ML062340035

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2006/08/16-RAI for the Review of Vermont Yankee Nuclear Power Station License Renewal Application
ML062340035
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 08/16/2006
From: Rowley J
NRC/NRR/ADRO/DLR/RLRB
To: Kansler M
Entergy Nuclear Operations
Rowley J, NRR/DLR/RLRB, 415-4053
References
%dam200611
Download: ML062340035 (9)


Text

August 16, 2006Mr. Michael KanslerPresident Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601-1839

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OFVERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWALAPPLICATION

Dear Mr. Kansler:

By letter dated January 25, 2006, as supplemented by letter dated March 15, 2006, the U.S.Nuclear Regulatory Commission (NRC) received the Entergy Nuclear Operations, Inc.,application for renewal of Operating License No. DPR-28 for the Vermont Yankee Nuclear Power Station (VYNPS). The NRC staff is reviewing the information contained in the licenserenewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Specifically, the enclosed requests for additional information are from Section 2.2, "Plant Level Scoping Results," and Section 2.3.3, "Auxiliary Systems," ofthe VYNPS license renewal application.Based on discussions with Mr. Jim DeVincentis of your staff, a mutually agreeable date for yourresponse is within 30 days of the date of this letter. If you have any questions regarding this letter or if circumstances result in your need to revise the response date, please contact me at 301-415-4053 or by e-mail at jgr@nrc.gov

.Sincerely, /RA/Jonathan Rowley, Project ManagerLicense Renewal Branch B Division of License Renewal Office of Nuclear Reactor RegulationDocket No. 50-271

Enclosure:

Requests for Additional Informationcc w/encl: See next page

ML062340035Document Name: E:\Filenet\ML062340035.wpdOFFICEPM:RLRB:DLRLA:DLRBC:RLRB:DLRNAMEJRowleyIKingJZimmerman DATE08/ 15 /0608/ 16 /0608/ 16 /06 Letter to Michael Kansler from Jonathan Rowley dated August 16, 2006

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OFVERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWALAPPLICATIONHARD COPYDLR R/FE-MAIL:JFairRWeisman AMurphy RPettis GGalletti DShum GBagchi SSmith (srs3)

SDuraiswamy YL (Renee) Li RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDe RidsNrrDci RidsNrreEemb RidsNrrDeEeeb RidsNrrDeEqva RidsNrrDss RidsNrrDnrl RidsOgcMailCenter RidsNrrAdes DLR Staff


JEads JRowley RLaufer JShea CAnderson, RI MSykes, RI DScrenci, RI MModes, RI DPelton, Sr. Resident MLemoncelli RidsOpaMail Vermont Yankee Nuclear Power Station cc:

Regional Administrator, Region IU. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415Mr. David R. LewisPillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W.

Washington, DC 20037-1128Mr. David O'Brien, CommissionerVermont Department of Public Service 112 State Street Montpelier, VT 05620-2601Mr. James Volz, ChairmanPublic Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116Operating Experience CoordinatorVermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354G. Dana Bisbee, Esq.Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108Ms. Deborah B. KatzBox 83 Shelburne Falls, MA 01370Ms. Carla A. White, RRPT, CHPRadiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070Mr. James M. DeVincentisManager, Licensing Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500Resident InspectorVermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission

P.O. Box 176 Vernon, VT 05354Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Rd.

Framingham, MA 01702-5399Jonathan M. Block, Esq.Main Street

P.O. Box 566 Putney, VT 05346-0566Mr. John F. McCannDirector, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Gary J. TaylorChief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213Mr. John T. HerronSr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Vermont Yankee Nuclear Power Station cc:

Mr. Oscar LimpiasVice President, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Christopher SchwartzVice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Michael J. ColombDirector of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Travis C. McCulloughAssistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Ted SullivanSite Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500Mr. James H. Sniezek5486 Nithsdale Drive Salisbury, MD 21801Ms. Stacey M. LousteauTreasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113Mr. Raymond ShadisNew England Coalition Post Office Box 98 Edgecomb, ME 04556Mr. James P. MatteauExecutive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301Mr. William K. ShermanVermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601Mr. Michael D. Lyster5931 Barclay Lane Naples, FL 34110-7306Ms. Charlene D. FaisonManager, Licensing 440 Hamilton Avenue White Plains, NY 10601Mr. James RossNuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 ENCLOSUREVERMONT YANKEE NUCLEAR POWER STATIONLICENSE RENEWAL APPLICATIONREQUESTS FOR ADDITIONAL INFORMATION (RAIs)RAI 2.2-1Table 2.2-4 of the license renewal application (LRA) identifies "Structures Not within the Scopeof License Renewal." This table identifies the "Office Building (administration and service buildings)" as not within the scope of license renewal (See page 2.2-10 of the LRA). The table identifies two updated final safety analysis report (UFSAR) sections as references for the office building. UFSAR Section 12.2.1.1.3 is an appropriate reference that identifies theadministration building as a seismic Class II structure. However, the second UFSAR Section 12.2.3 is actually for the turbine building and not the administration or service building. Clarifyand correct the reference to Section 12.2.3 in Table 2.2-4.RAI 2.2-3The pressure regulator and turbine generator control system is described in USFAR Section7.11. The purpose of the turbine generator control system is to control steam flow andpressure to the turbine and to protect the turbine from overpressure or excessive speed. The turbine generator controls work in conjunction with the "nuclear steam system" controls tomaintain essentially constant reactor pressure and limit reactor transients during load variations. The LRA does not address the nuclear steam system, nor does it appear to refer toUFSAR Section 7.11 in the text. Clarify whether the nuclear steam system is included in thescope of license renewal, or explain the basis for its exclusion. RAI 2.3.3.2a-1License renewal drawing LRA-G-191159-SH-01-0, at location H-12, depicts pipe section 2"-SW-566C within the scope of license renewal. Upstream from where 2"-SW-566C enters the reactor building from the outside, there is no drawing continuation to depict the licenserenewal boundary. Provide information for the continuation of 2"-SW-566C to the license renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.2a-2License renewal drawing LRA-G-191159-SH-01-0, at location H-11, drawing note 16 indicatespipe section 4"-SW-567 and its supports on the reactor building alternate cooling supply piping (where the vacuum breakers tie in) are seismic Class ll for structural integrity. This pipe section from valve 23D through valves RBAC-1A, 1B, 1C and 1D is not shown within the scope of license renewal. Failure of this pipe section could have an adverse effect on the intended pressure boundary function for the service water piping. Provide additional information about why this section of pipe and components are not shown within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a). RAI 2.3.3.2a-3License renewal drawing LRA-G-191159-SH-01-0, at location D-5, depicts the license renewalboundary on the downstream side of flow control valve (FCV)-104-17A. The pipe section from FCV-104-17A to the safety class boundary designation flag located at valve 171A and to the intake screens is shown not within the scope of license renewal. Similarly, the pipe section from FCV-104-17 B, C, D, and E to valves 17B, C, D and E and to the intake screens is also shown not within the scope of license renewal. Failure of these sections of pipe could have an adverse effect on the intended pressure boundary function for the service water piping. Provide additional information about why these sections of pipe and components are not shown within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.2a-4License renewal drawing LRA-G-191159-SH-02-0, at location G-6, depicts a license renewalboundary flag at the tee of pipe sections 2"-SW-566D and 8"-SW-34. There are no highlighted pipes or components on 2"-SW-566D or 8"-SW-34. Clarify which portions of pipe and components are and are not bounded by the aforementioned boundary flag and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.3-1License renewal drawing LRA-G-191159-SH-03-0, at location P-10 at valve 29 shows a sectionof pipe within the scope of license renewal. This section of pipe is the reactor building closed-cooling water (RBCCW) return to the alternate cooling system. However, a drawing continuation is not provided. Provide information for the continuation of this pipe section to thelicense renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.5a-1License renewal drawing G-191173, Sheet 1, at location H-5 shows a section of pipe within thescope of license renewal. The section of pipe includes check valve V-30 and a "penetration at concrete wall," with changes in seismic classifications at each end. The section of pipe is isolated from all other in-scope piping and is not in an in-scope flow path. Piping upstream of V-30 (8"-FPC-24, 6"FPC-24, and 8"FPC-34) contains two normally closed valves (V-28 and V-53) and is not shown within the scope of license renewal. Piping downstream of V-30 (4"-FPC-24 and 4"-FPC-25) is also not shown within the scope of license renewal. Failure of these sections of piping could have an adverse effect on the intended pressure boundary function for the fuel pool cooling piping. Provide information to justify exclusion from the scope of license renewal the piping from valves V-28 and V-53 to valve V-30 and from the reactor well diffusers to the current license renewal boundary at the penetration upstream of valve V-30.RAI 2.3.3.6-1License renewal drawing, LRA-G-191162, Sheet 2, provides information about the emergencydiesel generators, diesel-driven fire pump, and house heating boiler systems, supported by the fuel oil (FO) system. However, the drawing does not provide sufficient information about theJohn Deere diesel system, also supported by the FO system. For example, more information isrequired regarding the transfer system between the 75,000-gallon fuel oil storage tank and theday tanks for the two John Deere diesels and single fire pump diesel, which are required to provide an intended function for 10 CFR 54.4 (a)(3) in support of the fire protection regulation (10 CFR 50.48). The LRA text states only that a 500-gallon portable tank is used to transport fuel oil to the diesel day tanks. Typical components subject to aging management review (AMR) for diesels like the day tank, strainer, etc., for the John Deere diesel are not covered.

Provide the FO system drawings and describe the John Deere diesel system. Explain the relationship between the John Deere diesel and the FO systems and clarify what the AMRtables should include in both Sections 2.3.3.6 and 2.3.3.12. Also, provide information for thelicense renewal boundary that justifies its location with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.11-1License renewal drawing LRA-VY-E-75-002-0, at location K-13 at penetration X209D to the H 2/O 2 analyzers, shows a section of pipe within the scope of license renewal. However, thissame section of pipe on drawing LRA-G-191165-0, at location E-16 from penetration X209D through the continuation to drawing LRA-VY-E-75-002-0, is not shown within the scope oflicense renewal. Confirm whether this section of pipe is within the scope of license renewal, or if not, justify its exclusion.RAI 2.3.3.11-2License renewal drawing LRA-VY-E-75-002-0, at location J-9 shows a pipe section, includingvalve NG-16 to pipe section 20"-AC-13 within the scope of license renewal. However, this same section of pipe on drawing LRA-G-191175-SH-01-0, at location K-10 is not shown within the scope of license renewal. Confirm whether this section of pipe is within the scope of license renewal, or if not, justify its exclusion.RAI 2.3.3.11-3License renewal drawing LRA-VY-E-75-002-0, at location G-7 provides a continuation fromvalve VG-77 to drawing LRA-G-191165-0 (at location B-17) that is within the scope of license renewal. However, the license renewal boundary could not be located on drawing LRA-G-191165-0 (at location B-17). Provide additional information for the continuation of this pipe section to the license renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.11-4License renewal drawing LRA-VY-E-75-002-0, at location J-8 shows a pipe section downstream of valve VG-30A within the scope of license renewal. A drawing continuation to the license renewal boundary is not provided. Provide additional information for the continuation of this pipe section to the license renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a). RAI 2.3.3.11-5License renewal drawing LRA-VY-191165-0, at location I-15 provides a continuation of a pipesection from the H 2/O 2 analyzers to drawing LRA-VY-E-75-002-0 that is within the scope oflicense renewal. However, the license renewal boundary could not be located on drawing LRA-VY-E-75-002-0. Provide additional information for the continuation of this pipe section to the license renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.11-6License renewal drawing LRA-VY-191165-0, at location C-12 provides continuations to drawingLRA-G-191267 (at locations H-12 and H-5) for two pipe lines from the post accident sampling panel that are within the scope of license renewal. The license renewal boundary could not be located on LRA-G-191267-SH-01-0. Provide additional information for the continuation of these pipe sections to the license renewal boundary and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).RAI 2.3.3.13k-1License renewal drawing LRA-G-191178-SH-01-0, at location D-4, shows the common elbowdifferential flow element upstream piping and high side instrument lines connected to flow transmitters FT-12-1A and FT-12-1B not in the scope of license renewal. A failure of the flow element upstream reactor water cleanup (RWCU) piping or common high side instrument line could prevent the flow transmitters from detecting a high flow condition and the subsequent auto isolation of the RWCU isolation valves. The UFSAR states that the high flow auto closureof the RWCU isolation values prevents excessive loss of reactor coolant and reduces the amount of radioactive material released from the nuclear system caused by an RWCU linebreak. This line break isolation feature is necessary to support equipment qualification for high-energy line break analyses. Confirm whether the RWCU high flow auto isolation will occurwhen negative differential pressure is caused by either failure of the flow element upstream piping or the common high side instrument line. If not, explain why the flow element upstream piping and the common high side instrument lines are not shown in the scope of license renewal on the above drawing.