IR 05000271/2009004

IR 05000271-09-004, on 07/01/09 to 09/30/09, for Vermont Yankee Nuclear Power Station - NRC Integrated Inspection Report

ML093130444
Person / Time
Site:	Vermont Yankee
Issue date:	11/09/2009
From:	Diane Jackson NRC/RGN-I/DRP/PB5
To:	Michael Colomb Entergy Nuclear Operations
Jackson D E, RGN-I/DRP/PB5/610-337-5306
References
IR-09-004
Download: ML093130444 (42)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 November 9,2009 Mr. Michael Colomb Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station Vernon, VT 05354 SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000271/2009004

Dear Mr. Colomb:

On September 30,2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on October 8,2009, with you and other members of your staff.

The inspection examined activities performed under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one NRC identified finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section V I.A. 1 of the NRC Enforcement Manual. If you contest the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at the Vermont Yankee Nuclear Power Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at Vermont Yankee. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely, IRAJ Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Docket No. 50-271 License Nos. DPR-28

Enclosure:

Inspection Report No. 05000271/2009004 wI Attachment: Supplemental Information

REGION I==

Docket No.: 50-271 License No.: DPR-28 Report No.: 05000271/2009004 Licensee: Entergy Nuclear Operations, Inc.

Facility: Vermont Yankee Nuclear Power Station Location: Vernon, Vermont 05354-9766 Dates: July 1,2009 through September 30,2009 Inspectors: S. Kennedy, Sr. Resident Inspector, DRP D. Spindler, Acting Sr. Resident Inspector, DRP J. Krafty, Acting Sr. Resident Inspector, DRP H. Jones, Resident Inspector, DRP J. Schoppy, Sr. Reactor Inspector, DRS P. McKenna, Reactor Inspector, DRS J. Commiskey, Radiation Protection Inspector, DRS Approved by: Donald Jackson, Chief Projects Branch 5 Division of Reactor Projects Enclosure

REPORT DETAILS Summary of Plant Status Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power. On August 23, VY commenced a power reduction to approximately 50 percent.

to perform planned maintenance activities. VY returned to 100 percent power on August 27, and remained at or near 100 percent power for the remainder of the inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - 1 sample)

Adverse Weather (System/Seasonal)

a. Inspection Scope The inspectors reviewed Entergy's procedures for seasonal preparations to evaluate the process for implementation of hurricane weather preparedness. The inspectors reviewed adverse weather information contained in the External Events Design Basis Document and Updated Final Safety Analysis Report (UFSAR), and compared it to the actions specified in OP 3127, "Natural Phenomena." The inspectors interviewed operators in order to determine their familiarity with OP 3127. The inspectors performed a walk down of the Administrative Building and 4KV switchgear rooms and verified that the emergency equipment specified in the procedure to prevent flooding following a hurricane was available. Additional documents reviewed are listed in the Attachment.

b. Findings No findings of significance were identified.

1R04 Equipment Alignment (Quarterly) (71111.04Q - 4 samples)

a. Inspection Scope The inspectors performed partial system walkdowns of risk-significant systems to verify correct system alignment, and to identify any discrepancies that could impact system operability. Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings (P&IDs) and OPs. The inspectors observed valve positions, power supply availability, and the general condition of selected components. Finally, the inspectors evaluated material condition, housekeeping, and component labeling. The documents reviewed are listed in the Attachment. The following systems were inspected:

Enclosure

• 'A' Core Spray during the 'B' Core Spray Limiting Condition for Operation (LCO) on July 10, 2009;

• 1A Emergency Diesel Generator (EOG) when the 1B EDG was declared inoperable on August 19, 2009;

• Reactor Core Isolation Cooling (RCIC) before the scheduled High Pressure Coolant Injection (HPCI) surveillance on August 20, 2009; and

• Standby Liquid Control (SLC) after operability surveillance testing on August 20,2009.

b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05Q - 5 samples)

a. Inspection Scope The inspectors inspected five fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis, the Fire Hazards Analysis, and the Individual Plant Examination for External Events (IPEEE). The inspectors toured plant areas important to safety to evaluate Vermont Yankee's control of transient combustibles and ignition sources, and the material condition and operational status of fire protection systems, equipment, and barriers. The documents reviewed are listed in the Attachment. The following fire areas (FAs) and fire zones (FZs) were inspected:

• FZ-6, Turbine Building Elevation 228' and 245', Turbine Lube Oil Tank and Storage Room;

• FZ-7, Turbine Building Elevation 228', Feed Pump Room;

• FZ-7, Turbine Building Elevation 272', Operating Floor;

• FZ-7, Turbine Building Elevation 272', Heating, Ventilation and Air Conditioning (HVAC) Corridor; and

• FA -16, Cooling Towers.

b. Findings No findings of significance were identified.

1R07 Heat Sink Performance (71111.07 - 3 samples)

.1 Annual Sample Review (71111.07A - 1 sample)

a. Inspection Scope On July 20, 2009, the 'A' Reactor Building Component Cooling Water (RBCCW) Heat exchanger was opened for hydrolazing (cleaning). The inspectors observed portions of the hydrolazing process, interviewed relevant station personnel, and reviewed previous and current inspection results to determine whether the 'A' RBCCW heat exchanger was Enclosure

capable of performing its function. The inspectors also reviewed Entergy's corrective action program to ensure significant heat exchanger performance problems were appropriately identified and documented, and that the corrective actions assigned, if any, were appropriate. A list of documents reviewed is provided in the Attachment.

b. Findings No findings of significance were identified .

.2 Triennial Review (71111.07T ~ 2 samples)

a. Inspection Scope Based on a plant specific risk assessment, previous inspections, recent operational experience, and resident inspector input, the inspector performed a heat sink sample by inspecting the following heat exchangers/sinks:

• 'B' RBCCW heat exchanger (HX); and

• Performance of the ultimate heat sink (UHS), which included service water (SW)

system performance testing and a SW system walkdown.

The inspector reviewed Entergy's methods (inspection, cleaning, maintenance, and performance monitoring) used to ensure heat removal capabilities for the 'B' RBCCW HX and compared them to Entergy's commitments made in response to Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." The inspector reviewed the eddy current test methodology and results to verify that the number of mechanically plugged RBCCW HX tubes was properly controlled and bounded by assumptions in the engineering analyses. The inspector reviewed the 'B'

RBCCW HX specification sheets, associated maintenance history, performance trending, and operating procedures to ensure that Entergy maintained this risk significant HX consistent with design assumptions in heat transfer calculations and the UFSAR. The inspector also reviewed Entergy evaluations and operational controls associated with the potential for water hammer, HX degradation due to excessive flow induced vibration, and system leakage.

The inspector reviewed the SW system design to evaluate the adequacy of system monitoring and performance testing. The inspector reviewed the SW pump performance tests, operational and maintenance history, system health and walkdown reports, and in-service testing vibration monitoring results for adverse trends and to verify that the system functioned as designed. In addition, the inspector reviewed Entergy's monitoring and testing of interface valves between safety-related SW and non-safety related or non-seismic piping systems to ensure that adequate SW flow is available post-accident consistent with design basis assumptions.

The inspector reviewed Entergy's buried pipe inspection and monitoring program to independently assess the condition and structural integrity of the SW piping. The inspector reviewed a risk-informed sample of Entergy's disposition of active through-wall pipe leaks, including completed or planned corrective actions and structural evaluations.

Enclosure

The inspector reviewed system health and walkdown reports, SW pipe inspection records, operating logs, and surveillance test results to ensure that Entergy appropriately identified and dispositioned any SW leakage or degradation. The inspector performed an above ground walkdown of accessible areas containing buried SW piping to look for soil subsidence or other indications of piping leakage and/or deg radation.

The inspector walked down the 'B' RBCCW HX, accessible portions of SW piping in the reactor building and torus room, and SW intake area (including the SW pumps and traveling water screens) to assess the material condition and configuration control of these structures, systems and components (SSCs). The inspector also reviewed a sample of corrective action CRs related to the 'B' RBCCW HX, SW isolation valves, SW pumps, and SW piping integrity to ensure that Entergy appropriately identified, characterized, and corrected problems related to these essential SSCs. A list of documents reviewed is provided in the Attachment.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.110 - 1 sample)

a. Inspection Scope The inspectors observed a simulator-based licensed operator requalification (LOR)

exam on September 1, 2009. The inspectors evaluated crew performance in the areas of clarity and formality of communications; ability to take timely actions; prioritization, interpretation, and verification of alarms; procedure usage; control board manipulations; and command and control. Crew performance in these areas was compared to the Instructor Guide for Simulator LOR-27-301 Scenarios 5 and 6, Entergy management expectations, and guidelines. The inspectors also compared the simulator configuration with the actual control board configuration. Finally, the inspectors observed Vermont Yankee evaluators discuss identified weaknesses with the crew and individual crew members. The documents reviewed are listed in the Attachment.

b. Findings No findings of significance were identified.

1R 12 Maintenance Effectiveness (71111.120 - 3 samples)

a. Inspection Scope The inspectors reviewed Vermont Yankee's evaluations of three degraded conditions involving SSCs for maintenance effectiveness during this inspection period. The inspectors reviewed Vermont Yankee's implementation of the Maintenance Rule to determine if the condition was appropriately evaluated against applicable Maintenance Rule functional failure criteria, as found in Vermont Yankee scoping documents and Enclosure

procedures. The inspectors reviewed the applicable system health reports and discussed the issues with the Maintenance Rule Coordinator to determine if the conditions were appropriately tracked against the system performance criteria and classified in accordance with Maintenance Rule implementation guidance. The documents reviewed are listed in the Attachment. The specific systems reviewed included:

• Control Room HVAC;

• Condensate Storage and Transfer; and

• Average Power Range Monitor Subsystem.

b. Findings No findings of significance were identified.

1R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13 7 samples)

a. Inspection Scope The inspectors evaluated online risk management for seven planned maintenance activities. The inspectors reviewed maintenance risk evaluations, maintenance plans, work schedules, and control room logs to determine if concurrent or emergent maintenance activities significantly increased the plant risk. The inspectors compared reviewed items and activities to requirements listed in administrative procedure (AP)

0125, "Plant Equipment," and AP 0172, "Work Schedule Risk Management - Online."

The documents reviewed are listed in the Attachment. The maintenance activities inspected included:

• Work Order (WO) 00193448, "DC Bus DC-2 Ground Isolation Troubleshooting;"

• WO 00152137, "Emergent Work to Replace Relief Valve SR-16-19-77;"

• WO 00180885, "AS-2 Battery Testing and Replacement of Cell Increased Risk to*

Yellow;"

• CR 2009-2852, "SLC Emergent Work due to M&TE Found out of Calibration;"

• 345 KV Coolidge Line out of Service Due to Upstream Fault;

• WO 52186973, "Calibration of Degraded Grid Timing Relays, Yellow Risk;" and

• WO 51564187, "HPCI DC Valve Contactor Replacement, Yellow Risk."

b. Findings No findings of Significance were identified.

1R15 Operability Evaluations (71111.15 - 6 samples)

a. Inspection Scope The inspectors reviewed six operability evaluations prepared by Vermont Yankee. The inspectors evaluated the operability evaluations against the guidance contained in NRC Enclosure

Regulatory Issue Summary 2005-20, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," and Entergy procedure EN-OP-104, "Operability Determinations."

The documents reviewed are listed in the Attachment. The inspectors reviewed evaluations of the following degraded or non-conforming conditions:

• Ground On DC Electrical Bus DC-1 While Performing 'B' Residual Heat Removal (RHR) Logic Testing (CR 2009-2569);

• Turbine Bypass Valve Testing At Full Power (CR 2009-2672);

• Control Room HVAC Cross-tied With Service Building HVAC Due To Control Room Chiller Not Functioning (CR 2009-2786);

• 1B EDG Frequency Oscillations Following Surveillance Testing (CR 2009-2832);

• Steam Jet Air Ejector Off-Gas Detector Frequent Downscale Indications (CR 2009 3028); and

• 'A' Standby Gas Treatment (SBGT) System Non-Repeatable Test Results (CR 2009-3069).

b. Findings No findings of significance were identified.

1R18 Plant Modifications (71111.18 - 3 samples, 2 Permanent, 1 Temporary)

a. Inspection Scope The inspectors reviewed two permanent modifications and one temporary modification to ensure they did not adversely affect the availability, reliability, or functional capability of any risk-significant SSCs. For each modification, the inspectors reviewed the engineering change package, walked down the system, interviewed the project engineer, and compared the installation and control of the modification to the requirements of Entergy Corporate Procedure EN-DC-136, "Temporary Alterations."

The documents reviewed are listed in the Attachment. The modifications reviewed included:

• EC 15466, "Primary Met Tower Relocation (Permanent);"

• EC 2012, "Replacement of HPCI Time Delay Relays (Permanent);" and

• EC 17304, "Temporary Replacement of Instrument Air Dryer Skid During Maintenance (Temporary)."

b. Findings No findings of significance were identified.

Enclosure

1R19 Post-Maintenance Testing (71111.19 - 5 samples)

a. Inspection Scope The inspectors reviewed post maintenance testing (PMT) activities on five risk significant systems. The inspectors either observed the PMT or reviewed completed PMT documentation to determine if the test data met the acceptance criteria contained in the WO, Technical Specifications, UFSAR, and the in-service testing (1ST) program.

When testing was directly observed, the inspectors determined whether installed test equipment was appropriate and controlled, and whether the test was performed in accordance with applicable station procedures. The inspectors also reviewed the test activities to determine if the PMT was adequate to ensure system operability and functional capability following maintenance, if the systems were properly restored following testing, and if discrepancies were appropriately documented in the corrective action program (CAP). The documents reviewed are listed in the Attachment. The inspectors reviewed the PMTs performed for the following maintenance activities:

• Reactor Building Airlock Door Opened Approximately Four(4) Feet and the Motor Controller Tripped on the Thermal Overload (CR2009-2607);

• 'C' Reactor Feedwater Pump Inboard Mechanical Seal Leakage (CR2009-1712);

• DC-2 Bus Ground on RCIC Valve V13-30 (CR 2009-2680);

• SBGT Fan Drive Belt Replacement (WO 52021502); and

• HPCI DC Valve Contactor Replacement (WO 51564187).

b. Findings No findings of significance were identified.

'I R22 Surveillance Testing (71111.22 - 7 samples - 21ST, 5 Routine Surveillance)

a. Inspection Scope The inspectors observed seven surveillance tests to determine if the specified acceptance criteria was consistent with Technical Specification and UFSAR requirements, if the test was performed in accordance with the written procedure, if the test data was complete and met procedural requirements, and if the system was properly returned to service following testing. The inspectors observed selected pre-job briefings for the test activities. The inspectors also checked to determine if discrepancies were appropriately documented in the CAP. The documents reviewed are listed in the Attachment. The inspectors reviewed the following surveillance tests:

• On July 21,2009, OP4124, "RHR Pump 'B' (P-10-1B) operability test (1ST);"

• On July 27, 2009, OP 4181, "Station Service Water Pump 'A' operability test (Routine);"

• On August 4,2009, OP 4310, "Reactor Pressure Recirculation Pump Trip (RPT) and Alternate Rod Insertion (ARI) functional/calibration (Routine);"

Enclosure

• On August 10, 2009, OP 4126, "Diesel Generator surveillance for the 1A EDG (Routine);"

• On August 14, 2009, OP 4121, "RCIC Pump operability and full-flow test (1ST);"

• On August 24, 2009, OP 4424, "Control Rod scram testing and data reduction (Routine);" and

• On September 29,2009, OP 4115, "Torus to Drywell Vacuum Breaker position indication and alarm operability test (Routine)."

b. Findings No findings of significance were identified.

Cornerstone: Emergency Preparedness 1EP6 Drill Evaluation (71114.06 1 sample)

a. Inspection Scope The inspectors observed an emergency preparedness (EP) drill on September 16, 2009, and the subsequent player and lead controller critiques. Vermont Yankee preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI). The inspectors discussed the performance expectations and results with Vermont Yankee's EP staff to confirm correct implementation of the PI program. The inspectors focused on the ability of licensed operators to perform event classifications and make proper notifications in accordance with station procedures and industry guidance. The documents reviewed are listed in the Attachment.

b. Findings No findings of significance were identified.

2. RADIATION SAFETY Cornerstone: Occupational Radiation Safety 20S1 Access Control to Radiologically Significant Areas (71121.01 14 samples)

a. Inspection Scope During September 21-25,2009, the inspector conducted the following activities to verify that the licensee was properly implementing physical, engineering, and administrative controls for access to high radiation areas and other radiologically controlled areas, and that workers were adhering to these controls when working in these areas.

Implementation of the access control program was reviewed against the criteria contained in 10 CFR Part 20, Technical Specifications, and licensee's procedures required by the Technical Specifications as criteria for determining compliance. During Enclosure

the inspection, the inspector interviewed the radiation protection manager, radiation protection supervisors, and radiation workers.

Inspection Planning (1) PI events and associated documentation packages reported by the licensee in the Occupational Radiation Safety Cornerstone were reviewed.

Plant Walk Downs and RWP Reviews (2) Exposure significant work areas were identified for review within radiation areas, high radiation areas, and airborne areas in the plant. Associated licensee controls and surveys were review for adequacy. Work reviewed included Steam Dryer/Separator Pit Trash Removal and cleanup; Standby Fuel Pool Cooling Service Water Pipe Repair/Replacement (RWP 09-65); RWCU System Outage Window work (RWP 09-67); Remove New Control Rod Blade from SFP; V12 62A Steam Tunnel Steam Leak Repair (RWP 09-57); RWCU Phase Separator Room Steam Leak Repair (RWP 09-58); 'A' RHR LCO/System Outage Window (RWP 09-62); RCA Drain Cleaning (RWP 09-68); and Clean/Inspect FPC Heat Exchangers (RWP 09-55).

(3) Airborne radioactivity areas were reviewed to determine assurance that there were no radiation work permits for airborne radioactivity areas with the potential for individual worker internal exposures of greater than 50 mrem CEDE.

(4) Internal assessments were reviewed to determine adeq uacy and assurance that they were not equal to or greater than 50 mrem CEDE.

(5) Physical and programmatic controls for highly activated or contaminated materials (non-fuel) stored within the spent fuel pool were reviewed for adequacy.

Problem Identification and Resolution (6) Access controls related condition reports were reviewed since the last inspection in this area. Staff members were interviewed and documents reviewed to determine that follow-up activities are being conducted in an effective and timely manner, commensurate with their safety and risk.

(7) For repetitive deficiencies or significant individual deficiencies in problem identification and resolution, the inspector determined if the licensee's assessment activities were also identifying and addressing these deficiencies.

(8) Events occurring since the last inspection were reviewed to verify there were no performance indicator events that involved dose rates greater than 25 Rem/hour at 30 cm, dose rates greater than 500 Rem/hour at 1 meter, or unintended exposures greater than 100 mrem TEDE (or greater than 5 Rem SDE or greater than 1.5 Rem LDE).

Enclosure

Job-in-Progress Reviews (9) The inspector observed aspects of various on-going activities to confirm that radiological controls, such as required surveys, area postings, job coverage, and job site preparations were conducted. The inspector attended a pre-planning and briefing meeting for work associated with Steam Dryer/Separator Pit trash removal and cleanup.

(10) The inspector performed a job performance observation of the Steam Dryer/Separator Pit trash removal and cleanup to verify the adequacy of radiological controls, radiation protection job coverage, and contamination controls.

High Risk Significant, High Dose Rate High Radiation Areas (HRA) and Very HRA Controls (11) The inspectors reviewed keys to LHRA and VHRA to verify they were controlled and inventoried. Plant tours were completed to verify accessible LHRA's were properly secured and posted.

Radiation Worker Performance (12) The inspector reviewed condition reports related to radiation worker performance to determine if an observable pattern traceable to a similar cause was evident.

Radiation Protection Technician Proficiency (13) During observation of the work activities, radiation protection technician work performance was evaluated with respect to their knowledge of the radiological conditions, the specific radiation protection work requirements, and radiation protection procedures.

(14) The inspector reviewed condition reports related to radiation worker performance to determine if an observable pattern traceable to a similar cause was evident.

b. Findings No findings of significance were identified.

20S2 ALARA Planning and Controls (71121.02 -12 samples)

a. Inspection Scope During September 21-25, 2009, the inspector conducted the following activities to verify that the licensee was properly maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). Implementation of the ALARA program Enclosure

was reviewed against the criteria contained in 10 CFR Part 20, applicable industry standards, and the licensee's procedures.

Inspection Planning (1) The inspector reviewed pertinent information regarding cumUlative exposure history, current exposure trends, and on-going activities to assess current performance and outage exposure challenges. The inspector determined the site's 3-year rolling collective average exposure.

(2) The inspector reviewed work performed during the inspection period, the associated ALARA plans, RWPs, ALARA Committee Reviews, exposure estimates, actual exposures and post job reviews. Jobs reviewed included those listed in section 20S1.a(2) of this report.

(3) The inspector reviewed data to determine site specific trends in collective exposures and source term.

(4) The inspector reviewed implementing procedures associated with maintaining occupational exposures ALARA, which included a review of the processes used to estimate and track work activity exposures.

Radiological Work Planning (5) With respect to the work activities listed above, the inspector reviewed dose summary reports, related post-job ALARA reviews, related RWPs, exposure estimates and actual exposures, and ALARA Committee meeting paperwork.

(6) ALARA work activity evaluations, exposure estimates, and exposure mitigating requirements were reviewed for work packages previously mentioned.

(7) The inspector compared the results achieved with the intended dose that was established in the planning of the work. The inspector determined the reasons for any inconsistencies between the intended and actual work activity doses and station management awareness and involvement.

Job Site Inspections and ALARA Controls (8) The inspector observed in progress maintenance and operational activities being performed to verify that radiological controls, such as required surveys, job coverage, and contamination controls were implemented. Interviews were conducted to determine if workers were knowledgeable of the work area radiological conditions. Associated ALARA Plans and RWPs were reviewed to determine if appropriate exposure and contamination controls were being employed.

Enclosure

Source-Term Reduction and Control (9) The inspector reviewed licensee records to examine historical trends and current status of the plant source term, and the licensee's methods and process for monitoring variances in the source term due to changes in plant fuel performance or plant primary chemistry.

(10) The inspector reviewed the licensee's understanding of the plant source-term, source-term control strategy, cobalt reduction strategy and operating chemistry plan.

Declared Pregnant Workers (11) The inspector reviewed the licensee occupational radiological controls relative to declared pregnant workers to verify the implementation of appropriate monitoring and control in accordance with 10 CFR Part 20.

Problem Identification and Resolution (12) The inspector reviewed elements of the licensee's corrective action program related to implementing radiological controls to determine if problems are being entered into the program for timely resolution.

b. Findings No findings of significance were identified.

4. OTHER ACTIVITIES lOA]

40A1 Performance Indicator (PI) Verification (71151 - 3 samples)

a. Inspection Scope Mitigating Systems Cornerstone The inspectors sampled Entergy submittals for the three Pis listed below for the periods indicated. The inspectors reviewed selected operator logs, plant process computer data, licensee event reports, Maintenance Rule out of service logs, criticality data, Consolidated Data Entry Mitigating System Performance Indicator (MSPI) Derivation Reports for the unavailability index and unreliability index for each system, monitored component demands, and demand failure data. The inspectors discussed the PI data with responsible system engineers and licensing personnel. The PI definitions and guidance contained in Nuclear Energy Institute 99-02, "Regulatory Assessment Indicator Guideline," Revision 5, and AP 0094, "NRC Performance Indicator Reporting," Revision 14, were used to verify the accuracy and completeness of the PI data reported during this period. Documents reviewed are listed in the Attachment. The PI submittals reviewed were:

Enclosure

• Safety System Functional Failures: July 1, 2008 - June 30, 2009 (MS05);

• MSPI, High Pressure Injection System: July 1, 2008 June 30, 2009 (MS07); and

• MSPI, Heat Removal System: July 1, 2008 June 30, 2009 (MS08).

b. Findings No findings of significance were identified.

40A2 Identification and Resolution of Problems (71152 - 4 samples)

.1 Reviews of Items Entered into the Corrective Action Program a. Inspection Scope The inspectors performed a daily screening of each item entered into Entergy's CAP.

This review was accomplished by reviewing printouts of each condition report, attending daily screening meetings, and/or accessing Entergy's database. The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow-up.

b. Findings No findings of significance were identified .

.2 Annual Sample: Review of Procedures (1 Sample)

a Inspection Scope The inspectors reviewed the corrective actions associated with non-cited violation (NCV)05000271/2008008-01, "Inadequate Testing of Safety Related Batteries (CR 08 03423)," and the status of the procedure upgrade project. The extent of condition review performed as a result of this and other similar NCVs, identified procedural inadequacies which resulted in Entergy undertaking the procedure upgrade project.

Condition reports associated with procedural content and use along with the associated corrective actions were reviewed. The inspectors also reviewed procedure changes implemented by the procedure upgrade project.

b. Findings and Observations No findings of significance were identified.

The corrective actions planned for CR 08-03423 were reviewed and determined to be adequate. A review of six new procedures compared to four original procedures showed formatting changes intended to make the procedure easier to use. This review also showed removal of unnecessary information and logically separating some procedures into stand alone procedures to allow easier revision and to reduce the number of pages. As part of the procedure revision process, the content of each Enclosure

procedure is technically reviewed. The inspectors determined that the changes made to the six reviewed procedures adequately addressed the issues identified in CR 08 03423 .

.3 Annual Sample: Cooling Tower Structural Integrity Corrective Action Plan (1 sample)

a. Inspection Scope There are two CTs at Vermont Yankee, each containing 11 cells. The non-safety function of the cooling towers is to reduce the temperature of the water used to cool the plant before it is returned to the Connecticut River. Only one cell (cell 2-1) is safety related. The safety-related function of cell 2-1 is to provide an alternate means to remove reactor heat following a plant shutdown in the unlikely event that the normal heat removal system becomes unavailable. Adjacent cell 2-2 is not safety-related, but is structurally robust and is designed to physically separate and seismically protect cell 2 1. On August 21,2007, a portion of CT cell 2-4 collapsed while the plant was operating at full power with the CTs in service. Contributing causal factors included Entergy's failure to incorporate relevant CT operating experience (OE); the quality of inspections, especially for normally inaccessible areas; and structural degradation from multiple biological and mechanical mechanisms (see NRC Inspection Report 05000271/2007004, ML073110213). On July 11,2008, an auxiliary operator observed leakage from a slip joint in the circulating water distribution piping in CT cell 1-1. A total of four circulating water pipe horizontal support beams supporting the 60 inch diameter fiberglass pipe had failed in cell 1-1. Entergy determined that the root cause was an overload of the fiberglass reinforced plastic (FRP)-to-wooden horizontal support connection due to missing support clips on the FRP support columns (see NRC Special Inspection Report 05000271/2008009, ML082840367).

This inspection focused on Entergy's problem identification, evaluation, and resolution concerning several CT structural integrity issues, including causal factors related to the two events described above. The inspectors reviewed Entergy's CT assessments, corrective actions, and repair/refurbishment progress dating back to the NRC's last CT assessment in April 2009 (documented in NRC Problem Identification and Resolution Inspection Report 05000271/2009006, ML091540723). Specifically, the inspectors reviewed Entergy's associated inspection activities, root cause analyses, self assessments, Maintenance Rule (MR) paragraph (a)(1) action plan and goal monitoring, corrective action CRs, and short and long-term action plans. The inspectors also reviewed completed maintenance work orders, the CT deficiency matrix, CT operating and inspection procedures, walkdown reports, and system health reports.

The inspectors accompanied the CT system engineer and a civil design engineer on a periodic inspection to observe the thoroughness of their inspection and to ensure that they were identifying potential deficiencies at an appropriate threshold. In addition, the inspectors independently walked down accessible areas of both CTs on several occasions to inspect for wood degradation, fiberglass (FRP)-to-wood fit-up, adequate distribution pipe support (including clips where specified), scarf joint condition, bell and spigot valve flow, hardware material and condition (stainless, galvanized, or carbon steel), wood stressors (e.g. iron salt attack, fungal attack, and over-tightened fasteners),

Enclosure

ponding of water on the fan deck, and foreign material exclusion (FME) control in the CT-2 basin. Walkdown areas included the inner plenum, plenum catwalk, wet and dry waterdeck (with the CT in service and out of service), external basin area, fan deck, fan shrouds and viewing ports, and the inner plenum of cell 2-1 with CT-2 in service. A list of documents reviewed is provided in the Attachment.

b. Findings and Observations The inspectors noted the CTs improved material condition and Entergy's continued progress in their CT upgrade project. The inspectors observed engineering's CT ownership and the craft's attention-to-detail. The inspectors determined that Entergy's corrective actions for previous CT-related events were appropriately aligned with their root cause analyses and were implemented in a manner commensurate with the safety significance. In general, Entergy's CT self-assessments and corrective action effectiveness reviews were rigorous, self critical, and probing.

Entergy developed and implemented a detailed procedure to control the inspection and repairs to CT-1 and CT-2. The inspectors noted that Entergy procedure OP 52114,

"Cooling Tower Structural Inspection and Repair," incorporated appropriate inspection and repair guidelines, relevant industry OE, and applicable Cooling Tower Institute guidance. In general, Entergy adequately implemented the OP 52114 requirements; however, the inspectors identified an Entergy performance deficiency associated with one aspect of this procedure, as documented below. The inspectors also noted that Entergy revised procedure OP 2180, "Circulating Water/Cooling Tower Operation," to provide appropriate guidance to operators for use during their CT walkdowns.

Entergy appropriately and in a timely manner incorporated CT-related OE into their periodic CT inspections. Engineering performed frequent inspections of the CTs, demonstrated sufficient thoroughness, and, in general, identified deficient conditions at an appropriate level. During the 2009 Spring CT refurbishment campaign, Entergy design engineers performed thorough as-found inspections on the CT bays undergoing refurbishment (including the previously inaccessible fill areas). Entergy imported additional well-qualified and CT -savvy resources to perform detailed inspections on all accessible areas of the remaining CT bays. The inspectors noted that, in general, the Balance of Tower Inspection Team demonstrated attention-to-detail and succinctly documented identified deficiencies at a very low level in accordance with OP 52114.

The inspectors identified the following performance deficiency associated with Entergy's input of these deficiencies into their CAP.

Introduction. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," in that Entergy did not initiate corrective action condition reports (CRs) for all deficient items identified during CT inspections.

Description. Entergy's root cause evaluation associated with the 2007 CT cell 2-4 collapse (CR 2007-3243) included a corrective action to preclude repetition (CAPR) to prepare a Vermont Yankee procedure to control the inspection and repairs to CT-1 and CT-2. This CAPR also specified that a database be developed to capture and trend Enclosure

inspection results and repairs, and that all identified CT deficiencies be documented in the CAP. Entergy developed and implemented OP 52114, "Cooling Tower Structural Inspection and Repair," to address this particular CAPR.

During the 2009 Spring CT refurbishment campaign, the balance of tower inspection team identified deficiencies on each of the 22 cells; however, they did not identify any Deficiency Class 1 (DC1) conditions in cell 2-1 or cell 2-2 (the safety-related and seismic cooling tower cells, respectively). A DC1 is defined as a structural integrity or safety concern that needs immediate attention. A DC2 is defined as a potential structural integrity concern that needs to be scheduled for repair. The inspectors reviewed the deficiency database and noted eight DC2 deficiencies in cell 2-1, and eight DC2 deficiencies in cell 2-2. It was observed that these deficiencies were not in the CAP and it was not clear as to why there was a delay in entering these deficiencies into the CAP.

The inspectors noted that, for the practice of delaying the insertion of deficiencies into the CAP, the likelihood exists that certain important reviews or actions may be precluded. In the short term, deficiencies might not be tracked to resolution, management attention or other independent reviews would not be appropriately applied, and the need for operability determinations may be missed. In the longer term and if something is missed because of the delay, the CAP is designed to identify and evaluate potential common cause issues, and not utilizing this process could lead to a more significant common safety issue with the CTs.

Design engineering responded that none of the identified deficiencies represented re work or recurrence of issues repaired since August 2007. They also stated that they were in the process of performing an aggregate assessment of the deficiencies to provide a "snapshot" of the CTs' material condition as of May 15, 2009, and had planned to initiate one CR to capture this assessment. The inspectors identified that Entergy procedure OP 52114, Step 6, states, "Perform inspections, record all deficiencies and initiate a CR for all deficient items." The inspectors noted that Entergy had promptly initiated work orders and took appropriate action to address all the DC1 issues before the 20 non-safety cells were restored to service in mid-May, and had planned to schedule all the uncorrected DC2 deficiencies in the Spring 2010 repair period. The inspectors noted that waiting three to six months to initiate one CR for deficient conditions was not timely, did not adequately implement the Entergy CAP as intended, and was a violation of OP 52114 requirements.

Entergy entered this issue into the CAP (CR 2009-3049) and performed an operability assessment. Entergy concluded that the CTs remained operable for their power generation and safety design basis mode of operation based on the documented repairs of all DC1 items before the CTs were returned to service. Entergy determined that the repair database identified all the findings and accurately reflected the status of CT repairs. Entergy identified no deficiencies that impacted the current or past functionality or operability of the CTs.

Analysis. The inspectors determined that delaying the insertion of deficiencies into the CAP identified during CT inspections was a performance deficiency within Entergy's ability to foresee and correct and should have been prevented. Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no Enclosure

willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of NRC Inspection Manual Chapter (IMC) 0612, Appendix "Minor Examples," revealed that no minor examples were applicable to this finding. The inspectors determined the finding was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, for the practice of delaying the insertion of deficiencies into the CAP, the likelihood exists that certain important reviews or actions may be precluded such as issue tracking to resolution, appropriate management attention or independent review applied, need for operability determinations and other potential longer term effects. At the time of the inspection, the inspectors noted there were still items outstanding outside of the CAP that were being tracked for repair. The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The finding was determined to be of very low safety significance (Green)

because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. This finding had a cross-cutting aspect in the "Work Practices" component of the Human Performance cross-cutting area because Entergy did not follow procedures and initiate CRs to identify cooling tower deficiencies as required by OP 52114 H.4(b).

Enforcement. 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, from February 15, 2009, to September 3, 2009, Entergy failed to initiate CRs for all cooling tower deficiencies as required to be accomplished by procedure OP 52114. Because this finding was of very low safety significance and has been entered into Entergy's CAP (CR 2009-3049), it is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 05000271/2009004-01, Failure to Initiate Corrective Action Condition Reports for All Deficient Items Identified During Cooling Tower Inspections)

.4 Annual Sample: Cask Handling Operations Outside of the Radwaste Building (1 sample)

a. Inspection Scope During the inspection performed September 21-25,2009, the inspector reviewed implementation of the licensee's corrective action program as it relates to the cask handling operations outside of the radwaste building relative to the occasional detection of low-level contamination in the sediment trap surrounding man-hole #12 (MH-12),

which is associated with the South Storm Drain System. The cask loading process involves transferring a type 14-170 cask and liner (containing dewatered spent resins, weighing approximately 21 tons) from the radwaste building onto a transport trailer that is positioned outside of the building, in the near vicinity of MH-12. Transfer is made by use of a non-single failure proof crane (H178), rated for 35 tons.

As part of the inspection, the inspector reviewed the station UFSAR, Technical Enclosure

Specifications, Plant Process Control Program, Off-Site Dose Calculation Manual, condition reports, Cask Certificate of Compliance, H178 crane maintenance records, MH-12 storm drain sediment sample results, storm drain system sample results, and other associated documents. The inspector also interviewed Maintenance, Engineering, Chemistry, Environmental personnel, and toured the effected area.

b. Findings and Observations No findings of significance were identified.

The inspector determined that the process of handling dewatered resin casks outside of the radwaste building occasionally results in the presence of very low level contamination being identified, on-site, in a sediment trap surrounding MH-12. The inspector determined that the condition has not resulted in any unmonitored release of radioactive material to the public or environment; and that Entergy has implemented reasonable and effective actions to reduce or eliminate the potential for any unmonitored release of radioactive material to the public or environment with respect to regulatory requirements and compliance with the Off Site Dose Calculation Manual (ODCM).

Entergy has routinely reported the sediment trap activity in the Annual Radiological Environmental Operating Report (AREOR) since 1999, with the exception of 2004 when no detectable activity was identified. A review of data associated with the storm drain discharge sediment and storm drain water indicated no detectable levels of plant-related radioactivity were measured beyond the sediment trap, which indicated that the condition has not resulted in any unmonitored release of radioactivity to the environment. Notwithstanding, Entergy continues to actively monitor the storm drain water system and report sediment trap results in the AREOR.

Corrective actions implemented by Entergy to reduce or eliminate the potential for an unmonitored release of radioactive material to the environment include: periodic cleaning and vacuuming of the area, periodiC cleaning of the MH-12 sediment trap, re sealing of the asphalt in the areas of cask transport, use of a drop cloth during the process, and performing the activity during fair weather conditions. Entergy is continuing to monitor the cask transfer process, and evaluate additional actions to improve this process. The inspector confirmed that Entergy has been, and continues to maintain, conformance with applicable regulatory requirements .

.5 Annual Sample: MSIV Local Leak Rate Test Failures (1 sample)

a. Inspection Scope This inspection was conducted to assess the adequacy of Entergy's evaluation and resolution of Main Steam Isolation Valve (MSIV) Local Leak Rate Test (LLRT) failures.

Specifically, the inspectors reviewed the actions taken by Entergy following three MSIV LLRT failures in the October 2008 refueling outage, and compared those actions to the actions taken for MSIV LLRT failures back to 2001. The inspectors focused on the evaluation and resolution of the three failures in 2004, and the three failures in 2008.

Enclosure

The inspectors reviewed Entergy's condition reports, apparent cause evaluations, root cause evaluations and the adverse trend common cause analysis associated with the MSIV LLRT failures. The inspectors also discussed the results of these evaluations with the responsible engineering department personnel. This review was done to evaluate the effectiveness of Entergy's actions and determine if Entergy had promptly corrected adverse conditions when identified. Finally. the inspectors reviewed the long term actions planned by Entergy to address remaining deficiencies to determine if they were adequate. Documents reviewed are listed in the attachment.

b. Findings and Observations No findings of significance were identified.

The inspectors concluded Entergy appropriately evaluated the causes of the MSIV LLRT failures. The inspectors determined the common cause analysis conducted after the 2004 MSIV LLRT failures was extensive. The inspectors noted there were two apparent cause evaluations conducted for the 2008 LLRT failures; one for seat leakage and the other for stem leakage. The seat leakage apparent cause analysis attributed the leakage to corrosion product buildup on the valve disks which began to form when the MSIVs were left open after plant shutdown and without steam production. The corrective actions completed and planned were appropriate and included reviewing applicable shutdown procedures to develop a formal process to close MSIVs as soon as practical during plant shutdown and to keep them closed until after LLRT testing is completed.

The inspectors did note that Entergy missed assigning a corrective action for the 2004 LLRT failures to change their reactor shutdown procedure precautions to ensure that MSIVs were shut as soon as practical during a reactor shutdown in preparation for MSIV leak rate testing. Operating experience and Entergy's evaluations had attributed corrosion product buildup on the MSIV seating surfaces to leaving the valves open after the plant was no longer producing steam. The precaution to shut the MSIVs as soon as practical was in Entergy's LLRT procedure and was the practice for reactor plant shutdowns, but MSIV shutting was delayed for the 2008 LLRT because the reactor plant shutdown procedure did not contain this precaution. Entergy acknowledged this observation and has planned a procedure revision to their reactor plant shutdown procedure as part of the corrective action for the 2008 LLRT failures.

40A5 Other Activities

.1 Quarterly Resident Inspectors Observations of Security Personnel and Activities a. Inspection Scope During the inspection period, the inspectors performed the following observations of security force personnel and activities to ensure that the activities were consistent with Vermont Yankee security procedures and regulatory requirements relating to nuclear Enclosure

plant security. These observations took place during both normal plant working hours and backshift hours. Specifically, the inspectors:

• Observed operations within the central and secondary security alarm stations;

• Toured selected security officer response posts;

• Observed security force shift turnover activities; and

• Observed security officers on compensatory posts.

These quarterly resident inspectors' observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of inspectors' normal plant status review and inspection activities.

b. Findings No findings of significance were identified.

40A6 Meetings, including Exit Exit Meeting Summary On October 8,2009, the resident inspectors presented the inspection results to Mr. M.

Colomb, Site Vice President, and other members of the Vermont Yankee staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.

On September 24,2009, the radiation protection inspector presented the inspection results to Mr. Mike Philippon, Manager of Operations. The inspector confirmed that no proprietary information was provided or examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION Enclosure

A-1 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Vermont Yankee Personnel M. Colomb, Site Vice President C. Wamser, General Manager of Plant Operations J. Dreyfuss, Director of Nuclear Safety D. Mannai, Licensing Manager N. Rademacher, Director of Engineering M. Philippon, Operations Manager A. Robertshaw, Design Engineering P. Rose, Operations/FIN Team G. Von der Esch, Asst. Operations Manager L. Doucette, System Engineering P. Corbett, Manager, Quality Assurance P. Couture, Licensing Specialist L. Derting, Supervisor, Radwaste J. DeVincentis, Senior Licensing Engineer C. Eyre, Supervisor, ALARA J. Geyster, Supervisor, Radiation Protection M. Gosekamp, Manager, Maintenance J. Hardy, Superintendant, Chemistry G. Lozier, Manager, CA&A D. Mannai, Manager, Licensing R. Meister, Licensing M. Morgan, Superintendent, Training M. Philippon, Manager, Operations S. Skibniowski, Environmental SpeCialist P. Stover, Supervisor, Radiation Protection D. Tkatch, Manager, Radiation Protection R. Wanczyk, Enexus Site Representative LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 05000271/2009004-01 NCV Failure to initiate corrective action condition reports for all deficient items identified during cooling tower inspections.

(Section 40A2.3)

Attachment

A-2 LIST OF DOCUMENTS REVIEWED

• Denotes created as a result of NRC inspection Section 1R01! Adverse Weather Protection Procedures AP 3125, Emergency Plan Classification and Action Level Scheme, Rev. 21 OP 2106, Oil and Hazardous Materials Spill Prevention and Control, Rev. 28 OP 2181, Service Water/Alternate Cooling Operating Procedure, Rev. 109 Section 1R04: Equipment Alignment Procedures OP 2126, Diesel Generators, Rev. 55 OP 2121, Reactor Core Isolation Cooling, Rev. 52 OP 2123, Core Spray, Rev. 40 OP 2114, Standby Liquid Control, Rev. 33 Drawings G-191168, Flow Diagram Core Spray, Rev. 44 G-191171, Flow Diagram Standby Liquid Control, Rev. 27 G-191174, Flow Diagram Reactor Core Isolation Cooling System, Rev. 44 Section 1 ROS: Fire Protection Procedures OP 2186, Fire Suppression Systems, Rev. 56 OP 3020, Fire Emergency Response Procedure, Rev. 54 PP 7011, Vermont Yankee Fire Protection and Appendix R Program, Rev. 9 Miscellaneous Documents PFP-TB-1, Turbine Deck Elevation 272'-6," Rev. Date 5/27/07 PFP-TB-2, HVAC Corridor Elevation 272'-6," Rev. Date 5/1/03 PFP-TB-8, Lube Oil Room Elevation 228'-6" and 248'-6," Rev. Date 5/27/07 PFP-CT, Cooling Towers, Rev. Date 5/27/07 Fire Hazards Analysis, Rev. 10 Section 1R07: Heat Sink Performance Audits and Self-Assessments QA-08-2009-VY-1, Engineering Programs Quality Assurance Audit Report, dated 4/27/09 Calculations VYC-0868 EC Markup 14737, Service Water Inlet to Enhanced Fuel Pool Heat Exchangers, Rev. 2 VYC-1279F, SW Flow Analysis - LOCA, Seismic, Offsite Power Available, Bus Failure, Rev. 0 VYC-12791, SW Flow Analysis - Safe Shutdown after Tornado, Loss of Offsite Power, Bus Failure, Rev. 0 Attachment

A-3 Corrective Action Condition Reports 2006-2620 2007-4225 2008-4812 2009-1086 2006-2635 2008-2150 2008-4817 2009-1713 2006-3063 2008-2926 2008-5312 2009-1808 2006-3131 2008-3205 2009-0059 2009-2079 2007-0018 2008-3841 2009-0571 2009-2093 2007 -2469 2008-3852 2009-0657 2009-3247 2007-2911 2008-4259 2009-0706 2009-3260 2007 -2932 2008-4562 2009-1056 2009-3264 2007-3363 2008-4624 2009-1057 Design and Licensing Basis Documents BVY 90-007, Letter, Vermont Yankee Nuclear Power Corporation to USNRC, "Response to Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment," dated 1/22/90 BVY 07-071, Letter, Entergy Nuclear Operations, Inc. to USNRC, Re-submittal of Relief Request No. ISI-PT-01, Alternate Testing for Buried Piping Components, Fourth Inservice Inspection (lSI) Interval," dated 10/18/07 Design Basis Document for Accident - Event Combinations Tropical (AR), Rev. 6 Design Basis Document for Reactor Building Closed Cooling Water System (RCW-1), Rev. 15 Design Basis Document for Service water, residual heat Removal Service water, and Alternate Cooling Systems (SWSYS), Rev. 29 Drawings 58-845-3-1,4850 SQ FT Reactor Building Cooling Water System Heat Exchanger, Rev. 8 G-191230 Sh. 1, Site Yard Piping Plan, Rev. 36 G-1991159 Sh. 1 & Sh. 2, Flow Diagram Service Water System, Rev. 76 & 91 G-1991159 Sh. 3, Flow Diagram RCW Cooling Water System, Rev. 39 VYI-SW-Part 4 Sh. 1, Piping Isometric Drawing Service Water Torus Catwalk, Rev. 2 VYI-SW-Part 6 Sh. 2, Piping Isometric Drawing Service Water Reactor BLDG 151 & 2 nd FLR, Rev. 0 VYI-SW-Part 15 Sh. 1, Piping Isometric Drawing Service Water Turbine Building/South West Condenser, Rev. 3 VYS-RSW-HD177B Sh. 1, RSW-HD177B, Rev. 0 G-191159, Flow Diagram RCW Cooling Water System, Rev. 39, Sh. 3 Engineering Evaluations VY-RPT-05-00052, WBS 1.4.3.2 RBCCW EPU Task Report for ER-04-1409, dated 12/17105 CR-VTY-2009-02093, Apparent Cause Evaluation, dated 6128109 CR-VTY-2009-02093, Operability/Functionality Evaluation, dated 6/16/09 UND98-063 Response, Reassess the Service water Valve Refurbishment Program, dated 11/23/98 Inspection and Testing 8" SW-800 Radiographic Inspection Report (RT 1-4), dated 4/10109 & 7/9109 5265.02, E-8-1 B Heat Exchanger Inspection Data, dated 5/20/96 - 8/11/08 5265.07, 24"SW-17 Pipe Inspection Data, dated 3/24/95 5/24/07 EN-MA-118 Attachment 9.6, V70-43A Foreign Material Exclusion Component Close-Out data Attachment

A-4 Sheet, dated 11/2/08 PD04831.01, Record of Eddy Current Inspection of RBCCW-B (E-8-1 B), dated 9/13/06 Report # 08-001, 14"SW-1A114"SW-1B Ultrasonic Thickness Examination Report, dated 3/11/08 Report # 08-002, 8"SW-18B Ultrasonic Thickness Examination Report, dated 6/3/08 Report # 08-003, 8"SW-18B Ultrasonic Thickness Examination Report, dated 6/4/08 Report # 08-004, 8"SW-18B Ultrasonic Thickness Examination Report, dated 6/4/08 Report # 09-024, SW Pipe Weld Ultrasonic Thickness Examination Report, dated 2/25/09 Report # 09-056, 8"SW-5 Ultrasonic Thickness Examination Report, dated 6/18/09 Report # 09-057, 8"SW-5 Ultrasonic Thickness Examination Report, dated 6/19/09 Report # 09-058, 8"SW-5 Ultrasonic Thickness Examination Report, dated 6/18/09 Report # 09-059, 8"SW-5 Ultrasonic Thickness Examination Report, dated 6/19/09 Report # 09-060, 8"SW-5 Ultrasonic Thickness Examination Report, dated 6/20/09 Report # 27-FAC.025, SW Valve Replacement Area SW 445 Ultrasonic Thickness Examination Report, dated 10/27/08 RFO-27 OP-4028 Test Package, dated 11/7/08 STP 2007-01, Hydraulic Performance Test of the ACS System, dated 5/2/07 SW Ultrasonic Test Examination Program Summary Report, dated 6/23/09 SW-VT2-07, 20"SW-13 VT-2 Examination Report, dated 1/30/08 VYOPF 4181.01, Station Service Water Pump Operability Test, dated 12/18/08,1126/09, 3/18/09, 5/2109, 6/11/09, and 7/27/09 VYOPF 4181.08, Service Water Pump Capacity Test, dated 11/3/08 VYOPF 5265.01, V70-42A As-Found Service Water Valve Inspection, dated 11/1/08 VYOPF 5265.05, S-3-1 B As-Found Service Water Strainer Inspection, dated 3/2/09 VYOPF 5265.07, 8"SW-18A As-Found Service Water Pipe Inspection, dated 11/2/08 VYOPF 5265.07, 8"SW-18B As-Found Service Water Pipe Inspection, dated 10/27/08 VYNEF 8064.03, V70-43A Valve Bonnet Bolting Visual Examination, dated 11/2/08 VYNEF 8064.04, V70-43A Valve Internals Visual Examination, dated 11/2/08 VYNEF 8064.05, V70-43A Valve Leak-Check Examination Report, dated 11/5/08 Maintenance Rule, System Health, & Trending MIC Program Cornerstone Rollup Report, 2nd Otr 2009 RBCCW - 303' RB System Walkdown Inspection Checklist, dated 6/24/09 & 7/14/09 Reactor Building Closed Cooling Water System Health Report, 2nd Otr 2009 Service Water Pump Capacity & Vibration Trending Data, 6/14/07 - 5/17109 Service Water Pump Header Pressure AlB (PI-104-20Al20B) Control Room Log Readings, dated 1/12-15/09,3/12-15/09,5/25-28/09,8/17-19/09, & 9/14-21/09 Service Water System Health Report, 2nd Otr 2009 Service Water Through Wall Leaks Trending Data 1995 - 2009, dated 6/20/09 SW Intake and Pump Room System Walkdown Inspection Checklist, dated 6/11/09 & 8/3109 SW Pump Train B Reliability Maintenance Rule (a)(1 )Performance Improvement Plan (PIP) and Goal Monitoring Plan, dated 9/3/09 SW TB System Walkdown Inspection Checklist, dated 6/26/09 Miscellaneous Ecological Studies of the Connecticut River Vernon, Vermont Report 38, January - December 2008, dated May 2009 EPRI NP-7552M Project 3052-1, Heat Exchanger Performance Monitoring Guidelines Final Attachment

A-5 Report, December 1991 ME016, Preventive Maintenance Basis V70-19A1B, Rev. 8 ME017, Preventive Maintenance Basis V70-20, Rev. 7 Reactor Building Cooling Water System Heat Exchanger E-8-1A,B Specification Sheet, dated 5/20/69 Regulatory Guide 1.27, Ultimate Heat Sink for Nuclear Power Plants, Rev. 2 Risk-Informed Inspection Notebook for Vermont Yankee Nuclear Power Station, Revision 2.1a UND 98063 Preventive Maintenance Change Request, dated 11/24/98 VYOPF 4181.18, RBCCW Heat Exchanger Service Water ~P Check, Rev. 68 VYOPF 4181.18, RBCCW Heat Exchanger Service Water Differential Pressure Check for April 2009 Integrated Technologies, Inc. Preliminary Report of 'A' RBCCW Heat Exchanger dated 8/23/2006 VY Single Variable Trend of 'A' RBCCW Heat Exchanger Outlet Temperature June 2009 5265.02 Heat Exchanger Inspection Data for A RBCCW Heat Exchanger from 1995-2009 Operating Experience Generic Service Water System Risk-Based Inspection Guide, NUREG/CR-5865 EGG-2674 LO-NOE-2007-00078 (Vermont Yankee Response to NRC Information Notice 2007-06)

NRC Information Notice 2007-06: Potential Common Cause Vulnerabilities in Essential Service Water Systems, dated 2/9/07 Operating Experience Feedback Report - Service Water System Failures and Degradations, NUREG-1275 Vol. 3 Procedures ARS 21004, SERV WTR HDR PRESS LO (6-A-5), Rev. 3 CEP-BPT-0100, Buried Piping and Tanks Inspection and Monitoring, Rev. 0 EN-DC-195, Margin Management, Rev. 3 EN-DC-343, Buried Piping and Tanks Inspection and Monitoring, Rev. 1 ENN-DC-185 Attachment 9.1, Piping Leak Process Flow Chart, Rev. 0 ON 3147, Loss of RBCCW, Rev. 11 ON 3148, Loss of Service Water, Rev. 15 OP 2180, Circulating Water/Cooling Tower Operation, Rev. 95 OP 2181, Service Water/Alternate Cooling Operating Procedure, Rev. 109 OP 2182, Reactor Building Closed Cooling Water, Rev. 34 OP 5202 Table 1, Safety Related Heat Exchanger Tube Plugging Limits, Rev. 26 OP 5265, Service Water Component Inspection and Acceptance Criteria, Rev. 16 OP 4181, Service Water Alternate Cooling Operating Procedure, Rev. 68 OP 5265, Service Water Component Inspection and Acceptance Criteria, Rev. 16 OP 5202, Maintenancellnspection of Heat Exchangers, Pressure Vessels and Tanks, Rev. 26 NE 8064, Non-code Visual Examination Methods As Good Maintenance Practice, Rev. 2 PP 7021, Service Water Program, Rev. 2 Work Orders 00128291 51643269 52033424 Attachment

A-6 Section 1R11: Licensed Operator Regualification Program AFG 38, A TWS - Secondary Containment Emergency Depressurization, Rev. 1 Section 1R12: Maintenance Effectiveness Procedures OP 2192, HVAC System, Rev. 65 OP 4192, HVAC Surveillance, Rev. 30 OP 4363, HPCI Suction Transfer on Condensate Storage Tank (CST) Low Level Functional Test and CST Level Instrumentation Calibration, Rev. 27, performed 8/26/09 OP 2132, Average Power Range Monitor Channels, Rev. 23 OP 4400, Calibration of the Average Power Range Monitoring System to Core Thermal Power, Rev. 28 Condition Reports 2009-2940 2009-1340 2007-4275 2007-4181 2007-4144 2007-0132 2005-3997 2004-3754 2003-2025 2003-1973 2003-0129 2008-4477 2008-4480 1995-0674 Work Order 52036528 Calculations VYC-1502, Control Room Heatup due to loss of HVAC Drawings G-191237, HVAC- Flow Diagram Turbine, Service and Control Room Buildings, Rev. 10, Sh. 2 G-191159, Flow Diagram Service Water System, Rev. 91, Sh. 2 B-191301, APRM-RBM Position Indicators, Rev. 2, Sheet 678 B-191301, APRM Detector Level Indication Channel D&F, Sheet 684 B-191301, APRM Detector Level Indication Channel A&C, Sheet 681 B-191301, APRM Detector Level Indication Channel B, Sheet 683 B-191301, APRM Detector Level Indication Channel E, Sheet 682 Miscellaneous Documents Operability/Functionality Evaluation for CR-2007 -00132, HPCI and RCIC Suction Line Vortexing in the CST Vermont Yankee 10 CFR 50.65 Maintenance Rule Interpretation No.1; Applicability: Expected Attachment

A-7 Redundancy - Performance Monitoring, Rev. 6 Vermont Yankee 10 CFR 50.65 Maintenance Rule Scoping Basis Document for CST, Rev. 2 dated 9/30/2004 Vermont Yankee 10 CFR 50.65 Maintenance Rule Scoping Basis Document for Heating, Ventilation and Air Conditioning (HVAC), Rev. 4 dated 5/3/2007 Vermont Yankee Design Basis Document for Heating, Ventilation and Air Conditioning (HVAC)

Systems, Rev. 22 dated 5/31/2006 Vermont Yankee Plant Operations Review Committee Meeting Minutes to Discuss Basis for Maintaining Operability of Control Room HVAC, dated 2/26/1992 Log Entries from 2005-2009 Condensate Storage & Transfer System Health Report 2nd Quarter 2008 and 2009 HVAC System Health Report 2nd quarter 2009 Specification No. VYNP-III-H-193, Ebasco Specification - Refrigeration Liquid Chillers with Water Cooled and Air Cooled Condensers, dated February 6, 1969 Maintenance Rule (a)(1) to (a)(2) Disposition Memorandum, CST, dated 2/14/08 Maintenance Rule Evaluations for the following CRs: 2006-3670, 2007-0715,2007-0839,2009 1904 VY Maintenance Rule - State of the System Report, Condensate Storage and Transfer, 8/31/09 VYSE-MRL-2007-022, 10CFR50.65 Maintenance Rule Performance Evaluation/Action Plan for CST - Pump Train "A," Rev. 0, Update 2 VYOPF 4400.01 APRM Calibration to Core Thermal Power Data from December 2008 May 2009 EC 9158, Eliminate APRM Risk To Generation Design Vulnerability, Rev. 0 GE Evaluation for Vermont Yankee APRM Operation with Shared LPRMs, July 2008 Neutron Monitoring System Health Report, 2nd quarter 2009 Neutron Monitoring System Scoping Basis Document, Rev. 4 Design Basis Document for Reactor Protection System, Rev. 16 Section 1R13: Maintenance Risk Assessments and Emergent Work Control Work Orders 00193448 00152137 52028344 00180885 52029698 Condition Reports 2009-1729 2009-2852 2009-3276 Procedures EN-MA-125, Troubleshooting Control of Maintenance Activities, Rev. 3 EN-WM-101, Online Work Management Process, Rev. 4 EN-WM-104, On Line Risk Assessment, Rev. 0 AP 0172, Work Schedule Risk Maintenance - Online, Rev. 19 OP 4217, Alternate Shutdown Battery AS-2, Rev. 15 Attachment

A-8 OP 4114, Standby Liquid Control Surveillance, Rev. 60 OP 4256, Calibration of Degraded Grid ASEA RXKE1 Timing Relays, Rev. 13 OP 2120, High Pressure Coolant Injection System, Rev. 55 Miscellaneous Documents VYAPF 0172.02, Risk Management Worksheet for Degraded Grid Timing Relays, 9/16/09 Operating Agreement Between Entergy Nuclear Vermont Yankee LLC and Vermont Transco LLCNermont Electric Power Company, INC., 5/18/2009 Vermont Yankee EOOS Assessment for work week 0928 Vermont Yankee EOOS Assessment reevaluated for work week 0928 Vermont Yankee Form AP 0172.01 for work week 0928 Vermont Yankee EOOS Assessment for work week 0929 Vermont Yankee EOOS Assessment for work week 0939 Vermont Yankee Form AP 0172.01 for work week 0929 Vermont Yankee Form AP 0172.02 for work week 0929 Section 1R15: Operability Evaluations Procedures OP 4116, Secondary Containment Surveillance, Rev. 49, performed on 9/7109 and 9/9/09 OP 4126, Diesel Generators Surveillance, Rev. 83 OP 4353, RHR System Power Monitor Functional Test, Rev. 21 OP 4507, Source Calibration and Monthly Check of Steam Jet Air Ejector Off Gas Monitors, Rev. 15 OP 4387, Air Ejector Off Gas Radiation Monitoring System Functional/Calibration, Rev. 24 Condition Reports 2009-2043 2009-2594 2009-2786 2009-3028 Miscellaneous Documents Offisite Dose Calculation Manual 2000 VYOPF 4507.02, SJAE Off Gas Monitor Monthly Reading Check data from August 2009 VYOPF 4507.01, Calibration of SJAE Off Gas Monitor data from May 2008 and September 2009 Air Ejector Off Gas Radiation Monitor Source Calibration Data Sheet from September 2009 Air Ejector Off Gas Radiation Monitor Electronic Calibration Data Sheet from March 2009 Section 1R18: Plant Modifications Work Order 00118358 00206808 Condition Reports 2009-3153 2009-3144 2009-3101 Attachment

Miscellaneous Documents Meteorological Evaluation Services Co.* Inc Report. The Effect of the Vernon Substation on Data Collected at the Vermont Yankee Nuclear Power Station Primary Meteorological Tower. 7/3012009 Swager Communications. Inc. Letter. Guyed Tower Failure Technical Evaluation of ABB RXKLlRXKM Digital Relay Electro Magnetic Interference/Radio Frequency Interference (EMIIRFI) Testing TMOD No. EC 17304, Temporary Replacement Air Dryer skid during maintenance for D-1-1B Maintenance Rule Scoping Basis Document for Instrument Air Purchase Order 10181910 VYC-3056, HPCI Relay Mounting Details for EC 2012, Rev. 0 50.59 Screening Review EC2012 Section 1R19: Post-Maintenance Testing Procedures OP 4116. Secondary Containment Surveillance, Rev. 49 EN-DC-324, Preventative Maintenance Program, Rev. 5 Work Order 00194593 00203733 52022672 52021502 51564187 51564188 51564189 Condition Report 2009-1712 2009-2931 2009-2932 Drawings Burgmann Ident-No. 064123000, Mechanical Seal G-191301. Control Wiring Diagram HPCI Steam Supply Line Isolation Valve V23-16, Sheet 1437 G-1911169, Flow Diagram High Pressure Core Spray. Sheet 1 and 2 G-191646, Standby Gas Treatment System Logic Diagram. Rev. 10 Miscellaneous Documents WR 00171327

'C' Reactor Feed Pump Seal Replacement Action Plan, Issue Date 8/21/2009 VYOPF 4116.01, Secondary Containment Capability Check from September 10, 11,2009.

VYOPF 4102.03, Local Remote Valve Position Indication Test Data dated 9/24/2009 VYOPF 4120.01, HPCI Pump Operability Test Data dated 9/24/2009 Section 1R22: Surveillance Testing Attachment

A-10 Procedures OP 4181, Service Waterl Alternate Cooling System Surveillance, Rev. 68 OP 4124, Residual Heat Removal System Surveillance, Rev. 113 OP 4115, Primary Containment Surveillance, Rev. 61 Condition Report 2007-0433 2008-0829 2009-3334 Miscellaneous Documents Service Water Pump Capacity Data from 2007-2009 Service Water Pump P-7-1A 1ST Pump Date Reference Set dated 2/2/2005 Residual Heat Removal Pump P-10-1B 1ST Pump Date Reference Set dated 8/30/2005 Calibration History Query for PI-104-7A from 1992-2008 Vermont Yankee Design Basis Document for Service Water, Residual Heat Removal Service Water Alternate Cooling Systems, Rev. 29 Vermont Yankee Design Basis Document for Residual Heat Removal System, Rev. 4 VYOPF 4115.02, Torus to Drywell Vacuum Breaker Position Indication and Alarm Operability Test Data dated 9/29/2009 Vermont Yankee Design Basis Document for Containment Pressure Suppression System, Rev.

Section 1EP6: Emergency Preparedness Drill Procedures AP 3125, Emergency Plan Classification and Action Level Scheme, Rev. 21 OP 3020, Fire Emergency Response Procedure, Rev. 54 OP 3546, Operation of the Emergency Operations Facility/Recovery Center (EOF/RC), Rev. 27 Condition Reports 2009-3206 2009-3207 2009-3210 2009-3211 2009-3213 2009-3214 2009-3215 Section 20S1, 20S2: RADIATION SAFETY Condition Reports 2008-4335 2009-1550 2009-2788 2007-4712 2008-5065 2009-1932 2009-2836 2008-1863 2009-1263 2009-2011 2005-4007 2008-2034 2009-1428 2009-2214 2006-2940 2009-1496 2009-2528 2007-0106 Attachment

A-11 Procedures AP-0094, NRC Performance Indicator Reporting DP-0527, Radiation Protection Department Site Specific Expectations & Requirements DP-0545, Fuel Pool Storage Requirements EN-DC-341, Cobalt Reduction EN-DIR-RP-002, Radiation Protection Performance Indicator Program EN-Ll-119, Apparent Cause Evaluation (ACE) Process EN-RP-101, Access Control for Radiologically Controlled Areas EN-RP-102, Radiological Control EN-RP-104, Personnel Contamination EN-RP-105, Radiation Work Permits EN-RP-106, Survey Documentation EN-RP-108, Radiation Protection Posting EN-RP-110, ALARA Program EN-RP-141, Job Coverage EN-RP-203, Dose Assessment EN-RP-205, Prenatal Monitoring EN-RP-503, Selection, Issue, Use of Respiratory Protection Equipment OP-2106, Oil and Hazardous Material Spill Prevention and Control OP-2511, Radwaste Cask Liner Handling: 14-170 and 8-120 PP-7206, Use of Lifting Systems Other Documents:

Vermont Yankee 5 Year ALARA Plan Vermont Yankee 2009 ALARAISource Term Focus Area Plan Vermont Yankee ALARA Shielding Packages for Dose Rate Reductions in RFO-28 RFO-28 Dose Reduction Team Action Plan, dated 05/11,2009 Access Control Alarm Log (Electronic Dosimeter Alarms)

Personnel Contamination Events (PCE)

Air sample results report and radiation surveys for RWP 09-67 TEDE ALARA Evaluations ALARA Manager Committee and Sub-Committee Reviews Reactor Water Cleanup Demineralizer Resin Strategy, Memo dated 4/27/09 Radiation Protection Benchmark Report, LO-VTYLO-2009-00025 Snapshot Benchmark, LO-VTYLO-2009-00080 Snapshot Assessment, LO-VTYLO-2008-00152 Quality Assurance Surveillance Report, QS-2009-VY-015 MH-12 Assessment Team Report, dated 8/20/2009 Assessment Management Input Form, Addition of Radwaste Cask Room Ante-Room and Manhole #12 modification Radwaste Building 35 Ton Crane Maintenance Records Evaluation of Radioactive Materials Discharged via the Storm Drain System, calculation # VYC-1842 Storm Drain Water Sample Results (2006 - 2008)

MH-12 Sediment Trap Sample Results (2006 - 2009)

CNS 14-17011 Cask Book, Rev. 9 CNS 14-170111 Cask Book, Rev. 11 Attachment

A-12 Section 40A1: Performance Indicator (PI) Verification Condition Reports 2008-1480 2008-4477 2009-0206 2009-1132 2009-1427 Miscellaneous Documents Control Room Narrative Logs 6/30/2008-7/1/2009 Section 40A2: Problem Identification and Resolution Procedures OP 4200, Revision 31, "Main Steam Relief Valve Removal, Installation, and Testing" MMMP-MSRV-4200-21, Revision 00, "Main Steam Relief Valve Removal and Installation" OP 4312, Revision 24, "Reactor Vessel High Pressure Scram Functional Test/Calibration" ICST-4312-01, Revision 00, "Reactor Vessel High Pressure Scram Functional Test/Calibration" ICST-4312-02, Revision 00, "Reactor Vessel High Pressure Transmitter Calibration" OP 4450, Revision 15, "Rod Worth Minimizer Surveillance" OPST-RWM-4450-01, Revision 00, "Rod Worth Minimizer Operability Surveillance Test" RP 0507, Revision 18, "Primary Containment Entry" RPRP-PC-0507-01, Revision 00, "Drywell Clearance Entry" RPRP-PC-0507-02, Revision 00, "Torus Clearance Entry" EN-Ll-102, Corrective Action Process, Rev. 13 OP 2180, Circulating Water/Cooling Tower Operation, Rev. 95 OP 52114, Cooling Tower Structural Inspection and Repair, Rev. 1 OP 4030, Rev. 73, Types Band C Primary Containment Leakage Rate Testing OP 52106, Rev. 1, MSIV Troubleshooting and Repair Procedure EN-Ll-102, Rev 13, Corrective Action Process Work Orders 00179940 00131463 00169328 51066302 00180903 00131467 00169487 00187312 00157131 00169495 52025074 0016735 00169749 Drawings:

5920-2038, Rev. 12, Primary Steam Isolation Valves V2-80 & V2-2-86 Calculations:

VYC-2316, Rev. 0, Radiological AST Design Input Database VYC-2302, Rev. 4, Radiological AST LOCA Analysis Condition Report 2001-00888 2004-00836 2004-00841 2005-03306 2002-02211 2004-00838 2004-00918 2008-04246 2002-02212 2004-00839 2004-00955 2008-04282 Attachment

A-13 2008-04300 2008-05418 2009-01171 2009-01953 2008-04303 2009-00018 2009-01201 2009-02058 2008-04304 2009-00074 2009-01251 2009-02119 2008-05145 2009-00211 2009-01502 2009-02343 2008-02007 2009-00516 2009-01502 2009-02374 2008-02962 2009-00695 2009-01616 2009-02379 2008-03575 2009-00696 2009-01623 2009-02387 2008-03663 2009-00817 2009-01645 2009-02683 2008-03893 2009-00818 2009-01662 2009-02835 2008-04319 2009-01035 2009-01677 2009-02851 2008-04438 2009-01064 2009-01882 2009-03024 2008-05117 2009-01127 2009-01891 2009-03049 2008-05418 2009-01137 2009-01947 LO 2008-00119 Effectiveness Reviews and Self-Assessments VTY-2007-03243 and VTY-2007-03243 Effectiveness Review, dated 3/11/09 VTYLO-2008-84 CA1, Snapshot Assessment 1 Benchmark on: Cooling Tower Inspections and Maintenance during the 2009 Maintenance Period, dated 8/3/09 Engineering Evaluations CR-VTY-2007-03243, Structural Failure of CT 2-4 Root Cause Analysis Report, dated 9/21/07 CR-VTY-2007-03646, Determine the Human Performance Deficiencies Associated with the Organizational and Programmatic Causes Identified in Root Cause Analysis CR-VTY-2007 03243, Structural Failure of CT 2-4 Root Cause Analysis Report, dated 10/15/07 CR-VTY-2008-02904, Cooling Tower Cell 1-1 Distribution Pipe Found Leaking, Requiring Removal of Tower from Service Root Cause Analysis Report, dated 8/13108 CR-VTY-2008-03789, Functionality Assessment for Cooling Tower CT-1 Structural Inspection Findings, dated 9/18/08 Maintenance Rule, System Health & Trending 10CFR50.65 Maintenance Rule Performance EvaluationlAction Plan for Buildings - Cooling Tower Subsystem, dated 8/21/08 10CFR50.65 Maintenance Rule PIP and Goal Monitoring Report for Buildings - Cooling Tower Subsystem, dated 8/5/09 Buildings System Health Report, 2nd Qtr 2009 Engineering Cooling Tower Walkdown Report, dated 7/31/08, 817108, 8121/08, 827108, 9/15/08, 922108, 10/9/08,6/9/09, 7/7/09, 7/8/09, & 8/4/09 Expert Panel Meeting Minutes, dated 7/16/08 & 9/24/08 Miscellaneous Documents Control Room Log, dated 6/1109 - 6/30109 Cooling Tower 1 Repair List 2009, dated 5/19/09 Cooling Tower 2 Repair List 2009, dated 5/19/09 Cooling Tower 2 Repair List Deep Basin 2009, dated 6/10109 CT-1 and CT-2 2009 As-Built, dated 9/2109 CT-1 and CT-2 2010 As-Built (Draft), dated 9/2/09 CT-1 2009 OP 52114 Inspection Matrix (Bal of Tower), dated 5/15/09 CT-2 2009 OP 52114 Inspection Matrix (Bal of Tower), dated 5/15/09 Attachment

A-14 CTI Bulletin ESB-104, Wood Maintenance for Water-Cooling Towers, February 2007 Deferred Cooling Tower Repairs (from 2008), dated 5/19/09 LO-WTVTY-2008-00125, Conduct Engineering Walkdown of CT-1 & CT-2 NEIL-01-02R, Cooling Tower Structural Concerns, dated 8/21/01 System Engineering Memorandum From System ENG To VY Engineering DirectorNY System ENG MGR, Documentation of Cooling Tower Inspection Process to be Used to Satisfy CR VTY-2007- 3243 CA-35, dated 12/1/08 VYOPF 0150.08, Operations Department Monthly Task Performance Listing, dated 6/09, 7/09, &

8/09 MSIV SSC Maintenance Rule Performance History (9/1/2006 through 8131/2009)

ANSI/ANS-56.8-2002, Containment System Leakage Testing Requirements Licensee Event Report ER-20022211 Attachment

A-15 LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System ALARA As Low As is Reasonably Achievable AP Administrative Procedure CAP Corrective Action Program CAPR Corrective Action to Preclude Repetition CFR Code of Federal Regulations CR Condition Report CST Condensate Storage Tank CT Cooling Tower DRP Division of Reactor Projects DRS Division of Reactor Safety EDG Emergency Diesel Generator EP Emergency Preparedness FA Fire Area FME Foreign Material Exclusion FIN Fix-it-Now FRP Fiberglass Reinforced Plastic FZ Fire Zone HPCI High Pressure Coolant Injection HRA High Radiation Area HVAC Heating Ventilation and Air Conditioning HX Heat Exchanger IMC Inspection Manual Chapter IP [NRC] Inspection Procedure 1ST In-Service Testing IPEEE Individual Plant Examination for External Events LCO Limiting Condition for Operation LHRA Locked High Radiation Area LLRT Local Leak Rate Test MIC Microbiological Influenced Corrosion MR Maintenance Rule MSIV Main Steam Isolation Valve MSPI Mitigating System Performance Indicator NCV Non-cited Violation NRC Nuclear Regulatory Commission OE Operating Experience OP Operating Procedure P&ID Piping and Instrumentation Drawing PARS Publicly Available Records System PCE Personnel Contamination Event PI Performance Indicator PI&R Problem Identification and Resolution PIP Performance Improvement Plan PMT Post Maintenance Testing RBCCW Reactor Building Closed Cooling Water RCA Radiologically Controlled Area Attachment

A-16 RCIC Reactor Core Isolation Cooling RFO Refueling Outage RHR Residual Heat Removal RPT Reactor Pressure Recirculation Pump Trip RWCU Reactor Water Cleanup RWP Radiation Work Permit SBGT Standby Gas Treatment SDP Significance Determination Process SFP Spent Fuel Pool SLC Standby Liquid Control SSCs Structures, Systems and Components SW Service Water UFSAR Updated Final Safety Analysis Report UHS Ultimate Heat Sink VHRA Very High Radiation Area VY Vermont Yankee WO Work Order Attachment