ML113560064
| ML113560064 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 12/22/2011 |
| From: | Conte R Engineering Region 1 Branch 1 |
| To: | Wamser C Entergy Nuclear Operations |
| References | |
| IR-11-011 | |
| Download: ML113560064 (12) | |
See also: IR 05000271/2011011
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
December 22, 20lL
Mr. Christopher Wamser
Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear power Station
185 Old Ferry Road
P.O. Box 500
Brattleboro, VT 05302-0500
SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION
INSPECTION REPORT 0500027
- NRC INTEGRATED
1 t2ol 1 01 1
Dear Mr. Wamser:
on october 20,2011, the U.S. NuclearRegulatory Commission (NRC) completed
an inspection
at the Vermont Yankee Nuclear Power Staiion. the enctosed report documbnts the results of
the inspection, which were discussed on october 20, and December
z 2011, wrth you and other
members of your staff.
This inspection was an examination of activities under your renewed
operating license related to
the completion of commitments made during the renewed lic"nre
apptication f,rocess and
compliance with the conditions of your licenie. Under the renewed
operating license, entry into
the period of extended opelations is planned for March 22,2012. Th;
inap;tion
-witninwas directed
toward those activities and facilities accessible during the refueling
outate. these areas,
the inspection involved examination of selected proc6dur"s and representative
records,
observations of activities, and interviews with personnel.
on the basis of the samples selected for review, there were no findings identified
during this
inspection' We plan to continue to review Commitment Nos. 6, 12,aid
2s, along with your
process for commitment change management during future planned
license renewal team
inspections, prior to March 22.20112.
C. Wamser 2
tn accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading
Room).
Sincerely,
/Z,tr*J>M
Richard J. Conte, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No. 50-271
License No. DPR-28
Enclosure:
NRC lnspection Report 0500027 1 1201 101 1
cc w/enclosure: Distribution via ListServ
C. Wamser 2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading
Room).
Sincerely,
/RN
Richard J. Conte, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No. 50-271
License No. DPR-28
Enclosure:
NRC Inspection Report 05000271 1201 1011
cc w/enclosure: Distribution via ListServ
Distribution w/encl:
W. Dean, RA (RIORAMAIL RESOURCE)
D. Lew, DRA (RIORAMAIL RESOURCE)
D. Roberts, DRP (RIDRPMAIL RESOURCE)
D. Ayres, DRP (RIDRPMAIL RESOURCE)
C. Miller, DRS (RIDRSMAIL RESOURCE)
P. Wilson, DRS (RIDRSMAlL RESOURCE)
M. Franke, Rl OEDO
R. Bellamy, DRP
T. Setzer, DRP
E. Keighley, DRP
K. Dunham, DRP
S. Rich, DRP, Rl
A. Rancourt, DRP, OA
RidsNrrPMVermontYankee Resource
RidsNrrDorlLl 1 -1 Resource
ROPreportsResource@nrc.qov
SUNST Review complete: RJc (Reviewer's Initials) ADAMS ACCESSION NO': ML1 13560064
DOCUMENT NAME: G:\DRS\Engineering Branch 1\-- Meyer\W Lic Renewal\2o111206 05000271 2011011 VY 1P71003 Inspection Report'docx
After declaring this document "An Official Agency Record" it will be released to the Public.
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OFFICE RI/DRS
DATE 1219111 12112111
OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-271
License No.: DPR.28
Report No.: 0500027112011011
Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Vermont Yankee Nuclear Power Station
Location: Vernon, VT
Dates: October 17 - 20, and December 1, 2011
Inspectors: G. Meyer, Senior Reactor Inspector, Division of Reactor Safety
M. Modes, Senior Reactor Inspector, Division of Reactor Safety
Approved By: Richard J. Conte, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
-
lR 0500027112011011; 1011712011 121112011; Vermont Yankee Nuclear Power Station;
Review of License Renewal Activities.
The report covers a one week inspection of the implementation of license renewal activities
during the Vermont Yankee refueling outage. lt was performed by two region based
engineering inspectors under lnspection Procedure 71003.
Enclosure
RePort Details
4. oTHER ACTTVIilES (OA)
4042 Other - License RenewalActivities
On March 21,2011, NRC issued a renewed operating license for the facility, based on
review of the Vermont Yankee License RenewalApplication (LRA) submitted on
January 27 , 2006. ln March 2011, NRC issued Supplement 2 to NUREG 1907, "Safety
Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power
Station," which contained Appendix A, Commitment Listing, listing 55 commitments. The
applicant made the commitments to provide aging management programs to manage
aging effects on structures, systems, and components (SSC) prior to and during the
period of extended operation, as well as other information. The period of extended
operation begins on March 22,2012, upon expiration of the plant's original license term.
lnspection Scope (lP 71003)
This inspection was performed by two NRC Region I based inspectors to evaluate the
license renewal activities at the Vermont Yankee Nuclear Power Station in accordance
with Inspection Procedure (lP) 71003. The inspection was directed toward those
activities and facilities accessible during the refueling outage in order to determine if
license renewal commitments were being met.
b. Findinos and Observations
No findings were identified.
b. 1 In-plant Observations
The inspectors observed ongoing activities and inspected the general condition of SSCs
within the scope of license renewal. The inspectors performed reviews in the following
areas, as related to commitments and aging management programs (AMP):
o Drywell- Inservice Inspection (lSl) Program
. Service Water System - Commitment24 (System Walkdown Program)
. Reactor Building - Commitment 12 (Heat Exchanger Monitoring Program)
. Turbine Building - Commitmenl24 (System Walkdown Program)
. Cooling Tower - Commitments 21 and 23 (Cooling tower structural examinations)
. Yard - Commitment 1 (Offgas system buried piping 24'OG-5 and 16" OG-2)
. Yard - Commitment 54 (Standby gas treatment system buried piping 12'SGT-1)
. Advanced Offgas Building - Commitment 15 (Non-EQ Insulated Cables and
Connections Program)
The inspectors determined the general conditions to be satisfactory and the Entergy
activities to be in accordance with facility programs and procedures.
Enclosure
2
b.2 Commitments Reviewed
Commitment 6 - Computerized fatigue monitoring
In the March 2011 SER Supplement, Commitment 6 states, "A computerized monitoring
program (e.9., FatiguePro) will be used to directly determine cumulative fatigue usage
factors (CUF) for locations of interest."
The inspectors determined that Entergy had removed the use of FatiquePro as a part of
Commitment 6. Specifically, Entergy submitted the Vermont Yankee license renewal
application on January 27,2006, with an enhancement to the Fatigue Monitoring
Program, which stated that "A computerized monitoring program (e.9., FatiguePro) will
be used to directly determine CUFs for locations of interest." On March 30, 2007, NRC
issued "Safety Evaluation Report with Confirmatory ltems Related to the License
Renewal of Vermont Yankee Nuclear Power Station," which contained Appendix A,
Commitment Listing, in which Commitment 6 was recorded. Subsequent versions of the
Safety Evaluation Report (SER) as NUREG-1907 did not revise the commitment.
Entergy approved the removal of FatiguePro on January 6,2011. The renewed license
was issued March 21, 2011. In letter BVY 1 1-026 dated May 19, 2011, Entergy
informed NRC that Commitment 6 had been changed to be "Manual cycle counting will
be used to track and compare accumulated cycles against allowable values to determine
if cumulative usage factors are required to be updated." The inspectors noted that this
change, in essence, rescinded the commitment, as manualcycle counting had been the
existing method at the time of the application submittal and would not have necessitated
an enhancement and subsequent commitment. Also, the Entergy letter did not request
approval of the rescinding, as indicated by the statement that no action was required of
NRC.
The inspectors could not clearly determine whether Entergy had met the expectations of
the commitment change processes as specified in the license conditions of the renewed
Vermont Yankee license, NRC-endorsed NEI 99-04 "Guidelines for Managing NRC
Commitment Changes,' (ML003680088), and Entergy procedure EN-LI-1 1 0,
Commitment Management Program, Revision 4. The key concern is whether NEI 99-04
and EN-Ll-110 were consistent in pointing Entergy towards NRC notification versus NRC
approval in making changes to its commitments. The answer was not apparent in this
situation due to various possible interpretations of the two guidance documents,
particularly on how the commitment was considered during the staffs review and the
implementation timing of the commitment (scheduled for March 22,2012).
The inspectors noted that the significance of the above concerns was minimal in this
particular case. Manual cycle counting has represented an acceptable method in some
applications. The Pilgrim license renewal application, which was submitted concurrently
with the Vermont Yankee license renewal application, had used manual cycle counting,
and NRC issued the Pilgrim Safety Evaluation Report and supplements without a
commitment for fatigue monitoring. Other plants with renewed licenses have had
manual cycle counting. Also, Entergy chose to notify NRC in writing of the commitment
change.
Enclosure
3
In response to inspector questioning, Entergy wrote a condition report
(CR-HON-2011-1213) to address the commitment change guidance regarding NRC
notification vs. approval and disparities between the step-by-step form and a flowchart.
Further the renewed Vermont Yankee license includes a license condition (No. 3.P) that
requires Vermont Yankee to use the process stipulated in Title 10 of the Code of Federal
Regulations (10 CFR) 50.59 for changes to the updated final safety analysis report
(UFSAR) supplement submitted as part of a license renewal application pursuant to
10 CFR 54.21(d). 10 CFR 50.59 is required for any changes made to the information in
the UFSAR supplement if the changes are made in the supplement prior to the UFSAR
supplement being incorporated into the next UFSAR update. The UFSAR update is
scheduled in compliance with 10 CFR 50.71(e) without regard to the date the new
license is issued. Because Commitment 6 is not referenced in the information in the
UFSAR supplement, the license condition does not apply.
The inspectors determined that the revised Commitment 6 was being implemented. The
review of the May 19, 2011,letter is pending further NRC staff review.
Commitments 21 and 23 - Structural examinations of cooling tower
Commitment 21 states that "Guidance for performing structural examinations of wood to
identify loss of material, cracking, and change in material properties will be added to the
Structures Monitoring Program" by March 21,2012. Commitment 23 states that
"Guidance for performing structural examinations of PVC cooling tower fill to identify
cracking and change in material properties will be added to the Structures Monitoring
Program procedure" by March 21, 2012.
The inspectors reviewed the commitment completion review report, the structural
monitoring program procedure, and the cooling tower inspection procedure. In addition,
the inspectors inspected the general condition of the cooling towers and discussed the
most recent inspection records and repairs with the responsible engineer. The
inspectors reviewed condition reports from 2009, 2010, and 2011 related to identified
conditions and repairs for the cooling towers.
The inspector determined that Commitments 21 and 23 had been completed.
Commitment 25 - Cast Austenitic Stainless Steel Program
Commitment 25 states "lmplement the ThermalAging and Neutron lrradiation
Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in LRA
Section 8.1.29." Section 8.1.29 states the program will be "comparable to the program
described in NUREG-1801 Section Xl.M13." The applicable edition of NUREG-1801
(GALL Report) at the time of the application was Revision 1. In addition to addressing
critical elements of CASS aging, Section 8.1.29 states: "EPRI, the BWR Owners Group
and other industry groups are focused on reactor vessel internals to ensure a better
understanding of aging effects. Future Boiling Water Reactor Vessel Internals Project
(BWRVIP) reports, Electric Power Research Institute (EPRI) reports, and other industry
operating experience will provide additional bases for evaluations and inspections under
Enclosure
4
this program. This program will supplement reactor vessel internals inspections required
by the BWR Vessel Internals Program to assure that aging effects do not result in loss of
the intended functions of reactor vessel internals during the period of extended
operation."
The inspectors determined that in response to later guidance from the BWRVIP,
Entergy's revised program for: CASS aging management program was technically
acceptable. Specifically, after the details of the Vermont Yankee license renewal
application were established, the programmatic details of the thermal aging and neutron
irradiation embrittlement of cast austenitic stainless steelwere resolved and specified in
the Boiling Water Reactor Vessels lnternal Program (BWRVIP 234-2009). Section 6,7 of
the VIP states: "The inspection reco-mmendation given are based on the following
criteria: (1 ) fluence less than 3 x 10" nlcm', (2) adequate toughness (>. 255 kJ/m'), and
(3) applied stress (< Sksi). Entergy used BWRVIP 234-2009 as the method necessary to
manage the aging effect of thermal aging and neutron irradiation embrittlement of cast
austenitic stainless steelwithin procedures and specifications in the CASS aging
management program. Using the BWRVIP 234-2009 thresholds, all of Vermont
Yankee's CASS components that were within the scope of the original application were
below the stress threshold of the VIP procedure. Thus the components screened out of
the aging management program and needed no inspection.
However, the inspector noted a contradiction between the current program and what
Entergy had submitted in the application, including Commitment 25. More specifically,
the inspectors determined that use of the BWRVIP 234-2009 contradicted the
application, because GALL Report, Section Xl.M13, Revision 1 , stipulates the threshold
for inspection be established based on a single criterion of fluence > 10 n/cm2 (for
E > 1 MeV), which is three orders of magnitude, i.e., 1,000 times, lower than the
threshold used in BWRVIP 234-2009. lt should be noted that all of Vermont Yankee's
CASS components that were within the scope of the original application were below this
lower stress threshold also. The inspectors noted that GALL Report, Section Xl.M13,
Revision 2had established BWRVIP 234-2009 as an acceptable aging management
approach, but the inspectors also noted that an appropriate method of changing the
commitment had not come to completion using at least the commitment change process
based on NEI 99-04 (LO-LAR-2010-256). Also, in this case, the inspector observed that
the license condition 3.P that required the use of the 10 CFR 50.59 process for the
interim period between the issuance of the license and the extended period would have
applied to the changes to the commitment. On December 1,2011, the NRC staff
learned that Entergy had revised LO LAR 2010 0256 by Corrective Action No. CA-006;
and this change was made in order to implement the necessary corrective actions and
track the approval by the NRC, if needed, for the upgraded use of the VIP procedure in
their current program.
The inspectors determined that Commitment 25 and related change process will be
further reviewed in the next commitment inspection.
Enclosure
5
Commitment 12 - Heat Exchanger Monitoring Program
Commitment 12 provides that Entergy will "lmplement the Heat Exchanger Monitoring
Program as described in LRA Section 8.1.14' by March 21, 2012.
The inspectors reviewed the commitment completion review report, the heat exchanger
program procedure, and the heat exchanger monitoring procedure. In addition, the
inspectors inspected the general condition of the 1A and 1B motor generator lubricating
oil coolers (E-40-1A and E-40-18) and the turbine lubricating oil cooler (E-25-1A), which
were undergoing cleaning and inspection during the outage.
The inspectors determined that additional NRC review was appropriate on
Commitment 12 in general and Entergy corrective actions for any identified degradations
in particular during planned NRC inspections prior to the period of extended operations.
c. Summary
No findings were identified and general conditions in the plant areas observed were
satisfactory. The inspectors determined that Entergy actions on Commitments Nos. 23
and 25 were complete and met regulatory expectations as reflected in the staff's SER.
Additional NRC staff review is needed for the others noted in this report.
4OAO Exit Meetino
The inspectors presented the inspection results to Mr. Michael Colomb, then Site Vice
President; Mr. Steve Wamser, then Plant Manager; and other members of the staff on
October 20,2011. The inspectors confirmed that no proprietary material was examined
during the inspection.
On December 1, 2011, Mr. Richard Conte, NRC, led a discussion with Mr. Robert
Wanczyk, Manager of Licensing, and other Entergy staff on the observations related to
the commitment tracking process and how it was used for Commitment Nos. 6 and 25.
The results of this review were discussed under Commitment Nos. 6 and 25.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Colomb Site Vice President
N. Rademacher W engineering director
C. Wamser W general manager
B. Wanczyk W licensing manager
G. Thomas VY LR project manager
P. Guglielmino VY LR project implementation manager
J. Hoffman W LR team
D. Lach Entergy LR team
J. DeVincentis W licensing engineer
LIST OF ACRONYMS
AMP Aging Management Program
BWR Boiling Water Reactor
BWRVIP Boiling Water Reactor Vessel Internals Project
CASS Cast Austentic Stainless Steel
CR Condition Report
CUF Cumulative Fatigue Usage Factors
EPRI Electric Power Research Institute
EQ Environmental Qualification
GALL Generic Aging Lessons Learned
IP lnspection Procedure
tsl Inservice Inspection
LRA License Renewal Application
NEI Nuclear Energy Institute
RFO Refueling Outage
SER Safety Evaluation Report
SSC Structure, Systems, and Components
UFSAR Updated Final Safety Analysis Report
UT Ultrasonic Test
WO Work Order
General
W License Renewal Commitment and Program lmplementation, October 17,2011
Attachment
A-2
LIST OF DOCUMENTS REVIEWED
In-plant Observations
EN-DC-348, Non-EQ lnsulated Cables and Connections lnspection, Rev. 2
Commitment 6
EN-Ll-110 Rev. 4, Entergy Management Manual "Commitment Management Program"
Letter BVY 1 1-026, Entergy Vermont Yankee to NRC, Dated May 19, 2011
LRSICMS A-16774
LRSICMS A-16775
LRSICMS A.16776
LO-LAR-2101-00237
Commitment 12 (Heat Exchanqer Monitorinq Proqram)
VYNPS-LRID-14, Review of the Heat Exchanger Monitoring Aging Management Program for
License Renewal lmplementation, Rev. 0
ENN-SEP-HX-001, Heat Exchanger Program, Rev. 1
EN-DC-316, Heat Exchanger Performance and Condition Monitoring, Rev. 3
Commitments 21 and 23 (Coolinq tower structural examinations)
VYNPS-LRID-?7-2, Review of the Structural Monitoring Aging Management Program for
License Renewal lmplementation, Rev. 1
EN-DC-150, Condition Monitoring of Maintenance Rule Structures, Rev. 1 and Rev. 2 (dratt)
MTMP-CTS-52114-10, Cooling Tower Structural Inspection and Repair, Rev. 4
cR -2009-03034
cR-2010-02853
cR-2010-03793
cR-2010-03799
cR-2010-03833
Commitment 25
LO LAR 2010 00256
VYNPS-LRID-29 "Vermont Yankee Nuclear Power Station, ThermalAging and Neutron
lrradiation Embrittlement of Cast Austentic Stainless Steel (CASS) Program Review
for License Renewal lmplementation"
BWRVIP-234 "BWR Vessel and Internals Project Thermal Aging and Neutron Embrittlement."
Commitment 54
Attachment