the 4.16 safety buses.

phase buses) are not in scope of license renewal and 3.6.2.2-N-07(b) not require an AMP. The delay access circuit from the 345KV switchyard through the main generator-step-up transformer and unit aux transformer is not in scope for license renewal based on the response to 3.6.2.2-4/21/2006 1:46:05 PM Page 55 of 78

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N-07 above.

3.6.2.2-N-07(c)

No, there are no non-segregated phase buses in the path from the Unit Aux Transformer to the 4.16 safety buses.

Summary The in-scope components required for recovery from a SBO do not include any non-segregated phase bus that requires aging management review.

98 3.6.2.2-N-08 The long-lived, passive components from Al Haumann Stroud, Mike Open Nguyen, Duc 10 CFR 54.4 (a)(3) requires, in part, that all systems, the dam switchyard to the plant are in structures, and components (SSCs) relied on in safety scope and subject to AMR. The analyses or plant evaluation to perform a function that underground cables and connections are demonstrates compliance with the commission's included in E2. The Vernon Dam is regulations for station black out (10 CFR 50.63) are regulated by FERC and inspected per within the scope of license renewal. Vernon FERC regulations.

Hydroelectric Station has been designated as the Station Blackout (SBO) alternate ac (AAC) source and Follow-up Required X Yes No is used to meet SBO requirements 10 CFR 50.63.

Are all SSCs (including electrical components) associated with Vemon Hydroelectric Station included in the scope of licensee renewal? Ifthey are not, explain why not. If they are, provide an AMR for long-lived, passive SSCs associated with the hydro station.

99 Are there any other license renewal intended Vernon Dam is used for hydro-electric" Ahrabli, Reza Closed Woodfield, Jon functions other than SBO, associated with the Vernon generation and is the alternate AC source Dam? 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 altemate cooling cell in the event of a loss of Vernon Dam. The Vernon dam has no intended functions for (10CFR54.4(a)(1) or (a)(2). The Vernon dam is credited for station blackout (10CFR50.63), intended function 10CFR54.4(a)(3).

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100 The NRC requested additional information on The attached Information was provided to Metell / Sweet Open Eads, Johnny licensing renewal, specifcally on how aging the NRC. In addition a FERC inspection management applied to passive components in the report was provided for the damand Vernon Hydroelectic Station. NPCC Document A-3, Emergency Operational Criteria. The NRC requested additional information on jhow as underground cables, buried piping and support systems.

Attachment #100 101 B.1.30.3.M.04 LRA Section B.1.30.3 includes an Lod Potts Accepted Mike Morgan GALL X1.M21 discusses pump and heat exchanger exception to the performance and testing in the parameters monitored I inspected functional testing discussed in the attribute. Is this testing part of the Water Chemistry detection of aging effects attribute. This Control - Colsed Cooling Water Program? exception and its justification are equally applicable to th eparameters monitored I trended attribute.

102 B.1.9-K-11 Provided QA Surveillance 99-010, QA Rick Gerdus Lod Potts Accepted Kennedy, Mike Please provide a copy of QA Surveillance 99-010 and Audit Report QA-2-2005-VY-1 and CR-more recent QA surveillance of Diesel Fuel Monitoring VTY-2005-00196.

Program.

103 B.1.9-K-12 Provided Section 5 of OP2106 Rev. 18, Rick Gerdus Lori Potts Accepted Kennedy, Mike Please identify sample point locations on John Deere App.DJD Diesel day tank sample location diesel and diesel fire pump oil storgage tanks.(Diesel is at the bottom of this tank. Firepump Fuel Monitoring Program) diesel fuel supply & sample point are 2 inches from the bottom of the diesel fire pump fuel tank. (4/21106 08:00) 104 B.1.9-K-13 Provided spreadsheet of monthly analysis Rick Gerdus Lori Potts Accepted Kennedy, Mike Please provide 2000 and 2003 sample results data for the Main Fuel Oil Storage Tank spreadsheet. Also sample lab results for main storage for 2000 and 2003. Also, provided tank and EDG day tanks are desired. (Diesel Fuel example analysis results for samples from Monitoring Program) the Walpole NH supplier tank, the John Deere diesel storage tank, the diesel fire pump storage tank, and the EDG day tanks. (4/20/06 08,000 105 B.1.30.3.M.04 Third party assessment of "Chemistry" on Rick Gerdus Lod Potts Accepted Mike Morgan Please provide a copy of recent third party May 6, 2003 provided for review.

assessment of the water chemistry control - closed Summary states that closed cooling water cooling water program. systems are monitored and treated to provide a chemical environment that minimizes corrosion rates. (4/20/06 08:00) 4/21/2006 1:46:05 PM Page 57 of 78

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106 B.1.2.3-M-04 The existing relief request IS1-03, for B-G- Finnin, Ron Closed Rowley, Jonathan The Reactor Vessel Stud Program takes exception to 2 studs is based on Code Case N-652.

GALL based on relief request ISI-03. The NRC does Code Case N-652 has been endorsed by not believe this should be an exception. the NRC per Table I of Regulatory Guide 1.147, Revision 14.

Review the relief request and ASME code. Ifthis is not an exception, revise the program document. This is conservatively identified in the Reactor Closure Stud Program description as an exception to GALL, because it required relief to the existing code requirements.

107 The commitment to manage locations CUF>1.0 A license renewal commitment list has Finnin, Ron Accepted Hsu, Robert should be on a numbered commitment list. been prepared, and the above commitment is number 27 on the list.

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

NOTE: The commitment isin section 4 (4.3.3.?) not in App.B 108 Identify the site specific calculations for core plate No site specific calculation was found in Finnin, Ron Closed Hsu, Robert hold down bolt preload. the VYNPS current licensing basis for the number / preload of the core plate hold-down bolts required to prevent lateral motion of the core plate.

109 Accurately state I describe the information I See Attachment # 109 Ken Sweet Stroud, Mike Draft Nguyen, Duc documentation requested. Be as specific as possible.

The NRC requested a copy of the Vernon hydrodrawing.

110 Immediate assess: The NRC was told that Ken Sweet Stroud, Mike Draft Nguyen, Duc The NRC had a oneline diagram and asked if bus cables are used from the startup duct was used for theimmediate access source or the transformers to the 4 KV buses and delayed access source. He was interested if an AMR overhead 115 KV bare cable is used to applied to either source for segregated or non- supply the transformers with bus above segregrated bus, if used. the transformers.

Delayed Assess: The NRC was told that there is isophased busduct used on the backfeed for the 22 KV system and it connects to the auxiliary transformer. The NRC requested an AMR that followed NUREG 1801, Volume 1, for the isophase busduct.

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111 Please provide results of the last inspection of the Provided results of 1985 inspection to Dave King Lori Potts Closed Patterson, Malcol welds between the rerouted Malcolm Patterson. 4/19106 10:00 crd return line and the RWCU system. (BWR CRD Return Line Nozzle Program) 112 Please provide documentation related to resolution of Provided documentation 4/19/06 09:00 John Hoffman Lori Potts Closed Hsu, Robert vessel clad cracking.

113 The Bwr penetrations program second exception The inspection of the vessel penetrations Dave King Finnin, Ron Closed Hsu, Robert allows a smaller inspection than the code tol/2' versus 1/2T was approved via Relief (I/Z" vs 1/2" vessel wall thickness). What is the basis Request ISI-09. This relief request is in for this? turn based on ASME Code Case N-613-1.

Code case N-61 3-1 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 it required relief to the existing code requirements.

114 Do the VY instrument nozzles havea bored (cold Thid question was erroneously applied to Ron Finnin Finnin, Ron Closed Hsu, Robert worked) safe end extension? the vessel instrumentation noxzzles.

BWRVIP-49-A requires no additional Ifyes, they require additional inspection. 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 5920-52666R0 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 Accurately state I describe the information I Yes, this is a typographical error and it Ivy, Ted Accepted Lintz, Mark documentation requested. Be as specific as possible. should have said that the Buried Piping LRPD-05 section 4.4.1 second paragraph states that Inspection Program provides reasonable the BWR CRD Return Line Nozzle program provides assurance that the effects of aging will be reasonable assurance. Should this have been the managed such that the current licensing Buried Piping Inspection Progam? basis for the period of extended operation.

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116 B.1.17-N-04 The intent of the VY AMP B.1.17 is to Cox, Alan Open Nguyen, Duc GALL Xl .E3 under program description states, in inspect for water in manholes and to test part, that periodic actions such as inspecting for water the in-scope medium-voltage cables.

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 if you intend to use these periodic actions to preclude cable testings.

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 manholes.

117 B.1.17-N-05 Yes, all of the in-scope medium-voltage Lori Potts Accepted Nguyen, Duc GALL Xl .E3 recommends to test all in-scope cables will be subject to testing per the inaccessible medium-voltage cables. Are all program requirements.

inaccessible medium-voltage cables within the scope of license renewal tested?

118 B.1.17-N-06 The VY AMP B.1.17 will state that the Potts &Stroud Accepted Nguyen, Duc GALL Xt.E3 under parameters monitored/inspected specific type of test to be performed will states that the specific type of test performed will be be determined prior to the initial test and determined prior to the initial test and is to be a is to be a proven test for detecting proven test for detecting deterioration of the insulation deterioration of the insulation system due system due to wetting such as power factor; partial to wetting as described in EPRI TR-discharge test, or polarization index, as described in 103834-Pl-2, or other testing that is state-EPRI TR-1 03834-P1-2, or other testing that is state-of- of-the-art at the time the test is performed.

the-art at the time the test is performed. WNPS 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.

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LeadSunn~ort Status Isetr 119 B.1.17-N-07 Yes, the manholes are inspected on an Stroud, Mike Open Nguyen, Duc Do you currently inspect water inthe man holes. Are annual basis. An example is attached.

there any existing procedures for inspecting man holes. Provide a copy of these procedures.

120 B.1.17-N-08 VY does not have ary medium-voltage Stroud, Mike Accepted Nguyen, Duc GALL XI.E3 defines medium-voltage cable is the cable in-scope that is greater than 15KV.

voltage level from 2kV to 35kV VYNPS AMP B.1.17 The VY AMP B.1.17 will define medium-defines medium-voltage cable is the voltage level voltage cable as voltage level from 2KV to from 2kV to 15kV. Revise the scope of the 35KV.

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 inaccesible medium - voltage cables within the scope of licensee that are greater tham 15kV.

t.2~ ~ ~ - ~.- ~#&-4~-.

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121 B.1.18-N-03 VYNPS B.1.18 AMP under corrective Accepted Nguyen, Duc GALL X1.E2 under corrective actions states that such actions states that 'an engineering an evaluation is to consider the significance of the test evaluation will be performed when the test results, the operability of the component, the acceptance criteria are not met in order to reportability of the event, the extend of the concern, ensure that the intended functions of the the potential root causes for not meeting the test electrical cables can be maintained acceptance criteria, the corrective actions required, consistent with the current licensing and likelihood of recurrence in addition to 10 CFR basis. This evaluation is performed in Part 50, Appendix B. VYNPSB.1.18 under the same accordance with the Entergy corrective element only refers to 10 CFR Part 50 Appendix B to action process per procedure EN-LI-102.

address corrective actions. Revise your AMP This procedure provides the stated corrective actions to be consistent with GALL or elements to consider including the extent provide a justification of why such specific corrective of the concern, the potential root causes actions are not necessary. 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 in the 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, if corrected or eliminated, will preclude repetition of the event or condition.

Corrective Action - Corrective actions include actions intended to preclude repetition of significant conditions and 4/21/2006 1:46:05 PM Page 62 of 78

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those intended to correct adverse conditions.

Corrective Actions to Preclude Repetition

- A type of corrective action intended to correct the root cause of a condition and thereby preclude repetition.

A copy of EN-LI-102 is attached.

122 B.1.18-N-04 VYNPS electrical AMR, AMRE-01, states Stroud, Mike Accepted Nguyen, Duc Why high range radiation monitor cable is not that *Cables and connections in the high-considerel in scope of X1..E2. 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.

123 B.1.19-N-03 Resolution: Closed Nguyen, Duc For all new AMP provide a commitment number and Commitments numbers are being supplied the implementation period for this new program. in a table for all commitments.

124 B.l.19-N-04 In a structure means inside the plant not Stroud, Mike Accepted Nguyen, Duc GALL Xl .El under scope of program states that this outside. The VY B.11.19 will state that the inspection program applies to accessible electrical program applies to accessible electrical cables and connections within the scope of license cables and connections within the scope renewal that are installed in adverse localized of license renewal that are installed in environments caused by heat or radiation in the adverse localized environments caused by presence of oxygen. VYNPS AMP B.1.19 under the heat or radiation in the presence of same element you have stated that this program will oxygen.

include accessible insulated cables and connections installed in structures within the scope of license renewal and prone to adverse localized environments. Clarify if the scope of this program include only insulated cables and connections installed in structures which (structures) are in scope 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 structures are included in the scope of the AMP. Modify the scope of the program as appropriate to remove the confusion 125 B.1.19-N-05 A revised copy of GALL for XI.E3 was Cox, Alan Draft Nguyen, Duc Explain why the GALL X.E1, EQ, is included in the provided.

basic document for non-EQ insulated cables and connections program.

I - - -- - - -a .'

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126 3.6.2.2-N-09 No, the two types of fuse holders are all Stroud, Mike Accepted Nguyen, Duc located in active devices.

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 states that VYNPS employs two general types of fuse holders. The first type is the bolt-mount fuse holder that uses either a lug or capscrew 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 in circuits that perform no license renewal indented functions. Are there any bolt-mount fuse holders in scope of licensee renewal that are not part an active assembly. If there are, explain why aging effects as identified in the GALL is not applicable.

127 B.1.1-L-06 The Maintenance inspectons being Ivy, Ted Draft Lintz, Mark Program Description item. The LRA says 'Buried credited are inpspectons that are being components are inspected when excavated during performed on an as needed basis since maintenance". Is maintenance performed on an as there are no routine scheduled needed basis or is it on a scheduled frequency maintenance inspections of buried piping.

128 B.1.1-L-07 The focused inspection will be performed Lori Potts Draft Lintz, Mark Program Description item. The LRA says "A focused within the first 10 years of the period of inspection will be performed within the first 10 years of extended operation, unless an the period of extended operation...." The LRA seems opportunistic inspection occurs within this to address inspections that occur both before and ten-year period as stated in LRPD-02 during the period of extended operation; the Appendix section 4.1.B.4.b of the Buried Piping A reference does not clarify this confusion. When Inspection Program and in Appendix B.1.1 does VY plan to perform these focused inspections? 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 priop to the period of extended operation. These inspections revealed no coating or piping degradation.

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129 B.1.1-L-07 Appendix A is correct as written. The Ivy, Ted Draft Lintz, Mark Program Description item. Depending on the focused inspection is specified for the ten response to the above question, please clarify the years immediately after entering the Appendix A reference, as needed. period of extended operation. This is consistent with the SER for Brunswick dated March 2006.

130 B.1.1-L-08 It was the intent of the enhancement Ivy, Ted Draft Lintz, Mark Acceptance Criteria item. The GALL Report says "Any specified in B.1.1 to revise appropriate coating and wrapping degradations are reported and sections of procedure PP7030 to Include evaluated according to site corrective actions atributes of coating damage and evidence procedures." The LRA says "Coating and wrapping of corrosion. This would include updating degradation, or loss of material due to corrosion, is sections 4.3 &4.8.

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?

131 B.1.1-L-09 Yes, this is a typographical error and it Draft Lintz, Mark Operating Experience item.. Why does LRDP-05, should have said that the Buried Piping Section 4.4.1 reference the BWR CRD Return Line Inspection Program provides reasonable Nozzle Program? assurance that the effects of aging will be managed such that the current licensing basis for the period of extended operation.

132 B.1.30.2-M-03 Provided Revision 1 of Technical Rick Gerdus Lori Potts Accepted Mike Morgan An exception to BWRVIP - 130 criteria for feedwated Justification for Continued Operation of copper was noted. Please provide related information. Entergy Northeast Vermont (Water Chemistry Control - BWR Program. Yankee.(ENVY) with Feedwater Copper >

0.2 ppb. (4/20/06 08:00) 133 B.1.30.2-M-04 Third party assessment of BWR Water rick Gerdus Lori Potts Accepted Mike Morgan Please provide a copy of recent third party Chemistry control from March 2001, May assessments of the Water Chemical Control - BWR 2003 and April 2005 were provided for Program. review. (4/20106 08:00) 4/21/2006 1:46:05PM Page 65 of 78

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134 B.1.8-L-02 Type A testing) and due to the Ted Underkoffler Ahrabli, Reza &Port Accepted Lintz, Mark Detection of Aging Effects item. PP 7006, Section expectations of VY on maintaining 4.4.4, refers to a Type A Test, which will be operating procedures current, OP 4029 developed. Please explain. (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 that adopts the latest test equipment, processes, software programs, and testing philosophies into to the infrequently conducted evolution (SOER 91-01), thereby insuring that the complex Type A testing process is thoroughly understood by the test engineer. With the inception of 10CFR50 Option B (increased intervals of 135 B.1.8-L-03 Under current regulations and NEI Ted Underkoffler Ahrabli, Reza Accepted Lintz, Mark Monitoring and Trending item. The GALL Report says guidance, the one time change does not "The frequency of these tests depends on which affect the Type A test interval or number option (A or B)is selected. With Option A, testing is of tests to be conducted during the period performed on a regular fixed time interval as defined of extended operation.

in 10 CFR Part 50, Appendix J."The LRA says "The first Type A test 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 A test 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 4/2112006 1:46:05PM Page 66 of 78

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136 B.1.8-L-04 At present, VY does not take direct Ted Underkoffier Ahrabli, Reza Accepted Lintz, Mark Monitoring and Trending item. Does VY take any exception to any provision in RG 1.163.

exception to the testing guidance of RG 1.163 or NEI VY does take exception to NEI 94-01.

94-01? Specifically, with the adoption (TSA 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 I OCFR50 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 (TSA 223) for the VY current license and through the possible license extension period is required.

137 B.1.8-L-05 See B.1.1 8-L-04 exception basis for Ted Underkoffler Ahrabli, Reza Accepted Lintz, Mark Acceptance Criteria item. LRPD-02 identifies the response.

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 plants current licensing basis. The current licensing basis carries forward to the period of extended operation." The LRA says WVYNPS acceptance criteria are defined in plant technical specifications." Please expand on why the acceptance criteria is not consistent with the GALL Report.

138 VY incorporates, as necessary, lessons Ted Underkoffler Ahrabli, Reza Accepted Lintz, Mark B.1.8-L-06 learned into the Containment Leak Rate Operating Experience item. Does VY monitor industry Program from operating experiences issueslevents and assess these for applicability to its Identified at VY and industry operating own program? 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.

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139 B.1.14-K-01 Kelly Loch Ivy, Ted Accepted Kennedy, Mike Requested operating experience information on a sample of the heat exchangers included in the Heat RESPONSE:

Exchanger Monitoring Program if any is available. Operating History search was performed on the following components:

HPCI gland Seal condenser (E-18-1A)

HPCI Lube oil coolers (E-19-1A)

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

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

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

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

Reactor Recirculation pump seal water coolers (P-18-1 A/B Hx-3)

Reator Recirculation pump motor upper &

lower bearings oil coolers (P-1 8-1 A/B Hx-2)

Reactor Recirculation pump motor air coolers (P-1 8-1A/B 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 10104/2002- E-18-1A 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-l through 4 are inspected and lubricated during refueling outages-External inspections only LIST OF ATTACHMENTS:

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

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Su--Ort Status Inspector:

140 B.1.14-K-02 RESPONSE: Harry Breite Ivy, Ted Accepted Kennedy, Mike What is the proposed frequency of inspection and basis of the frequency selected for the heat The development of the non Service exchangers included in the Heat Exchanger Water (SW) cooled heat exchanger Monitoring Program. 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:

ODrywell Coolers, RRU-1 through 4 OHPCI Gland Seal Condenser, E-1 8-1A OHPCI Lube Oil Cooler, E-19-1A ORCIC Lube Oil Cooler, E-21-1A CST Reheat Coil, E-HB-1 Drywell Equipment Drain Cooler, E-ESC-1A Reactor Recirculation Pump Seal Water Coolers, P-1 8-1A HX-3 & P-1 8-1 B HX-3 Recirculation Pump Motor Upper & Lower Bearing Oil Coolers, P-18-lA HX-2 & P 1B HX-2 Recirculation Pump Motor Air Coolers, P-18-IA HX-1 & P-18-1B HX-l 13 The follow is an example of the steps which would be used to develop the plan:

1.DAn initial visual inspection would be performed of the in scope 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.OWhere 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 4/2"1/20061:46:05 PM Page 69 of 78

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Preventive Maintenance process.

4.oPerformance 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 B.t.12.1-L-07 System walkdown every 6 months, Larry Lukens Draft Lintz, Mark Scope of Program item. The GALL Report has starting prior to period of extended requirements in numerous program elements that are operations.

on a six-month frequency. The LRA states that these are on a refueling (twenty-month) frequency. Please The VY AMP B.1.17 will state that the discuss and justify the inspection frequency specific type of test to be performed will differential for the C02 .system. 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 142 ResolutionVYNPS electrical AMR, Stroud, Mike Draft Nguyen, Duc Accurately state / describe the information I AMRE-0 1, states that "Cables and documentation requested. Be as specific as possible. connections in the high-range reactor building area monitoring system, support B.1.18-N-04. Why high range radiation monitor a license renewal intended function.

cable is not considered in scope of XI.E2. 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.

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143 B.1.18-N-05 Al Haumann Stroud, Mike Open Nguyen, Duc 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 wUl be based on the specific instrumentation circuit under surveillance or being calibrated, as document in the 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.

144 B.1.18-N-06 Al Haumann Stroud, Mike Open Nguyen, Duc 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?

145 B.1.20-K-03 QA Surveillance SRVY 2002-025 and Ron Scherman Lori Potts Open Kennedy, Mike Please p[rovide QA Surveillance and self-assessment 2003 self-assessment provided. (4/19/06 referenced in operating experience for Oil Analysis 17:00)

Program.

146 B.1.12.1-L-07 The TRM frequencies are those that were Larry Lukens Draft Lintz, Mark Scope of Program item. The GALL Report has in the Technical Specifications. We have requirements in numerous program elements that are no objection to increasing the frequency of on a six-month frequency. The LRA states that these these surveillances, provided thatthey can are on a refueling (twenty-month) frequency. Please be safely performed online.

discuss and justify the inspection frequency differential for the C02 .system. System walkdown every 6 months starting prior to period of extended operation.

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I 147 B.1.12.1-L-08 VY has a Fire Hazards Analysis, which we Larry Lukens Draft Lintz, Mark Preventive Actions item. The GALL Report says "For will be happy to provide operating plants, the fire hazard analysis assesses the fire potential and fire hazard inall plant areas....

The LRA says "The NUREG-1 801 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?

148 B.1.12.1-L-09 These dampers are in ventilation ducts; Larry Lukens Draft Lintz, Mark Parameters Monitored/Inspected item. The GALL therefore, the conditions would be similar Report says "Visual inspection of the fire barrier walls, to other ambient conditions inthe plant.

ceilings, and floors examines any sign of degradation Specific materials not known at this time.

such as cracking, spalling, and loss of material Will research and provide separately caused by freeze-thaw, chemical attack, and reaction with aggregates." The LRA says "Procedures will be Material is carbon steel: environment is enhanced to specify that fire damper frames in fire indoor air.

barriers shall be inspected for corrosion." What is the material and environment of the damper frames?

149 B.1.12.1-L-10 Visual exam, consistent with ANSI 45.2.6 Larry Lukens Draft Lintz, Mark Parameters Monitored/Inspected item. What examination technique will be used?

150 B.1.12.1-L-11 Commitment #9 Larry Lukens Draft Lintz, Mark Parameters Monitored/nspected 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?

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151 B.1.12.1-L-12 Commitment #8 Larry Lukens Draft Lintz, Mark 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, separation of seals from walls and components, separation of layers of material, or ruptures or punctures of seals; no visual indications of concrete cracking, spalling 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 'significant?*

152 B.1.12.1-L-13 Commitment #8 Larry Lukens Draft Lintz, Mark Acceptance Criteria item. What actions are taken, either with or without significant corrosion?

153 B.1.12.1-L-14 Commitment #8 Larry Lukens Draft Lintz, Mark Acceptance Criteria item. Is there a VYNPS commitment associated with this enhancement?

154 B.1.12.1-L-15 Evidence of corrosion inside the fuel line Larry Lukens Draft Lintz, Mark Acceptance Criteria item. The GALL Report says "No would appear as corrosion products in the corrosion is acceptable in the fuel supply line for the fuel filter. Evidence of corrosion in the diesel-driven fire pump." The LRA says "Acceptance fuel filter would result in a Condition criteria will be enhanced to verify that the diesel Report and an evaluation. Evidence of engine did not exhibit signs of degradation while it corrosion would be an inspection criterion was running; such as fuel oil, lube oil, coolant, or for fuel filters removed from service. In exhaust gasleakage." Does the enhancement include addition, the internals of the fuel line are corrosion in the fuel supply line of the diesel-driven managed by the deisel fuel oil monitoring fire pump? program 155 B.1.12.1-L-16 Commitment # 9 Larry Lukens Draft Lintz, Mark Acceptance Criteria item. Is there a VYNPS commitment associated with this enhancement?

156 B.1.12.1-L-17 OE Coordinator provided 12 since 2002 Larry Lukens Draft Lintz, Mark Operating Experience item. Has VY experienced any with the key word "Fire."

fire-protection-related operating experience? Please describe.

157 B.1.12.1-L-18 VY routinely reviews Industry OE in Larry Lukens Draft Lintz, Mark Operating Experience item. Has VY reviewed and accordance with fleet procedure, EN-OE-applied the industry operating experience that relates 100. The VY OE coordinator routes OE to to fire protection? affected line organization groups, and enters action items into the corrective action process to ensure that timely review is completed and documented 412112006 1:46:05PM Page 73 of 78

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158 B.1.12.1-L-19 No Larry Lukens Draft Lintz, Mark Operating Experience item. Is any VY plant-specific operating experience not bounded by industry operating experience?

159 B.1.12.1-L-20 Yes. Surveillance Test #7134 is the Larry Lukens Draft Lintz, Mark Program Description item. Does VY inspect the fire Operating Cycle Test of Fire Barrier dampers? Dampers, using procedure OP 4019.

We will add Fire Dampers to the program description.

160 B.1.12.1-L-21 Yes. The pump end is identical to the Larry Lukens Draft Lintz, Mark Program Description item. Does VY have an electric diesel fire pump. It is located in the Intake fire pump? Structure. Component IDis P-40-1 B.

Managed by Fire Water Program. Test Procedure # OP 4105.

161 B.1.12.1-L-22 Test Procedure # Larry Lukens Lintz, Mark Program Description item. How does VY inspect/test Appendix R-required equipment?

162 B.1.12.1-L-23 At VY, the program is not yet sufficiently Larry Lukens Draft Lintz, Mark Detection of Aging Effects item. The GALL Report formal and will include training, says "Visual inspection by fire protection qualified acceptance criteria, and qualification as a inspectors...." Of what does this consist, at VY? "fire protection qualified individual ANSI 45.2.6 The injection program, EN-MA-1 02, will be used.

163 B.1.12.1-L-24 OP 4019 acceptance criteria will be Larry Lukens Draft Lintz, Mark Acceptance Criteria item. The GALL Report says revised to require that any recordable "Inspection results are acceptable if there are no .outside those allowed by approved visual indications (outside those allowed by approved penetration seal configurations" visual penetration seal configurations) of cracking,..." OP indication be identified and entered into 4019, Appendix B, allows cracks in poured concrete the corrective action process for barriers, fire barriers, concrete block walls, drywall, evaluation.

plaster, silicone foam, pyrocrete, and smoke/gas seals. The CA number to complete this action by 12/31/06 is CR-VTY-2006-112. CA-02; CA-03.

164 B.1.30.1-M-02 Rick Gerdus Ivy, Ted Open Mike Morgan Is the identified enhancement to AMP B.1.30, Water Chemistry Control - Auxiliary Systems, necessary and appropriate for this program 165 B.1.30.1-M-03 Rick Gerdus Ivy, Ted Open Mike Morgan Confirm that there are no other in-scope systems that rely on this AMP for managing the effects of aging.

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166 B.1.21-K-04 LRA Section 3 Table l's discussions Rick Gerdus Lori Potts Accepted Kennedy, Mike LRA Section 3 Table 2's do not list the One-Time provide the link between the One-Time Inspection Program with the water chemistry control Inspection and Water Chemistry Control porgrams for components for which GALL Program for these components.

recommends One-Time Inspection to verify The Appendix A description for the Water effectiveness of the Water Chemistry Control Program. Chemistry Control - BWR, closed cooling water and Auxiliary Systems programs will be revised to provide a link to the One-Time Inspection Program activities to confirm the effectiveness of these programs.

167 B.1.21.-K-05 Inspection locations will be based on Scott Goodwin Lori Potts Accepted Kennedy, Mike Please provide sample selection criteria for the small - physical accessability exposure levels, bore piping one-time inspection program. NDE techniques, and locations identified in NRC Information Notice 97-46, Unisolable Crack in High-Pressure Injection Piping. The initial population will include all Class 1 small - bore piping.

168 BI.15.2-P-01 Draft Patterson, Malcol Please explain why the AMP for ISI (IWB, IWC, &

IWD) is not consistent with the GALL AMP XI.MI 169 B.1.15.2-P-02 Draft Patterson, Malcol 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 ISI.

170 Provide the basis for determining the inspections Larry Lukens Finnin, Ron Open Hsu, Robert required for BWRVIP-48. Particarly address whether VY has any furnace sensitized material or Alloy 182 material that requires EVTI.

171 Provide the last two inspection reports for one David Grimes Ahrabli, Reza Open Woodfield, Jon unreinforced Masonry Wall without bracing, one reinforced Masonry Wall without bracing and one steel braced Masonry Wall.

172 Please provide copies of OP4339 and EN-OE-100, Provided copies of OP4339 and EN-OE- Lori Potts Accepted Lintz, Mark procedures related to the Fire Water System Program. 100.

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173 In Section2b Preventive actions of LRPD-02 and it is Yes, The Water Chemistry Control - Ivy, Ted Closed Patterson, Malcol stated that there are not preventive actions. GALL Closed Cooling Water and BWR programs says that monitoring of water chemistry to control pH at VYNPS controlpH and corrosive and concentration of corrosive contaminants and contaminants and could be effective in treatment with hydrazine are effitive in reducing controlling selective leaching. Therefore selective leaching. Do any of the systems that have andy system amd components with both selective leaching as an AMP have a treated water the selective leaching and the water environment that performs any of these treatments to chemistry programs as aging control selective leaching? management programs are included measures that could be effictive in controlling the aging effect of selective leaching.

174 What is the flaw evaluation calculation for the jet Larry Lukens Finnin, Ron Open Hsu, Robert pump diffuser welds? Is this calculation considered a TLAA?

175 Will LIT of the flawed jet pump diffuser welds Larry Lukens Finnin, Ron Open Hsu, Robert continue?

176 Will VY continue to inspect 10% of CRD guide tubes Larry Lukens Finnin, Ron Open Hsu, Robert every 12 years?

177 Will VY continue to inspect the top guide at the rate of Larry Lukens Finnin, Ron Closed Hsu, Robert 10% every 12 years?

This question has been addressed in item # 14.

178 What is the exam history, results, schedule and Larry Lukens Finnin, Ron Draft Hsu, Robert current status of shroud H8 and H9 welds?

179 Please provide a recent third party assessment of the Rich Rusin Lod Potts Draft Mike Morgan preventive maintenance program.

180 Following the proposed enhancement to the {eriodic Rich Rusin Lod Potts Draft Mike Morgan Surveillance and Preventive Maintenance Program, will it be apparent that these tasks contain an aging management element?

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181 B.1.22-L-01 The Walkdown program is not exclusive of Draft Lintz, Mark Program Description item. The GALL Report says any system material condition. It should "The External Surfaces Monitoring program is based be noted that the walkdown process may on system inspections and walkdowns. This program find signs of external piping degradation consists of periodic visual inspections of steel that would be evaluated for potential components such as piping, piping components, impact to interior piping surfaces. The ducting, and other components within the scope of walkdown program is not intended to license renewal and subject to AMR in order to inspect interior piping and component manage aging effects. The program manages aging surfaces unless they have been revealed effects through visual inspection of external surfaces for inspection during maintenance and for evidence of material loss. Loss of material due to repairs.

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 external 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?

182 B.1.22-L-02 System Walkdown use eye contact Draft Lintz, Mark Program Description item. What examination methods examination. System Engineers are not are used? qualified in visual 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.

183 System Walkdowns, both online and Draft Lintz, Mark B.1.22-L-03 during refueling outages, have found Operating Experience item. . Has VY experienced any corrosion on piping and component external surfaces-related operating experience? surfaces. For instance, each refueling, Please describe. the interior of the condenser hotwell and waterboxes are inspected. Repairs and or more detailed inspections are affected as required. In Refueling Outage 24 (November 2005) examination of spring cans supporting service water piping revealed rust and the need for recoating.

Corrective actions driven through condition reporting and work order planning will result in recoating in 2006.

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184 B.1.22-L-04 Vermont Yankee System Engineers have Draft Lintz, Mark Operating Experience item. Has VY reviewed and received training in the EPRI Aging applied the industry operating experience that relates Management Field guide, which in effect to external surfaces? 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.

185 B.1.22-L-05 Through its condition reporting system, Draft Lintz, Mark Operating Experience item. Is any VY plant-specific Vermont Yankee will contribute to industry operating experience not bounded by industry OE as its Condition Reporting Committee operating experience? directs. Aging related issues with Vermont Yankee are typical of industry based OE.

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