ML070440451

AMRM-02, Revision 1, Aging Management Review of RHR System.

ML070440451
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/11/2006
From:	- No Known Affiliation
To:	Office of Nuclear Reactor Regulation
Richmond, J E, RI/DRS/EB1, 610-337-5220
References
AMRM-02, AMRM-02. Rev 01
Download: ML070440451 (32)

Text

VERIFICATION OF VYNPS LICENSE RENEWAL PROJECT REPORT Title of Report: Aging Management Review of the Residual Heat Removal System Report Number: AMRM-02 Revision: 1 This report documents evaluations related to the VYNPS license renewal project. Signatures certify that the report was prepared, checked and reviewed by the License Renewal Project Team in accordance with the VYNPS license renewal project guidelines and that it was approved by the ENI License Renewal Project Manager and the VYNPS Manager, Engineering Projects.

License Renewal Project Team signatures also certify that a review for determining potential impact to other license renewal documents, based on previous revisions, was conducted for this revision.

Other document(s) impacted by this revision: Yes, See Attachment X No License Renewal Project Team Prepared by: Date: ______

Stan Batch Reviewed by: Date: ______

M. Keith Graham Approved by: Date: ______

David J. Lach, ENI LR Project Manager VYNPS Approval Reviewed by Date:

Approved by Date:

VYNPS Manager, Engineering Projects

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 2 of 32 REVISION DESCRIPTION SHEET Revision Description Pages and/or Sections Revised Number 1 To correct conflicting statements in section 1.3, page 6 Formatted: Font: (Default) Arial, 11 section 1.3 for SBO requirements. pt, Not Bold

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 3 of 32 TABLE OF CONTENTS 1.0 Introduction ..........................................................................................................4 1.1 Purpose ...............................................................................................................4 1.2 System Description ..............................................................................................4 1.3 System and Component Intended Functions .......................................................6 2.0 Screening.............................................................................................................8 3.0 Aging Effects Requiring Management..................................................................9 3.1 Drywell and Torus Spray Headers and Nozzles ...................................................9 3.2 Carbon Steel Components Containing Treated Water .......................................10 3.3 Stainless Steel Components Exposed to Treated Water and Indoor Air ............10 3.4 RHR Heat Exchangers (E-14-1A, 1B) ................................................................11 3.5 RHR Seal Coolers..............................................................................................12 3.6 Cyclone Separators and Seal Injection Components .........................................12 3.7 Thermal Expansion Accumulator (S-26A) ..........................................................12 3.8 Bolting................................................................................................................13 3.9 Operating Experience ........................................................................................13 4.0 Demonstration That Aging Effects Will Be Managed..........................................14 4.1 Water Chemistry Control - BWR Program .........................................................14 4.2 Water Chemistry Control - Closed Cooling Water Program ...............................15 4.3 System Walkdown Program...............................................................................15 4.4 Service Water Integrity Program ........................................................................15 4.5 Selective Leaching Program ..............................................................................16 4.6 Time-Limited Aging Analyses.............................................................................16 5.0 Summary and Conclusions ................................................................................17 6.0 References ........................................................................................................18 Attachments ..................................................................................................................20 Components Subject to AMR..................................................................20 Aging Management Review Results .......................................................29

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 4 of 32 1.0 Introduction 1.1 Purpose This report is part of the aging management review (AMR) of the integrated plant assessment (IPA) performed to extend the operating license of Vermont Yankee Nuclear Power Station (VYNPS). This report demonstrates the effects of aging on residual heat removal (RHR) system passive mechanical components will be adequately managed so that the intended functions will be maintained consistent with the current licensing basis as required by 10 CFR 54.21(a)(3). For additional information on the license renewal project and documentation, refer to the License Renewal Project Plan.

The purpose of this report is to demonstrate that the aging effects for passive mechanical components will be adequately managed for the period of extended operation associated with license renewal. The approach for demonstrating management of aging effects is to first identify the components that are subject to aging management review in Section 2.0. The next step is to define the aging effects requiring management for the system components in Section 3.0. Section 4.0 then evaluates if existing programs and commitments adequately manage those effects.

Applicable aging effects were determined using EPRI report 1003056 Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools (Ref. 4). This EPRI report provides the bases for identification of aging effects based on specific materials and environments and documents confirmation of the validity of the aging effects through review of industry experience. This aging management review report (AMRR), in conjunction with EPRI report 1003056, documents the identification and evaluation of aging effects requiring management for mechanical components in the RHR system.

1.2 System Description As described in the UFSAR section 4.8 (Ref. 2) and in the system DBD (Ref. 3), the RHR system consists of two closed loops, each loop containing two pumps in parallel, one heat exchanger, and the necessary valves and instrumentation. The RHR heat exchanger in each loop is cooled by the RHR service water (RHRSW) system. The RHR system is designed to remove decay heat energy from the reactor under both operational and accident conditions.

The system is normally in standby and is operated only during testing and periods when the unit is shutdown.

The modes of operation of the RHR system are as follows (Ref. 3):

low pressure coolant injection (LPCI) mode containment spray cooling (drywell spray and torus spray) mode suppression pool cooling mode shutdown cooling (SDC) mode alternate shutdown cooling mode augmented fuel pool cooling mode emergency reactor vessel fill (RHRSW intertie) mode alternate shutdown mode

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 5 of 32 The LPCI mode of RHR takes suction from the suppression pool and injects into the core region of the reactor vessel through one of the two reactor recirculation loops. This mode of operation is designed to restore and maintain the water level in the reactor vessel following a loss of coolant accident.

The containment spray cooling mode of RHR takes suction from the suppression pool and injects into spray headers located in the drywell and suppression chamber. This mode of operation is designed to reduce containment pressure and temperature following a loss of coolant accident by cooling any non-condensables and condensing any steam which may be present.

The suppression pool cooling mode of RHR takes suction from the suppression pool, passes it through the RHR heat exchangers, and returns flow to the suppression pool. This mode of operation is designed to remove heat from the suppression pool.

The shutdown cooling mode of RHR takes suction from the reactor vessel via the reactor recirculation A loop suction piping, passes it through the RHR heat exchangers, and returns it to the reactor through the recirculation lines. This mode of operation is designed to remove sensible and decay heat from the reactor during shutdown.

The alternate shutdown cooling mode provides a cooling path if the normal shutdown cooling path is inoperable. The RHR pumps take suction from the suppression pool, pass it through the RHR heat exchangers and inject into the vessel via the RHR injection valves. The SRVs on the reactor vessel are open to allow overflow to the suppression pool.

The augmented fuel pool cooling mode takes suction from the fuel pool cooling system, passes it through the RHR heat exchangers, and discharges back to the fuel pool cooling system. This mode of operation is designed to assist in fuel pool cooling during reactor shutdown periods and alternate cooling system operation. This is not a safety related function, but the components in this flow path are safety grade and are included in this AMRR. (Ref. 2, 18)

The emergency reactor vessel fill mode of RHR provides a cross-tie between the RHR service water system and the A loop of RHR piping. The RHRSW pumps take suction from the service water system and inject into the reactor vessel through the RHR piping. This mode of operation is designed to provide a source of water to maintain the reactor core covered (and fill containment) in the event that core standby cooling systems (CSCS) pumps are lost due to loss of containment pressure or in the event that adequate core cooling cannot be assured.

The alternate shutdown mode of RHR uses the RHR alternate shutdown panel to control the minimum number of valves required for vessel injection, torus cooling and shutdown cooling modes. This mode of operation is designed to achieve and maintain cold shutdown following a fire in the control room or cable vault which eliminates the normal means of control of the system.

For additional description of the system and its components, see the RHR system design basis document. (Ref. 3)

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 6 of 32 1.3 System and Component Intended Functions As described in UFSAR section 4.8, the safety objectives of the residual heat removal system are to:

1. To restore and maintain the coolant inventory in the reactor vessel so that the core is adequately cooled after a loss-of-coolant accident.

2. To provide cooling for the suppression pool so that condensation of the steam resulting from the blowdown due to the design basis loss-of-coolant accident is ensured.

3. To extend the redundancy of the core standby cooling systems by provision of containment cooling.

As described in section 4.8 of the UFSAR, the power generation objectives of the residual heat removal system are to:

1. Remove decay heat and residual heat from the nuclear system so that refueling and nuclear system servicing can be performed.

2. Supplement the fuel pool cooling system capacity when necessary to provide additional cooling capacity.

The components in the residual heat removal system that support the function to remove decay heat and residual heat from the nuclear system require an aging management review even though this is a nonsafety function since this function is required to support 10 CFR 50.48 (fire protection) requirements.

The system components that are only required for supplemental fuel pool cooling do not require aging management review since this is not a safety function nor is it required for the regulated events in the license renewal scoping criteria.

The components that are only required to support the emergency reactor vessel fill mode of RHR are included in this aging management review, but this function does not add any components to the review since the same components have a safety function.

The RHR system mechanical components perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48) since the RHR system is one of the systems credited in the fire hazard analysis report. (Ref. 3)

The RHR system passive mechanical components are not relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61-not applicable for BWRs), anticipated transients without scram (10 CFR 50.62), or station blackout (10 CFR 50.63). (Ref. 2, 6, 23)

For license renewal, the primary intended function of the RHR components and piping is to maintain system pressure boundary integrity. The heat exchangers have the additional function

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 7 of 32 1

of heat transfer . Spray nozzles and orifices required to limit the flow rate have the additional function of flow control. The cyclone separators have the additional function of filtration. For additional information on the system and component functions, see the RHR system design basis document (Ref. 3).

System components outside of the safety class boundary of the RHR system whose failure could prevent satisfactory accomplishment of safety functions [10 CFR 54.4(a)(2)] that are not reviewed in this AMRR are reviewed in AMRM-30, Aging Management Review of Nonsafety-related Systems and Components Affecting Safety-related Systems. For VYNPS this includes items such as piping, valves, pumps, and support elements outside of the safety class pressure boundary, that are required to be structurally sound in order to maintain the integrity of safety class piping.

Although the majority of the components reviewed in the this AMRR are in the RHR system, there is a small section of pipe (see LRA-G-191177 sheet 1) and four valves (V20-319A, B, C, and D) that in the database are in the radwaste (RDW) system code. These are included in this AMRR since their safety function is to maintain the RHR system pressure boundary. Refer to VYNPS Report LRPD-01, System and Structure Scoping Results, for additional information on scoping and intended functions of systems and structures for license renewal.

1 The RHR pump seal coolers are not required to transfer heat during analyzed accidents, but cooling by the seal coolers is credited for safe shutdown following a fire with alternate cooling water available from the service water system. (Ref. 8) Therefore, heat transfer is a license renewal intended function for the seal coolers.

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 8 of 32 2.0 Screening Passive, long-lived components that perform a license renewal component intended function are subject to aging management review. Bolting, cyclone separators, heat exchangers, strainers, thermowells, nozzles, orifices, tanks, pump casings, piping, tubing and valves in the RHR system that maintain system pressure boundary integrity or provide heat transfer are passive, long-lived components and are therefore subject to aging management review.

Components in the RHR system that are included in this AMRR include the suction strainers in the torus, the RHR pumps (P-10-1A, B, C, D), the RHR heat exchangers (E-14A, B), the drywell and torus spray headers and the valves and piping that maintain the pressure boundary of the RHR system. The components in the Class 1 boundary are reviewed in report AMRM-33, Aging Management Review of the Reactor Coolant System Pressure Boundary.

Insulation is installed on some equipment in the RHR system. For the evaluation of insulation, refer to LRPD-01, System and Structure Scoping Results, and AMRC-06, Aging Management Review of Bulk Commodities.

A list of the RHR system passive mechanical components subject to aging management review is included as Attachment 1. The flow diagrams associated with this system, highlighted to reflect the components requiring aging management review, are available as drawings LRA-G-191168, LRA-G-191172, and LRA-G-191177. (Ref. 1)

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 9 of 32 3.0 Aging Effects Requiring Management EPRI report 1003056 is used in this section to identify and evaluate aging effects requiring management. Aging effects for non-Class 1 components that may result in loss of intended functions are cracking (i.e., crack initiation, crack growth, and through-wall cracking), loss of material, and fouling. For additional information on aging effects, refer to EPRI report 1003056.

(Ref. 4) is a list of RHR system components that form the system pressure boundary.

These components require aging management review in this AMRR and are highlighted on the associated LRA drawing.

The following sections document the determination of aging effects requiring management for specific component materials and environments.

Portions of this system located in the primary containment where normal temperature is 165°F. Other portions of this system are in the reactor building where normal temperature is approximately 100°F. (Ref. 2) 3.1 Drywell and Torus Spray Headers and Nozzles The drywell and torus spray header piping is carbon steel and the nozzles are copper alloy 2

(brass ). They are normally exposed to an internal environment of nitrogen during operation and indoor air during outages. The RHR drywell and torus spray headers have isolation valves in the headers, but operating experience reveals leakage into the header has occurred in the past. (See note 10 on G-191172 and section 3.9 for further information.) The pipe can contain water up to the spray nozzle opening if leakage occurs since the nozzle is located on the side of the pipe. Therefore, the aging effects will be identified for both a dry and a wetted environment inside the pipe since the lower portions of the header may be wetted by water trapped below the nozzle. There is a drain now installed that should prevent water from accumulating to the point of reaching the nozzles, and if water did reach the elevation of the nozzle it will run out the nozzles since they are pointing downward, so water cannot be present in the nozzles. (Ref. 1, 3, 15)

Loss of material due to general corrosion, pitting corrosion, crevice corrosion and MIC is an aging effect requiring management for internal surfaces of spray header carbon steel components that are wetted. Loss of material due to localized galvanic corrosion is an aging effect requiring management for interfaces between carbon steel and the copper alloy components that are wetted. Erosion is not a concern since the header is not in use. Loss of material due to general corrosion is considered an aging effect requiring management for carbon steel internal or external surfaces exposed only to indoor air.

There are no aging effects requiring management for the copper alloy nozzles internal or external surfaces in indoor air and nitrogen environments since copper alloy is inherently resistant to corrosion.

2 The zinc content is not known, but this information is not required since these components are located in air and therefore not susceptible to selective leaching.

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 10 of 32 Cracking due to thermal fatigue is not an aging effect requiring management since this portion of the system is at ambient temperature and remains below the thresholds for fatigue during normal plant operation. (Ref. 1, 3) 3.2 Carbon Steel Components Exposed to Treated Water This section will review the treated water filled portions of the RHR system including pump casings, valves, piping, and thermowells that are carbon steel (pipe class CS-1, 2, and 5). See for a listing of carbon steel components. (Ref. 1, 11, 13)

Loss of material due to general corrosion, pitting corrosion, crevice corrosion and MIC is an aging effect requiring management for internal surfaces of RHR carbon steel components. Loss of material due to localized galvanic corrosion is an aging effect requiring management for interfaces between carbon steel and stainless steel components. Erosion is not a concern for the majority of the system components since the system is normally in standby, but loss of material due to erosion is an aging effect requiring management for the carbon steel components with high velocities such as pump casings.

Cracking due to thermal fatigue is an aging effect requiring management for RHR system components that are exposed to SDC temperatures during a plant cooldown. When the reactor pressure is reduced below 100 psig (steam dome), the piping of the RHR system that is used for shutdown cooling is flushed with hot reactor coolant to preheat the piping. The components not in the SDC flow path such as the spray headers and associated piping and valves will not experience elevated temperatures. Therefore both high temperature and low temperature environments are presented on Attachments 1 and 2. (Ref. 1, 3, 14)

Loss of material due to general corrosion is considered an aging effect requiring management for carbon steel external surfaces exposed to indoor air. There is a small portion of the suction piping that is submerged and exposed to the same environment on the external surface as the internal surface. This external submerged surface can experience loss of material due to general corrosion, pitting corrosion, crevice corrosion and MIC.

3.3 Stainless Steel Components Exposed to Treated Water and Indoor Air This section will review treated water filled portions of the RHR system that are constructed of stainless steel including suction strainers, flow orifices (flow elements and restricting orifices),

thermowells, valves and tubing. See Attachment 1 for a listing of the components. (Ref. 7, 11, 13, 17)

Loss of material due to pitting, crevice corrosion or MIC is an aging effect requiring management for internal wetted stainless steel surfaces. Loss of material due to erosion is not an aging effect requiring management due to the inherent resistance of stainless steel to erosion.

There are no aging effects requiring management for external stainless steel surfaces exposed to indoor air due to the inherent resistance of stainless steel to aging effects when not continuously wetted or exposed to aggressive chemicals.

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 11 of 32 Submerged components such as the suction strainers have the same aging effects requiring management on external surfaces as on internal surfaces. Loss of material due to pitting, crevice corrosion or MIC is an aging effect requiring management for internal and external wetted stainless steel surfaces. The suction strainers during normal plant operation are below the 140°F threshold for cracking from stress corrosion (SCC) and intergranular attack (IGA) since the torus water is below this threshold. (Ref. 16)

Cracking due to thermal fatigue is an aging effect requiring management for RHR system components exposed to SDC temperatures during a plant cooldown, since temperatures may be above the 270ºF threshold for thermal fatigue of stainless steels. The components not in the SDC flow path such as instrument tubing and valves and the suction strainers will not experience elevated temperatures. Therefore, cracking due to thermal fatigue is not an aging effect requiring management for these components.

3.4 RHR Heat Exchangers (E-14-1A, 1B)

The RHR heat exchangers are shell and tube heat exchangers. The heat exchangers are cooled by the RHR service water system. The shutdown cooling water flows through the shell and the RHR service water flows through the tubes. The heat exchanger tubes are stainless steel and the shell is carbon steel. The tube sheets are carbon steel clad with stainless steel.

(Since this combination of materials and environment are already included in the tubes and the shell, the tubesheet is not identified as a separate subcomponent in this report.) The channel covers (identified as component type bonnet in LRIS) are carbon steel. The heat exchanger is exposed to elevated temperatures during the initial stages of shutdown cooling operation. The shell external environment is indoor air. (Ref. 9)

Loss of material due to general corrosion, pitting corrosion, crevice corrosion, MIC and galvanic corrosion is an aging effect requiring management for internal surfaces of the carbon steel shell and channel cover. Loss of material is considered an aging effect requiring management for external carbon steel surfaces of the shell and channel cover.

Loss of material due to pitting corrosion, crevice corrosion, MIC and wear is an aging effect requiring management for external surfaces of the tubes. Loss of material due to pitting corrosion, crevice corrosion and MIC is an aging effect requiring management for internal surfaces of the tubes. Cracking due to IGA/SCC is an aging effect requiring management for internal and external surfaces of the stainless steel tubes.

Cracking due to thermal fatigue is an aging effect requiring management for the RHR heat exchangers since they are exposed to elevated SDC temperatures above the thresholds (220°F for carbon steel and 270°F for stainless steel) for this aging effect during a plant cooldown.

Reduction of fracture toughness due to thermal embrittlement is not an aging effect requiring management for the stainless steel components, since they are not above the threshold for this aging effect.

Fouling is an aging effect requiring management for both internal and external surfaces of the tubes.

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 12 of 32 3.5 RHR Seal Coolers The RHR seal coolers are small shell and tube heat exchangers with stainless steel tubes that contain the hot RHR water. The heat exchangers have cast iron (conservatively identified as gray cast iron for aging effects determination) shells that are normally cooled by treated water from the reactor building closed cooling water system and are exposed to indoor air on the external surface. The seal coolers are exposed to elevated temperatures during the initial stages of shutdown cooling operation. (Ref. 3, 13)

Loss of material due to pitting, crevice corrosion, MIC and wear is an aging effect requiring management for external surface of the tubes. Loss of material due to pitting, crevice corrosion, and MIC is an aging effect requiring management for internal surface of the tubes.

Cracking due to SCC/IGA is an aging effect requiring management for internal and external surfaces of the tubes.

Cracking due to thermal fatigue is an aging effect requiring management for the tubes since 0

they are exposed to elevated SDC temperatures above the 140 F threshold for cracking during a plant cooldown.

Fouling is an aging effect requiring management for internal and external surfaces of the tubes.

Loss of material due to general, pitting, crevice and galvanic corrosion, MIC, and selective leaching is an aging effect requiring management for internal surfaces of the shell.

Loss of material due to general corrosion is an aging effect requiring management for external surfaces of the shell.

3.6 Cyclone Separators and Seal Injection Components The cyclone separators are designed to provide filtered water (by cyclone action) to the pump seals. The cyclone separators and associated tubing are stainless steel. (Ref. 13)

The internal and external environments are the same as for the other system stainless steel components and the aging effects are the same as those identified in Section 3.3.

3.7 Thermal Expansion Accumulator (S-26A)

Containment valve V10-26A utilizes a one gallon thermal expansion accumulator (component type = tank) which provides additional volume for fluid thermal expansion. (Ref. 1, 3) This 3

accumulator is constructed of a carbon steel (coated ) shell and a stainless steel inlet port assembly (component type = tank since it is a portion of the tank). The tank contains treated water at essentially ambient area temperatures. (Ref. 12) 3 The component is coated, but aging effects are conservatively identified without crediting the coating.

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 13 of 32 Loss of material due to general corrosion, pitting corrosion, crevice corrosion and MIC is an aging effect requiring management for internal surfaces of the carbon steel shell. Loss of material due to localized galvanic corrosion is an aging effect requiring management for the interface of the carbon steel shell with the stainless steel inlet port assembly. Loss of material due to general corrosion is considered an aging effect requiring management for external surfaces of the carbon steel shell.

Loss of material due to pitting, crevice corrosion or MIC is an aging effect requiring management for internal wetted stainless steel surfaces. There are no aging effects requiring management for external stainless steel surfaces exposed to indoor air.

This component is not located on the high temperature portion of the system since it is on the valve used for the spray header. Therefore, cracking due to thermal fatigue is not an aging effect requiring management for this component. Cracking due to stress corrosion and intergranular attack is not an aging effect requiring management since the temperature remains below the 140°F threshold for these mechanisms in stainless steel.

3.8 Bolting Pressure retaining bolting in this system may be carbon steel or stainless steel and is exposed to indoor air.

Loss of material from general corrosion is considered an aging effect requiring management for carbon steel bolting exposed to indoor air, outdoor air. Loss of material is not an aging effect requiring management for copper alloy or stainless steel bolting that is not wetted.

3.9 Operating Experience The site review identified that internal piping leakage through closed valves has occurred that has resulted in internal wetting of the spray header components. A drain has been provided (see note 10 on G-191172 for further information). The spray headers were therefore evaluated in section 3.1 for the potential wetted environment at the bottom of the pipe. The review of site specific operating experience and recent industry operating experience completed in VYNPS Report LRPD-05, Operating Experience Review Results, did not identify any other aging effects applicable to the RHR system passive mechanical components not addressed in this aging management review report. (Ref. 10)

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 14 of 32 4.0 Demonstration That Aging Effects Will Be Managed The components of the RHR system that are subject to aging management review were described in Section 2.0. For those components, Section 3.0 documented the determination of aging effects requiring management. The aging management review is completed by demonstrating that existing programs, when continued into the period of extended operation, can manage the aging effects identified in Section 3.0. No further action is required for license renewal when the evaluation of an existing program demonstrates that it is adequate to manage the aging effect such that corrective action may be taken prior to loss of the system intended functions. Alternately, if existing programs cannot be shown to manage the aging effects for the period of extended operation, then action will be proposed to augment existing or create new programs to manage the identified effects of aging.

Demonstration for the purposes of this license renewal technical evaluation is accomplished by establishing a clear relationship among:

1) the components under review,

2) the aging effects on these items caused by the material-environment-stress combinations which, if undetected, could result in loss of the intended function such that the system could not perform its function(s) within the scope of license renewal in the period of extended operation, and

3) the credited aging management programs whose actions serve to preserve the system intended function(s) for the period of extended operation. lists component types and identifies the aging effects requiring management for the material and environment combinations. The Water Chemistry Control - BWR Program, Water Chemistry Control - Closed Cooling Water Program, System Walkdown Program, Service Water Integrity Program, and Selective Leaching Program in combination will manage the effects of aging, thereby precluding loss of the intended functions of the system. Sections 4.1 through 4.5 provide the clear relationship between the component, the aging effect and the aging management program actions which preserve the intended functions for the period of extended operation. Section 4.6 identifies applicable time-limited aging analyses. For a comprehensive review of programs credited for license renewal of VYNPS and a demonstration of how these programs will manage aging effects, see VYNPS Report LRPD-02, Aging Management Program Evaluation Results.

4.1 Water Chemistry Control - BWR Program The Water Chemistry Control - BWR Program maintains the system water quality to manage loss of material, cracking, and fouling as shown on Attachment 2. This program also minimizes fouling on heat transfer surfaces of the RHR heat exchangers. The Water Chemistry Control -

One-Time Inspection Program utilizes inspections or non-destructive evaluations of representative samples to verify that the Water Chemistry Control - BWR Program has been successful at managing the aging effects.

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 15 of 32 This program applies to component types indicated on Attachment 2. For additional information on the Water Chemistry Control - BWR Program and the Water Chemistry Control - One-Time Inspection Program, see VYNPS Report LRPD-02, Aging Management Program Evaluation Results. (Ref. 19) 4.2 Water Chemistry Control - Closed Cooling Water Program The Water Chemistry Control - Closed Cooling Water Program maintains the system water quality to manage loss of material and cracking on the RHR seal cooler as shown on . This program also minimizes fouling on heat transfer surfaces of the RHR heat exchangers. The Water Chemistry Control - One-Time Inspection Program utilizes inspections or non-destructive evaluations of representative samples to verify that the Water Chemistry Control - Closed Cooling Water Program has been successful at managing these aging effects.

This program applies to component types indicated on Attachment 2. For additional information on the Water Chemistry Control - Closed Cooling Water Program and the Water Chemistry Control - One-Time Inspection Program, see VYNPS Report LRPD-02, Aging Management Program Evaluation Results. (Ref. 19) 4.3 System Walkdown Program Under the System Walkdown Program, visual inspections are conducted to manage aging effects on components. For the RHR system, the System Walkdown Program manages loss of material for external carbon steel components by visual inspection of external surfaces. Since portions of the internal carbon steel surfaces of the spray headers are exposed to the same environment as the external surfaces, the external surfaces will be representative of the internal surfaces. Thus, loss of material on the internal surfaces of the spray headers is also managed by the System Walkdown Program.

This program applies to component types indicated on Attachment 2. For additional information on this program, see VYNPS report LRPD-02, Aging Management Program Evaluation Results.

(Ref. 19) 4.4 Service Water Integrity Program The Service Water Integrity Program includes condition and performance monitoring activities to inspect components for erosion and corrosion and verify the heat transfer capability of safety-related heat exchangers cooled by service water. Chemical treatment using biocides and chlorine and periodic cleaning and flushing of redundant or infrequently used loops are additional methods used under this program to manage loss of material, cracking, and fouling for the RHR heat exchangers.

This program applies to component types indicated on Attachment 2. For additional information on this program, see VYNPS report LRPD-02, Aging Management Program Evaluation Results.

(Ref. 19)

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 16 of 32 4.5 Selective Leaching Program The Selective Leaching Program ensures the integrity of components made from gray cast iron or copper alloy susceptible to selective leaching that are exposed to raw water, untreated water, treated water, steam, untreated air, or soil (groundwater). By one-time visual inspection and testing of a representative sample of the component population, the Selective Leaching Program will verify the absence of significant loss of material due to selective leaching for RHR system gray cast iron surfaces exposed to treated water.

This program applies to component types indicated on Attachment 2. For additional information on this program, see VYNPS Report LRPD-02, Aging Management Program Evaluation Results. (Ref. 19) 4.6 Time-Limited Aging Analyses Some RHR components are exposed to elevated temperatures during SDC operation that could result in cracking due to thermal fatigue. Metal fatigue is a TLAA applicable to portions of this system subjected to elevated temperatures.

See VYNPS Reports LRPD-03, TLAA and Exemption Evaluation Results, and LRPD-04, TLAA

- Mechanical Fatigue, for further review of time-limited aging analyses. (Ref. 21, 22)

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 17 of 32 5.0 Summary and Conclusions The following aging management programs address the aging effects requiring management for the RHR system.

• Water Chemistry Control- BWR Program

• Water Chemistry Control- Closed Cooling Water Program

• System Walkdown Program

• Service Water Integrity Program

• Selective Leaching Program For additional review of the programs credited for license renewal of VYNPS, see VYNPS Report LRPD-02, Aging Management Program Evaluation Results. contains the aging management review results for the RHR system.

In conclusion, programs described in Section 4.0 will provide reasonable assurance that the effects of aging on the residual heat removal system will be managed such that the intended functions will be maintained consistent with the current licensing basis throughout the period of extended operation.

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 18 of 32 6.0 References

1. Flow Diagrams G-191168 Rev. 43, Core Spray System G-191172 Rev. 64, Residual Heat Removal System G-191177 Sheet 1, Rev. 39, Radwaste Systems

2. VYNPS Updated Final Safety Analysis Report (UFSAR) Revision 19-1, Section 3.8.3, 4.8, 5.2.3.7, Table 5.2.1, 10.12.3

3. Document RHR, VYNPS Design Basis Document for Residual Heat Removal System, Rev.

2

4. EPRI Report 1003056, Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 3, (The Mechanical Tools)

5. ENN-MS-S-009-VY, Vermont Yankee Site Specific Guidance and System Safety Function Sheets, Rev. 0, 3/22/05

6. VYNPS SADBD Rev. 4, Safety Analyses Design Basis Document

7. VYS-049, RHR and CS Suction Strainers

8. VYNPP Appendix R Safe Shutdown Capability Analysis (SSCA), Rev. 7, 6/26/04

9. VYEM 0086, Rev. 3, SWECO RHR Heat Exchangers (RHR heat exchanger)

10. VYNPS Report LRPD-05, Operating Experience Review Results

11. Drawing Set B-191261 Rev. 6, VYNPS Instrument Installation Details

12. VYEM 0244 Rev. 1, Greer Bladder Accumulator (for S-10-26A)

13. VYEM 0067 Rev. 1, RHR Pumps

14. Procedure OP 2124, Rev. 53, Residual Heat Removal System

15. Drawings 6202-27 and 28 (for spray headers)

16. Memorandum VYS97-062, Torus Temperature Limit During Testing

17. Flow orifice and element information Memorandum VYE-2606 Restriction Orifices Drawing 5920-1663 PDCR 76-004 Specification VY 4.4

18. Email from Paul Rainey 3/1/05- Use of RHR for Fuel Pool Cooling is not a safety function

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 19 of 32

19. VYNPS Report LRPD-02, Aging Management Program Evaluation Results

20. VYNPS Report LRPD-05, Operating Experience Review Results

21. LRPD-03, TLAA and Exemption Evaluation Results

22. LRPD-04, TLAA - Mechanical Fatigue

23. VY-RPT-05-00004, Rev. 0, VYNPS EPU SBO Coping Analysis Report

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 20 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: AIR - INDOOR (EXTERNAL)

Comp ID Comp Type Comp Name Material RHR CS BOLTING bolting RHR CS BOLTING carbon steel RHR SS BOLTING bolting RHR SS BOLTING stainless steel ENVIRONMENT: AIR - INDOOR (INTERNAL)

Comp ID Comp Type Comp Name Material RHR SPRAY piping RHR SPRAY HEADERS carbon steel HEADERS RHR SPRAY nozzle RHR SPRAY NOZZLES copper alloy >15% zn NOZZLES ENVIRONMENT: RAW WATER (INTERNAL)

Comp ID Comp Type Comp Name Material E TUBES heat exchanger (tubes) RHR HEAT EXCHANGER TUBES stainless steel E-14 BONNET heat exchanger (bonnet) RHR HEAT EXCHANGER BONNET carbon steel ENVIRONMENT: TREATED WATER (EXTERNAL)

Comp ID Comp Type Comp Name Material RHR PIPE piping RHR PIPE carbon steel RHR SEAL COOLER heat exchanger (tubes) RHR SEAL COOLER TUBES stainless steel TUBES STX-224A, B RHR SUCTION strainer RHR SUCTION STRAINERS stainless steel STRAINERS

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 21 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER (INTERNAL)

Comp ID Comp Type Comp Name Material RHR PIPE piping RHR PIPE carbon steel RHR SEAL COOLER heat exchanger (shell) RHR SEAL COOLER SHELL gray cast iron SHELL RHR SPRAY piping RHR SPRAY HEADERS carbon steel HEADERS RHR SPRAY nozzle RHR SPRAY NOZZLES copper alloy >15% zn NOZZLES ST-X-224 A, B RHR SUCTION strainer RHR SUCTION STRAINERS stainless steel STRAINERS RHR TUBING tubing RHR TUBING stainless steel RHR-INSTRUMENT valve body RHR SS INSTRUMENT VALVES stainless steel VALVE S-10-26A tank THERMAL EXPANSION ACCUMULATOR CONNECTED TO BONNET OF MOV 10-26A carbon steel S-10-26A tank THERMAL EXPANSION ACCUMULATOR CONNECTED TO BONNET OF MOV 10-26A stainless steel V10-196A valve body GLOBE VALVE FUEL POOL COOLING DISCHARGE DRAIN RX BLDG 239' TORUS CATWALK IB carbon steel V10-196B valve body GLOBE VALVE FUEL POOL COOLING DISCHARGE DRAIN RX BLDG 239' TORUS CATWALK IB carbon steel V10-215A valve body ISOLATION VALVE FOR FILL PART OF ACCUMULATOR S-10-26A carbon steel V10-216A valve body ISOLATION VALVE FOR BLEED PORT OF ACCUMULATOR S-10-26A carbon steel V10-26A valve body CONTAINMENT SPRAY OUTBOARD INJECTION VALVE -FED FROM MCC-9B-4J carbon steel V10-26B valve body CONTAINMENT SPRAY OUTBOARD INJECTION VALVE -FED FROM MCC-8B-10K carbon steel V10-31A valve body CONTAINMENT SPRAY INBOARD INJECTION VALVE -FED FROM MCC-9B-5M carbon steel V10-31B valve body CONTAINMENT SPRAY INBOARD INJECTION VALVE -FED FROM MCC-8B-1F carbon steel V10-34A valve body SUPPRESSION CHAMBER SPRAY BYPASS VALVE -FED FROM MCC-9B-3C carbon steel V10-34B valve body SUPPRESSION CHAMBER SPRAY BYPASS VALVE -FED FROM MCC-8B-4F carbon steel V10-38A valve body SUPPRESSION CHAMBER SPRAY VALVE -FED FROM MCC-9B-5F carbon steel V10-38B valve body SUPPRESSION CHAMBER SPRAY VALVE -FED FROM MCC-8B-2J carbon steel V10-39A valve body SUPPRESSION CHAMBER SPRAY UPSTREAM A VALVE -FED FROM MCC-9B-5J carbon steel V10-39B valve body SUPPRESSION CHAMBER SPRAY UPSTREAM B VALVE -FED FROM MCC-8B-2M carbon steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 22 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER (INTERNAL)

Comp ID Comp Type Comp Name Material V10-52A valve body RHR GLOBE VALVE RHR LOOP A CONTAINMENT SPRAY TEST CONN RX BLDG 252' carbon steel V10-52B valve body RHR GLOBE VALVE RHR LOOP B CONTAINMENT SPRAY TEST RX BLDG 280' carbon steel V10-66 valve body RHR GATE VALVE (DISCHARGE TO RDW INBOARD ISOLATION VALVE) -FED FROM MCC-8B-1C carbon steel V10-95A valve body TEST CONNECTION ON 12"RHR 10 carbon steel V10-95B valve body TEST CONNECTION ON 12"RHR-15 carbon steel V10-96A valve body TEST CONNECTION ON V10-31A BONNET carbon steel V10-96B valve body TEST CONNECTION ON V10-31B BONNET carbon steel V20-319A valve body RDW GATE VALVE SOUTH RBFD PUMP 2A DISCHARGE TO RHR Rx BLDG SUMPS carbon steel V20-319B valve body RDW GATE VALVE SOUTH RBFD PUMP 2B DISCHARGE TO RHR Rx BLDG SUMPS carbon steel V20-319C valve body RDW GATE VALVE NORTH RBFD PUMP 2C DISCHARGE TO RHR Rx BLDG SUMPS carbon steel V20-319D valve body RDW GATE VALVE NORTH RBFD PUMP 2D DISCHARGE TO RHR Rx BLDG SUMPS carbon steel ENVIRONMENT: TREATED WATER >270°F (EXTERNAL)

Comp ID Comp Type Comp Name Material E TUBES heat exchanger (tubes) RHR HEAT EXCHANGER TUBES stainless steel ENVIRONMENT: TREATED WATER >270°F (INTERNAL)

Comp ID Comp Type Comp Name Material E-14-1A SHELL heat exchanger (shell) RHR HEAT EXCHANGER SHELL carbon steel E-14-1B SHELL heat exchanger (shell) RHR HEAT EXCHANGER SHELL carbon steel FCV-10-160 valve body RHR FLOW CONTROL VALVE SYSTEM PROCESS SAMPLING VALVES carbon steel FE-10-108A orifice FLOW ELEMENT stainless steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 23 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER >270°F (INTERNAL)

Comp ID Comp Type Comp Name Material FE-10-108B orifice FLOW ELEMENT stainless steel FE-10-110A orifice CONT SPRAY FLOW stainless steel FE-10-110B orifice CONT SPRAY FLOW stainless steel P-10-1A pump casing RHR PUMP carbon steel P-10-1B pump casing RHR PUMP carbon steel P-10-1C pump casing RHR PUMP carbon steel P-10-1D pump casing RHR PUMP carbon steel RHR CS Thermowells thermowell RHR CS THERMOWELLS carbon steel RHR CYCLONE cyclone separator RHR PUMP CYCLONE SEPARATORS stainless steel SEPARATORS RHR PIPE piping RHR PIPE carbon steel RHR SEAL COOLER heat exchanger (tubes) RHR SEAL COOLER TUBES stainless steel TUBES RHR SS thermowells thermowell RHR SS THERMOWELLS stainless steel RO-10-104A orifice RHR RESTRICTING ORIFICES stainless steel RO-10-104B orifice RHR RESTRICTING ORIFICES stainless steel RO-10-104C orifice RHR RESTRICTING ORIFICES stainless steel RO-10-104D orifice RHR RESTRICTING ORIFICES stainless steel RO-10-105A orifice 16" RESTRICTING ORIFICE stainless steel RO-10-105B orifice 16" RESTRICTING ORIFICE stainless steel RO-10-105C orifice 16" RESTRICTING ORIFICE stainless steel RO-10-105D orifice 16" RESTRICTING ORIFICE stainless steel SR-10-35A valve body RHR RELIEF VALVE (ABOVE V16-19-5J) carbon steel SR-10-35B valve body RHR RELIEF VALVE carbon steel SR-10-40 valve body RHR RELIEF VALVE carbon steel SR-10-72A valve body RHR PUMP SUCTION RELIEF VALVE carbon steel SR-10-72B valve body RHR PUMP SUCTION RELIEF VALVE carbon steel SR-10-72C valve body RHR PUMP SUCTION RELIEF VALVE carbon steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 24 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER >270°F (INTERNAL)

Comp ID Comp Type Comp Name Material SR-10-72D valve body RHR PUMP SUCTION RELIEF VALVE carbon steel SR-10-86A valve body RHR, RELIEF VALVE E-14-1A SHELLSIDE carbon steel SR-10-86B valve body RHR, RELIEF VALVE E-14-1B SHELLSIDE carbon steel V10-13A valve body RHR A SUPPRESSION POOL TO PUMP SUCTION VALVE -FED FROM MCC-9B-4C carbon steel V10-13B valve body RHR B SUPPRESSION POOL TO PUMP SUCTION VALVE -FED FROM MCC-8B-5J carbon steel V10-13C valve body RHR C SUPPRESSION POOL TO PUMP SUCTION VALVE -FED FROM MCC-9B-6G carbon steel V10-13D valve body RHR D SUPPRESSION POOL TO PUMP SUCTION VALVE -FED FROM MCC-8B-5M carbon steel V10-15A valve body RECIRC SUPPLY TO PUMP SUCTION VALVE -FED FROM MCC-9B-5C carbon steel V10-15B valve body RHR GATE VALVE RECIRC SUPPLY TO PUMP SUCTION VALVE -FED FROM MCC-8B-5C carbon steel V10-15C valve body RECIRC SUPPLY TO PUMP SUCTION VALVE -FED FROM MCC-9B-7J carbon steel V10-15D valve body RHR GATE VALVE RECIRC SUPPLY TO PUMP SUCTION VALVE -FED FROM MCC-8B-5F carbon steel RHR GATE VALVE RHR HX SHELL SIDE VENT/SAMPLE ROOT ISOL RX BLDG 232' NE CORNER ROOM V10-164A valve body carbon steel UPPER LEVEL V10-164B valve body GATE VALVE RHR HX SHELL SIDE VENT/SAMPLE ROOT ISOL RX BLDG 232' SE CORNER ROOM carbon steel V10-165A valve body RHR GATE VALVE carbon steel V10-165B valve body GATE VALVE carbon steel V10-165C valve body RHR GATE VALVE/RHR 'A' REACTOR COOLANT carbon steel V10-165D valve body GATE VALVE/RHR 'B' REACTOR COOLANT carbon steel V10-16A valve body RHR PUMPS MINFLOW BYPASS VALVE -FED FROM MCC-9B-10J carbon steel V10-16B valve body RHR PUMPS MINFLOW BYPASS VALVE -FED FROM MCC-8B-3J carbon steel V10-172A valve body GATE VALVE RHR HX A DRAIN TO RADWASTE RX BLDG 213' NE CORNER ROOM carbon steel V10-172B valve body RHR GATE VALVE RHR HX DRAIN TO RADWASTE RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel RHR GLOBE VALVE SERVICE WATER INJECTION/RHR TEST CONN RX BLDG 232' NE CORNER ROOM UPPER V10-180 valve body carbon steel LEVEL V10-182 valve body RHR CHECK VALVE carbon steel V10-183 valve body RHRSW TO RHR EMERGENCY INTERTIE VALVE FED FROM MCC-8B-2F carbon steel V10-198A valve body GLOBE VALVE PROCESS SAMPLING RX BLDG 239' TORUS CATWALK IB carbon steel V10-198B valve body GLOBE VALVE PROCESS SAMPLING RX BLDG 239' TORUS CATWALK IB carbon steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 25 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER >270°F (INTERNAL)

Comp ID Comp Type Comp Name Material V10-199A valve body GATE VALVE RHR DISCHARGE VENT SAMPLE CONN RX BLDG 213' NE CORNER ROOM carbon steel V10-19A valve body RHR CHECK VALVE carbon steel V10-19B valve body RHR CHECK VALVE RX. BLDG. carbon steel V10-19C valve body RHR CHECK VALVE carbon steel V10-19D valve body RHR CHECK VALVE carbon steel V10-20 valve body RHR LOOPS A AND B CROSSTIE VALVE -FED FROM MCC-9D-1J carbon steel RHR GATE VALVE RHR PUMPS B/D DISCHARGE HEADER VENT RX BLDG 239' SE CORNER ROOM LOWER V10-200A valve body carbon steel LEVEL V10-201A valve body RHR GATE VALVE LOOP A VENT RX BLDG 252' carbon steel V10-202A valve body RHR GATE VALVE LOOP B VENT RX BLDG 252' carbon steel V10-203A valve body GATE VALVE RHR DISCHARGE HEADER VENT RX BLDG 239' TORUS CATWALK BAY 15 carbon steel V10-204A valve body GATE VALVE RHR DISCHARGE HEADER VENT RX BLDG 239' TORUS CATWALK IB carbon steel RHR GATE VALVE RHR PUMPS A/C SUPP CHAMBER SUCTION DRAIN RX BLDG 213' TORUS AREA LOWER V10-206A valve body carbon steel LEVEL RHR GATE VALVE RHR PUMPS B/D SUPP CHAMBER SUCTION DRAIN RX BLDG 213' TORUS AREA LOWER V10-206B valve body carbon steel LEVEL V10-21A valve body GATE VALVE RHR PUMP A DISCHARGE FLUSH RX BLDG 213' NE CORNER ROOM carbon steel V10-21B valve body RHR GATE VALVE RHR PUMP B DISCHARGE FLUSH RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-21C valve body GATE VALVE RHR PUMP C DISCHARGE FLUSH RX BLDG 213' NE CORNER ROOM carbon steel V10-21D valve body RHR GATE VALVE RHR PUMP D DISCHARGE FLUSH RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel GATE VALVE PUMP A FLUSH CONN - SUCTION RX BLDG 213' NE CORNER ROOM, IN VICINITY OF RHR V10-22A valve body carbon steel PUMPS RHR GATE VALVE PUMP B FLUSH CONN - SUCTION RX BLDG 239' SE CORNER ROOM LOWER LEVEL, IN V10-22B valve body carbon steel VICINITY OF RHR PUMPS V10-22C valve body GATE VALVE RHR PUMP C SUCTION FLUSH RX BLDG 213' NE CORNER ROOM, IN VICINITY OF RHR PUMPS carbon steel RHR GATE VALVE RHR PUMP D SUCTION LINE FLUSH RX BLDG 239' SE CORNER ROOM LOWER LEVEL, IN V10-22D valve body carbon steel VICINITY OF RHR PUMPS V10-235 valve body CUW ISOLATION VALVE FOR SHUTDOWN CLEAN UP BYPASS TO RHR carbon steel V10-23A valve body GATE VALVE RHR HX A INLET RX BLDG 213' NE CORNER ROOM carbon steel V10-23B valve body RHR GATE VALVE RHR HX INLET RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 26 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER >270°F (INTERNAL)

Comp ID Comp Type Comp Name Material V10-28A valve body RHR GATE VALVE RHR HX OUTLET RX BLDG 232' NE CORNER ROOM UPPER LEVEL carbon steel GATE VALVE RHR HX B OUTLET RX BLDG 232' SE CORNER ROOM 7' ABOVE FLOOR, SOUTH SIDE OF HEAT V10-28B valve body carbon steel EXCHANGER.

V10-3 valve body RHR VALVE COMMON PUMP SUCTION LINE FOR RCU TEMP TIE-IN RX BLDG 280' carbon steel V10-30A valve body GATE VALVE RHR LOOP A PRESSURIZING LINE RX BLDG 213' NE CORNER ROOM carbon steel V10-30B valve body RHR GATE VALVE RHR LOOP B PRESSURIZING LINE RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-36A valve body RHR CHECK VALVE carbon steel V10-36B valve body RHR CHECK VALVE carbon steel V10-47A valve body GATE VALVE RHR PUMP A DISCHARGE RX BLDG 213' NE CORNER ROOM carbon steel V10-47B valve body RHR GATE VALVE RHR PUMP B DISCHARGE RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-47C valve body GATE VALVE RHR PUMP C DISCHARGE RX BLDG 213' NE CORNER ROOM carbon steel V10-47D valve body RHR GATE VALVE RHR PUMP D DISCHARGE RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-48A valve body RHR CHECK VALVE, DISCHARGE CHECK FOR P-10-1A. carbon steel V10-48B valve body RHR CHECK VALVE, DISCHARGE CHECK FOR P-10-1B. carbon steel V10-48C valve body RHR CHECK VALVE, DISCHARGE CHECK FOR P-10-1C. carbon steel V10-48D valve body RHR CHECK VALVE, DISCHARGE FOR P-10-1D. carbon steel V10-49A valve body GATE VALVE PUMP A VENT RX BLDG 213' NE CORNER ROOM carbon steel V10-49B valve body RHR GATE VALVE RHR PUMP B VENT RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-49C valve body GATE VALVE RHR PUMP C VENT RX BLDG 213' NE CORNER ROOM carbon steel V10-49D valve body RHR GATE VALVE RHR PUMP D VENT RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel GATE VALVE RHR LOOP A FLUSHING CONN FROM CONDENSATE TRANSFER RX BLDG 239' TORUS V10-56 valve body carbon steel CATWALK IB V10-57 valve body DISCHARGE TO RADWASTE OUTBOARD ISOLATION VALVE -FED FROM MCC-DC-2A-3K carbon steel V10-61A valve body GLOBE VALVE RHR PUMP A DRAIN TO RADWASTE RX BLDG 213' NE CORNER ROOM carbon steel RHR GLOBE VALVE RHR PUMP B DRAIN TO RADWASTE ROOT RX BLDG 239' SE CORNER ROOM LOWER V10-61B valve body carbon steel LEVEL V10-61C valve body GLOBE VALVE RHR PUMP C DRAIN RX BLDG 213' NE CORNER ROOM carbon steel V10-61D valve body RHR GLOBE VALVE RHR PUMP D DRAIN TO RADWASTE RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-65A valve body RHR PUMPS DISCHARGE / HEAT EXCHANGER BYPASS VALVE -FED FROM MCC-9B-3J carbon steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 27 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER >270°F (INTERNAL)

Comp ID Comp Type Comp Name Material V10-65B valve body RHR PUMPS DISCHARGE VALVE -FED FROM MCC-8B-1J carbon steel V10-69A valve body RHR PUMP "A" MINIMUM FLOW VALVE carbon steel V10-69B valve body RHR PUMP "B" MINIMUM FLOW VALVE carbon steel V10-69C valve body RHR PUMP "C" MINIMUM FLOW VALVE carbon steel V10-69D valve body RHR PUMP "D" MINIMUM FLOW VALVE carbon steel V10-71A valve body GATE VALVE RHR LOOP A INJECTION LINE FLUSH RX BLDG 239' TORUS CATWALK IB carbon steel V10-71B valve body GATE VALVE RHR LOOP B INJECTION LINE FLUSH RX BLDG 239' TORUS CATWALK IB carbon steel V10-73 valve body GATE VALVE RHR SHUTDOWN SUCTION FLUSH RX BLDG 239' TORUS CATWALK IB carbon steel GATE VALVE RHR LOOP B FLUSHING CONN FROM CONDENSATE TRANSFER RX BLDG 239' TORUS V10-75 valve body carbon steel CATWALK IB V10-802A valve body VALVE FLOW TRANSMITTER SW FT-111A ROOT ISOL RX BLDG 252' carbon steel V10-802B valve body VALVE FLOW TRANSMITTER FT-111B ROOT ISOL RX BLDG 252' carbon steel V10-803A valve body VALVE FLOW TRANSMITTER SW FT-111A ROOT ISOL RX BLDG 252' carbon steel V10-803B valve body VALVE FLOW TRANSMITTER FT-111B ROOT ISOL RX BLDG 252' carbon steel V10-804A valve body RHR DISCHARGE HEADER A FT-109A ROOT ISOL RX BLDG 239' TORUS CATWALK IB carbon steel V10-804B valve body RHR DISCHARGE HEADER FLOW B FT-109B ROOT ISOL RX BLDG 239' TORUS CATWALK IB carbon steel V10-805A valve body RHR DISCHARGE HEADER FLOW A FT-109A ROOT ISOL RX BLDG 239' TORUS CATWALK IB carbon steel V10-805B valve body RHR DISCHARGE HEADER FLOW B FT-109B ROOT ISOL RX BLDG 239' TORUS CATWALK IB carbon steel V10-806A valve body RHR PUMP DISCHARGE HEADER P/S-122A ROOT ISOL RX BLDG 239' TORUS CATWALK IB carbon steel V10-806B valve body RHR PUMP DISCHARGE HEADER P/S-122B ROOT ISOL RX BLDG 239' TORUS CATWALK IB carbon steel V10-807 valve body RHR SHUTDOWN SUCTION P/S-118 ROOT ISOL RX BLDG 239' TORUS CATWALK IB carbon steel V10-808A valve body PI-107A AND PS-105A ROOT ISOL RX BLDG 213' NE CORNER ROOM carbon steel V10-808B valve body VALVE PI-107B AND PS-105B ROOT ISOL RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-808C valve body RI-107C AND PS-105C ROOT ISOL RX BLDG 213' NE CORNER ROOM carbon steel V10-808D valve body VALVE PI-107D AND PS-105D ROOT ISOL RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-809A valve body DPS-92A, DPT-91A, AND DPT-91C ROOT ISOL RX BLDG 213' NE CORNER ROOM carbon steel V10-809B valve body VALVE DPT-91B AND DPS-92B ROOT ISOL RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-810A valve body PS-156 ROOT ISOL RX BLDG 213' NE CORNER ROOM carbon steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 28 of 32 Attachment 1-Components Subject to AMR ENVIRONMENT: TREATED WATER >270°F (INTERNAL)

Comp ID Comp Type Comp Name Material V10-810B valve body VALVE PS-156B ROOT ISOL RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-812A valve body VALVE carbon steel V10-812B valve body VALVE carbon steel V10-815A valve body PI-106A ROOT ISOL RX BLDG 213' NE CORNER ROOM carbon steel V10-815A-1 valve body "A" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815A-2 valve body "A" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815A-3 valve body "A" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815A-4 valve body "A" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815B valve body VALVE PI-106B ROOT ISOL RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel V10-815C valve body PI-106C ROOT ISOL RX BLDG 213' NE CORNER ROOM carbon steel V10-815C-1 valve body "C" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815C-2 valve body "C" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815C-3 valve body "C" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815C-4 valve body "C" RHR PUMP SUCTION HEAD LOSS TEST TAP carbon steel V10-815D valve body VALVE PI-106 D ROOT ISOL RX BLDG 239' SE CORNER ROOM LOWER LEVEL carbon steel Isolation valve to quick disconnect on the discharge side of Residual Heat Removal Pump "A" (P-10-1A). Being installed by V10-817A valve body carbon steel WOSE 2002-012.

Isolation valve to quick disconnect on the discharge side of Residual Heat Removal Pump "B" (P-10-1B). Being installed by V10-817B valve body carbon steel WOSE 2002-013.

Isolation valve to quick disconnect on the suction side of Residual Heat Removal Pump "C" (P-10-1C). Being installed by V10-817C valve body carbon steel WOSE 2002-014.

Isolation valve to quick disconnect on the suction side of Residual Heat Removal Pump "D" (P-10-1D). Being installed by V10-817D valve body carbon steel WOSE 2002-015.

V10-822A valve body TEST CONN RHR-66 AND 57 carbon steel V10-822B valve body TEST CONN RHR-66 AND 57 carbon steel V10-87 valve body GLOBE VALVE RHR RECIRC SUCTION LINE TEST CONN RX BLDG 239' TORUS CATWALK IB carbon steel V10-9 valve body RHR GATE VALVE FUEL POOL COOLING RX BLDG 232' NE CORNER ROOM UPPER LEVEL carbon steel V10-94A valve body TEST CONNECTION DRAIN VALVE carbon steel

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 29 of 32 Attachment 2-Components Subject to AMR Aging Effect Requiring Aging Management Component Type Intended Function Material Environment Management Programs Bolting Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown Stainless steel Air - indoor (ext) None None Pressure boundary &

Cyclone separator Stainless steel Air - indoor (ext) None None filtration Water chemistry control Treated water >270°f (int) Cracking

- BWR Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Heat exchanger Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown (bonnet) Raw water (int) Loss of material Service water integrity Heat exchanger Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown (shell)

Treated water >270°f (int) Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Gray cast iron Air - indoor (ext) Loss of material System walkdown Water chemistry control Treated water (int) Loss of material

- closed cooling water Selective leaching Loss of material program Heat exchanger Heat transfer Stainless steel Raw water (int) Fouling Service water integrity (tubes)

Water chemistry control Treated water (ext) Fouling

- closed cooling water Water chemistry control Treated water >270°f (ext) Fouling

- BWR Water chemistry control Treated water >270°f (int) Fouling

- BWR

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 30 of 32 Attachment 2-Components Subject to AMR Aging Effect Requiring Aging Management Component Type Intended Function Material Environment Management Programs Heat exchanger Pressure boundary Stainless steel Raw water (int) Cracking Service water integrity (tubes) (continued)

Loss of material Service water integrity Water chemistry control Treated water (ext) Loss of material

- closed cooling water Water chemistry control Treated water >270°f (ext) Cracking

- BWR Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Loss of material-wear Service water integrity Water chemistry control Treated water >270°f (int) Cracking

- BWR Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Pressure boundary & Copper alloy >15%

Nozzle Air - indoor (ext) None None flow control zinc Air - indoor (int) None None Orifice Pressure boundary Stainless steel Air - indoor (ext) None None Water chemistry control Treated water >270°f (int) Cracking

- BWR

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 31 of 32 Attachment 2-Components Subject to AMR Aging Effect Requiring Aging Management Component Type Intended Function Material Environment Management Programs Orifice (continued) Pressure boundary Stainless steel Treated water >270°f (int) Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Pressure boundary &

Stainless steel Air - indoor (ext) None None flow control Water chemistry control Treated water >270°f (int) Cracking

- BWR Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Piping Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown Air - indoor (int) Loss of material System walkdown Water chemistry control Treated water (ext) Loss of material

- BWR Water chemistry control Treated water (int) Loss of material

- BWR Treated water >270°f (int) Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Pump casing Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown Treated water >270°f (int) Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Water chemistry control Strainer Filtration Stainless steel Treated water (ext) Loss of material

- BWR Treated water (int) Water chemistry control Loss of material

- BWR

VYNPS License Renewal Project AMRM-02 Revision 1 Aging Management Review of the Residual Heat Removal System Page 32 of 32 Attachment 2-Components Subject to AMR Aging Effect Requiring Aging Management Component Type Intended Function Material Environment Management Programs Tank Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown Water chemistry control Treated water (int) Loss of material

- BWR Stainless steel Air - indoor (ext) None None Water chemistry control Treated water (int) Loss of material

- BWR Thermowell Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown Treated water >270°f (int) Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Stainless steel Air - indoor (ext) None None Water chemistry control Treated water >270°f (int) Cracking

- BWR Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Tubing Pressure boundary Stainless steel Air - indoor (ext) None None Water chemistry control Treated water (int) Loss of material

- BWR Valve body Pressure boundary Carbon steel Air - indoor (ext) Loss of material System walkdown Water chemistry control Treated water (int) Loss of material

- BWR Treated water >270°f (int) Cracking-fatigue Metal fatigue TLAA Water chemistry control Loss of material

- BWR Stainless steel Air - indoor (ext) None None Water chemistry control Treated water (int) Loss of material

- BWR