ML102070412
| ML102070412 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/03/2010 |
| From: | Robert Kuntz License Renewal Projects Branch 2 |
| To: | Michael Colomb Entergy Nuclear Operations |
| Robert Kuntz, 415-3733 DLR/NRR | |
| References | |
| TAC MC9668 | |
| Download: ML102070412 (26) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 3, 2010 Mr. Michael Colomb Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station 185 Old Ferry Road P.O. Box 500 Brattleboro, VT 05302-0500
SUBJECT:
AUDIT REPORT REGARDING THE VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MC9668)
Dear Mr. Colomb:
By letter dated January 25,2006, Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the Operating License DPR-28 for the Vermont Yankee Nuclear Power Station for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). On May 27,2010, the NRC audit team completed the on-site audit to independently verify, on a sampling basis, that information provided by Entergy material to the renewal of the Vermont Yankee Nuclear Power Station (VYNPS) operating license was complete and accurate. The audit report is enclosed.
If you have any questions, please contact Robert Kuntz at 301-415-3733 or bye-mail at robert.kuntz@nrc.gov.
Ro ert F untz, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulations Docket No. 50-271
Enclosures:
As stated cc w/encls: Distribution via Listserv
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL Docket No:
050-271 License No:
DPR-28 Licensee:
Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc.
Facility:
Vermont Yankee Nuclear Power Station Location:
Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station 185 Old Ferry Road P.O. Box 500 Brattleboro, VT 05302-0500 Dates:
May 25,2010 May 27,2010 On-Site Reviewers:
D. Pelton, Branch Chief, Division of License Renewal (DLR)
W. Holston, Senior Mechanical Engineer, DLR D. Brittner, Mechanical Engineer, DLR T. Bums, Inspector, Region I Support:
R. Kuntz, Senior Project Manager, DLR G. Casto, Branch Chief, Division of Safety Systems B. Brady, Senior Project Manager, DLR B. Lehman, Structural Engineer, DLR Q. Gan, Project Engineer, DLR Approved By:
David Pelton, Chief Aging Management of Plant Systems Division of License Renewal Office of Nuclear Reactor Regulation David Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation ENCLOSURE
Division of License Renewal Audit Supporting the Agency Response to the Vermont Yankee Nuclear Power Station Demand for Information 1.0 Audit Objective The objective of this audit was to independently verify, on a sampling basis, that information provided by Entergy material to the renewal of the Vermont Yankee Nuclear Power Station (VYNPS) operating license was complete and accurate. The staff reviewed a variety of the license renewal activities performed by Entergy Nuclear Operations, Inc. (Entergy) (e.g.,
scoping, aging management reviews, development of aging management programs) covering a broad range of structures, systems, and components (SSCs). These reviews were performed both in-office at NRC Headquarters and on-site at VYNPS.
2.0 Audit Methodology 2.1 In-Office Audit Activities 2.1.1 Review of VYNPS License Renewal Related Documentation The staff reviewed a sample of the docketed information related to Entergy's license renewal application (LRA) for VYNPS to verify that the information provided was complete and accurate.
Examples of information reviewed included Entergy's responses to requests for information (RAls), LRA amendments, Entergy's responses to staff questions posed during the aging management program (AMP) audit, and relevant portions of Entergy statements contained in the VYNPS license renewal hearing files. The staff compared the information reviewed to the information Entergy originally provided in the LRA as well as to the requirements of 10 CFR Part 54, the VYNPS Technical Specifications, and the Updated Final Safety Analysis Report (UFSAR) to verify that the information was consistent and complete. The reviewed information was also compared to the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR)," and NUREG-1801, "Generic Aging Lessons Learned (GALL) Report." The staff concluded that the information reviewed was accurate and complete.
2.2 On-Site Audit Activities 2.2.1 Review of the scoping and screening processes used in the development of the VYNPS LRA The staff selected a random (statistical) sample of 82 plant mechanical, electrical, and structural components from the VYNPS Plant Equipment Database (see Table 1). Information regarding a component's system, function, tag number, location, name, etc., was extracted from the database for each selected component. The staff met with Entergy staff responsible for determining which systems and associated components were required to be subjected to an
-2 aging management review (AMR), in accordance with 10 CFR Part 54.4, and requested that they: 1) verify that sampled plant components determined to be within the scope of license renewal had been evaluated in the LRA and 2) provide a justification supporting any sampled plant components that were determined not to be within the scope of license renewal. The staff reviewed Entergy's conclusions, reviewed plant drawings, and performed plant walk-downs to independently verify that the information provided in the LRA was appropriate for each sampled component. The staff concluded that Entergy had appropriately scoped each of the sampled components as either being subject to or not subject to an AMR for license renewal.
2.2.1.1 Review to Determine if Plant Materials and Environments had been Appropriately Included and Evaluated in the VYNPS LRA The staff selected a statistical sample of 35 mechanical, electrical, and structural components from the AMR tables in the VYNPS LRA (see Table 2). The staff extracted information on the component's system, material, and environment from the LRA. The staff performed walk-downs of the accessible sampled components to verify the component's material and environment. If a sampled component was not accessible, the staff reviewed plant documentation including the UFSAR, plant system and design drawings, plant design specifications, plant system descriptions, and component vendor manuals to determine the component's material and environment. The staff concluded that the LRA information regarding the material and environment for the selected sample of components was complete and accurate.
2.2.1.2 Review to Verify that Entergy had Accurately Accounted for Buried and Underground Piping The staff reviewed the VYNPS yard piping drawings to independently identify buried and underground piping located on-site. The staff performed walk-downs of yard areas and conducted interviews with the buried piping program engineer. The staff also reviewed the results of system walk-downs previously performed by NRC inspectors during the performance of NRC Inspection Procedure (IP) 71002, "License Renewal Inspection," as documented in NRC Inspection Report 05000271/2007006, dated June 4,2007 (ADAMS Accession No. ML071550330). Additionally, the staff had the opportunity to observe exposed portions of buried piping that had been previously excavated by Entergy in conjunction with actions taken to investigate the cause of a leak from an underground portion of piping in the augmented off-gas (AOG) system. The staff compared the results of this review to a list of buried and underground piping Entergy had provided in preparation for this audit. The staff did not identify any discrepancies with Entergy's accounting of buried and underground piping.
2.2.1.3 Review to Verify that the VYNPS LRA Included and Accurately Described Systems within the Scope of License Renewal that Contained Buried and/or Underground Piping and that these Systems Credited Appropriate Aging Management Program(s)
-3 The staff reviewed the LRA to determine which systems or portions of systems Entergy described as 1) being within the scope of license renewal and 2) contained buried and/or underground piping. The staff compared these systems to the verified list of systems containing buried and/or underground piping, the scoping criteria in the SRP-LR and the GALL Report, as including buried and/or underground piping. The staff concluded that the LRA did include and accurately describe systems within the scope of license renewal that contained buried and/or underground piping. Table 3 contains a detailed listing of the systems reviewed that contained buried and underground piping.
The staff reviewed the LRA to identify the AMR line-items associated with each in-scope system that included buried and/or underground piping. The staff compared the AMP credited in the LRA for these line-items to that recommended for the associated line item in the GALL Report.
The staff determined that Entergy had appropriately applied AMP B.1.1, "Buried Piping Inspection Program," to the in-scope portion of systems containing buried piping and had appropriately applied AMP B.1.28, "System Walk-down Program," to the in-scope portion of systems containing underground piping.
Since the May 2008 issuance of NUREG-1907, "Safety Evaluation Report [SER] Related to the License Renewal of Vermont Yankee Nuclear Power Station," there have been a number of examples of industry operating experience (OE) involving corrosion and leakage of in-scope buried and underground piping. Also, VYNPS has recently experienced leakage from an underground portion of piping within the AOG system. While this leakage was not from a portion of the AOG system that is within the scope of license renewal, there are portions of in scope piping systems that are in a similar environment (i.e., contained in a vault or other structure where it is exposed to air and where access is limited). The staff concluded that Entergy should re-evaluate AMP B.1.1 to determine if the proposed aging management of similar in scope piping is adequate to manage the effects of aging given the industry and VYNPS-specific OE (the staff had been pursuing and will continue to pursue this issue generically with all license renewal applicants). Entergy management has agreed to perform this evaluation and, if necessary, supplement the VYNPS LRA to address this issue.
During its review, the staff noted that UFSAR Supplement A.2.1.32 associated with the System Walk-down Program does not state how aging effects will be managed for components that are inaccessible during both plant operations and refueling outages. Discussions with Entergy staff revealed that, in fact, some in-scope underground piping is in pipe chases or vaults where physical access to the external surfaces of the piping is not possible during any modes of operation. Both the GALL Report and the SRP-LR recommend that surfaces that are inaccessible or not readily visible during both plant operations and refueling outages will be inspected at intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation. The staff concluded that VYNPS LRA UFSAR Supplement A.2.1.32 may require clarification of the program requirements for the inspection of surfaces that are inaccessible or not readily visible during both plant operations and refueling outages. Entergy management has agreed, if necessary, to supplement the VYNPS LRA to address this issue.
-4 2.2.2 Generic License Renewal Items The aging management of neutron absorption material in spent fuel pools and ASME Code Class 1 small-bore piping are issues that have recently been receiving additional scrutiny by the staff to ensure programs implemented by applicants sufficiently address known aging effects.
While Entergy has proposed AMPs addressing neutron absorbing material in spent fuel pools and ASME Code Class 1 small-bore piping at VYNPS, because of recent operating experience, the staff is concerned that these programs may not be sufficient to ensure that aging effects are adequately managed. During the audit, the staff discussed these programs and staff concerns with Entergy staff and management.
The staff noted that the VYNPS Water Chemistry Control-BWR Program and One-Time Inspection Program are credited for managing the aging of Boral' used as a neutron absorbing material in the spent fuel pool. The staff is concerned that these programs do not fully address potential aging effects as discussed in License Renewal Interim Staff Guidance (LR-ISG) LR ISG-2009-01, "Staff Guidance Regarding Plant-Specific Aging Management Review and Aging Management Program for Spent Fuel Pool Neutron-Absorbing Material Other than Boraflex,"
issued May 4,2010. The staff requested that the applicant review the recommendations in LR ISG-2009-01 and provide a description of any changes made to existing programs to ensure the aging of Boral' is appropriately managed or provide a justification as to why these recommendations would not apply to VYNPS.
The staff also noted that in NUREG-1907 (Commitment 16), Entergy committed to using the One-Time Inspection Program to inspect ASME Code Class 1 small-bore piping systems. Since the issuance of NUREG-1907, additional operating experience has come to light that indicates that the performance of a volumetric examination of these systems, including associated socket welds, is necessary in order to detect internal surface cracking such that the condition can be monitored and/or corrected. The staff is concerned that the One-Time Inspection Program currently committed to by Entergy in NUREG-1907 may not be sufficient to detect the existence of internal surface cracking because the inspection methodology to be applied to various portions of these systems (e.g., external surface examination or volumetric examination) is not explicitly identified. The staff requested that the applicant provide a description of any changes made to the One-Time Inspection Program to ensure an appropriate inspection technique is applied to ASME Code Class 1 small-bore piping systems, including socket welds, in order to determine whether cracking is an issue.
Entergy management has agreed to supplement the VYNPS LRA to address these issues.
3.0 Conclusion Based on the results of the audit activities described above, the staff concluded that the information reviewed material to the renewal of the VYNPS operating license was complete and accurate. However, the staff also concluded that Entergy should re-evaluate the Buried Piping Inspection Program to determine if enhancements are warranted to account for lessons learned from industry and VYNPS-specific OE and should revise the LRA, as appropriate. Additionally, the staff concluded that Entergy may need to revise the VYNPS LRA to clarify System Walkdown Program requirements for the inspection of surfaces that are inaccessible or not
-5 readily visible during both plant operations and refueling outages. Entergy management has agreed to supplement the VYNPS LRA to address these issues.
Additionally, the staff concluded that Entergy should re-evaluate both the AMPs for neutron absorbing material used in the spent fuel pool and ASME Code Class 1 small-bore piping to ensure these programs sufficiently address known aging effects. Entergy management has agreed to supplement the VYNPS LRA to address these issues
Table 1 - Vermont Yankee Random Sample of Components Reviewed for Scoping and Screening During the Audit Random Equipment System CompOnent Function Plant InLR subject Basis for Scoping and Screening No..
10 Category Drawing Scope toAMR 258 10A-K68B Residual Heat Relay Active Y
N Active Removal (RHR) 349 10A-S6A RHR Switch Active Y
N Active 870 16A-S61C
, Primary Switch Active Y
N Active I containment isolation system (PCIS) y-1624 2F-AF 115 Meter Active N
Active kilo-volt (KVJ 1767 3-8-AD RHR Service Meter Active Y
N Active Water (SW)
. 1859 4-6-AD RHR Meter Active Y
N Active 2145 5R-EK 345KV Relay Active Y
N Active 2236 6F-GR 345KV Relay Active Y
N Active 2522 7F-AL 345KV Switch Active Y
N Active
'2899 ACD-116-101 Secondary Door Fire evaluated Y
Required for compliance with 10 CFR 50.48 Y
containment Barrier as bulk (SEC) commodity in AMC06.
c-:;:--
AK25-M-E-L 480 Alternate
--~
2991 Breaker Active Y
N Active 2709 Q.urrentJACL 3134 AOD-1-149-4
N Drywell cooling damper. Component does not ventilation, and 191238 (J perform a safety-function, does not support a system air conditioning 5): AMRM-intended function (HVAC) 19 3511 BUS-12-2HR 480!-~_ Cubicle None N
N Does not sueeort s~stem intended function.
'3889 CC-116-4 SEC Concentrator Active N
N Does not sueeort s~stem intended function.
4031 COB-HP-9 HVAC Pump None N
N Construction office building located near containment access building; does not support system intended function.
ENCLOSURE 2
Table 1 - Vermont Yankee Random Sample of Components Reviewed for Scoping and Screening During the Audit r:::
CT-2-8 Circulating Cooling Tower None N
N Cooling tower 2, Cells 1 and 2 are in scope and water (CW) subject to an AMR, however, Cell 8 is not safety related, has no intended function.
CWHO-6B CW Valve None Y
N hydraulic gate control equipment for circulating water is located in a prefabricated shed on top of the discharge structure, not safety related (SR) and cannot impact SR equipment; does not support system intended function.
5021 DCW-3A Diesel Valve pressure LRA-5920 Y
Y Generator boundary 4147
'5164-I-br::109-3 (DG)
Sam plying Indicator Active Y
N Active (SPL)
-N
~-
I 5541 DT-11 480AC Transformer Active Y
Active 5775 DW-1029 Obsolete Valve None 191176 N
N Equipment sheet 2 (OBS) 6010 EI-g.:8-38 4KV Meter Active Y
N Active 6530 F-3-136-10 Hydraulic Filter pressure Y
Y 23 Control Units boundary FE=1a9B~
~~HCU) 6907 Nuclear Boiler Element pressure Y
Y (NB) boundary
-~--
7897 FSL-52-1A Condensate Switch Active Y
Active Demineralizer (CD)
-y--r-:-: --
8040 FT-2-3-64K NB Transmitter Active N
Active 9029 HS-106D House heating Valve pressure Y
Y
:c-c--
Boiler (HB) boundary y-I---c 9315 HSCR-129E HB Valve pressure Y
boundary 9692 L-55 HVAC Damper None 191160 N
N Damper in instrument air compressor room; does not
-~
support system intended function.
10161 LP-1TB 208AC Panel Active Y
Active 10447 LSL-20-1 Radiological Switch Active Y
N Active Waster( RDW) 11201 MCC-7A-4K 480AC Cubicle Support Y
Y in-scope eqpt.
~-----
Table 1 - Vermont Yankee Random Sample of Components Reviewed for Scoping and Screening During the Audit
~:9:i-MCC-7C-7B 480AC Cubicle Support Y-'Y--
I in-scope 11670- ~MCt-OC-2A-eqpt.
---1-=-----\\--
1250C Cubicle Support Y
Y 4E in-scope eqpt.
f'r 11813 MLF-9 Support Lifting Fixture None N
System not in scope; plant equipment.
I Equipment 1--:f219:r-(SUPP)
N Located in new warehouse. Not SR and cannot f--, - ---
PAL-104-53 affect SR equipment 13088 Service Water Alarm Active Y
N Active
\\-----
f.---
(SW) 13557 PI-104-6A CW Indicator Active Y
N Active 14220 PIC-102-35B Condensate Controller Active Y
N Active 1445S (C)
Y--r-:--
POS-2-86A NB Switch Active N
Active
'146Sg-A1 PS-105-24B1 Service and Switch Active Y
N ACtIVe Instrument Air 14975 PS-79-0 Potable Water Tank 1------r -
Y Y
pressure (PW) boundary 15353 PW-164 PW Valve N
N Potable water to the administration building. Not SR f------
and cannot affect SR equipment 15730 RC-S3 HB Valve N
N Located at SBA-248, medical office. Not SR and cannot affect SR equipment 15821 RELAy-Building Building Shelter G191142 Y
Y Station black-out (SBO) function.
HOUSE (Sewage and System protection Components)
(BLO)
l-16719
- RWE~1A HVAC Fan None N
N Fan in radwaste building; does not support system
'17097 intended function.
-S-7'9-101F PW Strainer None N
N
,;,rot SR and cannot affect SR equipment; does not 1--:f7'239 19117~
support system intended function.
SB~16-19-103 Primary Valve pressure Y
Y Potential to affect safety related equipment-Containment boundary sheet 1 and structural support Atmospheric 2
Control (PCAC)
Table 1 - Vermont Yankee Random Sample of Components Reviewed for Seeping and Screening During the Audit
~1
-SL.:-123 SUPP Sling N
N Plant equipment 18606 80-3-122-26 HCU Valve pressure Y
Y 15 boundary
-- ~;
18840 SOV-OG-954 Advanced Off-Valve
-None N
N Not SR and cannot affect SR equipment; does not G~s(AOG) support system intended function_
19218 SR-70-7 Obsolete Equipment obsolete N
N Obsolete number.
1-----
(OBS) e.quipment
_ 19595 STA-2-184 Recirc Flow Actuator Active Y
N Active T9738 1A
_~ontrol (RR)
SW-113 HVAC Switch Active Y
N Active f.-- - -
OSEF-3
- ~---1--=
20258 TCV-C-25 OBS Equipment obsolete N
N Obsolete number.
~-c-equipment
~~O_ TE-1-149-52 PCAC Element Active Y
N Active 20493 TE-103-67 Plant Specific Element Active Y
N Active 4A-1 Note (103)
~-
TE~12-118 Retired 20636 Retired in Element None N
N F'lace (RIP)
~"f4e TI-16-19-42B PCAC Indicator Active Y
N Active 23889 V20-278 ROW Valve None N
N Not SR and cannot affect SR equipment. Located in the radwaste build ina 26765 V65-5E OBS Valve obsolete N
N Obsolete number.
equipment 29029 VT2-505 Instrument Air Valve None N
N
. Contains dry air and is not required for structural (IA) support. Not SR 29172 V72-591 IA Valve None N
N Contains dry air and is not required for structural support. Not SR 29407 V72-822A OG Valve pressure 191160 Y
y AMRM-13 boundary (015) 29550
\\/72-910B IA Valve no 191160 N
N Contains dry air and is not required for structural intended sheet 2 (1 support. Not SR function
- 7) for (a)(1),
(a)(2), or (a)(3 )
30305 V76-328 Fire Protection Valve pressure LRA Y
Y (FP) boundary 191163 (C5)
Table 1 - Vermont Yankee Random Sample of Components Reviewed for Scoping and Screening During the Audit 130682
\\/78-60B Fuel Oil (FO)
Valve pressure LRA Y
Y boundary 191162; sheet 2 (O N ---i-No,a plant system.
~9
- 9)
VY-1111 Health Rad Active N
Physicist/
Instrument Radiation protection
\\----------
(HP/RP)
N 31151
\\lY:2000-26 HP/RP Rad Active N
Not a plant system.
Instrument 31294 VY-2639 OBS Equipment obsolete N
N Obsolete.
equipment 31437
- VY-483 HP/RP Rad Active N
N Not a plant system.
Instrument
---~.---
31528 VY-5358 OBS Equipment obsolete N
N Obsolete.
equipment 31906 VY-L-2164 Movats and Movats test N
N Not plant system.
. Test equipment Equipment (M&TE)
--\\---;:-:-----
r 32660 V72-161 IA Valve None N
Contains dry air and is not required for structural support. Not SR
-Trolley 33038 M-260 SUPP spare N
N equipment 33415 VY-6582 OBS Gauge Active N
N Active 33701 FIS-OG-301A AOG Switch Active Y
N Active 33792 BP-RXB-4 BLD Panel EN, PB, Y
Y
'33935 SSR BRE-NW BLD Building N
N Building has no intended function for license renewal.
34078 V52:59A CD Valve None 191274 N
N Contains dry air and is not required for structural support. Not SR Turbine 34456 VBE-110-9A Detector Active Y
N Active Generator (TG)
I--
34690 TDR-104-1A SW Relay Active Y
N Active 34925 SW-381-8-2 345KV Switch Active Y
N Active 35067 PS-52-7B CD Switch Active Y
~
Active
Table 1 - Vermont Yankee Random Sample of Components Reviewed for Scoping and Screening During the Audit Table 1 Key:
Random No - Each item in the equipment database was assigned an identification number so that a random selection could be made by the NRC staff. The NRC staff selected 85 of these components by a random number generator.
Equipment 10 - The plant specific designation given to components by the applicant.
System - Abbreviated name of the system in which the component is located.
Component Category - The specific name given to a component describing its function.
Function - Entries to denote whether the component is active, obsolete or has no function related to license renewal.
Plant Drawing - The Plant drawings that contain the referenced component.
In LR Scope - Identifies whether the component is in scope for license renewal.
Subject to AMR -Identifies whether the component is subject to an AMR.
Basis for Scoping and Screening - The applicant's basis determining if the component is subject to an AMR.
Table 2 - Vermont Yankee Random Sample of Components Reviewed for Environments and Materials ISLseq NRC LRA Page LRA Table Grouping Component Intended Material Environment Other material Other Environment (random* seq No.
Type Function number) 931 254 3.3-92 3.3.2-05 Orifice Pressure Stainless Air - indoor None Treated Water boundary steel external (ext)
Air Indoor, Treated I
220 225 3.1-69 3.1.2-3 Piping and Pressure Stainh~SS-- treated water Carbon steel fittings >=4" boundary steel
> 270°F Water, Treated Water I NPS internal (int)
> 220 F
~~-
Air - indoor (ext)
I 1736 358 3.3-192 3.3.2-13-21 Valve body Pressure Carbon Raw water None boundary steel (int)
I
~--
1842 464 3.3-207 3.3.2-13-30 Heat Pressure Carbon Air - indoor None Treated Water exchanger boundary steel (ext)
. (shell) 434 133 3.2-49 3.2.2-4 Heat Heat transfer Copper Lube oil (ext)
None Treated water>
exchanger alloy >15%
140°F (ext), Treated (tubes)
Zn Water I
~
Air - indoor (ext) 334 3.3-188 3.3.2-13-19 Valve body Pressure Stainless Treated water None I
boundary steel (int) 1917 539
_._-f-, -
3.3-218 3.3.2-13-34 Tubing Pressure Stainless Raw water Copper alloy Condensation (ext)
I
[210-boLJl1dary steel (int)
<15%Zn 215 3.1-67 3.1.2-3 Piping and Pressure Carbon Air-indoor Stainless Steel. Treated water>
I fittings <4" boundary steel (ext) 270°F (int), Treated NPS Water I
673 377
'3.2--75 3.2.2-7 Piping Pressure Stainless Gas (int)
Carbon steel Air - indoor (ext),
i boundary steel Treated Water,
\\
Untreated Water 1612 234 3.3~1jS-3.3.2-13-14 Tubing Pressure Copper Fuel oil (int)
Stainless steel Air - indoor (ext)
I boundary alloy <15%
I Zn 2215 151 3.5.:aa 3.5.2-5 Vernon Dam Support for Carbon Exposed to None Exposed to weather, I
structural Criterion (a)(3) steel fluid Protected from I
r:
3 r--3.3~179
-- steel etluipment environment weather I
265 3.3.2-13-16 Filter Pressure Carbon Treated water Stainless steel Air - indoor (ext) i I hgusing boundary steel (int)
I 3.3-10~ ---.---.
1031 354 3.3.2-08 Filter Pressure Carbon Lube oil (int)
Stainless steel, Raw water (int)
I housing boundary steel 1
Air Indoor, Treated Water
> 140 OF I
Table 2 - Vermont Yankee Random Sample of Components Reviewed for Environments and Materials ISlseq NRC LRA Page lRATable Grouping Component Intended Material Environment Other material Other Environment (random seq No.
Type Function number) 2249 187 3.5-71 3.5.2-6 Conduit Support for Galvanized Protected None Protected from Criterion (a)(1),
steel from weather Weather (a)(2), and
( a)(3) equipment 922 245 3.3-91 3.3.2-05 Bolting Pressure
~----
Stainless Air ~ indoor Carbon steel None 866 189 3.3-84 3.3.2-04
- Pump casing boundary Pressure steel Carbon (ext)
Treated water None Air Indoor, Treated I
boundary steel_ > 140°F (int)
Water, Lube Oil 2125 60 3.5-55 3.5.2-1 Lubrite
-Support for Lubrite
-Protected None None sliding Criterion (a)( 1 )
from weather 1295--
618-~ 3.3-135 3.3.2-11
- sllpports Diaphragm equipment Pressure Stainless Air - indoor None Silicone, Treated I
2075 38-3.4-30r--" --
3.4.2-1 Tubing -
boundary Pressure steel Stainless (int)
Steam>
None Water Air indoor I
1444 66 3.3-153 3.3.2-13-05 Tubing boundary Pressure steel Copper 270°F (int)
Treated water None Air - indoor (ext)
I boundary alloy <15%
(int) 1628r--c -- -
250 3.3-177 3.3.2-13-15
r Piping
-~----
Pressure bound~1Y..
Zn Gray cast iron Raw water (int)
Carbon steel Air indoor, Air Outdoor I I i
459 160 161 3.2-52 3.2.2-4 Orifice Pressure boundary Stainless steel Treated water (int)
Carbon steel Treated water>
140°F (int), Lube Oil, I
-1637--~59 2140 80 3.3-177 3.5-58 3.3.2-13-15
~---- --
3.5.2-2 Valve body Exterior Flow control Pressure boundary Flood barrier Gray cast iron Concrete Air - outdoor (ext)
Exposed to Carbon steel None Air Indoor Air Indoor, Raw Water None I
I I
walls below
. elev 254' Pressure
. boundary weather I
Support for Criterion (a)(1)
'1867~ 489 3.3-210 3.3.2-13-31 Rupture Disk equipment Pressure Carbon Air - indoor None Steam> 270°F (int) -sg-58 3.2-39 3.2.2-1 Thermowell
!>oundary Pressure steel Stainless (ext)
Air - indoor Carbon steel Treated water>
I boundary steel (ext) 270°F (intl, Treated Water II
Table 2 - Vermont Yankee Random Sample of Components Reviewed for Environments and Materials ISL seq NRC LRAPage LRA Table Grouping Component Intended Material Environment Other material Other Environment (random seq No.
Type Function number) 226 231 3.1-70 3.1.2-3 Piping and Pressure Stainless Treated water Carbon steel Treated water>
fittings >=4" boundary steel
- (int)
_270°F (int), Air I
NPS Indoor, Treated water
> 220°F {int}
I t,
568 3.3-129 3.3.2-10 Heat Pressure Copper Condensation None Treated Water, Raw exchanger boundary alloy <15%
(ext)
Water, Freon, Steam I
~tubes}
Zn
> 220°F
_ 2224-
~-
Support for I
160 3.5-67 3.5.2-5 N2 tank Concrete Exposed to None None restraining Criterion (a)(2) weather wall equipment 997 3.3-100 3.3.2-07 Stainless Steel None 320 Bolting Pressure Carbon Air - indoor 642--r34 '3.2-=72
boundary steel
{extJ I
3.2.2-6 Filter Pressure Sfainless Air-indoor None None I
h()using boundary steel (ext)
I 468
-172 3.2-53 3.2.2-4 Piping Pressure Carbon Treated water Stainless steel Air Indoor, Air I
boundary steel
> 140°F (int)
Outdoor, Treated I
Water, Untreated Air, I I
Steam> 220°F, Lube I
Oil, Treated Water>
I 140°F 990 313 3.3-98 3.3.2-06 Valve body Pressure Carbon Air - indoor Copper alloy Fuei Oil, Air Outdoor, I boundary steel (ext)
>15%Zn, Treated Air I
Stainless Steel
'T752 374 3.3-194
- 3.3.2-13-22
-- Valve body Pressure Carbon Untreated Stainless steel Treated Water I
3.1-48
bounda...ry steel water (int) 86 89 3.1.2-1 Safe r:;- --
Stainless Treated water None Air Indoor Safe ends Pressure
- _Ends,
>=4" Recirc boundary steel
> 270°F (int)
_J I Thermal inlet (N1)
- ISleeves, Recirc outlet I I
__ L
- Flanges, (N2) and Caps
~
I
Table 2 - Vermont Yankee Random Sample of Components Reviewed for Environments and Materials Table 2 Key:
ISL seq (random number) - Number assigned by the applicant as an identifier for each AMR line item.
NRC seq - Number assigned by the NRC staff as an identifier for each AMR line item. The staff selected 35 of these components by a random number generator for review.
LRA page No. - LRA page number where the AMR line item can be found.
LRA Table - LRA table where the AMR line item can be found.
Grouping - The gathering of similar components to be treated as one for an AMR.
Component Type - Type of component for which the AMR is applicable.
Intended Function - The function of the component that puts it within the scope of license renewal. Criterion (a)(1), (a)(2), or (a)(3) refers to the subparagraphs of Section 54.4 of Title 10 of the Code of Federal Regulations.
Material-The material composition of the component.
Environment - The internal or external environment to which the component is subject.
Other Material-Other material composition for the same component type in the same LRA table.
Other Environment - Other environments, internally or externally, existing for this component type in the same LRA table.
Table 3 - Vermont Yankee Buried and Underground Piping Reviewed During the Audit VY~~C~~NRC VY In S
'n Buried s.ys.tem Input Input Chec.k. C.heCk S
SCct°~1 9 AMR Table Piping I c.om.ments t
BP UGP BP UGP cope e Ion In LRA
-nitrogen injection is via the CAD system. The buried pipe Primary portions of the PCAC system are the nitrogen backup lines to Containment (a)(1) the in plant nitrogen supply. The (a)(1) scope functions (e.g.,
Atmospheric Y
Y
.,(
.,(
()(2) 2.3.3.11 3.3.2-11 No. primary containment isolation, torus vent rupture disc, are Control a
accomplished inside primary and secondary containment. The (PCAC)
(a)(2) function is very spatial effects and thus not applicable to 1 - - - -
__I--
bc-=u:.:.,ri:.;:e.::.d...cp.,:.rip:.::e:.:.,._________________-;
Augmented Off Gas y
Y
.,(
.,(
(a)(2) 2.3.3.13 3.3.2-13-1 Circ. Water Y
.,(
(a)( 1)
(a)(2) 2.3.3.13 3.3.2-13-9 I-------+---__\\__ -- --+- ___ ---\\_--------1___
+
Circ. Water Priming piping Y
.,(
No Table 2.2-2 x
Fuel Oil y
y
"(1"(
2.3.3.6 I-----
.,(
Fire Protection y _\\--_---+___\\--__+-~_:_~~_;_~-41_2_._3._3_.8_-+1_3_.3_._2-8_
(a)(1)
.,(
y HVAC
( a)(2) 2.3.3.10 13.3.2-10
( a)(3)
No No The (a)(~) functions are accomplished in the main conde~ser and within the vent stack and thus not related to buned pipe.
The (a)(1) function is to support alternate cooling mode of operation and is associated with the safety-related cooling tower cell and fan and the cooling tower deep basin, none of I which is associated with buried piping.
x x
LRA Table 3.3.2-6 references the Buried Piping and System Walkdown Programs Yes 1L~A Table 3.3.2-8 references the Buried Piping Program No System to maintain negative pressure and process the air to the stack (e.g., RB, TB). Rad Waste and AOG tie into this system.
The (a)(1) functions are to provide primary containment pressure boundary, support secondary containment by isolating normal ventilation exhaust paths under accident conditions, HELB protection for RCIC and local fan coolers.
The (a)(2) function is spatial only. The (a)(3) function is related to the control room isolation function in an Appendix R event.
None of these are associated with buried piping.
x x
~en I~IrrBT;~f]-:.-'-...~____
Table 3 - Vermont Yankee Buried and Underground Piping Reviewed During the Audit VY VY NRC NRC In Scoping Buried System Input Input Check Check AMRTabie Piping Comments I
BP UGP BP UGP Scope Section In LRA The (a)(1) functions are to provide primary containment isolation and air to MSIVs. RB rail air lock inflatable seal. SRVs and over pressure protection for AOVs. Based on a review of AMRM-30, AMR of NSR and Components Affecting Safety (a)( 1 )
Related Structures. the (a)(2) function is spatial. The (a)(3)
Instrument Air Y
./
(a)(2) 2.3.3.7 3.3.2-7 No function is to provide instrument air to support the FP and SBO (a)(3) scenarios. Based on a review of yard drawings and walkdowns. the buried piping portion of IA provides air to non scope components (e.g.. intake structure. sewage treatment) from the plant and does not serve as a make-up source for the above. None of the LR functions are associated with buried piping.
0 John Deere Fuel Tanks Misc Y
( a)(3) 2.3.3.12 3.3.2-12 No Credited for lighting during (a)(3) related App R scenarios.
Buried J2iJ2ing l2ortion is associated with Fuel Oil covered above.
Off Gas Y
Y
./
./
Evaluated with AOG above C
The (a)(1) functions are to provide RHR system pressure boundary and support primary containment isolation. Based on Rad. Waste Y
Y
./
(a)(2) 2.3.3.13 3.3.2-13-32 No a review of AMRM-30. AMR of NSR and Components Affecting Safety Related Structures. the (a)(2) function is spatial. None of the LR functions are associated with buried piping.
Service Air Y
./
(a)(1) 2.3.3.7 3.3.2-7 No No buried pipe in scope, see discussion for Instrument Air.
Stand-by Gas Y
./
(a)(1) 2.3.2.6 3.2.2-6 Yes LRA Table 3.2.2-6 references the Buried Piping Program Treatment (a)(2)
~,
Storm Drains Y
Y
./
C )
No x
x x
Includes transformer moat drains Supp Y
0 No x
x x
Gas and diesel tank, refuels company vehicles
\\
(a)(1)
LRA Table 3.3.2-2 references the Buried Piping and System Service Water Y
Y
./ \\
./
~:~m 2.3.3.2 3.3.2-2 Yes Walkdown Programs
\\
,-...fL..,
V
\\?~.ft\\ ~;;J~
Table 3 - Vermont Yankee Buried and Underground Piping Reviewed During the Audit VY VY NRC NRC In Scoping Buried System Input Input Check Check AMRTable Piping Comments BP UGP BP UGP Scope Section In LRA Includes:
Yard Misc Y
./
No x
x x
- Septic
- Wells
- City Water
--- The (a)(1) function is to maintain the control room ventilation Heating Steam (a)(1)
No, system pressure boundary. Based on a review of AMRM-30, I
(HSCR) (HW)
Y
./
(a)(2) 2.3.3.10 3.3.2-13-18 vaulted AMR of NSR and Components Affecting Safety Related (HB)
(a)(3) only Structures, the (a)(2) function is spatial. The (a)(3) function is for App R control room envelope. LRA Table 3.3.2-13-18
--- references the System Walkdown ProQram (a)(1 )
No, HPCI Y
./
~:~~~~
2.3.2.4 3.2.2-4 vaulted LRA Table 3.2.2-4 references the System Walkdown Program only (a)(1 )
No, RCIC Y
./
(a)(2) 2.3.2.5 3.2.2-5 vaulted LRA Table 3.2.2-5 references the System Walkdown Program (a)(3) 0l'lly (a)(1 )
No, LRA Table 3.3.2-13-5 references the System Walkdown CRD Y
./
~:~~~~
2.3.1 3.3.2-13-5 vaulted only Program
~-
(a)(1)
No, Core Spray Y
./
(a)(2) 2.3.2.2 3.2.2-2 vaulted LRA Table 3..2.2-2 references the System Walkdown Program (a)(3) only Condensate (a)(1 )
No, LRA Table 3.3.2-13-27 references the System Walkdown Y
./
_~:~m 2.3.2.5 3.3.2-13-27 vaulted Transfer only' Program i-Demineralized No, LRA Table 3.3.2-13-12 references the System Walkdown Y
./
(a)(2) 2.3.3.13 3.3.2-13-12 vaulted Water only Program Fuel Pool Y
./
No x
x x
Vaulted portion is only a fill line that per LRA drawings is Cooling outside of scope.
(a)(1) function to provide over pressure protection of SR IA (a)(1 )
SVs. (a)(2) function is spatial.
Nitrogen Y
Y
./
./
2.3.3.7 3.3.2-13-24 No All in scope piping is stainless steel, for exposure to air, no (a)(2)
AMP or AERM. None of the LR functions are associated with buried piping.
Table 3 - Vermont Yankee Buried and Underground Piping Reviewed During the Audit Table 3 Key:
System - Entergy's name for the system.
VY Input BP & UGP - Systems identified by VYNPS with buried and underground piping.
NRC Check BP & UGP - NRC systems identified by NRC with buried and underground piping based on drawing review and yard walkdown.
In Scope - Determination in the LRA of whether the system is within the scope of license renewal. Entries in this column are the criteria under Section 54.4 of Title 10 of the Code of Federal Regulations (10 CFR 54.4) that put the system within the scope of license renewal.
Scoping Section - Section in the LRA where*the scoping of the system is discussed.
AMR Table - The table in the LRA that contains the AMR results for the system.
Burled Pipe in LRA - Do the AMR results presented in the LRA for the system contain component(s) exposed to an environment identified as soil or air (vaulted) as confirmed in licensee's yard area drawings?
Supplemental Information Related to the Division of License Renewal Audit of Vermont Yankee Meetings:
Entrance Meeting May 25, 2010 Exit Meeting May 27,2010 Key Entergy Management that Attended the Entrance and Exit Meetings:
Michael Colomb Site Vice-President Chris Wamser General Manager Norman Rademacher Director of Engineering Glen Lozier Director of Nuclear Safety Assessment Jim DeVincentis Licensing Manager Entergy Personnel Contacted During the Conduct of the Audit:
Gary Bailey Vermont Yankee Buried Piping and Tank Program Manager Julie Robinson License Renewal Project Staff James Di Vincentis Vermont Yankee Licensing Manager Richard Meister Vermont Yankee Licensing Staff List of Documents Reviewed:
Plant Drawings Site Plan for NW Leach Field and Force Main from Di ENCLOSURE 3
i Supplemental Information Related to the Division of License Renewal Audit of Vermont Yankee 15920-12894 Hydrogen Storage Site Plan Underground Utilities South Warehouse Area
. 5920-12894 Hydrogen Storage Site Plan Underground Utilities South
- 15 Warehouse Area 5920-12894 Hydrogen Line Plan and Profile and Underground Utilit~ Details 3
5920-12894 15 Warehouse Area 5920-12894 Hydrogen Storage Site Plan Underground Utilities South Hydrogen Storage Site Plan Details and Notes 154 5920-FS-307 Composite Underground West 1
5920-FS-307 2
5920-FS-307 Com~osite Undf?rground North Composite Underground East 3
5920-FS-307 Composite Underground South 4
Miscellaneous Plant Documents:
AMRM-30 Aging management review of NSR and 25 (Heating Boiler) 27 - 28 (Instrument Air) 32 - 33 (Rad Waste)
LRPD-11 I Components Affecting Safety Related Structures Review of Buried Pipe Related to VYNPS LRA Verification of Vermont Yankee Nuclear Power Station License Renewal Project Report (Program Basis Documents), Revision 3 EN-DC-178 System Walk-down Procedure AMC06 Vermont Yankee Bulk Commodity Listing Regulatory Documents:
10 CFR 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" NUREG-1907, "Safety Evaluation Report Related to License Renewal of Vermont Yankee Nuclear Power Station" NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" NUREG1801, "Generic Aging Lessons Learned (GALL) Report" Licensing Documents:
VYNPS Technical Specifications VYNPS Updated Final Safety Analysis Report
Supplemental Information Related to the Division of License Renewal Audit of Vermont Yankee Vermont Yankee License Renewal Hearing Files:
2006 Transcripts, Pleadings, Board Orders, Applicant Exhibits, Intervener Exhibits, Staff Exhibits, Applicant Pre-Filed Testimony, Intervener Pre-Filed Testimony, and Staff Pre-Filed Testimony 2007 Transcripts, Pleadings, Board Orders, Applicant Exhibits, Intervener Exhibits, Staff Exhibits, Applicant Pre-Filed Testimony, Intervener Pre-Filed Testimony, and Staff Pre-Filed Testimony 200S Transcripts, Pleadings, Board Orders, Applicant Exhibits, Intervener Exhibits, Staff Exhibits, Applicant Pre-Filed Testimony, Intervener Pre-Filed Testimony, and Staff Pre-Filed Testimony 2009 Transcripts, Pleadings, Board Orders, Applicant Exhibits, Intervener Exhibits, Staff Exhibits, Applicant Pre-Filed Testimony, Intervener Pre-Filed Testimony, and Staff Pre-Filed Testimony 2010 Transcripts, Pleadings, Board Orders, Applicant Exhibits, Intervener Exhibits, Staff Exhibits, Applicant Pre-Filed Testimony, Intervener Pre-Filed Testimony, and Staff Pre-Filed Testimony Vermont Yankee License Renewal Application (LRA) Amendment Submittal Letters I Appl.icant designated letter Number AmemdmentiAttachment Number, Letter Name I
Amendment S I BVY-06-076 i BVY 090 Amendment 15 Amendment 19 I BVY-06-097 Amendment 22 I BVY-06-100 Amendment 23, Attachment 6
- BVY-07-003 BVY-07-01S Amendment 26, Attachment 4 BVY-07-047 Amendment 27, Attachment 5 Amendment 31 BVY-07-066 r::
. BVY-07-076 Amendment 32 BVY-07-0S2 Amendment 33 BVY-OS-002 Amendment 34 I
. BVY -OS-OOS Amendment 35, Attachments1 and 2
.~
I BVY-OS-012 Amendment 36, Attachment 2 I
Response to NRC Letter Dated 2/2/10 I
' ML102070412 OFFICE PM:RPB2:DLR LA:DLR BC:RAPB:DLR OGC BC:RPB2:DLR PM:RPB2:DLR NAME RKuntz YEdmonds DPelton LSubin DWrona RKuntz DATE 0815/10 0815110 08111/10 08119/10 09/03/10 09/03/10 I
Letter to M. Colomb from R. Kuntz dated September 3,2010
SUBJECT:
AUDIT REPORT REGARDING THE VERMONT YANKEE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MC9668)
DISTRIBUTION:
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