ML082340083

Vermont Yankee July 2008 Evidentiary Hearing - Intervenor Exhibit NEC-JH_44, Entergy, Focused Self-Assessment Report: Vermont Yankee Piping Flow Accelerated Corrosion Inspection Program (October 28, 2004)

ML082340083
Person / Time
Site:	Vermont Yankee
Issue date:	10/28/2004
From:	Fitzpatrick J Entergy Corp, Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee
To:	NRC/SECY/RAS
SECY RAS
References
06-849-03-LR, 50-271-LR, Entergy-Intervenor-NEC-JH_44, NEC-JH_44, NEC038462, RAS M-212 LO-VTYLO-2003-00327
Download: ML082340083 (43)

Text

fATIS H~-

NEC-JH 44

• Entergy FOCUSED *LF-ASSESSMENT REPORT

.DEPARTMEi NJT: ENVY Design Engineering

..TITLE: Vermont Yankee Piping Flow Accelerated Corrosion Inspection Program .

Condition Report LO-VTYLO-2003-00327

]

I Prepared By: Approved By:

James H. C ianlDate

]

] DOCKETED USNRC August 12, 2008 (11:00am) DOMd 4-1 BdA No. NZ-*9 ODftlc OFFICE OF SECRETARY RULEMAKINGS AND Page 10143 NI1St Other ,,

.. ADJUDICATIONS STAFF I NEC038462 4-""-o0 ZW t) -ý>0

--03

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 TABLE OF CONTENTS Page 1.0 EXECUTIVE SUM MARy ............................................................... 3 2.0 SCOPE OF ASSESSMENT ......................... ..............

I 4 3.0 OBJECTIVES, CRITERIA, & METHODOLOGy................................. 4 4.0 EVALUATION SUMMARy ............................... ........ 16

5.0 CONCLUSION

S AND RECOMMENDED ACTIONS ........................... 31

6.0 REFERENCES

...... ........................................................ 43 7.0 TEAM MEMBERS.. 43 Page 2 of 43 NEC038463

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 EXECUTIVE SUMMMARY The objective this Self Assessment of the Vermont Yankee Piping Flow Accelerated.

Corrosion (FAC) Inspection Program was to review the program for compliance with applicable industry standards and NRC guidelines and requirements: A purpose of this assessment was to determine whether or not, problems, or generic weaknesses exist relative to the station implementation of its long term FAC monitoring program.

Specific objectives, evaluation criteria, and the corresponding assessment methodology were developed by the FAC working group (the 5 plant FAC Program Coordinators) using industry documents and previous ENS self-assessment reports. All aspects of the program- plan including documentation, management controls, CHECWORKS predictive models, structural evaluations, drawings, condition reports, organizational -interfaces were reviewed by the Self-Assessment team. In general, the following conclusions were drawn:

The Vermont Yankee Piping FAC Inspection Program is consistent with other FAC programs among the Entergy Nuclear South plants and throughout the industry. Any guidance provided by the NRC has been and is being followed appropriately.

Several strengths were identified in the methods and documentation of the. selection of'.

components for inspection, piping replacements with FAC resistant materials, and the level of FAC related experience of the program engineers.

No weaknesses or deficiencies were identified that wouldindicate that the VY Piping FAC Inspection Program could impact long-term monitoring of FAC or result in a. challenge to nuclear or personnel safety, equipment reliability, or station performance.

Several Areas for Improvement were identified in the areas of formalized documentation of program reports and program relatedcommunications, transition issues related to converting to ENN procedures, and in timely updates of the CHECWORKS models.

Recommendations to enhance these areas and other minor process and procedural issues with the program are documented and appropriate actions have been entered into PCRS.

Page 3 of43 NEC038464

ENVY Design Engineering Self Assessment: LO-VTYLO.2003-00327 1.0 SCOPE OF ASSESSMENT This assessment will focus on the Vermont Yankee Piping Flow Accelerated Corrosion (FAC) Inspection Program activities and processes to comply with generic letter 89-08.

This assessment will include a thorough review and evaluation of the FAC Program processes in accordance with applicable industry standards and NRC guidelines. This assessment will verify that the FAC Program includes systematic methods for predicting

• which systems are susceptible to FAC, inspecting 'components determined to be susceptible, analyzing and trending inspectibn data to determine EC/FAC wear rates, determining future inspection times based on past inspection results, and repairing or replacing piping components determined or predicted to wear below minimum requirements.

This assessment will determine whether or not management controls, problems, or generic weaknesses exist relative to the station implementation of its long term FAC monitoring program.

2.0 OBJECTIVES, CRITERIA, & METHODOLOGY This assessment is the first of five planned FAC program assessments for the ENN plants. Insights and findings from these assessments will be used to develop a common FAC Program .for the ENN fleet. Specific objectives, evaluation criteria and the corresponding assessment methodology have been developed by the FAC working group (the 5 plant FAC Program Coordinators). The intent is'to evaluate the FAC Program at each plant using essentially the same criteria.

The attributes that follow each or the objectives were taken from previous self assessments performed by ENS, INPO 97-002, "Performance Objectives and Criteria for Operating Nuclear Generating Stations" (OR, EN. &OE), NSAC-202L "Recommendations for an Effective Flow-Accelerated Corrosion Program", the NRC Inspection Manual 49001 Sections 02 and 03, and Generic Letter, GL 89-08.

The following objectives and criteria were used to assess the specific areas of the self-assessment to determine the overall health and effectiveness of the Vermont Yankee Piping Flow Accelerated Corrosion (FAC) Inspection Program.

2.1 Programmatic lea.dership/Responsibility Objective- Ensure that Vermont Yankee Nuclear Power Plant (VYNPP) Flow Accelerated Corrosion (FAG) Program is provided with adequate leadership and that the responsibility for the program is clearly defined. Determine if the FAC Program owner and any dedicated backup personnel are qualified for the position.

Criterion 2.1.1 - Management Determine if there is an active Management participation in, and commitment to the FAC program.

• Methodology: Review of all levels of site procedures. relating to FAC program to determine extent of Management's role in the program.

Page 4of43 NEC038465

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327.

Criterion 2.1.2: Documentation Determine if there is a station document that defines the overall program.

Methodology: Review station documents for definition and implementation of the.

FAG program.

Criterion 2.1.3 Program Awareness Determine if appropriate site personnel are aware of who owns the FAG Program.

Methodology: Review Station documents or interview appropriate site personnel such as operations, system engineers, chemistry supervision, design engineering, and corporate metallurgist to determine their familiarity with the FAG program owner. Document their interactions with the FAG engineer.

Criterion 2.1.4:- Roles & Responsibilities Determine if the roles and responsibilities of the FAG program are clearly defined and understood.

Methodology: Review station documents for definition of FAG program roles and responsibilities. Interview program owner and supportgroups to determine if the roles and responsibilities are clear and followed.

Criterion 2.1.5 - Training Determine if personnel responsible for the FAG program have received appropriate training for the position.

Methodology: Request documentation or other evidence such as a training matrix or certificates shOWing the description and; completion of training that has been obtained for the FAG program owner and any backup personnel. Such as Introductory FAG, EPRI GHEGWORKS, NDE training, etc.

Criterion 2.1.6 - Qualification Determine if FAC program owner is qualified for the position.

Methodology:. Request documentation or other evidence such as a training matrix showing a description and completion of the position qualification.

Criterion 2.1.7 - Bench Strength Determine the bench strength and qualifications/training of backup personnel.

Methodology: Request documentation or other evidence such as a training matrix showing a description and completion of the position qualification.

Criterion 2.1.8 - Personnel Turnover Determine if personnel turnover is an issue for the FAC program.

Methodology: Interview program owner and supervisor to determine length of time in position for incumbent and predecessors. Review method and thoroughness of turnover.

Criterion 2.1.9 - Resources/Schedule Determine if program task/activities are completed in a timely manner and impact of time, schedule, resources, and accelerated milestones.

Methodology: Interview program owner to determine how much time is spent on FAG program during a fuel cycle, other responsibilities other than the FAG program and roles and responsibilities during outages. Interview program owners Page50f43

~NEC038466

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 immediate supervisor for his expectations from program owner and perspective of the programs owner workload.

2.2 System Susceptibility Objective - Determine if the FAC Program includes systematic methods for categorizing which systems are susceptible to FAC, predicting and analyzing FAC, and for prioritizing inspections. Determine if the methods are consistent With industry practice.

Criterion 2.2.1 - Susceptibility 'Review Determine if there is a formal susceptibility review performed for each system and component that may be: susceptible to FAC.

Methodologty Perform a review of program documents to ensure that a formal FAC susceptibility evaluation'has been performed- Ensure that scope of the review includes all susceptible plant piping shown on plant drawings and includes piping components on-vendor supplied equipment. Ensure that the criteria used in the susceptibility evaluation is consistent with NSAC 202L.

Criterion 2.2.2 Ranking Criteria Determine if the criteria used to rank the susceptible piping components in the various systems are in accordance with NSAC 262L-or other accepted industry practices.

Methodology: Review FAC Program documents to determine whether the guidance provided in NSAC 202L is consistently applied. If other criteria. are used,,

determine if the basis used is documented and defensible.

Criterion 2.2.3 - Documentation and Reviews Determine if the susceptibility analysis is' adequately documented, checked, and/or independently reviewed.

Methodology: Review Program documentation / susceptibility analysis to verify jf the analysis was checked or independently reviewed.

Criterion 2.2.4- Udates Determine if the susceptibility analysis report(s) are updated and at what frequency.

Methodology: Perform a document review of the susceptibility analysis report to determine if the report(s) are current. Also determine if the reports are updated at an appropriate frequency.

Criterion 2.2.5 Scope &System Alignment Determine whether systems and components being ranked are appropriately aligned with plant operating procedures and the pertinent

• drawings/flow diagrams. Determine if piping on vendor supplied equipment is included in the scope of FAC program.

Methodology: Review program documents to determine whether systems and components being ranked are appropriately aligned with plant operating procedures and the pertinent drawings! flow diagrams. Review vendor supplied drawings toverify if piping drawings are included in the document system and in the FAC program.

Page 6 of 43 NEC038467

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.2.6- Small Bore Susceptibility Determine if there is a susceptibility analysis performed for the small-bore piping. and if there is inspection priority assigned to the piping.

. Methodology: Perform a document review of the small bore susceptibility analysis, if applicable. Otherwise conduct interviews with FAC Responsible engineer to determine how the FAC program handles small bore piping.

Criterion 2.2.7- Department Interface Determine how other plant departments effectively contribute to the Susceptibility Analysis.

Methodology: Perform a document review of site procedures and protocols to determine if the roles and responsibilities for interfacing departments are clearly defined, and there is evidence of input from other plant departments. Conduct interviews with FAC Responsible engineer to determine how effective are the respective departmental inputs to enhancing the FAC program.

Criterion 2.2.8 - Abnormal Conditions Determine.how changes in operating conditions,

• off-normal or abnormal system lineup, component leakage or operating experience are

• communicated, documented and evaluated for impact on the FAC program.

Methodologc: Perform a document review of site procedures and protocols,

• system health reports, Condition Reports (Event Reports at VY), site and industry operating experience, E-Mail, or other Communications to determine how system Condition changes or alignment are documented, communicated then evaluated for impact on the FAC program. Conduct interviews with system engineering, operations, and performance groups to evaluate how are changes to system conditions and system alignment affecting the FAC program is documented and communicated to the FAC engineer.

2.3 Documentation Objective - Ensure that FAC Documentation is in compliance with industry standards and that it is maintained in accordance with established processes and procedures.

Criterion 2.3.1 - Controlling Program procedure. The controlling program procedure is up to date and is current with respect to industry codes and standards.

V " Methodology: Review FAC program documents and references to determine if the controlling procedure is up to date and meets the requirements of applicable industry codes and standards. The controlling program procedure should be consistent with NSAC 202L guidelines.

Criterion 2.3.2 - Supporting Documents. Gridding procedures, engineering standards, and engineering directives, etc., are maintained up to. date with current revisions.

Methodology: 'Review FAC program documents and references to determine if the supporting documents are up to date and meet the requirements of applicable industry codes and standards.

SPage 7 of 43 NEC038468

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.3.3 - Document Reviews All appropriate program documents (Procedures, Models, Component Evaluations, etc.) are checked and reviewed per plant procedures and/or industry practices.

Methodology: Review FAC Program Documents (including a sample of historical records) to determine if Program Documents are reviewed and checked in accordance with program procedures or industry practices:

Criterion 2:3.4 - Component Database The component inspection database must be properly maintained.

Methodology: Review FAC component database to assure that it is properly updated and maintained.

Criterion 2.3.5 - Post-Outage Report The Post-Outage report.must be completed and issued in a timely manner.

Methodology: Review FAC Documentation to assure that the Post-Outage.

Reports are completed and issued in a timely manner.

Criterion 2.3.6.- CHECWORKS Pass 2 CHECWORKS Pass 2 analysis and records must be up to date and adequately documented.

Methodology: Review, FAC Documentation to assure that the CHECWORKS Pass 2 analysis and records are completed in a timely manner.

.Criterion 2.3.7 -. FAC Program Drawings FAC Program record drawings must document the component locations, the CHECWORKS numbering system, must be up to date. The documentation should be consistent with NSAC 202L Guidelines.

Methodology: Review a sample of plant FAC drawings to ensure that they indicate the component locations, the CHECWORKS numbering system, and they reflect the current plant configuration.

2.4 Model Verification and Review Objective - Ensurethat FAC predictive computer model used (such as CHECWORKS) is verified, reviewed and maintained in accordance to the plant's FAC Program procedures.

Criterion 2.4.1 - Model ReviewNerification. Determine if models are reviewed/verified and properly signed off.

Methodology: Review FAC program documents to determine if formal guidance for review/verification and sign off exists for the models. Review one system model to determine if it has been reviewed by a second person prior to being used.

Criterion 2.4.2 - Model Updates. Determine if model is updated with projected operating hours for the next outage,* current chemistry conditions, and other changes in operating parameters.

Page 8 of 43 NEC038469

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Methodology: Review model to determine that operating parameters such as current chemistry conditions, operating hours and power level information are up to date.

Criterion 2.4.3 - Modeled systems accuracy. Determine if models reflect the complete piping system being modeled; Methodology: Review a sample of one system model to ensure that all components in the piping system are included in the model..

Criterion 2.4.4 - Component data accuracy. Determine if component information in a system model is correct.

Methodology: Review a segment of a modeled system to ensure correct inputs were used such as material, geometry code, diameter, and nominal thickness.

Also review a. model segment in Which a component has been .replaced.

Review replacement information for accuracy and ensure system drawings were updated appropriately.

Criterion 2.4.5 - Component Inspection data. Determine if component inspection data has been imported -into model and processed correctly; Methodology: Review a sample of one system model to ensure. component inspection data was imported into model according to application guidelines.

Criterion 2.4.6 - Predictive Analyses Determine if the predictive computer model analyses are reviewed and used as part of the inspection selection process in accordance with program procedures.

Methodology: Review a sample of Pass! and Pass 2 model results to ensure results are appropriately used for planning component inspections.

2.5 Inspection Planning Objective - Ensure that FAC examination locations are selected in accordance with the site procedures and industry practices.

Criterion 2.5.1 ý Inspection Process Determine if there is a procedure or formal process for selecting components for inspection.

Methodology: Review FAC Program documents to identify procedures and/or formal processes used to select components for inspection. Ensure that

'procedures provide sufficient guidance for component selection, and the guidance is consistent with NSAC 202L recommendations.

Criterion 2.5.2 - CHECWORKS Pass 1, Determine if only CHECWORKS Pass 1 analysis models are used as a basis in the selection process.

Methodology: Review FAC Program CHECWORKS analyses for use of only CHECWORKS Pass 1 analyses. Determine if the rational for only using a Pass 1 analyses for the inspection/selection process exists and is documented.

! Page 9of43 NEC038470

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.5.3 - CHECWORKS Pass 2 Determine if CHECWORKS Pass 2 analysis models are used in the selection process.

Methodology: Review FAC Program CHECWORKS analyses for use of CHECWORKS Pass 2 analyses in the inspection/selection process. Determine if analyses are current and performed in accordance with site procedures and. NSAC 202L Guidelines.

Criterion 2.5.4.- Previous Inspections Determine if &how previous inspection results are used in the selection process.

Methodology: Review FAC Program documents to determine if past inspection data is used in the selection process. Determine if the components recommended for repeat inspections in past inspection reports have in fact been inspected or scheduled for inspection.

Criterion 2.5.5 -Industry Events Determine if recent and past industry events are considered in the inspection planning process.

Methodology: Review a sample of industry operating experience (OE) to insure that it has been factored into the component selection process.

Criterion 2.5.6 -Selection Documentation Determine if the results of the inspection planning process are formally documented and if the selection logic for each location is captured.

Methodology: Review a sample of component selection documents to determine if the rational for component selection (or exclusion/deferral) is documented.

Criterion 2.5.7 : Control Valve Piping - Determine if susceptible components and piping downstream of control valves are covered in the program.

Methodology: Review a sample of plant flow diagrams for several susceptible systems and locate piping sections downstrearn of control valves. Determine if

• these locations are, inspected and monitored for FAC. -

Criterion 2.5.8 -Turbine Cross Around Epina Determine if the turbine cross around piping is inspected on a regular basis and if the frequency is supported by inspecfion data.

Methodology: Review the turbine cross around piping inspection reports and available documentation for inspection history, trending, and future inspection/repair/replacement plans.

Criterion 2.5.9 - Dissimilar Metal Effects Determine if piping componentS adjacent to upgraded materials are included in the inspection program scope to detect localized thinning caused by "entrance effect" at dissimilar metal connections.

Methodology: Review a sample of plant documents to determine locations of components replaced with FAC resistant materials. Verify inspections of original components adjacent to those replaced with FAC resistant materials.

Page 10 of 43 NEC038471

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.5.10 - Selection Review Determine if the piping component inspection Jist is reviewed by a person other than the originator and also if there are any program requirements for the review.

Methodology: Review component selection documents and Ior interview responsible individuals for evidence that reviews of component selection documents are performed by another individual than the originator. Ensure evidence of reviews (documented by signature or other means) exists.

Criterion 2.541.1 Selection Input Determine. if input from other groups is included in the inspection planning process ((Le., Valve Group, Systems Engineering, Thermal Performance Monitoring, Operations, etc.)

Methodology: Review a sample of component selection documents and for interview responsible individuals for evidence that input and/or reviews by other plant groups have been considered in the selection process.

Criterion 2.5.12 - Scope Expansion. Determine if the program contains specific guidelines for scope expansion in the case of high or unexpected wear.

Methodology: Review program documents for specific scope expansion guidelines for in thecase of high or unexpected wear. Review previous inspection reports for evidence that guidelines were followed.

Criterion 2.5.13 - Normally Closed Valves Determine if piping downstream of normally closed - but leaking valves is being considered for inspection.

Methodology: Review piping susceptibility analysis, previous inspection reports, Thermal Performance Monitoring Data, and condition reports to determine if a sample of piping downstream of normally closed (but leaking) valves is considered for inspection.

Criterion 2.5.14 - Small Bore Program Determine if there is an adequate small bore program for prioritizing and scheduling inspections.

Methodology: Review piping susceptibility analysis, previous inspection reports, and. small bore related documents to determine the scope and schedule of the small bore piping inspection program. Compare plant documents to recommendations contained in Appendix A of NSAC 202L.

2.6 Performing Inspections.

Objective - Ensure that FAC Examinations are performed in accordance with the site

• procedures and FAC Program.documents and that they are consistent with industry standards.

Criterion 2.6.1 - Procedures Determine if there are formal procedures for performing inspections.

ýMethodoloQv: Review FAC Program documents to determine if formal procedures exist that provide sufficient guidance for performing FAC Inspections. Ensure this Page 11 of 43 NEC038472

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 guidance is consistent with NSAC 202L. Ensure the procedures are current, properly reviewed, and reflect current industry techniques and practices.

Criterion 2.6.2 - Inspection Grids Determine if component inspection grids are permanently marked or documented to insure that future inspections can be repeated at the same locations.

Methodology: Review FAC Program documents for gridding instructions and determine that the grids are reproducible to ensure repeatability. Determine if the markers used for grid layout are permanent enough to ensure repeatability.

Criterion 2.6.3 - Gridding of Components Determine if inspection gridding is performed in accordance with industry practice and Program requirements.

Methodology: Review several FAC inspection reports, photographs, and drawings ofcomponents from past outages to ensure Inspection grids cover the entire component, the grid size used is consistent with NSAC 202L, the area on both sides of each pipe to component weld is inspected, and the grids extend upstream and downstream of the inspected component.

Criterion 2.6.4 - Qualifications/Certifications Determine if NDE Inspectors are properly qualified in accordance with the plant procedures and equipment certifications.

Methodology: Review a sample of inspector certificates of qualification from the.

last outage. Ensure inspectors qualifications were current and reviewed by QA prior to performing inspections, and inspectors were qualified.to the proper UT Level for the inspections performed. Review a sample of equipment certifications from last outage and all equipment used in the inspections had current certifications.

Criterion 2.6.5 - Baseline Measurements Determine if UT measurements are taken on all components that are being replaced with susceptible materials.

Methodology: Review a sample of FAC inspection data of replaced components to ensure baseline data was obtained and documented in the FAC Program.

Criterion 2.6.6 -Suspect Readings Determine if suspect readings are verified for accuracy and areas of significant wear arescanned or the size of the grid reduced to identify the extent and depth of the thinning.

Methodology: Review a sample of FAC inspection data for evidence of checking data for suspect UT readings and verification that these readings were investigated and verified for accuracy.

Criterion 2.6.7- Organization of Data Files Determine if there is a formal system for organizing and maintaining the inspection data files.

Methodology: Interview FAC Responsible engineer and review process used for organizing and maintaining inspection data files. Ensure Inspection data is retained in accordance with plant procedures and are available for future retrieval.

Page 12 of 43 NEC038473

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327.

2.7 Data Evaluation Objective - Determine if the process for collecting, evaluating, analyzing and trending data is effective and is performed in accordance with established standards.

Criterion 2.7.1_- UT Data Evaluation Determine if there is a formal process for evaluating UT data and performing wall thinning evaluations.

Methodology: Perform document reviews of UT procedure, data sheets and the component evaluation procedure to determine if the process is adequate for dispositioning components for continued service or replacement..

Criterion 2.7.2 - Evaluation Process Determine if the criteria and process used to evaluate components is in accordance with plant procedures andindustry standards.

Methodology: Review evaluation procedure and a sample of evaluations to determine if the methodology used to perform the evaluations is in accordance With plant procedures and whether the evaluations provide the necessary data to effectively disposition the components for continued service..

• . Criterion 2.7.3 - Document Review Determine if the. acceptance evaluations performed for each component are documented and reviewed.

Methodology: Review Program Documentation and.a sample of component evaluations to verify if the evaluations are formally documented and are checked or independently reviewed.

Criterion 2.7.4 - Safety Margins Determine if appropriate safety margins are applied in remaining service life evaluations.

Methodology: Perform a document review of the evaluati6n process and sample some component evaluations to assess what safety margins are applied and whether it they are consistent with applicable codes and industry standards.

2.8 Performing Repairs Objective - Ensure'that FAC Repairs/Replacements are performed in accordance with established processes. procedures and applicable codes.

Criterion 2.8.1 :_Repairs/Replacement Determine if formal procedures are followed when performing repairs or replacements.

Methodology: Review FAC program documents to determine if formal approved procedures are available that provide guidance for performing repairs and replacements that are consistent with applicable piping codes and meet the intent of NSAC-202L-R2.

Criterion 2.8.2 - External Repairs Determine if external repairs are performed in accordance with applicable codes and standards. There are several ASME code cases that may be utilized for safety related piping and components. Prior NRC Page 13 of43 NEC038474

ENVY Design Engineering S elfAssessment: LO-VTYLO-2003-00327 approval may be required to use these code cases. These code cases can generally be used for non-safety related piping also.

• Methodology: Review FAC Program documents and historical records to determine if External Repairs are performed in accordance with approved codes and standards and are corisistent with NSAC 202L guidelines. Welding must be accomplished using approved procedures and qualified welders.

Criterion 2.8.3 - Internal Weld Repair Determine if internal weld repairs are performed in accordance with applicable codes and standards.

Methodology:. Review FAC Program documents and historical records to determine if internal weld repairs are performed in accordance with approved codes and standards and are consistent with NSAC 202L guidelines. Welding must be accomplished using approved procedures and qualified welders.

Criterion 2.8.4 - Material Upgrad Process Determine if piping material upgrades are accomplished using approved site procedures.

.Methodology:. Review FAC documentation of material upgrades to ensure that the material upgrades have been reviewed and approved prior to installation in the plant and accomplished using approved procedures and processes.

Criterion 2.8.5 - Material Upgrad Documentation Determine if documentation of material.upgrades is included in the FAC program documentation.

Methodology: Review FAC program documents to verify that material upgrade details have been properly incorporated into the plant drawings, specifications, predictive models, and associated data bases.

2.9 Long Term Strategy Objective - Determine if the FAC Program hasa long-term strategy that is consistent

.with the guidance provided in EPRI guideline NSAC-202L-R2, "Recommendations for an Effective FAC Program"..

Criterion 2.9.1 - Establishment of a Long Term Strategy Determine if a long-term strategy is in place and if it is effective.

Methodology: Review FAC program documents to determine if a long-term strategy exists and if the strategy is consistent with NSAC-202L guidelines.

Criterion 2.9.2 - Reduction of wear rates Determine ifthe -long-term strategy in place focuses on reducing FAC wear rates.

Methodology: Review FAC long-term strategy to determine if the strategy focuses on reducing wear rates and that the strategy on reducing wear rates is consistent to NSAC-202L guidelines.

Page 14 of 43 NEC038475

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.9.3 - Modeling Long-term Options Determine if analytical models used have been updated to reflect current information and used to evaluate long-term options.

Methodology: Review FAC program documents and a sample of predictive models to determine that all relevant information is Up to date, and if model information is used in long-term planning efforts.

Criterion 2.9.4 -- Water Chemistry Determine if past and future plant chemistry or water treatment is effectively used to control FAC degradation.

Methodology: Review program documentation to ensure changes in plant chemistry or water treatments are known and this information is used (either through FAC predictive model or other means) in controlling FAC degradation.

Also review interface with Chemistry and. FAC engineer.

Criterion 2.9.5 -_ System Changes Determine if system changes are reviewed and evaluated by the appropriate individual or department.

Methodology: Review FAC. program documentation to ensure there is a process in place for informing FAC engineer of system changes that may effect FAC susceptible systems and that the effects of these changes to FAC are considered by appropriate department prior to making modifications to FAC susceptible systems. Also, ensure that replacements performed under the FAC program are communicated to system engineering (as well as other related departments) and appropriate drawings are updated with new material changes.

Criterion 2.9.6 - Inspection and Replacement Goals Determine if inspection and replacement goals are developed and documented for the next 3 to 5 years.

Methodology: Review FAG program documentation to determine if inspection and replacement goals for the next 3 to 5 years have been set.

Criterion 2.9.7 - Plant Benefits Determine if there is evidence of continual improvement to the plant due to FAC program efforts.

Methodology: Review FAC program and plant documentation to determine if there has been improvement in areas of water treatment, a reduction of wear in once high FAC susceptible systems, and replacement of susceptible components with corrosion resistant materials.

Page 15 of 43 NEC03 8476

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 3.0 EVALUATION

SUMMARY

Criterion 2.1.1 - Management: Determine if there is an active Management participation in, and commitment to the FAC program.

Vermont Yankee's response to GL-89-08 was reviewed for commitment to maintaining a FAC Program. The FAC program procedure PP 7028,. Section 3, and the Engineering Program Procedure PP 7031 which delineates management responsibilities to the.

Director level were also reviewed. It was concluded that there is an active Management role in the FAC Program.

Criterion 2.1.2 - Documentation: Determine if there is a station document that defines the overall program.

Program procedurb PP 7028, VY Piping FAC Inspection Program defines the responsibilities and implementation requirements for the.FAC Program. Engineering Program Procedure PP 7031 delineates management responsibilities to the Director level.

These documents along with related station procedures'define the overall program.

Criterion 2.1.3 - Program Awareness: Determine if appropriate. site personnel are aware of who owns the FAC Program.

~r..-.MAWE I,,. .*

T" "Kwere reviewed and a clear delineation of roles and responsibilities for the various departments for interaction with the FAC Program was found. The FAG Program Coordinator is in design engineering. Also reviewed examples of documentation which demonstrated close ties with other groups for timely notification of leaks, access to system engineering thermal performance reports, and the monthly and weekly chemistry reports. This information, is also available on plant web site.

Criterion 2.1.4- Roles & Responsibilities: Determine if the roles and responsibilities of the FAC program asre clearly defined and .understood.

.Program procedure .PP 7028 and PP 7031 clearly define the roles and responsibilities of the various groups that implement and support the FAC Program. Interviews with the Program Engineer clearly illustrated that everyone works together and provides support.

when needed, and are familiar with the needs of the FACGProgram.

Criterion 2.1.5 - Training.: Determine if personnel responsible for the FAC program have received appropriate training for the position.

Vermont Yankee and Yankee Atomic training records for the program owner and back-up were reviewed. Both individuals have received the appropriate training for the FAC Program. Examples include the CHECWORKS Training Session from EPRI, an ASME sponsored Assessment .of Material Aging and Assessment of Remaining Life evaluation course, and a Piping Flow Accelerated Corrosion (Mechanical Only) course.

Criterion 2.1.6 - Qualification: Deterniine if FAC program owner is gualified for the position.

There is no qualification matrix for the FAC Program. in the ESP Program at this time.

However there is a qualification matrix for the MSIDE department that shows the Program Owner is qualified to administer the FAG Program.

Page 16 of 43 NEC038477

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.1.7 - Bench Strength: Determine the bench strength and qualifications/

training gf backup personnel.

Vermont Yankee and Yankee Atomic training records show that the program owner and back-up have received the appropriate training for the FAC Program. There is no qualification matrix for the FAG Program in the ESP Program at this time. However, there is a qualification matrix for the MS/DE department that shows the program owner and backup are qualified to implement the FAC program. Also, a third design engineer with previous FAC Program experience at other plants is available.

Criterion 2.1.8 - Personnel Turnover: Determine if personnel turnover is an issue for the FAC program.

There is no issue at this time as the program owner has been in this position since the start of the FAC Program. The backup engineer has also been involved with the program since 1993. The current status of the program and future work is well documented which would be a valuable tool if turnover would be necessary.

Criterion 2.1.9 - Resources/Schedule: Determine Lf program taskfactivities are completed in a timel manner and impac offt_*_e schedule, resources, and accelerated milestones.

An interview with program owner revealed that the time actually spent on FAC Program is 1/2 FTE averaged over the. fuel cycle. Other responsibilities included ISI and IWE support.

The program owner also supports IWE during outages. The actual time spent on FAC is very close to the time budgeted. Normally this works well, and emergent work can be fit in.

with little or no impact to the program. Work planning is excellent and is formally planned using the Engineering Work Control (EWC) process.

wiik,6L W(rlh(- nthsHv meesm waýs-e-ý,~i-(t L- prora ~ h r An interview with Program owners' supervisor reiterated the issues stated above. After the EPU is finished, the workload will return to normal. The work scheduling process via the EWC is well suited to identify and track items to completion by Program owner and his supervisor.

Criterion 2.2.1 - Susceptibility Review: Determine if there is a formal susceptibility review performed for each system and component that May be susceptible to FAG.

A susceptibility review was performed for the plant piping in accordance with NSAC 202L.

er separat tht ýi i fl s, ;Ki i~{ ýq &jlt plilk: i Id hav I p o .ror~ i iJfi: igtrbk' jnpsci a inc iiC I EX, . a Fi for large bore piping provides such ranking. :Ve.*e1 .e . 2-.

'Was, aI" This document is not in the document system nor, is it an attachment to or an appendix to a procedure. P.,eýgnz^Ig-t'ato-o_,_,e!:g, n!,

'A-clt, p eI'dpJ re maI

'dqtho erb-t _e 'pipingdr'qm~

Page 17 of43 NEC038478

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 A review of incorporation of the vendor supplied piping into the susceptible review was also performed by sampling the HPCI system and reviewing, drawing GE191169, with the result that all piping was included.

Criterion 2.2.2 : Ranking Criteria: Determine if the criteria used to rank the susceptible pipin components in-the various systems are in accordance with NSAC202L or other accepted industry practices.

A review of the FAC Susceptible Piping Identification Report shows that the guidance provided by NSAC 202L was used to screen the various piping systems for inclusion or exclusion in the FAC program. beeJ!n t A *t

• Criterion 2.2.3 - Documentation !§ hoand P Reviews:

_t q-~ . Determine 1 if the susceptibility analysis is adequately documented, checked .and/o__r independently reviewed.

Criterion 2.2.4 - Updates: Determine if the susceptibility a r are updated andreplaced C .*~

at what Li frequency."" * . 16h ý, ti ""I-.*c-h-**.:

J".p'e*1.f*

(I ,';,' I I,T t:N Az A review of program procedure PP 7028. section 3.2.12 post outage activity requires, the update and maintenance of the FAnsusceptible piping document to reflect plant changes.

During 2001 Outage, approximately 6 ft of piping. (on MSD piping in steam tunnel was replaced with chrome-moiy piping. AOG steam reducing station drains from steam.tr'ap to condenser was also replaced. In addition linesW'3/4-HCN-188-H1 and % "-HCN-189-D3 which are drains from 3"-MSD-4 from the steam traps at pressure reducing station were Criterion 2.2.5 Scop__e_&Syst _Alinment: Determine whether systems and components benq ranked aree appropriately a withplant operating procedures and the pertinent Sdrawings flo._.ww diag~rams. Determine Lf pg-gn vendor supplied.equipment is included in th__e sco_*p~e of FAC programn.

Feedwater piping drawings 5920-FSI-24 & 5920-FSI-25 and a sampling of the components of the CHECWORKS model were reviewed to verify if the components within the model match with the piping configuration. A sampling of vendor supplied piping using

• HPCI. piping (Vendor drawing. Gi191169 Sht. 212) lines 2-HPCI-8, 2-HPCI-9, &2-HPCI-12

• was also checked to determine if those lines were in the FAG program. System line up was checked against OP-2172 tonverify line for normal operation.

Page 18 of 43 NEC038479

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Large bore components being ranked are appropriately aligned with plant operating procedures and the pertinent drawings ( flow diagrams and vendor supplied equipment piping is included in the scope of FAC program.

Criterion 2.2.6.- Small Bore Susceptibility: Determine if there is a susceptibilit analysis performed for the small-bore p "in and if there is inspection pririty assigned to the The susceptibility analysis for small bore piping is complete. However, inspection priorities are not documented. Initially, engineering judgment was used to select small bore inspection locations, such as high pressure lines and steam.leak offs.

Criterion 2.2.7- Department Interface: Determine how other plant departments effectively contribute to the Susceptibility Analysis.

Conducted an interview with the FAC program engineer to define how the respective departmental inputs are processed and updated. Reviewed system engineering variance reports, thermal performance reports and chemistry reports to determine what vital information was available and continues to exist for the development of the ranking for the small bore piping. Reports form the various departmentsare adequate to assist in performing the susceptibility analysis.

Criterion 2.2.8 - Abnormal Conditions: Determine how changes i operating conditions.

off-normal or abnormal system lineup. domponent leakage or operating experience are communicated documented, and evaluated for impact on the FAC program.

A document review of site procedures and protocols, system health reports, Event Reports (Condition Reports), site and industry operating experience, and Emails was performed to determine how system condition changes or alignments are documented, communicated then evaluated for impact on the FAC program. Off normal events are reported through the following reports; Monthly Chemistry Report,. System Engineering Variance Report, and the Thermal Performance Report. 'I liý Criterion 2.3.1 - Controlling Program Procedure: The controlling program procedure is u_-to date and is current with respect to indust codes and standards.

The program procedure is consistent with NSAC 202L guidelines. ' 1t-'

dnaftii*staceaf,_ t 's~teh7eath io!*m. iý,eir i I eifor eýip! bilehis update should

_OlfbuJtd, to~i 1W -k~i sself-býsr-ýmn, e on ltf inb6 61rviu s&Fs ,)7X/ _'2

~

-9Q ~ ~ -8}g-lae "This update should include not only update to the -procedure content per the commitments but also update.

erh- .edure See AFt 2.3-1 Page 19 of 43 NEC038480

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.3.2 - Supporting Documents: Gridding procedures, engineering standards, and engineering directives, etc are maintained u_* to date with current revisions.

guidelines that were once a part of the VY site procedure. The gridding procedure will need to be moved to a new procedure or incorporated into an existing procedure. The FAC engineer is aware of the change, and will add the necessary gridding guidelines removed from the UT procedure to the FAC program procedure as a supplement. This is not only a problem for VY but also for other ENN FAC programs. -xisijg,3 *..t Criterion 2.3.3 -Document Reviews: All_/ appropriate' oro~gram documents (Procedures, Models _Cornponent Evaluations, et are checked and reviewed pe pln rocedures and/or industry practices.

The FA program procedure, PP 7028, and. department procedure DP 0072, for Structural Evaluation of Thinned Wall Piping Components, and several component ievaluations were reviewed. The documents were prepared by the FAG engineer and reviewed by Backup FAG engineer. NDE reports are reviewed and checked by a Level Ill examiner as well as by the FAG engineer.

Criterion 2.3.4 - Component Database: The component inspection database must be pro eduresy maintained.

StutrlEvlainonngComponen update of the small bore database is currently in the EWC schedule. AFn 2.2-1.

For large bore components information and all inspection data to date has been inauded in the CHECWORKS database. At this time CHECWORKS is considered themain component database for large bore components. A separate a FACTRAK import into an Excel spreadsheet was created in 1996 to summarize which large bore components have been inspected, but has not been updated.

Criterion 2.3.5 -ost-Outa Re

__ort: The Post-Outae reepoA must be smapleted and issued in a timely manner.

Section 4.1.12 of PP 7028 requires that outage Inspection Reports are to be issued within 90 days of startup. The report itself is very detailed, giving a summary of the inspection activities performed, the goals that were planned andforaccomplished and inspection or repairs and results. The report also includes recommendations future replacements future spirqed monitonrng. 199 tosummarizeewhich, rge.bor.e coponentshav Page 20 of 43 NEC038481

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.3.6 - CHECWORKS Pass 2: CHECWORKS Pass 2 analysis and records must be up to date and adequately documented.

A Pass 2 analysis was run for all CHECWORKS lines during 1996. After 1996 only the most susceptible lines were run. 1(t, U.-FA-1

• ~ ~Criterion.2._337 - FAC Program Drawings: FAC Proggram record drawings@ must Sdocument the component locations, thee CHECWORKS numbering sytm must be up too date. The documentation should be consistent with NSAC 202L Guidelines."

! FAG large bore location sketches areýý"O~~ located in Appendix A of PP 7028. The sketches nothno i' represent lines in CHECWORKS and all`Pcomponents ~ inAM[23 the CHECWORKS models are emfi~aeet identified on the sketches using the CHECWORKS numbering system. Information on the

~component location sketches is consistent with thle CHECKWORKS model and the i component numbering system. The sketches reference P&lDs and pipe drawings used to develop drawings, but the FAG sketches can only be updated as a procedure update since they are part of the FAG program procedure.

Criterion 2.4.1 - Model ReviewNerification: Determine if models dare reviewed

• verifieddd an._.d prooerlpv. Sigssned off.

The complete CHECWORKS models and wear rate analyses were updated in 1996 These were prepared in-house and reviewed by FAG coordinator. *8]

W-~

to the CHEeWORKS ~ models x~ ~ btdtdwihUdtarm2

~ ~should

~ be~ formally

'" id: updated and reviewed. See AsI 2.4-1

((Ilss~ul Criterion 2.4.2 - Model sUkdates: Determine f modeldis d l A witof

_h projected operating hours for the next outgan current chemistry conditions and other chanoesa in oprtif n tarameters.

.* CHECWORKS database has been updated with current oper~ating hours (up to Cycle 29) and heat balance parameters are current. There have been no significant chemistry changes performed at W, so cchmistry parameters remain unchanged. used to Criterion 2.4.31 Modeled Systems Accuracy: Determine if models reflect the comoplete T n system being modeled.

21 ofU43 lPage NEC038482

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 A detailed review of the CHECWORKS model for a section of the feedwater system (Discharge line from pump PI-I-A to 24" FW header, FAC sketch-No. 001) was performed. The modeled line segment included all components in the line from pump nozzle to the feedwater header. Component identifiers in CHECWORKS model matched identifiers on FAC drawings. 01 j.  ;* !j-Criterion 2.4.4 - Component Data Accuracy: Determine if component information in a system model is correct.

Review of CHECWORKS line segment FDW-001 showed all component information to be correct and verified by the heat balance and flow diagrams. Portions of the Feedwater Flush lines 8"-FDW-22A & 10"-FDW-23A on Location Sketch .022 have been upgraded to A335-P1 1. material. The P&ID, the CHECKWORKS model, and the FAC drawing were reviewed. aV~IUhejP3l ff Y-M Criterion 2.4.5 - Component Inspection Data: Determine if componentinspection data has been imported into model and processed correctly.

Last inspection (2002) data was imported. into CHECWORKS by NDE and reviewed to ensure that the data matched data logger readings.. The UT data matrix from CHECWORKS is printed out and signed by NDE. .8t`tKM3 R-a

ýg - c ~ag , ng pqrteýt, Criterion 2.4.6 - Predictive Analyses: Determine if the predictive 2comuter model analyses are reyiewed and used as part of the inspection selection process in accordance with proAgram& procedures.

A review of PP 7028 rev 1, Appendix A, Component Location Sketch 008, and the associated Passl/Pass2 results was performed. Outage inspection plans considered these results in the location selection process. For example, Pass 2 analysis from the 2001 CHECWORKS run was used when developing the scope for.2002 outage. This is documented in the FAC inspe~ction scope worksheets for the 2002 refueling outage which describes the reasoning behind the selection of each component scoped for the outage.

SThis is stated in the "Inspection Location Worksheets I Methods and

'Reasons for Component Selection" for the 2004 refueling outage. Updates of the CHECWORKS models are scheduled in the EWC process. AFI 2.4-1:

Criterion 2.5.1 Inspection Process: Determine if there is a procedure orformal process for selecting components f inspection.

ar Reviewed program procedure PP 7028 where Section 4.4.1 specifies the process for selecting components and Appendix Aof PP 7028 defines the criteria forselection of components forminspection. This approach is consistent with NSAC 202L P2 guidelines.

Page 22 of 43 NEC038483

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Criterion 2.5.2 - CHECWORKS Pass 1: Determine if onp.yCHECWORKS Pass 1 analysis models are used as a basis in the selection process.

CHECWORKS Pass 1 analysis output is only used to exclude lines from the inspection selection process in terms of susceptible or not susceptible. Since a large number of the lines in the large bore FAC.program were either originally FAC resistant Chrome-moly piping materials or have been replaced with FAC resistant materials and there are only few segments that have no inspection data, this approach is prudent.

Criterion 2.5.3 - CHECWORKS Pass 2: Determine if CHECWORKS Pass 2 analysi models are used in the selection process.

Generally most of the inspection selections from the CHECWORKS output are from the.

Pass 2 analysis. output. 410 - , te qsWea.ten*6,tb 1,2 Industry practice is to update the CHECWORKS models after each refueling outage. .. a0 s ge '

............................ p.in tonf I n*rThe OE highlighted the changes in component ranking occurred as result of not including the latest inspection data. AFI 2.4-1 Criterion 2.5.4 - Previous Inspections: Determine if &how previous inspection results are

• used in the selection process, Criteria for selecting components for inspection during a refueling outage are contained in the "Inspection Location Worksheets/Methods and Reasons for Component Selection".

One criterion is for components selected for measured or apparent wear found during previous inspections.. Inspection Nos. 01-03 &01-04, component Nos. FDO1EL01 and FD01 TE05 as shown on Sketch 004 were tracked from the 2001 inspection report which recommended re-inspection in 2004. A review of the work scope for 2004 included these components for re-inspection. Components recommended for repeat inspections in past inspection reports have been re-inspected.

Criterion. 2.5.5 Industry Events: Determine if recent and past industry events are considered in the inspection Rlanning process.

The "Inspection Location Worksheets/Methods and Reasons for Component Selection" for the .2004 RFO were reviewed. Under the criterion for "Largebore Components Identified by Industry Events/Experience", .a total of 18 events since January 2001 are listed. From Surry-1 OE was tracked for a leak in the 8" condenser drain, header for the.3d/4e point FW Heater vents, the thinning in the Gland Steam piping inside the condenser and the 12" condenser drain header from the MS Drain Trap Lines. Similar piping at VY is an 8" low point drain header, which is scheduled for inspection during the 2004 RFO. The other 17 OE's were reviewed and found either they.were dispositioned by scheduling for future inspection or explaining why no further action is required.

Criterion 2.5.6 - Selection Documentation: Determine if the results of the inspection Slanning process are formally documented and if the selection Iogic for each location is captured.

Reviewed program procedure PP 7028 which includes the section on "Inspection Location

• Worksheets / Methods and Reasons for Component Selection". These worksheets provide a rigorous and thorough method to aid in the identification andselection of components for inspection. It includes all the selection criteria necessary for a thorough Page 23 of 43 NEC038484

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 review of small bore, large bore, feedwater heater shells, and cross-around piping. The worksheets address inspections based on previous inspection results, CHECWORKS evaluations, CHECWORKS model calibration, OE, off normal flow conditions, malfunctioning equipment such as leaking valves, and engineering judgment. The worksheets prepared by the program owner and reviewed by the backup FAC program Engineer. Components identified in the worksheets are compiled in the Scoping memo to Program Owners supervisor.

The worksheets used to select inspections should be considered a program strength STR 2.5-1. They present a thorough, rigorous, documented approach to inspection selection incorporating all the criteria in NSAC-202L, and site specific issues.

Criterion 2.5.7- Control Valve Piping: Determine if susceptible components and piping downstream of control valves are covered in the program.

Plant flow diagrams and inspection reports on piping and components up and down stream of flow control valves FCV6-12A and -128 were reviewed. Up and downstream components of FCV6-12A (FD07RD02, FD07RD03 and FD07SP03) were inspected in 1990, 1993 and 1995. Up and down stream components of FCV6-128 (FD08SP02 and FD08RD03) were inspected in 1995. VY FAC program effectively addresses piping downstream of flow control valves.'

Criterion 2.5.8 - Turbine Cross Around Piping: Determine if the turbine cross around p "in is inspected on a regula basis and if the frequency is supported by inspection data.

The "Inspection Location Worksheets/Methods and Reasons for Component.Selection" for the 2004 RFO was reviewed for the selection of the cross around piping. Also, a sampling ofsthe V.aspa'ýp.. ,was performed. From these it can be concluded that the cross around piping has numerous inspections and the. plans for future inspections as documented the 2004 inspection selection demonstrate that the piping is inspected on a frequent basis and is more than adequate.

Criterion 2.5.9 - Dissimilar Metal Effects: Determine if Rijpg components adjacent to upgraded materials. are included in the inspection program score to detect localized thinning caused by "entrance effect" at dissimilar metal connections.

Reviewed plant flow diagrams for instances of non susceptible materials (chrome-moly,

• stainless steel) adjacent to susceptible materials (carbon steel). Although there are not many instances of dissimilar metal interfaces at VY, one interface was found on feedwater line 4"-FDW-4, sketch 017. The chrome component was pipe FD04SP1 2 connected to a carbon steel reducer FD04RD01. ;,-, ec til The VY FAC program effectively addresses dissimilar metal connections.

Criterion 2.5.10 - -Selection 'Review: be'f hirl1f tiThi'k ft riý 1Jftt~.

ren

• ew t aiti0,i6 f6' f d .&d ýl The "Inspection Location Worksheets/Methods and Reasons for Component Selection" for the 2004 RFO were reviewed. The worksheets were reviewed and documented by signature. There is no. program or procedural requirement for the review. Existing commitment No. LO-VTYLO-2002-341 is in place to formalize the-'nspection Location Page 24 of 43 NEC038485

ENVY Design Engineering Self Assessment: *LO-VTYLO-2003-00327 Worksheet process. Documentation and review requirements will be included in the procedure update.

Criterion 2.5.11 - Selection Input: Determine if input from other group* is included in the inspection olannin process ((Le Valve Group, System Engineering, Thermal Performance Monitoring. Operations, etc.)

Reviewed the system engineering production variance report and thermal performance report and determined.thatthose reports are good sources for input-into the selection process. Interviewed the program owner as to which other group contributed to the selection process and another good source cited is the operating experience group who routinely distribute issue FAG related industry events.

Criterion 2.5.12.:-Scope Expansion: Determine if the rogram contains specific guidelines for scope expansion in the case of high or unexpected wear.

Reviewed program procedure PP 7028, section 4.4.7.2 and Appendix E relating to criteria for scope expansion. Reviewed 1996 Outage inspection report with specific examples of scope expansion as documented in data sheets YA-UT-1 12-95,YA-UT-1 12-114 &YA-UT-

.112-128 due to high or unexpected wear for the feedwater and condensate system.

Criterion 2;5.13 : Normally Closed 'Valves: Determine iff2g downstream of normally closed - but leaking valves is being considered for inspection.

Reviewed the thermal performance variance report (1999) that shows valve leakage by indication of tail pipe. temperature measurement with associated inspection during the 1999 refueling outage. Inspection data-sheets YA-UT-1 12-220/221/222 AND YA-UT-1 12-214/215/216, document the inspections.

Criterion 2.5.14- Small Bore Program: Determine if there is an adequate small bore program forprioritizing and scheduling inspections.

Reviewed piping susceptibility analysis, previous inspection reports, and small bore related documents to determine the scope and schedule of the small bore piping inspection program. Compare plant documents to recommendations contained in Appendix A -of NSAC 202L. ý A)t *5fl- _-,- ' are, r)"p, See AFI 2.2-1 Criterion 2.6.1 - Procedures: Determine if there are formal procedures for performing

] inspections.

Reviewed program procedure PP 7028 section 4.4.4. "Prepare piping components for inspection", Section 4.4.5, "Perform UT inspections", and Section 4.4 6 for Level III and

• compliance responsibilities. The procedure specific instructions and guidance for performing FAC inspections.are consistent with NSAC 202L Rev.2.

Program procedure PP 7028 references NDE Procedure NE 8053 which has been superceded by ENN-NDE-9.05 Rev.O and subsequently needs to be revised. In addition the details for performing gridding do not exist in the new procedure and no active procedure contains those instructions. Therefore a new procedure has to be generated or the gridding instructions incorporated in the program procedure- iM-. L'U procedure.

Page 25 of43 S*CNEC038486

ENVY Design Engineering Self Assessment: LO-TYLO-2003-00327 Criterion 2.6.2 -Inspection Grids: Determine.if component inspection grids are permanently marked or documented to insure that future inspections can be repeated at the same locations.

Reviewed program procedure PP7028 Section 4.4.4.2 which references procedure NE 8053 Appendix A for gridding instructions. This procedure states the requirements for gridding to ensure the applied grids are documented and reproducible. .

procedure.

Criterion 2.6.3 - Griddinq of Components: Determine if inspection griddin performed in accordance with industry practice and Program requirements.

Reviewed program procedure PP.7028, Section 4.4.4;2 which references procedure NE 8053 Appendix A for gridding instructions: This procedure states the requirement for gridding to ensure reproduction and repeatability. Also reviewed inspection data sheet 8053-02-111. for component FD14EL05 and data sheet 8053-02-110 for component FD14TE02 from the 2002 refueling outage and concluded that the gridding is consistent with the requirements of NSAC 202L Rev.2 and industry standards.

Criterion 2.6.4 - Qualifications/Certifications: Determine if NDE Inspectors a properl qualified in accordance with the plant procedures and equipment certifications.

Reviewed certification / qualification records for two FAC inspectors and determined that the processing and review of the technicians qualification and certification were conducted and accepted in accordance with plant protocol.

Criterion 2.6.5 - Baseline Measurements: Determine if UT measurements are taken on all components that are being replaced with susceptible materials, No baseline measurements have been performed to date. However no permanent large bore replacements with carbon steel piping have been performed due to FAC related

damage, Criterion 2.6.6 - Suspect Readings: Determine if suspectreadings are verified for.

accuracy and areas of significant wear are scanned or the size gid rgQfhe reduced to identify the extent and depth of the thinning.

Reviewed data sheet YA-UT-1 12-213 for component FD07ELO1 for counter-bore and YA-UT-1 12-238 for component FD14SP03 with suspect reading lower than area reading and data sheet showed readings were re-taken and new measurement replaced the previous one.

Criterion 2.6.7- Organization of Data Files: Determine if there is a formal system for organizing and maintaining the inspection data files.

Reviewed program procedure PP 7028 with particular reference to Sections 4.4.1.3 and 6.3 which- require formal record retention. Interviewed FAC program owner for compliance and determined inspection records are retained in accordance with PP 7028.

Criterion 2.7.1- UT Data Evaluation: Determine if there is a formal process forevaluatinq UT data and performing wall thinning evaluations.

Page 26 of 43 NEC038487

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 DP 0072 is used to evaluate components for continued service or replacement and outlines a formal process to perform evaluations. Evaluations are not considered calculations but they are reviewed and signed by an independent reviewer and are permanently stored by records for plant lifetime. Safety class piping and components under ASME section XI requirements are dispositioned in accordance with DP 4027.

UT data is reviewed by Level III examiner and signed. Reviewed 2000 Outage Report Inspection No. 2000-04, DP 0072 provides a formalized process, data.sheets, and is found to be adequate for dispositioning components for continued service or replacement.

lh- th- TM I79nliýLred. jj Criterion 2.7.2 - Evaluation Process: Determine if the criteria and process usedto evaluate components is in accordance-with plant procedures and industry standards.

The FAC program document, PP 7028 rev 1, refers to DP 0072 for evaluating components. Component evaluations are performed in accordance with plant procedure DP 0072, "Structural Evaluation of Thinned wall piping components. At this time, VY is not, required to perform evaluations based on ENN-DC-1 33. Component evaluations are also consistent with industry procedure NSAC-202L.

0 ROw tio be ý-qt ~ ~ ~ p~~~Q Criterion 2.7.3 - Document Review: Determine if the acceptance evaluations performed for each component are documented and reviewed.

A review of the 2000 Outage Report Inspection No.. 2000-04, the completed, acceptance evaluation includes the component evaluations, NDE reports, and structural evaluations (entire component evaluation worksheet) was performed. These are reviewed, checked, and approved. All worksheets are stored in records for plant lifetime.

' Criterion 2.7.4 - Safety Margins: Determine if appropriate safety margins are applied in remaining service life evaluations.

Criterion 2.8.1 - Repairs/Replacement: Determine if formal procedures are followed when performing reairs oI replacements.

Formal procedures exist for repair/replacement. Safety class ASME section Xl.

components 2P are dispositioned under 4027, and component repairs or replacements are performed undernAP 0070. Non-safety repairs/replacements would .be controlled via maintenance work orders for like-for-like. For upgraded material replacements, an engineering, recommendation, followed by an equivalency evaluation and either a minor Page 27 of 43 NEC038488

.ENVY Design.Engineering Self Assessment: LO-VTYLO-2003-00327 mod or design change to implement the replacement. AP 0070 "AS ME Section XI Repair and Replacement Procedure" provides a formal process, that is consistent with ASME Section Xl and NSAC-202L-R2.

Criterion 2.8.2 - External Repairs: Determine ifexternal repairs are performed in accordance with applicable codes and standards. (Thereare several ASME code cases that may be utilized for safet related ip"ing and components. Prior NRC approval may be required to. use these code cases. These code cases can *generally be used for non-safety related njp"in also.

All external weld repairs are considered temporary, are performed using approved procedures, and require approval from the ANII. These are either permanently repaired or replaced during the next opportune time or outageý. External repairs to.

Safety Class Piping would require a relief request and would be performed under the requirements of AP 0070, "ASME Section XI Repair and Replacement Procedure",

No external repairs to Safety Class piping due to FAC related damage have been performed at VY.

Criterion 2.8.3 - Internal Weld Repair: Determine if internal weld repairs are performed in accordance with applicable codes and standards.

Internal weld repairs on non Safety Class piping are considered permanent, are performed using approved procedures, and require approval from the ANII. Internal

• weld repairs to Safety Class Piping are performed under the requirements ofAP 0070, "ASME Section XI Repair and Replacement Procedure" using approved welders and welding procedures. This is consistent with ASME Section XI and NSAC-202L-R2 guidelines.

Criterion 2.8.4 - Material Uporade Process: Detennine if p"ing material upgrades are accomplished using approved site procedures.

Equivalency evaluations, engineering recommendations, and mod packages for material upgrades due to FAC are reviewed and approved prior to -installation in the plant. Replacement of FAC susceptible systems with Cr-Mo (P11 or. P22 ) is common knowledge plant-wide and is not stated in FAC program procedure. All material changes are shown on system P&IDs.

PP 7028, does not identify a specific process or procedure to be used when making a material upgrade. After the FAC engineer determines that a material upgrade is required, the Design Engineering Group performs the required evaluations and develops the modification packages using the standard design processes provided by AP 0020, and AP 6008.

Documents pertaining to modifications made to line 1"-MSD-407 (dated 4-3-95) and line 2"-MSD-406. (dated 4-10-95) were reviewed and found reasonable. Additionally,.

document VY-DC72003-02, an in-process modification package Was likewise reviewed and found to be reasonable.

Criterion 2.8.5 : Material Upgrade Documentation: Determine if documentation of.

material upgrades is included in the FAC program documentation.

Material changes are captured on the plant P&IDs and not the plant's line specification (the Ebasco Piping Specification QC-10 line list is historical). For the FAC program, Page 28 of 43 NEC038489

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 changes to material -have been updated in CHECWORKSbut not all updated lines have been captured in the FAC system susceptibility documentation, and FAC isometrics. See AFI2.2-3.

Portions of the Feedwater Flush lines (8"-FDW-22A & 10"-FDW-23A) have been upgraded to A335 P11 material. The P&ID, the CHECKWORKS model, and the FAC drawing were reviewed. While the P&ID and the CHECKWORKS model were updated, the FAC Component Location Sketches were only "marked-up".

See AFI 2.3-1.

Criterion 2.9.1 - Establishment of a Long Term Strategy: Determine if a long-term strategy is in place and if it is effective.

VY is a BWR which has limited chemistry options for reducing FAC. The most effective long term method for reducing FAC wear is replacements with FAC resistant materials.

VY has been vigilant on replacing susceptible systems with FAC resistant materials in order to reduce FAC long term. Areas that have been replaced with FAC resistant material to date are:

o MS Drain Lines to #2 FDW heaters downstream of LCV o - MS drain bypass lines to condenser downstream of LCV o FDW flush lines from normally closed valves to pressure reducing orifices near the condenser..

o FDW pump bypass lines for normally closed valves to the condenser.

o Turbine cross around piping (7 of 8 lines).

o Main steam small bore drains from HPCI and RCIC turbine steam supply to the condenser.

o Steam Leads continuous drain to the condenser downstream of turbine stoptcontrol valves.

o Two condensate return lines from the AOG steam pressure reducing station to the condenser.

o LP turbine casings including the extraction steam stubs o Extraction nozzles and partial shell replacement on #2 HP FW heater o #3 &#4 feedwater heaters o .#5 feedwater heaters in the condenser neck P. .jý Vermont Yankee's proactive piping replacements with FAC resistant material is considered as a program strength. See STR 2.9-1 Criterion 2,9.2 - Reduction of Wear Rates: Determine if the long-term strateQV in place focuses on reducing FAC wear rates.

Replacement efforts are the primary foqus on reducing wear rates and consistent with

j. NSAC-202L guidelines as stated in Criterion 2.9.1 above.

Criterion 2.9.3- Modeling Long-Term Options: Determine if analytical models used have been updated to reflect current information and used to evaluate long-term options.

Page 2 of'4 NEC03 8490

.ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 in- . UI

, See AFI 2.4.1.

Criterion 2.9.4 - Water Chemistry: Determine if past and future plant chemistry water treatment is effectively used to control FAC degradation.

Since VY is a BWR, there is very little that can be done to reduce FAC wear. rats through water chemistry changes. Dissolved oxygen in the final feedwater has been maintained in the 20 to 30 PPB range from 1996 to 2003.

Criterion 2.9.5 - System Changes: Determine if system changes are reviewed and evaluated by the appropriate individual or department.

Reviewed FAC program documentation to ensure there is a process in place for informing FAC engineer of system changes that may effect FAC susceptible systems and that the effects of.these changes to FAC are considered by appropriate department prior to making modifications to FAC susceptible systems and to ensure that replacements performed under the FAC program are communicated to system engineering (as well as other related departments) and appropriate drawings are updated. with new material changes, Since the VY FAC Coordinator is part of the Design Engineering Group,. he has direct access to information on system changessuch as modifications and replacements being developed that may affect FAG susceptible systems. This is considered a strength of the program. See STR 2.9-2 Criterion 2.9.6 :- Inspectian d Replacement Goals: D-etermine if inspection and replacement goals are developed and documented for the next 3 to 5 years.

VY does not have a planned replacement goal for the nextthree to five years, Replacements have been based on current need. Also many piping systems which would have been found to be highly susceptible to FAC were originally designed with resistant materials or have already been replaced with FAC resistant materials. VY has made a conscious effort to replace piping systems and components that are susceptible with FAC resistant materials, STR 2.9-1 Criterion 2.9.7- Plant Benefits: Determine if there is evidence of continual improvement Lo the pant due to FAG program efforts.

The ongoing effort of replacing systems with FAC resistant material has drastically reduced the amount of inspections performed during refueling outages. Oil i iiPP  :

fThis is seen as a program strength. STR 2.9-1 Page 30 of43 NEC038491

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327

4.0 CONCLUSION

S AND RECOMMENDED ACTIONS Objective 2.1 Programmatic Leadership/Responsibility - Ensure that Vermont Yankee Nuclear Power Plant (VYNPP) Flow Accelerated Corrosion (FAC) Program is provided with adequate leadership and that the responsibilityfor the program is clearly defined.

Determine if the FAC Program owner and any dedicated backup personnel are qualified for the position.

Conclusion There is an active Management role in the FAC Program. Program procedures define the responsibilities, implementation reqqirements, and interactions between the various plant departments that implement and support the FAC Program. The FAC Program owner and the assigned backup are qualified to administer the FAC Program. Also, a third design engineer with previous FAC Program experience at others plants is available.

Personnel turnover is no issue at this time as the program owner has been .in this position since the start of the FAC Program. The backup engineer has also been involved with the program since 1993. The current status of the program and future work is well documented which would be a valuable tool if turnover would be necessary. The experience of both engineers along with a low turnover is considered as a program strength. SiR.2.1-1 Time actually spent on the FAC Program is /2 FTE averaged over.the fuel cycle. The actual time spent on FAC is very close to the time budgeted. Normally this works well and emergent work can be fit in with little or no impact to the program. Work planning is excellent and is formally planned using the Engineering Work Control (EWe) process.

However, during the last operating. cycle, -this was not true. The program owner needed to spend a good deal of time.working on the EPU and pushed out many of the program commitments over three months. This was recognized by the program owner and his supervisor as an unusual event. Program tasks are- routinely performed on schedule. An interview with Program owners' supervisor reiterated the issues stated above. After the EPU is finished, the workload will return to normal. -The work scheduling process via the EWC is

-well suited to identify and track items to completion by Program owner and his supervisor.

Areas for Improvement

• None identified for Objective 2.1 Strengths STR 2.1-1 The plant and FAC related experience of both the FAC program engineer and the backup engineer, program documentation, and lowturnover is considered as a program strength.

Objective 2.2 - System Susceptibility- Determine if the FAC Program includes systematic methods for categorizing which systems are susceptible to FAC, predicting and analyzing FAC, and for prioritizing inspections. Determine if the methods are consistent with industry practice.

Conclusion Page 31 of43 NEC038492

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 A susceptibility review-was performed for the plant piping in accordance with NSAC 202L.

This review evaluated all plant piping systems (large bore and small bore) for susceptibility to FAG. The scope of the document was to evaluate each system as either susceptible or not and if so, to classify each system for the methodology for.evaluation. This approach gives a single place to verify inclusion or exclusion intothe program. .R_ M fi.q)

Large bore components which are ranked for inspection priority using CHECWORKS are appropriately aligned with plant operating procedures and the pertinent drawings / flow diagrams. Vendor supplied equipment piping is included in the scope of FAG program.

• Inspection priorities for small bore* piping are not formally documented. Initially, engineering judgment was used to select small .bore inspection locations, such as high pressure lines and steam leak offs. The majority of small bore inspections at VY were performed in 1993 and 1995 prior to the publishing of ranking criteria in Revision 1 of NSAC 202L. W 'af The review of the susceptibility report determined that the document is not formal even though there was a peer review was performed. The report was a program generated document with no requirement for this review. This document is not in the records management system as a- separately controlled document nor is itan attachment to oran appendix to a procedure. AFI 2.2-2 A. review of program procedure PP 7028, Section 3.2.1.2 post outage activity requires the update and maintenance of the FAG susceptible piping document to reflect plant changes.

Piping material changes made during the 2001 refueling outage have not been incorporated into the report. AFI 2.2-3 Inputs from other plant departments which impact the susceptibility evaluation and inspection

.priorities include engineering monthly thermal performance monitoring and chemistry reports.

These are adequate to assist the FAG program engineer in performing the susceptibility analysis. Off normal events affecting the FAG program are reported through PCRS, chemistry report, and the System *Engineering Production Variance Report. These tools assist in scoping lines for inspection or incorporating in the susceptible report. However, the link with operations needs to be strengthened. AFI2.2-4 A recommendation is to develop a formal method for Operations Department to communicate changs .in operating conditions, off-normal or abnormal system lineups to FAC Program for assessment.

-Areasfor Improvement AFI2.2-1 Small bore piping inspections are not formally tanked or prioritized. Appendix A of NSAC-202L, Rev.2 provides recommendations for an effective small bore FAC program. Once lines are categorized as susceptible to FAG, it provides criteria for prioritizing inspections based on consequences to the plant. It is recommended that a ranking of small bore Page 32 of 43 NEC038493

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 piping in accordance Appendix A of NSAC-202L Rev.2 be performed and formally documented.

Consequences Susceptibility small bore lines have been identified in the piping FAC susceptibility analysis. A large number of small bore inspections at VY were performed in 1993 and 1995 prior to the publishing of ranking criteria in Revision 1 of NSAC 202L.

Engineering judgment with respect to personal safety and consequences. of failure were used in the location selections. Additional inspections have been performed each refueling outage since 1995. From 1992 to 2002, approximately 110 sections of small bore piping have been inspected, some sections have multiple inspections. This represents a significant portion of the total susceptible small bore population. Given the large number of inspections performed to. date, these should include all. high priority locations. Also, lines showing significant wearhave been. replaced. with FAC resistant materials. A formal ranking and inspection prioritization will insure that all high priority lines areinspected.

Recommendation Update the FAC small bore database to include a detailed ranking of the small bore piping .in terms of inspection priority and risk consequence to the plant. This activity is currently on the EWC schedule foe the FAC Program activities. No new condition report is required.

AFI2.2-2 The susceptibility for the plant piping was~performed and reviewed in accordance with NSAC. 202L. However it is a program generated document not formally included into the plant records management system. This document resides in the FAC Program Notebook and is controlled by the FAC Program Coordinator. The VY document system in place prior to becoming Entergy only assigned formal numbers to calculations. No system was in place to number or catalog "reports" other than though incorporation into the program of job files.

Consequences The susceptibility review was performed for the plant piping in accordance with NSAC.202L is an internal program document and is controlled by the FAC Program owner. Since the document.is not in the formal records management system the possibility of obsolescence or loss with personnel turnover exists.

Recommendation An update to the FAG susceptibility evaluation is currently on the EWC schedule. The revision will be performed and documented using ENN procedure No. ENN-DC-147,."Engineering Reports.". All new program reports and other documents which are not classified as calculations will be incorporated into the RIMS using ENN-DC-147. No new condition report is

-required.

AFI2.2-3 Page 33 of 43 NEC038494

ENVY Design Engineering Self Assessment: LO-VTYLO72003-00327 A review of program documents including PP. 7028, the FAC Susceptibility Evaluation, the Small Bore Piping Database, and updates to the CHECWORKS models shows that updates have not been performed in timely manner. Some.activities were informally performed with significant time elapsed without a formal revision.

Consequences Planned updates to the susceptibility report and the small bore database report only result in not formally documenting piping replacements performed since the last update. There is no adverse affects to the plant susceptibility, only on the timeliness of document updates. Timely updates to the CHECWORKS models are good practice. Given low wear rates from recent outage inspection data and nearly constant plant operating conditions, there is no immediate need for model updates. However operation under HWC and the planned power uprate warrant model revisions.

Recommendation

-An update to the FAC susceptibility evaluation, small bore data base, and the CHECWORKS models is currently on the EWC schedule. However, based on the amount of EPU related work, which has resulted in deferring completion of planned program activities, additional monitoring may be required. A separate Snapshot Assessment should be performed insure that these planned program activities were actually performed in a timely manner. The results of the assessment may identify the need to revise/improve existing scheduling/resources & trend performance.

Condition Report: LO-VTYLO-2003-00327 CA2 AF12.2-4 There is no formal method for Operations Dept to communicate changes in operating conditions, off-normal or abnormal system lineups to the FAC Program for assessment.

Consequences Changes in operating conditions, off-normal or abnormal system lineups, component leakage or operating experience are communicated, can affect FAC wear rates in piping and components.. Information on off normal conditions is currently obtained through a review of site procedures, system health -reports, thermal peorfrmance monitoring reports, Condition Reports, and site and industry operating experience. These tools assist in scoping lines for inspection or

• incorporating in the susceptible report. However the link with operations needs to be strengthened.

Recommendation Page 34 of 43 NEC038495

ENVY Design Engineering Self Assessment: LO-VTYLO-200.3-00327 Develop formal method or protocol for. Operations Dept to communicate.

."' .- 'Y'

.Condition Report: LO-VTYLO-2003-00327 CA3 Objective 2.3 - Documentation- Ensure that FAC Documentation is in compliance with industry standards and that it is maintained in accordance with established processes and procedures.

Conclusion The FAC program procedure, PP 7028, and department procedure DP 0072, for Structural Evaluation of Thinned Wall Piping Components, and several component evaluations were reviewed. The documents were prepared by the FAG engineer and reviewed by the backup FAC engineer. NDE reports are reviewed and checked by a Level III examiner as well as by the FAG engineer.. The program procedure and supporting procedures are consistent with NSAC 202L guidelines.

• i* ..T inisu...............................

dae. h u d i c u e n ......... to l ..............

p a e t th.. .. r ........

c d r ...... ~pe r tev o c n ntti..........

L- -ýq-0068s~ r-ei' SThis update should include not-only update to the procedure content per the commitments as but also update and formalize the FAG isometric drawings which are part of the program procedure. AFI2.3-1

• e~l i~t* &9.e~

t* ~riti~*.*The gridding procedure has resided in. the UT procedure (NE-8053) until recently, when NE-8053 was made obsolete by ENN-NDE-9.05 rev 0. This is not only an issue for VY but also for other ENN FAC programs. The new NDE procedure does not include FAC gridding guidelines that were once a part of the VY site procedure. The gridding procedure will be relocated into an Appendix in the FAC Program procedure. neE-1thb*f I n--lce, VY has not adopted the new ENN procedure'for wall thinning evaluations, ENN-DC-133 for their FAG program. Adoption of the new ENN procedure for VY is TBD. At this time VY still uses its plant specific procedure for evaluating wall thinning (DP 0072). Modification of DP0072 and conversion to ENN-DC-1 33 for wall thinning evaluations is required. AFI2.3-2.

buJR jb~~cr An update of the small bore database is currently in the EWC schedule. See AFI 2.2-1. For large bore components, information and all inspection data to date has been included in the CHEGWORKS database. At this time CHECWORKS is considered the main component database for large bore components.

Refueling Outage Inspection Reports for the last three refueling outages have been issued within 90 days of startup. The reports summarize the inspection activities performed, the goals that were planned and accomplished, and the inspection results. The reports also

'Page 35 013.5 NEC038496

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 include recommendations for future replacements or repairs and future required monitoring.

The reports are prepared by the FAC engineer and independently reviewed and signed.

FAC large bore piping component location sketches are located in Appendix A of PP 7028.

The sketches identify the lines and components included in the CHECWORKS database and predictive models. Information on the component location sketches is consistent with the CHECKWORKS model and the component numbering system. The sketches reference P&IDs and pipe drawings used to develop drawings, but the FAC sketches can only be updated as a procedure update since they are part of the FAC program procedure.

The component location sketches are not included in the plant drawing list-and are not controlled through configuration management. Specific sketches have not been updated to reflect recent material replacements. Revisions to the sketches are not controlled using the same configuration management same process as for P&IDs or plant piping drawings. It is recommended that the FAC component location sketches be updated, removed from the procedure. converted into plant drawings, and placed under configuration management control. This will ensure that they reflect current plant configuration including material changes. AFI 2.3-1.

Areas for improvement AFI2.3-1 The FAC Component Location Sketches are contained in Appendix A of PP 7028. The practice at other ENN plants is that the "FAC Isometrics' are separate controlled drawings.

Updating the FAG component location sketches, removing them from the procedure, and converting them into plant drawings placed under configuration management control will ensure that they reflect current plant configuration including material changes. A similar condition existed at VY for the plant fire barrier ketches. These were converted to VY plant drawings (8-191500 series).. ENN FAG Program standardizatiop will require converting the existing FAC Component Location Sketches to VY controlled drawings.

Consequences The component location sketches are not included in the plant draWing list and are not controlled 'through configuration management.. Specific sketches'are marked up pending a change to-the Program Procedure. Since the document is not in the formal records management system the possibility of using outdated information with loss or personnel turnover exists.

Recommendation Update the FAC component location sketches to incorporate recent piping changes, remove them from the procedure, and convert them into plant drawings.

This will ensure that they reflect current plant configuration inclUding material changes. (Note: This is not atrivial effort. The electronic files are onan obsolete format.. A previous -effort with J. Fortierwas made, with little success. Need to explore options Icosts etc.)

qtib6 Ra p;QO32of 43 Page 36 of 43 NEC038497

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 AFI2.3-2 VY has not adopted the new ENN procedure for wall thinning evaluations, ENN-DC-133 for their FAC program. Adoption of the new ENN procedure for VY is TBD. At this time VY still uses its plant specific procedure for evaluating wall thinning (DP 0072). There are

.incompatibilities and different focus area in these procedures. Modification'of DP0072 and conversion to ENN-DC-133 for wall thinning evaluations is required for fleet standardization.

Consequences There is no choice. VY will use ENN standard procedures. Technical concerns with use of ENN-DC-133 must be resolved.

Recommendation Resolve technical issues with use of ENN-DC-133 inits currentform and support procedure revision to be consistent with requirements from the new ENN FAC Program Procedure, ENN-DC-315.

Obiective 2.4- Model Verification and Review- Ensure that FAC predictive computer model used (such as CHECWORKS) is verified, reviewed and maintained in accordance to the plant's FAC Program procedures.

Conclusion

- CHECWORKS models and wear rate analyses for large bore systems are used at Vermont Yankee. A complete revision t*oall plant models was performed in 1996. These were prepared in-house and reviewed by FAC coordinator. 'Se.ý'.1 o

• Outage insPection plans consider both CHECWORKS Pass 1 & Pass 2 results for selecting components for inspection.

The CHECWORKS database has been updated with current operating hours (up to cycle 29) and heat balance parameters are current. All inspection data to date has been imported into the CHECWORKS database. There have been no significant chemistry changes performed at VY to date. The FAC coordinator is aware of future plant plans such as starting HWC and power uprate and will update CHECWORKS according when these plans are implemented.

• A review of the CHECWORKS models for two lines was performed. The models included all piping components, contained the correct component identifiers, and reflected the correct geometry. All component information was found to be correct and verified by the heat balance and flow diagrams.

Areas for Improvement AFI2.4-1 Updates to the CHECWORKS models should be formally updated and reviewed.

. Page 37 of 43 NEC038498

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 Consequences The evaluations are not considered as formal plant calculations based on. the classification of the EPRI software. CHECWORKS is used as an inspection planning tool.

The results are statistically based and do (did) not fit the attributes required for calculations underAP 0017. The.current CHECWORKS evaluations are internal program documents. The VY document system in place prior to becoming Entergy only assigned formal numbers to calculations. No system was in place to number or catalog "reports" otherthan though incorporation into the program ofjob files. Since the model updates are not in the formal records management system the possibility of obsolescence or loss with personnel turnover exists..

Recommendation With adoption of ENN-DC-147 "Engineering Reports" and "ENN-DC-126" formal mechanisms is now available to perform, review and document the CHECWORKS model input and analysis updates. Review all program generated documents and incorporate them into RIMS.per ENN-DC-126 or ENN-DC-147 as appropriate.

Obiective 2.5 -Inspection Planning - Ensure that FAC examination locations are selected in accordance with the site procedures and industry practices.

Conclusion Program procedure PP 7028 Section 4.4.1 specifies the process for selecting components and Appendix E of PP 7028 defines the criteria for selection of components for inspection.

This approach used is consistent with NSAC 202L R2 guidelines.

CHECWORKS Pass 1 analysis, output is only used to exclude lines from the inspection selection process in terms of susceptible or not susceptible. Generally most of the inspection selections from the CHECWORKS output are from the Pass 2 analysis output This is

.consistent with .the NSAC 202L approach. However, CHECWORKS model updates to include recent inspection data have not been performed. See AFI 2.4-1.

The selection of inspection locations effectively considers known industry issues with piping downstream of flow control valves, turbine cross around piping, dissimilar metal connections.

Examination locations consider input from other plant departments such as System Engineering (thermal performance monitoring), Chemistry, and the Operating Experience Coordinator.

The selection of components for inspection during a refueling outage is documented on worksheets titled "Inspection Location Worksheets/Methods and Reasons for Component Selection". These worksheets provide a rigorous and thorough method to aid in the identification and selection of components for inspection. The worksheets include all the selection criteria necessary for a thorough review.of small bore, large bore, feedwater heater shells, and cross-around, piping. The worksheets address inspections based on previous inspection results, CHECWORKS evaluations, CHECWORKS model calibration, OE, off.

normal flow conditions,, malfunctioning equipment such as leaking valves, and engineering judgment. The worksheets are prepared by the program owner and reviewed by the backup FAC program Engineer. -Components identified in the worksheets are compiled in the Page 38 of 43 NEC038499

ENVY Design Enginee-ing SelfAssessment: LO-VTYLO-2003-00327 Refueling Outage Scoping memo to Program Owners supervisor. The worksheets used to select inspections should be considered program strength. STR 2.5-1 It presents a thorough documented approach to inspection selection incorporating all the criteria in NSAC-202L, and site specific issues.

• Areasfor Improvement None identified for Objective 2.5 Strengths STIR 2.5-1 The worksheets used to select inspections should be considered a program strength. The

• worksheets present a thorough, rigorous, documented approach to inspection selection incorporating all the criteria in NSAC-202L, and site specific issues.

Objective 2.6 - Performing Inspections - Ensure that FAC Examinations are performed in accordance with the site procedures and FAC Program documents and that they are consistent with industry standards.

Conclusion A review of program procedure PP 7028 and the applicable NDE procedures for Level III supervision and compliance responsibilities was performed. The procedure specific instructions and guidance for performing FAC inspections are consistent with NSAC 202L Rev.2.

There is an issue related to the ENN .transition. The gridding procedure has resided in the VY site LIT procedure NE-8053. NE-8053 was made obsolete. by ENN-NDE-9.05 rev 0. This is not only an issue forVY but also for other ENN FAC programs. The new NDE procedure.

does not include FAC gridding guidelines thatwere once a part of the VY-site procedure. The gridding procedure will be relocated into an Appendix in the FAC Program procedure.

EXisting commitment No. LQ-vrVLO-2003-00528 is in place to relocate the component"

• gridding guidelines.

Several component inspection reports were reviewed and it was concluded that the gridding convention used (size & extent) is consistent with the requirements of NSAC 202L Rev.2 and industry standards.

Certification ! qualification records for two FAC inspectors were reviewed and it was

-J determined that the processing and review of the technicians qualification and certification records were conducted and accepted in accordance with plant protocol.

Data sheets were reviewed for evidence that repeat.inspection of suspect readings is performed. Two inspections from the 2001 refueling outage demonstrated questioning of the data. One was at a counter-bore and the other at a suspect reading lower than the surrounding area. The documentation showed both readings were re-taken and new measurements replaced the previous ones.

Page 39 of 43 NEC038500

ENVY Design Engineering SelfAssessment: LO-VTYLO-2003-00327 Program procedure PP 7028 was reviewed with particularreference to Sections 4.4.1.3 and 6.3 which require formal record retention. Interviewed FAC program owner for compliance and determined inspection records are retained in accordance with PP 7028.

Areas for Improvement None identified for Objective 2.6 Objective 2.7 Data Evaluation - Determine if the process for collecting, evaluating, analyzing and trending data is effective and is performed in accordance with established standards.

Conclusion The FAC program document, PP 7028 rev 1, refers to DP 0072 for.evaluating components.

Component evaluations are performed in accordance with plant procedure DP 0072, "Structural Evaluation of Thinned wail piping components. At this time, VY is not required to perform evaluations based. on ENN-DC-1 33. Component evaluations are also consistent with industry.procedure NSAC-202L R2.

DP 0072 is used to evaluate components for continued service or replacement and outlines a formal process to.perform evaluations. Evaluations are not considered calculations but they are reviewed and signed by an independent reviewer and are permanently stored by records for plant lifetime. Safety class piping and components under ASME section X1 requirements are dispositioned in accordance with DP 4027.

The 2000 Refueling Outage Report was reviewed for examples of component evaluations, specifically inspection No. 2000-04. The completed acceptance evaluation includes the component disposition, NDE reports, and structural evaluation which is documented on a Component Evaluation Worksheet. uT data is reviewed, by Level III examiner and signed.

The evaluations are independently reviewed. All worksheets are stored in records for plant lifetime. DP 0072 provides a formalized process, which includes criteria and data sheets, and the appropriate safety factors. It is found to be adequate for dispositioning components for continued service or replacement.

Areas for Improvement None identified for Objective 2.7 Obiective 2.8 - Performing Repairs- Ensure that FAC Repairs/Replacements are performed in accordance with established processes, procedures and applicable codes.

Conclusion Formal procedures exist for repair/replacement. Safety class ASME section XI components are evaluated and dispositioned under DP 4027, and component repairs / replacements are performed underAP 0070. Non-safety repairslreplacements would be controlled via maintenance work orders for like-for-like replacements.- For upgraded material replacements, an engineering recommendation, followed by an equivalency evaluation and either a WOSE Minor Mod per AP 0020 or a design change perAP 6008 is required to implement the replacement. AP 0070 "ASME Section XA Repair and Replacement Procedure" provides a Page 40 of 43 NEC038501

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00.327 formal process, that is consistent with the requirements of ASME Section.XI and NSAC-202L-

.. R2.

All external weld repairs are considered temporary, are performed using approved procedures, and require approval from the ANII. These are either permanently repaired or replaced during the next opportune time or refueling outage. External repairs to Safety Class Piping would require a relief and would be performed under the requirements of AP 0070, "ASME Section XI Repair and Replacement Procedure". To date no external repairs to Safety Class piping due to FAG related damage have been performed at VY.

Internal weld repairs on non Safety Class piping are considered permanent, are performed using approved procedures, and require approval from the ANII. Internal weld repairs to Safety Class Piping are performed under the requirements of AP 0070, "ASME Section XI Repair and Replacement Procedure" using approved welders and. welding

• procedures This is consistent with ASME Section XI and NSAC-202L-R2 guidelines.

Equivalency evaluations, engineering recommendations, and mod packages for material

..upgrades due to FAC are reviewed and approved prior to installation in the plant.

Replacement of FAC susceptible systems with Cr-Mo (P11 or P22) is common knowledge plant-wide and is not stated in FAC program procedure. All material changes are shown on system P&IDs. PP 7028 does not identify a specific process or procedure to be used when making a material upgrade. After the FAC engineer determines that a material upgrade is required, the Design Engineering Group performs the required evaluations and

-develops the modification packages using the standard design processes provided by AP 0020, and AP 6008.

Areas for Improvement None identified for Objective 2.8 Objective 2.9 -Long Term Strategy- Determine if the FAC Program has a long-term

• ! strategy that Is consistent with the guidance .provided in EPRI guideline NSAC-202L-R2, "Recommendations for an Effective FAC Program".

Conclusion VY is a BWR which has limited chemistry options for reducing FAC. The most effective long term method for reducing FAC wear is replacements with FAC resistant materials, VY has been vigilant on replacing susceptible systems with FAC resistant materials in order to reduce FAC long term. Areas that have been replaced include Moisture Separator Drain lines downstream of level control valves, feedwater flush and pump bypass lines downstream of normally closed valves on piping leading to the condenser, turbine cross around piping, small bore steam drain lines to the condenser, both LP turbine casings, all LP feedwater heaters.

Other systems and such as feedwater heater vents and the HP feedwater heaters are planned for replacement with FAC resistant material due to the 20% power uprate. These replacement efforts are the primary focus on reducing wear rates at VY and are consistent with NSAG-202L guidelines.

The FAC coordinator is aware of future plant plans such as starting HWC and power uprate and will update the CHECWORKS predictive models as these plans are implemented. Since.

VY is a BWR, there is very little that can be done to reduce FAC wear rats through water eP i ~Page 41 of 43 NEC038502

ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327 chemistry changes. &hit}d~r 00 t~

The FAC program documentation was reviewed to ensure there is a process in place for informing FAC engineer of system changes that may effect FAC susceptible systems and that the effects of these changes. to FAC are considered by appropriate department prior to making modifications to FAC susceptible systems and to ensure that replacements performed under the .FAC program are communicated to system engineering (as well as other related departments) and appropriate drawings are updated with new material changes. Since the VY FAC Coordinator is part of the Design Engineering Group, he has direct access to information on system changes such as modifications and replacements being developed that may affect FAC susceptible systems. This is considered a strength of the program. STR 2.9-1 VY does not have a planned replacement goal for the next three to five years. Replacements have been based on current need. Also many piping systems which would have been found to be highly susceptible to FAC were originally design with resistant materials or have already been replaced with FAC Resistant materials. VY has made a conscious effort to replace piping systems and components that are susceptible with FAC resistant materials.

The ongoing effort of replacing systems with FAC resistant materials has reduced the amount of inspections performed during refueling outages. On average the number of inspections performed is around 20 to.30 piping components which is far below the average of typical plants. This is-seen as.a program strength. STR 2.9-2.

Areas for Improvement None identified for Objective 2.9 Strengths STR 2.9-1 The VY FAC Program Coordinator and the backup engineer are part of the Design Engineering Group: They have direct access to information on system changes such

• as modifications and replacements being developed that may affect FAC susceptible systems.

STR 2.9-2 The ongoing efforts of replacing piping with FAC resistant materials, has allowed a reduction in the number of inspections required to be performed during refueling outages. On average, around 20 to 30 piping components are inspected per refueling outage. This is less than the typical number of inspections performed for similar plants..

Page 42 0143 NEC038503

4 ENVY Design Engineering Self Assessment: LO-VTYLO-2003-00327

5.0 REFERENCES

. ENW Commitment LO-VTYLO-2003-00327 (VY AP0028 No. OPW-2003-0161_01),

Conduct a Focused Self-Assessment of.ENW Piping FAC Inspection Program, PP 7028.

. ENW Self Assessment No. OPW-2003-0145_01 Assessment Planning Worksheet

. INPO "Principles for Self-Assessment and Corrective Action Programs", December 1999

. EPRI'NSAC-202L-R2, "Recommendations for an Effective Flow-Accelerated Corrosion Program", Final Report, April 1999.

. INPO 97-002, "Performance Objectives and Criteria for Operating Nuclear Generating Stations" INPO 03-004 (Preliminary) "Performance Objectives and Criteria"

• EPRI CHUG White Paper No.3, "A Summary of Tasks and Resources Required to Implement an Effective FAC Program", February 1999.USNRC Inspection Manual-Inspection Procedure 49001

• EPRI/Altran Report No. 95217-TR-01 Rev.O, "Guideline for Interviewing Plant Personnel within a FAC Program", August 1996.

ENN-Ll-104 Rev.4 , "Self Assessment & Benchmarking Process" Vermont Yankee Program ProcedureaPP 7028, "Piping FAC Inspection Program"

• Vermont Yankee Department .Procedure DP 0072 "Structural Evaluation of Thinned Wall Piping Components"

. EPRI CHECWORKS Computer Program Users Guide TR-03496

. EPRI CHECWORKS "FAC Application Guidelines for Plant Modeling and Interpretation of Inspection Data", Draft Report, February 1997.

ENN-DC-133 "Structural Evaluation of Wall Thinning in Carbon and Low Alloy Steel Piping" 6.0 TEAM MEMBERS Team Leader: James Fitzpatrick* V.Y. FAC Program Coordinator Team Member: Hazel Pearsall I[P.2 FAC Program Coordinator Team Member: Harry Hartjen I.P.3 FAC Program Coordinator Team Member: Ian Mew J.A.F. FAC Program Coordinator Team Member: Gerald Bechen Pilgrim FAC Program Coordinator Team Member: John Moriarty*- C.A.&A (VY)**

• The Team Leader completed the Team Leader Checklist on completed 8/5103.

' CA&A representative reviewed then Assessment Plan ,but was called to military duty prior to the assessment.

Page 43 of 43 NEC038504