ML13042A272

Issuance of Amendment 256 Revision to License Condition 3.P and 3.S

ML13042A272
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/17/2013
From:	Richard Guzman Plant Licensing Branch 1
To:	Entergy Nuclear Vermont Yankee, Entergy Nuclear Operations
Guzman R
References
TAC ME8151
Download: ML13042A272 (59)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 17, 2013 Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION -ISSUANCE OF AMENDMENT TO RENEWED FACILITY OPERATING LICENSE RE: LICENSE CONDITION 3.P AND 3.0 CHANGES (TAC NO. ME8151)

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 256 to Renewed Facility Operating License No. DPR-28 for the Vermont Yankee Nuclear Power Station (VYNPS), in response to your application dated March 5,2012, as supplemented on November 20, 2012, March 26, March 29, and April 5, 2013.

The licensee's application for the proposed amendment revised the VYNPS License Conditions 3.P and 3.0 to clarify that the information in the updated final safety analysis report (UFSAR) supplement submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21 (d), as revised during the license renewal application review process, and as supplemented by commitments of Appendix A of Supplement 2 of NUREG-1907, can be incorporated as part of the UFSAR and may be changed without prior NRC approval provided the requirements of 10 CFR 50.59 have been previously satisfied. Entergy submitted a related license amendment request by letter dated March 12, 2012 (ADAMS Accession No. ML12079A031). The submittal is being reviewed under a separate technical assignment control (TAG) number.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Therefore, TAC No. ME8151 associated with this review will be closed.

Sincerely,

~

Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. Amendment No. 256 to License No. DPR-28

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY NUCLEAR VERMONT YANKEE. LLC AND ENTERGY NUCLEAR OPERATIONS. INC.

DOCKET NO. 50-271 VERMONT YANKEE NUCLEAR POWER STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 256 Renewed License No. DPR-28

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations. Inc. (the licensee) dated March 5, 2012, as supplemented by correspondence dated November 20, 2012, March 26, March 29, and April 5,2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable reqUirements have been satisfied.

- 2

2.

Accordingly, the license is amended as indicated in the attachment to this license amendment, and paragraph 3.B of the Renewed Facility Operating License No. DPR-28 is hereby amended to read as follows:

(B)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 256, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

Further, the license is amended as indicated in the attachment to this license amendment, and paragraph 3.P and 3.0 of the Renewed Facility Operating License No. DPR-28 is hereby amended to read as follows:

P.

The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21 (d), as revised during the license renewal application process, and as supplemented by Commitment Nos. 1-5,6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39, 42, 43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 shall be incorporated as part of the UFSAR which will be updated in accordance with 10 CFR 50.71(e).

As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1-5,6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19,2011),7-36,38,39,42,43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

O.

This paragraph deleted by Amendment No. 256, April 17, 2013.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION Sean C. Meighan, Acting Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachment Changes to the License Date of Issuance: Apr; 1 17, 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 256 RENEWED FACILITY OPERATING LICENSE NO. DPR-28 DOCKET NO. 50-271 Replace the following pages of the Renewed Facility Operating License with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page 3 Page 3 Page 13 Page 13

- 3 D. Entergy Nuclear Operations, Inc., pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any Byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components.

E. Entergy Nuclear Operations, Inc., pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A. Maximum Power Level Entergy Nuclear Operations, Inc. is authorized to operate the facility at reactor core power levels not to exceed 1912 megawatts thermal in accordance with the Technical Specifications (Appendix A) appended hereto.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 256 are hereby incorporated in the license. Entergy Nuclear Operations, Inc. shall operate the facility in accordance with the Technical Specifications.

C. Reports Entergy Nuclear Operations, Inc. shall make reports in accordance with the requirements of the Technical Specifications.

D. This paragraph deleted by Amendment No. 226.

E. Environmental Conditions Pursuant to the Initial Decision of the presiding Atomic Safety and Licensing Board issued February 27, 1973, the following conditions for the protection of the environment are incorporated herein:

1.

This paragraph deleted by Amendment No. 206, October 22, 2001.

2.

This paragraph deleted by Amendment 131,10107/91.

Renewed Facility Operating License No. DPR-28 Amendment No. ~, 256

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6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders O.

The licensee shall implement and maintain all Actions required by to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

P.

The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21 (d), as revised during the license renewal application process, and as supplemented by Commitment Nos. 1-5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39,42,43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 shall be incorporated as part of the UFSAR which will be updated in accordance with 10 CFR 50.71 (e).

As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1-5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39,42,43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Q.

This paragraph deleted by Amendment No. 256, April 17, 2013.

R.

Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

shall implement the most recent staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (lSP) as the method to demonstrate compliance with the requirements of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule withdrawal schedule must be submitted for NRC staff review and approval. Any changes to the BWRVIP ISP capsule withdrawal schedule which affects the time of withdrawal of any surveillance capsules must be incorporated into the licensing basis. If any surveillance capsules are removed without the intent to test them, these capsules must be stored in a manner which maintains them in a condition which would support re-insertion into the reactor pressure vessel, if necessary.

Renewed Facility Operating License No. DPR-28 Amendment No. 256

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 256 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-28 ENTERGY NUCLEAR VERMONT YANKEE, LLC AND ENTERGY NUCLEAR OPERATIONS, INC.

VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271

1.0 INTRODUCTION

By application dated January 27,2006, Entergy Nuclear Operations, Inc. (Entergy or the licensee) requested renewal of the operating license in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 54 for Vermont Yankee Nuclear Power Station (VY or vyNPS) for a period of 20 years beyond the March 21, 2012, expiration date. The Nuclear Regulatory Commission's (NRC's) review of the license renewal application (LRA) is contained in NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station," May 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML081430109). In September 2009, the NRC staff issued Supplement 1 to NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station" (ADAMS Accession No. ML092740567). In March 2011, the NRC staff issued Supplement 2 to NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station," (ADAMS Accession No. ML110770495). Appendix A of Supplement 2 to NUREG-1907 contains a list of 54 commitments made by the applicant to complete license renewal-related inspections and implement, modify or enhance aging management programs that manage the aging effects of systems, structures, and components (SSCs) prior to and during the period of extended operation (PEO). The NRC issued the renewed operating license for VY on March 21,2011 (ADAMS Accession No. ML052720265).

By letter dated March 5, 2012, (ADAMS Accession No. ML12068A110), Entergy submitted a license amendment request proposing changes to the renewed operating license for VY. The proposed changes would modify the VY renewed facility operating license condition (RFOLC) 3.P to clarify that the programs and activities described in the updated final safety analysis report (UFSAR) supplement submitted pursuant to 10 CFR 54.21 (d), as revised during the LRA review process, may be changed without prior NRC approval provided the requirements of 10 CFR 50.59 have been previously satisfied. Additionally, the licensee proposed to revise RFOLC 3.Q to only apply to the programs and activities identified in Appendix A of Supplement 2 to NUREG-1907 and the UFSAR supplement to be completed before the period of extended

- 2 operation. Also, a new regulatory commitment was included in the letter to incorporate the list of commitments from Appendix A of Supplement 2 to NUREG-1907 into the UFSAR supplement.

By letter dated March 12, 2012 (ADAMS Accession No. ML12079A031) Entergy submitted a license amendment request proposing changes to the License Renewal Commitment (LRC) No.

3 as described in Appendix A of Supplement 2 to NUREG-1907 to clarify inspection requirements for the fire pump diesel storage tank; LRC NO.6 as described in Appendix A of Supplement 2 to NUREG-1907 to clarify inspection requirements for manual cycle counting; LRC No. 16 as described LRA Section B.1.21, to revise the one-time inspection program; and LRC No. 19 as described in LRA Section B.1.25 to revise the selective leaching aging management program. This submittal is being reviewed by the NRC staff under a separate technical assignment control number.

By letter dated April 24, 2012 (ADAMS Accession No. ML12142A361), the licensee submitted Revision 25 of the UFSAR which included the list of commitments from Appendix A of Supplement 2 to NUREG-1907.

By letter dated October 10, 2012 (ADAMS Accession No. ML122840333), the NRC requested that the licensee provide technical justification to explain why each action in the commitment list from Appendix A of Supplement 2 to NUREG-1907. that had been escalated to license conditions, could be managed using 10 CFR 50.59. By letter dated November 20, 2012 (ADAMS Accession No. ML12331A281). Entergy provided the additional information requested, as well as newly proposed wording for RFOLC 3.P and 3.0, and stated that the commitments listed in Appendix A of NUREG-1907 had been incorporated in Revision 25 of the UFSAR.

In an e-mail messagedatedMarch26.2013{ADAMSAccessionNo.ML13085A421). a supplemental letter dated March 29,2013 (ADAMS Accession No. ML13092A106), and an additional e-mail message on April 5. 2013 (ADAMS Accession No. ML13095A278), the licensee agreed to: (1) consolidate the commitment numbers listed in RFOLC 3.P; {2} include an "and" in RFOLC 3.P; (3) change the phrase"... is henceforth... " to "shall be incorporated as..." in RFOLC 3.P; and (4) delete RFOLC 3.0.

The supplemental correspondence dated November 20.2012, March 26.2013. March 29, 2013.

and April 5, 2013, provided additional information that clarified the application. did not expand the scope of the application as originally noticed. and did not change the Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on April 3. 2012 (77 FR 20074).

2.0 REGULATORY EVALUATION

The statements of consideration for the 1995 revision to the Part 54 rule note that, "The license renewal review is intended to identify any additional actions that will be needed to maintain the functionality of the SSCs in the PEO." These actions can be addressed in the licensing basis by imposing a license condition, providing a description of the action in the UFSAR supplement. or accepting a commitment made by the applicant and documented by the NRC staff in the safety evaluation report (SER) for license renewal. The Office of Nuclear Reactor Regulation (NRR)

Office Instruction LlC-105, "Managing Regulatory Commitments Made by Licensees to the NRC." Revision 4 states:

-3

... the inclusion of actions or programs into the operating license, including technical specifications and license conditions, creates an obligation or regulatory requirement upon the licensee. This should only be used if the NRC staff deems that the commitment is essential for ensuring the health and safety of the public. Such obligations include actions that form the basis for the NRC staff's reasonable assurance finding on a licensing action. LlC-100 ["Control of Licensing Bases for Operating Reactors," Revision 4] defines obligations as follows: Conditions or actions that are legally binding requirements imposed on licensees through applicable rules, regulations, orders, and licenses (including technical specifications and license conditions). The imposition of obligations (sometimes referred to as regulatory requirements) during routine interactions with licensees should be reserved for matters that satisfy the criteria of 10 CFR 50.36 or are otherwise found to be of high safety or regulatory significance. The major distinction between obligations and other parts of the licensing bases is that changes generally cannot be made without prior NRC approval.

Since commitments made by a licensee in support of a license action, such as a license amendment request, are not legally binding, the staff's safety evaluation (SE) should not rely on commitments as a basis for any part of the staff's approval of a proposed licensing action. Therefore, if the NRC staff needs to rely on a regulatory commitment in an SE, then the staff must escalate the commitment to an obligation, or incorporate it into a mandated licensing basis document.

In accordance with 10 CFR 54.21, applicants submit, as part of the LRA, an UFSAR supplement. The UFSAR supplement is revised throughout the course of the LRA review. The UFSAR supplement may include, as submitted and subsequently expanded throughout the LRA review, additional actions the applicant commits to performing to manage the aging effects of SSCs that are in the scope of license renewal. If a renewed operating license is approved, the UFSAR supplement, and any additional actions or commitments that are already included therein, would become part of the UFSAR and managed using 10 CFR 50.59. A separate license condition may be imposed for actions that are of high safety or regulatory significance to be managed in accordance with 10 CFR 50.90.

Since 2005, most license renewal commitments made by licensees have been listed in an Appendix to the NRC staffs SER, regardless of whether the commitments were included in the UFSAR supplement. Although the VY UFSAR supplement did not include a list commitments, over 50 commitments made by VY during the review were listed in Appendix A of Supplement 2 to NUREG-1907.

Four license conditions were incorporated in the renewed operating license issued for VY on March 21, 2011. The licensee's license amendment request is applicable to two of the four license conditions.

RFOLC 3.P states:

The information in the UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21 (d), shall be incorporated into the next UFSAR no later than the next scheduled update required by 10 CFR 50.71 (e), following the issuance of this renewed operating license. Until this update is complete, Entergy Nuclear

-4 Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the information in the supplement without Commission approval provided that Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.,

evaluates such changes pursuant to the criteria in 10 CFR 50.59 and otherwise complies with the requirements of that section.

RFOLC 3.Q states:

The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),

describes certain future activities to be completed prior to and/or during the period of extended operation. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. shall complete these activities in accordance with Appendix A of Supplement 2 to NUREG-1907, "Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power Station,"

issued March 2011 (excluding Commitment No. 37, which is superseded by the steam dryer license condition). Entergy Nuclear Vermont Yankee, LLC or Entergy Nuclear Operations, Inc. shall notify the NRC in writing when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.

While the first license condition quoted above allows changes to the license renewal programs and activities described in the UFSAR supplement if permissible under 10 CFR 50.59, the second license condition requires completion of license renewal programs and activities listed in the UFSAR supplement in accordance with the commitments listed in Appendix A of Supplement 2 to NUREG-1907, implying that any changes to these programs and activities require prior NRC approval of a license amendment application via 10 CFR 50.90. This limitation on the use of 10 CFR 50.59 is not what the staff intended, if the commitments are incorporated in the UFSAR.

The NRC staff intended the commitments listed in Appendix A of the VY license renewal SER and the UFSAR supplement to be managed in accordance with the requirements of 10 CFR 50.59 after the UFSAR supplement is updated to include license renewal commitments. The primary purpose of the second license condition was to ensure that certain license renewal programs and activities were implemented and/or completed prior to the period of extended operation consistent with Appendix A commitments and that the NRC receive notification of completion to enable verification by NRC inspection. VY could not use 10 CFR 50.59 to modify any SER, Appendix A commitments that were not listed in the UFSAR supplement.

Revisions 1 and 2 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants [SRP-LR]," (ADAMS Accession Nos. ML052110007 and ML103490036) provide guidance to NRC staff reviewers on LRAs and states in both revisions, "The summary description of the programs and activities for managing the effects of aging for the period of extended operation in the FSAR Supplement should be sufficiently comprehensive, such that later changes can be controlled by 10 CFR 50.59. The description should contain information associated with the bases for determining that aging effects will be managed during the period of extended operation. The description should also contain any future aging management activities, including enhancements and commitments, to be completed before the period of extended operation."

- 5 During a "Post-approval Site Inspection for License Renewal," NRC inspectors identified that the actions in the commitments listed in Appendix A of Supplement 2 to NUREG-1907 had not been incorporated into the UFSAR supplement This was documented in NRC's inspection report, "Vermont Yankee Nuclear Power - NRC Inspection Report 05000271/2012008," dated April 20, 2012 (ADAMS Accession No. ML12103A406).

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes to the VY Renewed Operating License In its license amendment request, the licensee proposed to modify RFOLC 3.P and RFOLC 3.0 to clarify that the licensee can make changes to the Appendix A, Supplement 2 to NUREG-1907 list of commitments using 10 CFR 50.59 criteria, as opposed to the 10 CFR 50.90 license amendment request process.

By letter dated November 20, 2012, the licensee noted that the Appendix A list of commitments from NUREG-1907 had been incorporated in Revision 25 of the UFSAR in April 2012. Also, the licensee submitted revised language for both RFOLC 3.P and 3.0 to supersede its original request. Specifically, the licensee proposed RFOLC 3.P to state:

The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21 (d), as revised during the license renewal application process, as supplemented by Commitment Nos. 1, 2, 3, 4, 5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7, 8, 9,10,11,12,13, 14,15,16,17,18,19,20,21,22,23,24,25,26,28,30, 31,32, 33, 34, 35,36, 38,39,42,43,45,46,47,48,49,50,52,53,54, and 55 of Appendix A of Supplement 2 of NUREG-1907 is henceforth part of the UFSAR which will be updated in accordance with 10 CFR 50.71 (e). As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1,2,3,4,5,6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7, 8, 9,10,11,12,13,14,15,16,17, 18,19,20,21,22,23,24,25,26,28,30,31,32,33,34,35, 36, 38,39,42,43, 45,46,47,48,49,50,52,53,54, and 55 of Appendix A of Supplement 2 of NUREG-1907 provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

The proposed change would enable the licensee to modify the commitments listed in RFOLC 3.P using 10 CFR 50.59 without the need for prior NRC approval.

The licensee also proposed that RFOLC 3.0 be limited to the period prior to extended operation (by removal of the phrase "and/or during") to state:

The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21 (d),

describes certain future activities to be completed prior to the period of extended operation. Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. shall complete these activities in accordance with Appendix A of Supplement 2 to NUREG-1907, "Safety Evaluation Report Related to the License

- 6 Renewal of Vermont Yankee Nuclear Power Station," issued March 2011 (excluding Commitment No. 37, which is superseded by the steam dryer license condition). Entergy Nuclear Vermont Yankee, LLC or Entergy Nuclear Operations, Inc. shall notify the NRC in writing when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.

In e-mail messagesdatedMarch26.2013(ADAMSAccessionNo.ML13085A421) and April 5, 2013 (ADAMS Accession No. ML13095A278), and by supplemental letter dated March 29, 2013 (ADAMS Accession No. ML13092A106), the licensee agreed to consolidate the commitment numbers listed in RFOLC 3.P, add "and" to RFOLC 3.P, and delete RFOLC 3.0.

3.2

NRC Staff Evaluation

Because the language in VY license condition RFOLC 3.0 escalates the actions in Appendix A of Supplement 2 to NUREG-1907 to license conditions, any licensee changes to those actions would require prior NRC approval and a 10 CFR 50.90 license amendment application. These commitments relate to programs and activities for managing aging effects prior to and during the period of extended operation. The NRC staff's license renewal SER relied on the actions listed in Appendix A. According to LlC-105, actions that are relied upon by the staff should be incorporated in the UFSAR or escalated to a license condition.

Consistent with the SRP-LR, the staff expected that commitments in Appendix A of the VY license renewal SER to be included in the UFSAR and managed via 10 CFR 50.59. The 10 CFR 50.59 process will ensure that any changes to the facility, procedures, testing methods or analyses described in the FSAR are evaluated via a structured and disciplined approach, and records of the changes are maintained available for NRC inspection. Many of the commitments involve establishing and/or implementing aging management programs that require periodic inspections, testing and maintenance activities to be completed prior to and during the period of extended operation. The 10 CFR 50.59 process provides assurance that any future modifications to the commitments would not: (1) result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated); (2) result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); (3) result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated); (4) result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); (5) create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report (as updated);

(6) create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); (7) result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered; or (8) result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. License renewal actions that were of high safety or regulatory significance were captured in separate and detailed license conditions. For example, RFOLC 3.R states:

Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.

shall implement the most recent staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance

- 7 Program (ISP) as the method to demonstrate compliance with the requirements of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule withdrawal schedule must be submitted for NRC staff review and approval. Any changes to the BWRVIP ISP capsule withdrawal schedule which affects the time of withdrawal of any surveillance capsules must be incorporated into the licensing basis. If any surveillance capsules are removed without the intent to test them, these capsules must be stored in a manner which maintains them in a condition which would support re-insertion into the reactor pressure vessel, if necessary.

Below is the NRC staff's evaluation of each commitment listed in Appendix A of Supplement 2 to NUREG-1907. For each commitment, the staff considered whether: (1) the commitment can be managed under 10 CFR 50.59, and (2) the inspection results documented in inspection report (IR) 0500027112011011 for Phase I (ADAMS Accession No. ML113560064) and 05000271/2012008 for Phase II (ADAMS Accession No. ML12103A406) or other information indicates the commitments were implemented or completed by the licensee.

Commitment NO.1:

Guidance for performing examinations of buried piping will be enhanced to specify that coating degradation and corrosion are attributes to be evaluated.

Assessment for Commitment NO.1:

Commitment No.1 was reviewed by inspectors during Phase I of the IP 71003 inspection. The results were documented in IR 05000271/2011011 which states, "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):

Yard - Commitment 1 (Off-gas system buried piping 24" OG-5 and 16" OG-2)

The inspectors determined the general conditions to be satisfactory and the Entergy activities to be in accordance with facility programs and procedures."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that general conditions of the buried piping were satisfactory. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things:

result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 1 may be managed using 10 CFR 50.59.

- 8 Commitment No.2:

Fifteen (15) percent of the top guide locations will be inspected using enhanced visual inspection technique, EVT-1, within the first 18 years of the period of extended operation, with at least one third of the inspections to be completed within the first 6 years and at least two thirds within the first 12 years of the period of extended operation. Locations selected for examination will be areas that have exceeded the neutron fluence threshold.

Assessment for Commitment NO.2:

Commitment No.2 was reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states, "By way of procedure SEP-RVI-006, Revision 2, Section 2.1.2 parts (a), (b), and (c), the applicant committed to inspect 5 percent of the top guide locations using an EVT-1 during the first 6 years of extended operation, with an additional 5 percent in subsequent 6 year intervals for a total of 15 percent by the end of 18 years."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the procedure consistent with the commitment to provide reasonable assurance that future inspections would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things:

result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No.2 may be managed using 10 CFR 50.59.

Commitment NO.3:

The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonic thickness measurement of the fuel oil storage and fire pump diesel storage (day) tank bottom surfaces will be performed every 10 years during tank cleaning and inspection.

Commitment NO.4:

The Diesel Fuel Monitoring Program will be enhanced to specify that UT measurements of the fuel oil storage tank bottom surface will have acceptance criterion in accordance with American Petroleum Institute [API] standard API 653 and UT measurements of the fire pump diesel storage (day) tank bottom surface will have acceptance criterion in accordance with Steel Tank Institute standard STI SP001.

- 9 Assessment for Commitment Nos. 3 and 4:

By letter dated March, 12,2012 (ADAMS Accession No. ML12079A031), the licensee submitted a separate license amendment request to clarify inspection requirements for the "fire pump diesel storage tank in Commitment 3. The March 12, 2012, license amendment request will be evaluated separate from this safety evaluation. Commitment Nos. 3 and 4 as reflected in NUREG-1907, Appendix A were reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states, "These commitments require the licensee to enhance the Diesel Fuel Monitoring Program to perform UTs of the bottoms of the fuel oil storage tank and the fire pump diesel storage tank every 10 years. The acceptance criteria for these tests will be in accordance with the American Petroleum Institute Standard 653 and the Steel Tank Institute Standard SP001. The inspectors reviewed the license renewal application, Safety Evaluation Report, and the licensee's implementation plan, and discussed these commitments with applicable plant staff and license renewal personnel. The inspectors reviewed the ultrasonic testing reports, testing results evaluations, and applicable industry standards. For both the fuel oil storage tank and the fire pump diesel day tank, the tank bottom thickness results were greater than the acceptance criteria. Also, evaluations of the effect of corrosion on the tank bottoms determined that the thicknesses were projected to remain above the acceptance criteria at least until additional ultrasonic testing is performed in 10 years. The inspectors reviewed the general condition of the fire pump diesel day tank and found it to be acceptable."

By letter dated November 20, 2012, Entergy stated these commitments were implemented and the UFSAR revised to include the commitments. NRC inspection confirmed that the licensee implemented the commitments to provide reasonable assurance that future inspections would be completed and acceptance criteria would be met. The 10 CFR 50.59 process provides assurance that any future modifications to the commitments described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. NRC staff therefore concludes that Commitment Nos. 3 and 4, as stated in the VY SER for license renewal, Appendix A, may be managed USil1g 10 CFR 50.59.

Commitment No.5:

The Fatigue Monitoring Program will be modified to require periodic update of cumulative fatigue usage factors (CUFs), or to require update of CUFs if the number of accumulated cycles approaches the number assumed in the design calculation.

Assessment for Commitment No.5:

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance

- 10 that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment NO.5 may be managed using 10 CFR 50.59.

Commitment NO.6:

A computerized monitoring program (e.g., FatiguePro) will be used to directly determine cumulative fatigue usage factors (CUFs) for locations of interest.

Assessment for Commitment NO.6:

Before receiving its renewed operating license on March 21,2011, the licensee revised Commitment NO.6 in January 2011 to state:

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.

By letter dated May 19, 2011 (ADAMS Accession No. ML11145A117), Entergy submitted information to document and inform the NRC of the proposed change to Commitment No.6.

The IP 71003 inspection team identified that the commitment was changed by the licensee in January 2011, before the renewed operating license was approved on March 11, 2011.

Because license conditions RFOLC 3.P and 3.0 had not yet been issued, the changes to commitments for license renewal were managed using the guidance in NEI 99-04.

In its letter of May 19, 2011, the licensee stated that VYNPS currently uses a manual counting method for the thermal or pressure transient cycles that are associated with the plant's design basis transients. The licensee stated that manual counting of design basis transient events is not a labor intensive process because, on average, there have been six or less total transient occurrences per plant operating cycle. The licensee stated that, for VY, the number of transient cycles projected to the end of the period of extended operation was predicted to be less than 60 percent of the number assumed for the transients in the design basis. The licensee stated that, since the projected number of cycles is significantly less than the number of cycles assumed for the transients in the design basis, VY will not use a computerized monitoring program to directly determine the CUFs during the PE~. The licensee stated that, instead, VYNPS will continue to use manual transient cycle counting to track and compare accumulated cycles for the design basis transients against allowable values to determine if cumulative usage factors are required to be updated during the PE~.

The licensee stated that the letter of May 19, 2011, serves to update the VYNPS docket relative to this prior commitment in LRA Commitment NO.6 and that in the revised commitment will continue to provide adequate assurance of the ability to track the number of critical thermal and pressure transients for selected reactor coolant system components.

- 11 NRC Staff Review The licensee is required by its ASME Section III design code of record to have established cycle-dependent CUF or It fatigue analyses for those components at the plant that were designed to ASME Section III design requirements and were required to be evaluated in accordance with cycle-dependent fatigue analysis methodology in ASME Section III. In general, the code required the licensee to perform this type of fatigue analysis for those components that are defined as either ASME Code Class 1 reactor coolant pressure boundary components, ASME Code Class reactor vessel internal core support structure components, or ASME Code Class structural components, although the code of record would permit the licensee to exempt the components from the fatigue analysis if specific design or operational criteria were met.

The CUF or It values in these fatigue analyses are based on those design basis transients that the applicant has determined are applicable to the components and has assumed for in the fatigue analyses. The number of cycles assumed for in the design basis for these transients are inputs to the fatigue analyses (i.e., calculations). The licensee identified these fatigue analyses as time-limited aging analyses for the VY LRA. The staff approved these time-limited aging analyses (TLAAs) in Chapter 4 of NUREG-1907, as supplemented in Supplements 1 and 2 of the safety evaluation report.

For those fatigue analysis TLAAs that were accepted in accordance with the NRC criterion in 10 CFR 54.21(c)(1)(iii), the licensee credits its Fatigue Monitoring Program (LRA Aging Management Program [AMP] B1.1) for ensuring that the impact of fatigue-induced cracking on the components would be adequately managed during the period of extended operation. The staff accepted this AMP in Section 3.0.3.2 of NUREG-1907. The licensee's Fatigue Monitoring Program monitors for the occurrences of those design basis transients that are defined in the VY UFSAR and analyzed for in the fatigue analysis TLAAs. The AMP calls for the licensee to total the number of occurrences so that a comparison can be made to upper bound cycle limits that have been established in the design basis for these transients.

The licensee's change in commitment dated May 19, 2011, relates to a change in the way the licensee would perform its cycle counting activities for the Fatigue Monitoring Program.

Specifically, the licensee would manually track and record any design basis transients that occur at the plant to determine the total number of occurrences (cycles) for these transients, so that a comparison can be made to the number of cycles assumed for the transients in the CUF or It fatigue analyses. The staff finds this approach acceptable because (1) the licensee is already currently using this method to manage its CUFs in order to comply with the ASME Section III design code, and (2) the projected design basis transient events at the facility provide for a significant margin of safety when compared to design limits for these transients in the UFSAR.

Based on this review, the staff concludes that the licensee's change to LRA Commitment NO.6 does not change the staff's previous conclusion regarding VY's Fatigue Monitoring Program, as documented in NUREG-1907 and subsequent supplements.

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report

- 12 (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No.6 as revised may be managed using 10 CFR 50.59.

Commitment NO.7:

The allowable number of effective transients will be established for monitored transients. This will allow quantitative projection of future margin.

Assessment for Commitment NO.7:

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated). The NRC staff therefore concludes that Commitment NO.7 may be managed using 10 CFR 50.59.

Commitment NO.8:

Procedures will be enhanced to specify that fire damper frames in fire barriers will be inspected for corrosion. Acceptance criteria will be enhanced to verify no significant corrosion.

Assessment for Commitment NO.8:

Commitment No.8 was reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states,

'The inspectors reviewed the commitment completion review report and licensee procedure OP-4019, "Surveillance of Plant Fire Barriers and Fire Rated Assemblies," to verify that the surveillance procedure had been enhanced to include fire damper frame inspections. The inspectors noted that OP-4019 included a schedule, list of dampers, and acceptance criteria to adequately control the required inspections. The inspectors also interviewed the project manager to review any operating experience or implementation issues."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the procedure consistent with the commitment to provide reasonable assurance that future inspections would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated);

result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment NO.8 may be managed using 10 CFR 50.59.

-13 Commitment NO.9:

Procedures will be enhanced to state that the diesel engine subsystems (including the fuel supply line) will be observed while the pump is running.

Acceptance criteria will be enhanced to verify that the diesel engine did not exhibit signs of degradation while it was running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.

Assessment for Commitment NO.9:

Commitment NO.9 was reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states, in part, "The inspectors noted the revised monthly surveillance procedure contained steps specifying observation of the fire pump diesel and its sub-systems, and stipulated acceptance criteria for these observations. The 18-month surveillance procedure contained steps specifying observation of the fire pump diesel and its SUb-systems, but did not specify related acceptance criteria. The licensee issued a procedure change request, which provided the appropriate acceptance criteria for the 18-month surveillance procedure. The inspectors verified the proposed procedure change specified acceptance criteria for the 18-month surveillance.

The inspectors observed the general condition of the fire pump diesel and its sub-systems, and found the conditions to be acceptable."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the procedure consistent with the commitment to provide reasonable assurance that future inspections would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated);

result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No.9 may be managed using 10 CFR 50.59.

Commitment No. 10:

Fire Water System Program procedures will be enhanced to specify that in accordance with NFPA 25 (2002 edition), Section 5.3.1.1.1, when sprinklers have been in place for 50 years a representative sample of sprinkler heads will be submitted to a recognized testing laboratory for field service testing. This sampling will be repeated every 10 years.

Assessment for Commitment No.1 0:

Commitment No. 10 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part,

- 14 "The inspectors reviewed the commitment completion review report and applicable fire protection work orders to verify that all sprinkler systems which will reach 50 years of age during the period of extended operation will be subjected to testing in accordance with NFPA 25-2002, "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems." The inspectors noted that the installation date was determined for all sprinkler systems to determine the required initial test date. The inspectors also noted documentation tracking the scheduling of the inspections at 10 year intervals after the initial 50 year inspection."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee performed the necessary actions consistent with the commitment to provide reasonable assurance that future samplings would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated). The NRC staff therefore concludes that Commitment No.1 0 may be managed using 10 CFR 50.59.

Commitment No. 11:

The Fire Water System Program will be enhanced to specify that wall thickness evaluations of fire protection piping will be performed on system components using non intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion/MIC (bio fouling). These inspections will be performed before the end of the current operating term and during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.

Assessment for Commitment No. 11:

Commitment No. 11 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part "The inspectors noted that based upon worst case test results and conservative estimates of corrosion rates, all samples are expected to be above the minimum required wall thickness at the end of the period of extended operation. The inspectors also interviewed the project manager to review any operating experience or implementation issues."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the program consistent with the commitment to provide reasonable assurance that future inspections would be completed. Also inspectors reviewed initial inspection results which were found to be acceptable. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things, result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated). The NRC staff therefore concludes that Commitment No. 11 may be managed using 10 CFR 50.59.

- 15 Commitment No. 12:

Implement the Heat Exchanger Monitoring Program as described in LRA Section B.1.14.

Assessment for Commitment No. 12:

Commitment No. 12 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "As documented in Inspection Report 05000271/2011011, the inspectors reviewed the conditions of three heat exchangers which were opened for cleaning and inspection during the refueling outage in October 2011. The inspectors reviewed the license renewal application, Safety Evaluation Report, the licensee implementation plan, and discussed this commitment with applicable plant staff and license renewal personnel. The inspectors reviewed the licensee's corporate and Vermont Yankee site procedures for the heat exchanger monitoring program. The heat exchanger monitoring program is an existing program that organizes the heat exchanger inspections and maintenance activities, previously performed individually, within the preventive maintenance program. As part of the license renewal application process additional heat exchangers were added to the program. Inspections of these heat exchangers are planned in the next few years. The inspectors reviewed the three most recent Heat Exchanger Program Health Reports and corrective action documents associated with degradations on three heat exchangers. The inspectors noted that ENN-SEP-HX-001, "Heat Exchanger Program," Revision 1, addressed the heat exchangers added during license renewal but was not clear regarding heat exchangers being covered and the inspection approaches for baseline and periodic inspections, largely due to non-specific use of "samples" and "sampling."

The inspectors reviewed Revision 2 of the procedure which included clear, specific guidance and resolved the concern."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspections and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 12 may be managed using 10 CFR 50.59.

- 16 Commitment No. 13:

Implement the Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.17.

Inspections for water accumulation in manholes containing inaccessible low voltage and medium-voltage cables with a license renewal intended function will be performed at least once every year. Additional condition-based inspections of these manholes will be performed based on: a) potentially high water table conditions, as indicated by high river level, and b) after periods of heavy rain.

The inspection results are expected to indicate whether the inspection frequency should be modified.

Inaccessible low-voltage cables (400 V to 2 kV) with a license renewal intended function are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every six years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.

Assessment for Commitment No. 13:

Commitment No. 13 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part, "The inspectors reviewed the commitment completion review reports, manhole inspection results, and cable test results to verify that potential aging effects to inaccessible cables were being adequately managed. The inspectors reviewed tan delta and insulation resistance test results to verify that cable testing frequencies were established based on cable performance. The inspectors verified that the cable testing program included medium and low voltage cables.

The inspectors also reviewed the manhole inspection results and determined that all of the manholes had been inspected and future work orders were designed to inspect the manholes on appropriate frequencies and at least once every year.

The inspectors reviewed OP-PHEN-3127, "Natural Phenomena Operating Procedure," to verify that the manholes will be inspected under conditions of high river level or after heavy rain. The inspectors also interviewed the project manager to review any operating experience or implementation issues.

Commitment [No.] 43 applied the Commitment [No.] 13 cable testing program to the cables between Vermont Yankee and the Vernon Hydro Station. The inspectors reviewed the cable testing program to ensure that the cables between Vermont Yankee and Vernon Hydro Station were included in the cable testing program, the cables had been tested satisfactorily, and the cable testing frequency was set at 6 years."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspections and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications

- 17 to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 13 may be managed using 10 CFR 50.59.

Commitment No. 14:

Implement the Non Environmental Qualification Instrumentation Circuits Test Review Program as described in LRA Section 8.1.18.

Assessment for Commitment No. 14:

Commitment No. 14 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The program, as described in the license renewal application, consists of enhancing the Intermediate Range Monitoring and Local Power Range Monitoring detector testing programs to collect data sufficient to verify the adequacy of the Intermediate Range Monitoring and Local Power Range Monitoring cables. The inspectors reviewed the commitment completion review report, revised test procedure, and initial test results to verify that any potential aging effects in the Intermediate Range Monitoring or Local Power Range Monitoring cables are being adequately managed. The inspectors reviewed VY-RPT-00018, "Non-EQ Sensitive Instrumentation Circuits Cable and Connection Evaluation," to verify the initial test results demonstrated adequate performance of the associated cables. The inspectors also interviewed the project manager to review any operating experience or implementation issues."

8y letter dated November 20. 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspections and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 14 may be managed using 10 CFR 50.59.

-18 Commitment No. 15:

Implement the Non Environmental Qualification Insulated Cables and Connections Program as described in LRA Section B.1.19.

Assessment for Commitment No. 15:

Commitment No. 15 was reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states, in part,

'The inspectors reviewed the commitment completion review report and inspection results to verify that potential aging effects to cables and connections are being adequately managed. The inspectors reviewed VY-RPT-11-00019, "Cable and Connection Inspection Summary Report," which documented the inspection of the plant for adverse localized environments and aging effects to cables and connections. The inspectors reviewed the work orders and condition reports that were generated as a result of the walk down to verify that conditions adverse to quality were being identified and resolved."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspections and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 15 may be managed using 10 CFR 50.59.

Commitment No. 16:

Implement the One Time Inspection Program as described in LRA Section B.1.21.

Assessment for Commitment No. 16: By letter dated March, 12, 2012 (ADAMS Accession No. ML12079A031), the licensee submitted a license amendment request to revise the one-time inspection program in Commitment 16. The March 12 request will be evaluated separate from this safety evaluation. Commitment No. 16 as reflected in NUREG-1907, Appendix A was reviewed by inspectors during Phase II ofthe IP 71003 inspection. The results were documented in IR 0500027112012008 which states, "The inspectors reviewed the license renewal application, Safety Evaluation Report, the licensee implementation plan, and discussed this commitment with applicable plant staff and license renewal personnel. The inspectors reviewed

- 19 the licensee's corporate procedure for one-time inspection, the summary report of the one-time inspection program (draft and final), and inspection testing matrix.

The inspectors reviewed inspection reports, material/environment evaluations, and condition reports further evaluating discrepancies. The licensee concluded that one-time inspections demonstrated that no additional aging management activities were needed. The inspectors noted that the "One-Time Inspection Program as described in LRA Section 8.1.21" included inspection of the cast austenitic stainless steel main steam line flow restrictors. These inspections were discussed in Amendment 16 to the License Renewal Application submitted by the licensee and in the Safety Evaluation Report. The inspectors noted the inspection matrix listed these inspections as not applicable, and the licensee had not initiated any regulatory process to revise its commitment. The licensee personnel stated that preparations for the inspections had determined that the inspections were impractical. In addition, the licensee determined that plans for onetime inspections of the reactor vessel leak-off line should be covered under Commitment [No.] 53. In letter BVY 12-016, dated March 12, 2012, the licensee addressed these concerns by modifying License Renewal Application Section A,2.1.23 which describes the application of the One-Time Inspection Program at B.1.21."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspections and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 16, as stated in the VY SER for license renewal, Appendix A, may be managed using 10 CFR 50.59.

Commitment No. 17:

Enhance the Periodic Surveillance and Preventive Maintenance Program to assure that the effects of aging will be managed as described in LRA Section 8.1.22.

Assessment for Commitment No. 17:

Commitment No. 17 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part, "The Periodic Surveillance and Preventive Maintenance Program includes periodic inspections and tests that manage aging effects not managed by other aging management programs. The inspectors reviewed Work

- 20 Order 52295664-01, cleaning and inspection (mechanical and electrical) of reactor recirculation ventilation unit-7 in the reactor building completed during the fall 2011 refueling outage. The inspectors reviewed Work Order 52329127-01, cleaning and inspection of Aircon SAC-1 Control Room Air Conditioner (Package Fan Coil for the Control Room HVAC Filters and Cooling System) completed in August 2011. Inspection of the reactor building crane rails and girders is scheduled for completion during February 2012. This program has resulted in revisions to the included equipment maintenance procedures to specify that the inspection procedure is fulfilling a license renewal aging management commitment."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the program consistent with the commitment to provide reasonable assurance that future surveillances and maintenance activities would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 17 may be managed using 10 CFR 50.59.

Commitment No. 18:

Enhance the Reactor Vessel Surveillance Program to proceduralize the data analysis, acceptance criteria, and corrective actions described in the program description in LRA Section B.1.24.

Assessment for Commitment No. 18:

Commitment No. 18 was reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states, "This commitment, which requires writing a procedure, was implemented by revising SEP-FTP-VTY, Revision 1, "Reactor Vessel Fracture Toughness and Surveillance Material Testing At Vermont Yankee," to stipulate data analysis, and acceptance criteria, by incorporating Boiling Water Reactor Vessel Internals Project (BWRVIP)-86 and BWRVIP-135. After determining the effects on plant operating parameters caused by new data provided by the BWRVIP-135 program, the revised procedure was enhanced to clarify that significant departures from expected performance should be entered into the corrective action program in accordance with EN-U-102."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the program consistent with the commitment to provide reasonable assurance that future surveillances and corrective actions would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR

- 21 would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 18 may be managed using 10 CFR 50.59.

Commitment No. 19:

Implement the Selective Leaching Program as described in LRA Section B.1.25.

Assessment for Commitment No. 19:

By letter dated March, 12,2012 (ADAMS Accession No. ML12079A031), the licensee submitted a license amendment request to revise the selective leaching program in Commitment 19. The March 12 request will be evaluated separate from this safety evaluation. Commitment No. 19 as reflected in NUREG-1907, Appendix A was reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states, in part, "The inspectors reviewed the license renewal application, Safety Evaluation Report, the licensee implementation plan, and the licensee commitment closure verification, and discussed this commitment with applicable plant staff and license renewal personnel. The inspectors reviewed the licensee's corporate selective leaching procedure, the draft and final selective leaching summary report, inspection sample matrix, inspection reports, and technical report with destructive examinations of some copper alloy components.

During review of the sample matrix, the licensee identified that some samples for gray cast iron in a raw water environment were actually copper alloy material mischaracterized as gray cast iron; this necessitated additional samples. Later the inspectors reviewed the two additional samples inspected. The inspectors reviewed the "Evaluation of the Gray Cast Iron Valves in the Fire Protection System Based on External Ultrasonic Test Examinations," dated January 18, 2012, and a later version dated March 20,2012, discussed the evaluation with testing personnel and applicable license renewal staff. The licensee had applied the ultrasonic testing to 20 fire protection system components, which were not otherwise accessible for selective leaching inspection. A sample of gray cast iron material with selective leaching from another Entergy facility had been used to qualify the ultrasonic test method. The evaluation of each component determined the wall thicknesses, calculated a maximum possible leaching thickness, and projected potential wall thickness loss over 20 years. In all but one case, the licensee determined that the remaining wall thicknesses would exceed the design minimum wall thickness. For the one valve with insufficient calculated wall thickness, the licensee planned to repeat the inspection in 5 years. The inspectors determined the licensee's ultrasonic test method had a sound technical basis. The results of the test, when combined with the multiple conservatisms of the evaluations, and the visual and hardness inspections of other gray cast iron valves, supports a conclusion that aging management activities for selective leaching are not required. The inspectors requested a

- 22 repeat inspection on a second valve with the least calculated margin (8 percent) above the design minimum wall thickness. The licensee determined that visual inspecting the two valves by March 21,2014, would be more appropriate and issued work orders to perform these inspections. The inspectors noted the Nuclear Regulatory Commission guidance in NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report" and the Licensee statements made in their license renewal application at Section B.1.25 "Selective Leaching Program" have no provision for ultrasonic testing for selective leaching. In letter BW 12 016, dated March 12, 2012, the licensee addressed this concern by modifying the aging management program the commitment refers to in the original renewal application at A.2.1.27.

The inspectors reviewed the "Results of Soil Corrosivity Testing - Buried Pipe Initiative, Vermont Yankee," dated December 12,2011, which documented the testing and analysis of soil conditions in the vicinity of buried fire piping with gray cast iron valves. The report provided a detailed technical basis why selective leaching was not likely to occur on the buried valves, the visual inspection would be superfluous, and the excavation to enable the inspection unnecessary. The inspectors determined this approach had a reasonable technical basis and was conservative. However, the NRC guidance in NUREG-1801, Revision 1, GALL Report and licensee statements made in the license renewal application at Section B.1.25 "Selective Leaching Program" have no provision for soil corrosivity testing for selective leaching, nor had the licensee initiated any regulatory process to revise its commitment. In letter BW 12-016, dated March 12, 2012, the licensee addressed this concern by modifying A.2.1.27 of the original application."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspections and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 19, as stated in the VY SER for license renewal, Appendix A, may be managed using 10 CFR 50.59.

Commitment No. 20:

Enhance the Structures Monitoring Program to specify that process facility crane rails and girders, condensate storage tank (CST) enclosure, CO2tank enclosure, N2 tank enclosure and restraining wall, CST pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man way seals and gaskets, and hatch seals and gaskets are included in the program.

- 23 Assessment for Commitment No. 20:

Commitment No. 20 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part, "The applicant has enhanced the Structural Monitoring Program to specify that process facility crane rails and girders, condensate storage tank enclosure, CO2 tank enclosure, N2 tank enclosure and restraining wall, condensate storage tank pipe trench, diesel generator cable trench, fuel oil pump house, service water pipe trench, man way seals and gaskets, and hatch seals and gaskets are included in the program. The inspectors reviewed the commitment completion review report, the Structural Monitoring Program documents and program procedure. Specifically, inspectors reviewed the procedure EN-DC-150, "Condition Monitoring of Maintenance Rule Structures" to verify the procedure was updated to identify the specific structures and components. Attachment 9.17, of the procedure, listed the structures, components, and equipment covered by the monitoring program and monitoring procedure."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the program consistent with the commitment to provide reasonable assurance that the structures listed in the commitment would be monitored. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 20 may be managed using 10 CFR 50.59.

Commitment No. 21:

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.

Assessment for Commitment No. 21:

Commitment No. 21 was reviewed by inspectors during Phase I of the IP 71003 inspection. The results were documented in IR 05000271/2011011 which states, "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.

- 24 The inspector determined that Commitment Nos. 21 and 23 had been completed."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the program consistent with the commitment to provide reasonable assurance that aging effects of wood would be evaluated. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 21 may be managed using 10 CFR 50.59.

Commitment No. 22:

Guidance for performing structural examinations of elastomers (seals and gaskets) to identify cracking and change in material properties (cracking when manually flexed) will be enhanced in the Structures Monitoring Program procedure.

Assessment for Comrnitment No. 22:

Commitment No. 22 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states,

The inspectors reviewed the revised and updated procedures to verify that guidance for performing structural examinations of elastomers (seals and gaskets) to identify cracking and change in material properties (cracking when manually flexed) had been enhanced in the structural monitoring program.

Procedure EN-DC-150, Sections 5.9 and 8.0 have been revised and updated to provide guidance for inspection and monitoring of elastomers."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the program consistent with the commitment to provide reasonable assurance that aging effects of elastomers would be evaluated. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things:

result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in

- 25 the safety analyses. The NRC staff therefore concludes that Commitment No. 22 may be managed using 10 CFR 50.59.

Commitment No. 23:

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.

Assessment for Commitment No. 23:

Commitment No. 23 was reviewed by inspectors during Phase I of the IP 71003 inspection. The results were documented in IR 05000271/2011011, which states, "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 Commitment Nos. 21 and 23 had been completed."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the program consistent with the commitment to provide reasonable assurance that aging effects of PVC cooling tower fill would be evaluated. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated);

create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses.

The NRC staff therefore concludes that Commitment No. 23 may be managed using 10 CFR 50.59.

Commitment No. 24:

System walkdown guidance documents will be enhanced to perform periodic system engineer inspections of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject system will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a)(2).

- 26 Assessment for Commitment No. 24:

Commitment No. 24 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The licensee modified Procedure EN-DC-178, "System Walk down Program" and Procedure ENN-MS-S-004, "VYNPS System Categorization" to require periodic walk downs to inspect for the effects of aging on system equipment and components."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced procedures consistent with the commitment to provide reasonable assurance that future inspections would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated);

result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 24 may be managed using 10 CFR 50.59.

Commitment No. 25:

Implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in LRA Section B.1.29.

Assessment for Commitment No. 25:

Commitment No. 25 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "Section B.1.29 of the license renewal application states the program will be "comparable to the program described in NUREG-1801 Section XI.M13." The applicable edition of Nuclear Regulatory Commission guidance in NUREG-1801, GALL Report is Revision 1. In addition to addressing critical elements of CASS aging, Section B.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 BWRVIP reports, EPRI reports, and other industry operating experience will provide additional bases for evaluations and inspections under 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." 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 steel were resolved and specified in the BWRVIP 234-2009.

- 27 Section 6.7 of the program states: "The inspection recommendation given are based on the following criteria: (1) fluence less than 3 X 1020 n/cm2; (2) adequate toughness (> 255 kJ/m2); and (3) applied stress << 5ksi)." The licensee used BWRVIP 234-2009 as the method necessary to manage the aging effect of thermal aging and neutron irradiation embrittlement of CASS and proceduralize the specifications in the CASS aging management program. Using the BWRVIP 234-2009 thresholds, all of Vermont Yankee's CASS components, within the scope of the original application, were below the stress threshold of the selection criteria established in BWRVIP 234-2009. Thus, the components screened out of the aging management program and needed no inspection. The criteria used in BWRVIP 234-2009 is different than the criteria stipulated in the NRC guidance in the applicable Revision 1 of NUREG-1801, GALL Report,Section XI,M13, because the inspection threshold in the guidance is established based on a single criterion of fluence > 1017 n/cm2 (for E > 1 MeV). This threshold is three orders of magnitude lower than the threshold used in BWRVIP 234-2009 for fluence. The inspectors noted Revision 2 of NUREG-1801, GALL Report,Section XI,M13, accepted BWRVIP 234-2009 as an aging management. The licensee revised LO LAR 2010-0256 to resolve the criteria differences. The commitment was to implement Section B.1.29 of the application, and Section B.1.29 of the application includes the provision to supplement the approach using "future BWRVIP reports, EPRI reports, and other industry operating experience" to "provide additional bases for evaluations and inspections under this program." Under the provisions of B.1.29 the application of BWRVIP 234-2009, as an additional bases for evaluation, is acceptable."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspections and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 25 may be managed using 10 CFR 50.59.

Commitment No. 26:

Procedures will be enhanced to flush the John Deere Diesel Generator cooling water system and replace the coolant and coolant conditioner every three years.

Assessment for Commitment No. 26:

Commitment No. 26 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part,

- 28

'The inspectors reviewed the revised preventive maintenance procedures, and the work order for the three-year preventive maintenance of this diesel generator completed on June 11, 2011. The licensee's inspection is on a 3 year cycle. The inspectors observed the general condition of the John Deere diesel generator and its cooling systems, and found the conditions to be acceptable."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced procedures consistent with the commitment to provide reasonable assurance that future maintenance activities would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated);

create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 26 may be managed using 10 CFR 50.59.

Commitment No. 27:

At least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR 6260 for BWRs of the VY vintage, VY will refine our current fatigue analyses to include the effects of reactor water environment and verify that the cumulative usage factors (CUFs) are less than 1.

This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations, including NUREG/CR 6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adjusted CUF.

2. More limiting VY specific locations with a valid CUF may be added in addition to the NUREG/CR 6260 locations.

3. Representative CUF values from other plants, adjusted to or enveloping the VY plant specific external loads may be used if demonstrated applicable to VY.

4. An analysis using an NRC approved version of the ASME code or NRC approved alternative (e.g., NRC approved code case) may be performed to determine a valid CUF.

During the period of extended operation, VY may also use one of the following options for fatigue management if ongoing monitoring indicates a potential for a condition outside the analysis bounds noted above:

- 29

1. Update andlor refine the affected analyses described above.

2. Implement an inspection program that has been reviewed and approved by the NRC (e.g., periodic nondestructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC).

3. Repair or replace the affected locations before exceeding a CUF of 1.0.

Assessment for Commitment No. 27:

By letter dated November 20, 2012, Entergy stated that Option 1 had been completed and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, amollg other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that although Commitment No. 27 is complete, inclusion in the UFSAR is consistent with the staffs expectation at the time of renewal. Therefore this commitment can be managed using 10 CFR 50.59.

Commitment No. 28:

Revise program procedures to indicate that the Instrument Air Program will maintain instrument air quality in accordance with ISA S7.3.

Assessment for Commitment No. 28:

Commitment No. 28 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "LO-LAR-2010-00259 was created to track progress on this commitment. The licensee has revised Procedure RP 4620 to include ISA S7.3 as the sampling criteria for air quality. Also, the licensee has added a supervisory review of the sampling results to ensure that the criteria of ISA S7.3 are met during sampling analysis."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the procedure consistent with the commitment to provide reasonable assurance that air quality will be maintained. The 10 CFR 50.59 process provides assurance that any future modifications the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a

- 30 malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 28 may be managed using 10 CFR 50.59.

Commitment No. 29:

VYNPS will perform one of the following:

1. Install core plate wedges, or,

2. Complete a plant-specific analysis to determine acceptance criteria for continued inspection of core plate hold down bolting in accordance with BWRVIP-25 and submit the inspection plan and analysis to the NRC one year prior to the period of extended operation for NRC review and approval.

Assessment for Commitment No. 29:

The licensee indicated that they picked Option 2 of the commitment. By letter dated March 28, 2012 (ADAMS Accession No. ML120760152), the NRC staff approved the analysis and inspection plan for the core plate rim hold-down bolts. Inspections of the core plate hold down bolts are part of the licensee's BWR Vessel Internals Program. Any changes or deviations from the NRC-approved inspection or evaluation protocols for the rim hold-down bolts should be processed in accordance with the VY BWRVIP-94 implementation process in addition to its 10 CFR 50.59 process. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses.

By letter dated November 20, 2012, Entergy stated this commitment has been completed and the UFSAR revised to include the commitment. The NRC staff therefore concludes that although Commitment No. 29 is complete, inclusion in the UFSAR is consistent with the staff's expectation at the time of renewal. Therefore this commitment can be managed using 10 CFR 50.59.

Commitment No. 30:

Revise System Walkdown Program to specify CO2 system inspections every 6 months.

- 31 Assessment for Commitment No. 30:

Commitment No. 30 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part, "The inspectors reviewed the design of the CO2 system holding tank, an ASME, Boiler and Pressure Vessel Code, Section 8 pressure vessel, and determined that it was not possible to visually inspect the steel walls to detect signs of aging in the form of corrosion. The CO2 tank walls are made of steel and are covered with insulation and a sheet metal cover. The sheet metal cover is designed to protect the insulation and the tank from weather related aging effects caused by the tank's location out-of-doors. The licensee has defined the system periodic walk down to ensure that the sheet metal cover is visually inspected to detect signs of aging. Should aging effects become evident, the licensee will enter the condition into the corrective action process and address the condition based upon appropriate engineering guidance. The evidence of aging affects at the insulation cover gives sufficient time to respond to the deterioration of the tank so that the effect of the aging is managed."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the program consistent with the commitment to provide reasonable assurance that future inspections would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 30 may be managed using 10 CFR 50.59.

Commitment No. 31:

Revise Fire Water System Program to specify annual fire hydrant gasket inspections and flow tests.

Assessment for Commitment No. 31:

Commitment No. 31 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part, "The inspectors noted that OP-41 03, Fire Protection Equipment Surveillance, included a schedule, list of locations, and acceptance criteria to adequately control the gasket inspections. The inspectors noted that OP-41 OS, Fire Protection Systems Surveillance, included a schedule, list of locations, and acceptance criteria to adequately control the flow tests."

- 32 By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the program consistent with the commitment to provide reasonable assurance thatfuture inspections and testing would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 31 may be managed using 10 CFR 50.59.

Commitment No. 32:

Implement the Metal Enclosed Bus Program. Details are provided in an LRA Amendment 16, Attachment 3 and LRA Amendment 23, 7.

Assessment for Commitment No. 32:

Commitment No. 32 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The licensee revised plant component procedures to include steps to conduct cleaning and inspection of metal-enclosed bus ducting. These changes were made to ensure the monitoring of aging effects on metal-enclosed bus ducting is included in maintenance procedures. The inspectors reviewed Work Orders 52298615-04, "T-1-1A Main Transformer Outage Inspection," 52298263-02, "T-2-1A Auxiliary Transformer Refuel Outage PMs," and 52334425-0, "Isophase-bus, Outage PM-Clean Inspect and Test," for the recent cleaning of a section of bus ducting during the Fall 2011 refueling outage."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspection, testing and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 32 may be managed using 10 CFR 50.59.

- 33 Commitment No. 33:

Include within the Structures Monitoring Program provisions that will ensure an engineering evaluation is made on a periodic basis (at least once every five years) of groundwater samples to assess aggressiveness of groundwater to concrete. Samples will be monitored for sulfates, pH and chlorides.

Assessment for Commitment No. 33:

Commitment No. 33 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The inspectors noted that the groundwater monitoring program implemented by the applicant was included within the structural monitoring program to ensure an engineering evaluation was made on a periodic basis of at least once every 5 years of groundwater samples. The periodic ground water sample assessment evaluates the aggressiveness of groundwater to concrete. Samples are evaluated for sulfates, pH and chlorides. Attachment 9.17 to the Procedure EN-DC-150, Revision 2, defined a non-aggressive groundwater as having: pH >

5.5, sulfates < 1500 ppm, and chlorides < 500 ppm. A condition report would be initiated to assess the effects of groundwater if it exceeded these thresholds.

The inspectors reviewed groundwater test results to assess the implementation and effectiveness of the program."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the program consistent with the commitment to provide reasonable assurance that future evaluations would be performed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysiS report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 33 may be managed using 10 CFR 50.59.

Commitment No. 34:

Implement the Bolting Integrity Program. Details are provided in an LRA Amendment 16, Attachment 2 and LRA Amendment 23, Attachment 5.

Assessment for Commitment No. 34:

Commitment No. 34 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The Bolting Integrity Program is another program included within the Structural Monitoring Program. The Structural Monitoring Procedure has been enhanced and updated to clarify and provide additional guidance for assuring bolting

- 34 integrity at present, and also during the period of extended operation. The inspectors reviewed revised and updated procedures to verify the extent, clarity, and appropriateness of the guidance. Procedures reviewed included:

EN-DC-150, "Condition Monitoring of Maintenance Rule Structures," including Attachments 9.1,9.2, and 9.17; EN-DC-178; MMMP-TORQ-0212; and SEP-ISI-VTY-001. The inspectors discussed these enhancements with the applicant's engineering and inspection personnel to determine the bases for the guidance."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspection and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 34 may be managed using 10 CFR 50.59.

Commitment No. 35:

Provide within the System Walkdown Training Program a process to document biennial refresher training of Engineers to demonstrate inclusion of the methodology for aging management of plant equipment as described in EPRI Aging Assessment Field Guide or comparable instructional guide.

Assessment for Commitment No. 35:

Commitment No. 35 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The licensee has implemented a 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> classroom training program for system engineers to train the engineers in the methodology of detection of aging mechanisms. This program requires periodic refresher training in the same subject areas."

By letter dated November 20,2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection verified the training program had been revised consistent with the commitment to provide reasonable assurance that system engineers are provided training to detect aging effect. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an

- 35 SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 35 may be managed using 10 CFR 50.59.

Commitment No. 36:

If technology to inspect the hidden jet pump thermal sleeve and core spray thermal sleeve welds has not been developed and approved by the NRC at least two years prior to the period of extended operation, VY will initiate plant specific action to resolve this issue. That plant specific action may be justification that the welds do not require inspection.

Assessment for Commitment No. 36:

Commitment No. 36 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The licensee discovered indications in six jet pumps by ultrasonic testing in 1996 and repeated the ultrasonic test of the jet pumps after two subsequent cycles of operation. No growth was noted in the indications. The utility acceptably chose to use EVT-1 to continue monitoring the indications. Because the licensee uses EVT-1 to monitor indications in six jet pumps originally discovered by ultrasonic testing, they do not strictly follow the guidance contained in BWRVIP-41 that flaws be subsequently examined by the method of original discovery. In addition the licensee has chosen to defer the ultrasonic testing of a series of inaccessible, or hidden, welds until a delivery system for ultrasonic testing can be devised.

This means the licensee does not follow the guidance of BWRVI P 41 to perform a modified VT -1 of 100 percent of the hidden welds over two 6-year inspection cycles and 35 percent of these welds per inspection cycle after that. The licensee's position is justified by BWRVIP 41, Section 2.3.3.5, which states that the hidden jet pump welds are far enough into the nozzle that failure at these welds would not result in the thermal sleeve disengaging from the nozzle before the riser contacted the shroud. If the jet pump thermal sleeve or riser piping severed, it would be detected through jet pump monitoring, which alarms if the riser pipe moves more than 10 percent while at or above a core flow of 42 Mlb/hr.

Therefore, deferral of inspection of the inaccessible welds is justified in keeping with the guidance. In addition, during the review of the aging management program implementing this commitment, the NRC staff noted the safety evaluation report that accompanied the NRC's acceptance of BWRVIP 41 stated an aging management review of the nozzle thermal sleeve should be provided by users of the procedure. The licensee committed, as stated in [Commitment No.]

36 above, to plant-specific action to resolve this issue, 2 years prior to the period of extended operation [PE~], if technology to inspect the hidden jet pump thermal sleeve and core spray thermal sleeve welds has not been developed and approved by the NRC. The licensee generated "Aging Management Review of the Reactor Vessels Internals," AMRM-32, Revision 1, August 28,2008, in line with the suggestion contained in the safety evaluation report associated with BWRVIP 41. In addition, in commitment closure verification form, LRS/CMS I.D.A-16808 LOR-LAR-2010-00267, the licensee recorded their rationale for not

- 36 performing an ultrasonic test of the hidden and cores spray welds thus satisfying the commitment's requirements."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that plant-specific action would be taken to resolve issues with inspection activities.

The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the desjgn bases or in the safety analyses. By letter dated November 20, 2012, Entergy stated this commitment has been implemented. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment. The NRC staff therefore concludes that Commitment No. 36 may be managed using 10 CFR 50.59.

Commitment No. 37:

Continue inspections in accordance with the steam dryer monitoring plan, Revision 3 in the event that the BWRVIP-139 is not approved prior to the period of extended operation.

Assessment for Commitment No. 37:

This commitment addresses the continuation of inspections of the steam dryer in accordance with the Steam Dryer Monitoring Program (SDMP), Revision 3 in the event that BWRVIP-139 was not approved by the NRC staff prior to the period of extended operation. In its transmittal letter of the Vermont Yankee Renewed Facility Operating License dated March 21, 2011 (ADAMS Accession No. ML092110050), the NRC issued the following license condition (RFOLC 3.S.) for the aging management of the steam dryer at VYNPS, rendering Commitment 37 null and void:

In accordance with Atomic Safety and Licensing Board order LBP-08-25, dated November 24, 2008, notwithstanding any other provision of this license, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. shall continue to perform and implement the continuous parameter monitoring, moisture content monitoring, and visual inspections specified in the SDMP at the intervals specified in General Electric Services Information Letter 644, Revision

2. These shall continue for the full term of the period of extended operation unless this provision of the license is duly amended.

The licensee submitted a separate license amendment application dated December 11, 2011 (ADAMS Accession No. ML11363A049), as supplemented by letter dated October 3,2012 (ADAMS Accession No. ML12284A478) to revise RFOLC 3.S. and allow BWRVIP-139-A, "BWR

- 37 Vessel and Internals Project Steam Dryer Inspection and Flaw Evaluation Guidelines," to be the basis for future steam dryer monitoring and inspections on an inspection interval of at least every third refueling outage. The NRC staff approved the license amendment request in VY License Amendment No. 229, dated December 19, 2012 (ADAMS Accession No. ML12338A236), and revised RFOLC 3.S to state:

1. The licensee shall inspect the steam dryer during refueling outage (RFO) 31. If the steam dryer inspection results from RFO 31 demonstrate that (a) any new cracking due to either fatigue or intergranular stress-corrosion cracking (IGSCC) is not significant (i.e., is evaluated to be acceptable without repair), and (b) all previously identified indications (including the new indication identified in RFO 27) show no crack growth requiring repair, the licensee shall initiate a program to perform steam dryer inspections at least every third refueling outage.

2. If the steam dryer inspection during RFO 31 or any subsequent steam dryer inspection reveals new cracking due to either fatigue or IGSCC that requires repair, or any growth of existing cracking that requires repair, the licensee shall inspect the steam dryer during each refueling outage.

3. The steam dryer inspection during RFO 31 and all future steam dryer inspections shall meet the guidelines in BWRVI P-139-A with the exception of the inspection interval specified in BWRVIP-139-A. The results of the steam dryer inspection beginning with RFO 31 and continuing for all future inspections shall be submitted to the NRC within 6 months of each steam dryer inspection completion.

4. This license condition shall continue for the full term of the period of extended operation unless duly amended.

The NRC staff concludes that the licensee's technical justification demonstrates that Commitment No. 37 has been superseded by RFOLC 3.S and need not be included in the UFSAR supplement or managed using 10 CFR 50.59.

Commitment No. 38:

The BWRVIP-116 report which was approved by the staff will be implemented at VYNPS with the conditions documented in Sections 3 and 4 of the staffs final SE dated March 1,2006, for the BWRVIP 116 report.

Commitment No. 39:

If the VYNPS standby capsule is removed from the reactor vessel without the intent to test it, the capsule will be stored in a manner which maintains it in a condition which would permit its future use, including during the period of extended operation, if necessary.

Assessment for Commitment Nos. 38 and 39:

Commitment Nos. 38 and 39 were reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states,

- 38 "BWRVIP-86, Revision 1, replaces BWRVIP-116 and is approved by the NRC.

Commitment [No.] 39 requirements are narrowed by [RFOLC] 3.R to specify the future use must support the re-insertion into the reactor vessel. Condition 3.R states:

Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. shall implement the most recent NRC staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) as the method to demonstrate compliance with the requirements of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule withdrawal schedule must be submitted for NRC staff review and approval. Any changes to the BWRVIP ISP capsule withdrawal schedule which affects the time of withdrawal of any surveillance capsules must be incorporated into the licensing basis. If any surveillance capsules are removed without the intent to test them, these capsules must be stored in a manner which maintains them in a condition which would support re-insertion into the reactor.

The licensee incorporated these commitments into SEP-FTY-VTY, Revision 1, issued January 3, 2012, "Reactor Vessel Fracture Toughness and Surveillance Material Testing in Vermont Yankee." The inspectors noted the procedure also incorporated the other requirements of the license condition, including the requirement to submit to the NRC, for approval, any changes made to the capsule withdrawal schedule. The procedure also incorporates the requirement to incorporate changes affecting the time of withdrawal, as stipulated in BWRVIP-86, "Updated BWR Integrated Surveillance Program (lSP) Implementation Plan" into the design basis."

By letter dated November 20, 2012, Entergy stated these commitments were implemented and the UFSAR revised to include the commitments. NRC inspection confirmed that the licensee implemented the necessary actions consistent with these commitments to provide reasonable assurance that the capsule withdrawal schedule will be followed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: require a change to the technical specifications incorporated in the license; result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes Commitment Nos. 38 and 39 may be managed using 10 CFR 50.59.

Commitment No. 40:

This commitment has been deleted and replaced with Commitment No. 43.

- 39 Commitment No. 41:

This commitment has been deleted and replaced with Commitment No. 43.

Commitment No. 42:

Implement the Bolted Cable Connections Program. Details are provided in LRA Amendment 23, Attachment 7.

Assessment for Commitment No. 42:

Commitment No. 42 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The program, as described in the LRA, is a one-time program to confirm that loosening of bolted connections is not occurring. The inspectors reviewed the commitment completion review report and associated work orders to verify that the inspection program demonstrated that the loosening of bolted cable connections was not occurring. The inspection program evaluated a sample of bolted cable connections by inspecting them visually and testing the connection resistances. Connection resistances were measured prior to and after maintenance which disconnected and reconnected the bolted cable connection.

The acceptance criteria for connection resistances were that the as-found resistances must be within a factor of five of the as-left resistances. The inspectors had several concerns about the program. The inspectors questioned the basis for the factor of five acceptance criteria. Entergy reviewed the acceptance criteria and determined that appropriate acceptance criteria would be 125 micro-ohms based on an evaluation of voltage drop and heating.

[The]125 micro-ohms is the result of a bounding calculation using the maximum loaded conductor connection at Vermont Yankee which is the 3750 kVA T Vernon-Hydro Transformer at full load compared to the voltage-drop criteria used for a voltage sensitive connection at Vermont Yankee, such as the 50 mV criteria used for the Station Battery installation. The inspectors reviewed the evaluation for the revised value and determined that there was a sufficient technical basis for the new acceptance criteria. The total bolted connection population was determined and the sampling program of EPRI Report TR-107514 was applied.

The confidence level criteria applied to a random population would have resulted in a minimum sample of 25 bolted connections. The guidance, however, gives selection criteria for circuit loading, adverse location, such as high temperature, high humidity, vibration, etc., that resulted in 220 bolted connections being selected. After reviewing the data, the inspectors questioned samples recorded on a scale of ohms instead of micro-ohms. After reviewing the documented test equipment used to develop the data, Entergy determined some samples were taken with instruments incapable of reporting values in micro-ohms. Entergy agreed the samples performed with incorrect instruments were not valid samples for demonstrating that connections were adequate or inadequate, and subsequently removed the samples from the evaluation. The inspectors determined that removing the invalid samples was appropriate. The inspectors questioned other samples recorded with large resistances. Entergy reviewed this issue and identified six samples in excess of the 125 micro-ohms threshold. The

- 40 locations were all associated with connections made to transformer T-3-1 B. The connections were C1333C and D on Phase A, C1333B and C of Phase B, and C1333C and E on Phase C. Entergy reviewed the associated work orders to verify the documented visual inspections of the connections did not report any signs of overheating. Overheating would have been expected for a connection with large resistance. Based on the lack of reported overheating and the location of the samples, Entergy suggested the large resistances were due to poor measuring techniques. To verify this, Entergy created a corrective action (LO LAR-2010-00271 CA 4) to re-measure the connections during the next scheduled maintenance on the connections with high recorded resistances. The inspectors reviewed Entergy's evaluation and the work orders and agreed that there is reasonable assurance that the connections were not loose and that re-measuring the connections is appropriate. In light of the previous concerns, the inspectors questioned the adequacy of the data available to provide reasonable assurance that this one-time program had demonstrated that the loosening of bolted connections was not occurring. Entergy provided the inspectors with operating experience reviews in the form of condition report searches, which showed that between January 1, 1998, and February 29, 2012, there were only two potential examples of bolted electrical connections loosening. CR-VTY-2007-02196 was a loose connection in the main transformer control panel and CR-VTY-2007-02605 was a loose connection to DG-3-1A output connector. Entergy also provided the revision to VY-RPT-11-00017, Bolted Cable Connection Inspection Report, which documented 220 diverse samples. Of the samples, only six did not meet the initial acceptance criteria; but all six met the visual inspection acceptance criteria and all six will be re-measured to confirm the results. The inspectors reviewed the operating experience results and revised report and agreed that Entergy had demonstrated reasonable assurance of the effectiveness of this one-time program."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future inspection, testing and maintenance activities would be completed in accordance with the program. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 42 may be managed using 10 CFR 50.59.

Commitment No. 43:

Establish and implement a program that will require testing of the two 13.8 kV cables from the two Vernon Hydro Station 13.8 kV switchgear buses to the 13.8

- 41 kV / 69 kV step up transformers before the period of extended operation and at least once every 6 years after the initial test.

Assessment for Commitment No. 43:

Commitment No. 43 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The inspectors reviewed the commitment completion review reports, manhole inspection results, and cable test results to verify that potential aging effects to inaccessible cables were being adequately managed. The inspectors reviewed tan delta and insulation resistance test results to verify that cable testing frequencies were established based on cable performance. The inspectors verified that the cable testing program included medium and low voltage cables.

The inspectors also reviewed the manhole inspection results and determined that all of the manholes had been inspected and future work orders were designed to inspect the manholes on appropriate frequencies and at least once every year.

The inspectors reviewed OP-PHEN-3127, "Natural Phenomena Operating Procedure," to verify that the manholes will be inspected under conditions of high river level or after heavy rain. The inspectors also interviewed the project manager to review any operating experience or implementation issues.

Commitment [No.] 43 applied the Commitment [No.] 13 cable testing program to the cables between Vermont Yankee and the Vernon Hydro Station. The inspectors reviewed the cable testing program to ensure that the cables between Vermont Yankee and Vernon Hydro Station were included in the cable testing program, the cables had been tested satisfactorily, and the cable testing frequency was set at 6 years."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee implemented the necessary actions consistent with the commitment to provide reasonable assurance that future testing activities would be completed in accordance with the program.

Inspectors also reviewed the initial test results which were found to be satisfactory. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 43 may be managed using 10 CFR 50.59.

Commitment No. 44:

This Commitment has been deleted and replaced with Commitment No. 54.

- 42 Commitment No. 45:

Enhance the Service Water Integrity Program to require a periodic visual inspection of the RHRSW pump motor cooling coil internal surface for loss of material.

Assessment for Commitment No. 45:

Commitment No. 45 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "As recorded in Condition Report LO-LAR-2010-00274, the licensee revised the "Vermont Yankee Heat Exchanger Program" (EN-SEP-HX-001) to include the periodic visual inspection of the RHRSW pump motor cooling internal surfaces and to flush the RHRSW Pump Motor Coolers. Procedure OPOP-RHR-2124, "Residual Heat Removal System," has been revised to add Attachment 7 - "Coil Flush." This "Residual Heat Removal Service Water Pump Motor Cooling" attachment provides a procedure for performing a pre-inspection flush of the RHRSW Pump Motor Coolers. Work Orders (00291967-01, 00291968-01, 00291969-01, and 00291970-01) were initiated to perform baseline cooler flushes and visual inspections. The licensee documented, via CR-VTY-2012 00218, efforts to perform a boroscopic visual inspection on a mockup of the RHRSW pump motor cooler. The boroscopic examination failed and CR-VTY-2012-00218, "Corrective Action Plan," contains various steps to remedy the failure. For example:

• Action A, 1. determine if a boroscope exists that can negotiate the piping elbows of the motor cooling coils.

• Action A, 2. determine if a repair technique is available to allow the inlet and outlet lines to be cut off for access.

• Action A, 3. determine if alternate NDE is available.

• Action A, 4. identify the cost and availability of replacement coils. The inspectors noted that replacement of the coils, without a destructive visual examination of the existent coils would require revising the commitment because no visual inspection would be performed.

The licensee stated that, although these motor coolers are original plant equipment subject to aging effects, the coolers are periodically inspected during operator rounds and no leakage has been detected visually. Although no visual examination of the internal surface of the RHRSW pump motor cooling internal surfaces has been performed, the commitment to enhance the service water integrity program to require the inspection has been completed. Because the coolers currently meet design and operational requirements without leakage, and are visually inspected on a regular basis, there is adequate time for the licensee to find and implement an alternate solution."

- 43 By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the program consistent with the commitment to provide reasonable assurance that future inspections would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated);

result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 45 may be managed using 10 CFR 50.59.

Commitment No. 46:

Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the fire pump diesel storage (day) tank will be analyzed according to ASTM 0975 and for particulates per ASTM 02276. Also, fuel oil in the John Deere diesel storage tank will be analyzed for particulates per ASTM 02276.

Commitment No. 47:

Enhance the Diesel Fuel Monitoring Program to specify that fuel oil in the common portable fuel oil storage tank will be analyzed according to ASTM 0975, per ASTM 02276 for particulates, and per ASTM 02709 for water and sediment.

Assessment for Commitment Nos. 46 and 47:

Commitment Nos. 46 and 47 were reviewed by inspectors during Phase II of the IP 71003 inspection. The results were documented in IR 05000271/2012008 which states, in part, "The inspectors reviewed the chemistry procedure used to sample and test diesel fuel oil, which had been revised to include the fire pump diesel, John Deere diesel, and common portable fuel oil storage tanks per the applicable standards.

The inspectors reviewed five completed fuel oil analyses for the fire pump and John Deere diesels. The common portable fuel oil storage tank is stored empty and used only as needed; no usage has occurred subsequent to the enhancement. "

By letter dated November 20, 2012, Entergy stated these commitments have been implemented and the UFSAR revised to include the commitments. NRC inspection confirmed that the licensee implemented the necessary actions consistent with these commitments to provide reasonable assurance that fuel oil would be analyzed in accordance with applicable standards.

The 10 CFR 50.59 process provides assurance that any future modifications to the commitments described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously

- 44 evaluated in the final safety analysis report (as updated); result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment Nos. 46 and 47 may be managed using 10 CFR 50.59.

Commitment No. 48:

Perform an internal inspection of the underground Service Water piping before entering the period of extended operation.

Assessment for Commitment No. 48:

By letter dated November 20, 2012, Entergy stated this commitment has been implemented and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated).

The NRC staff therefore concludes that Commitment No. 48 may be managed using 10 CFR 50.59.

Commitment No. 49:

Revise station procedures to specify fire hydrant hose testing, inspection, and replacement, if necessary, in accordance with NFPA code specifications for fire hydrant hoses.

Assessment for Commitment No. 49:

Commitment No. 49 was reviewed by inspectors during Phase II of the IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "The inspectors reviewed the commitment completion review report and applicable surveillance procedure to verify that the procedures had been enhanced to include guidance in accordance with NFPA 1962-2008, "Standard for the Inspection, Care, and Use of Fire Hose, Couplings, and Nozzles and the Service Testing of Fire Hose." The inspectors noted that OP-41 04, Fire Hose Service Test Surveillance, included the requirements of NFPA 1962. The inspectors also interviewed the project manager to review any operating experience or implementation issues."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee revised the procedure consistent with the commitment to provide reasonable assurance that future inspection, testing and maintenance activities would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a

- 45 malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 49 may be managed using 10 CFR 50.59.

Commitment No. 50:

During the period of extended operation, review the Vernon Dam owner FERC required report(s) at a minimum of every five years to confirm that the Vernon Dam owner is performing the required FERC inspections. Document deficiencies in the Entergy Corrective Actions Program and evaluate operability as described in BVY 96-043 and BVY 97-043 if it is determined that the required inspections are not being performed.

Assessment for Commitment No. 50:

Commitment No. 50 was reviewed by inspectors during Phase II of the I P 71003 inspection.

The results were documented in IR 05000271/2012008 which states, "In a letter dated July 3,2007, the licensee committed to confirm the Vernon Dam owner is performing the required FERC inspections based on a review of the Vernon Dam owner's report to FERC. On July 14, 2011, the licensee submitted a request FERC for a copy of the "Dam Safety Inspection Report" for the Vernon Project for the period May 11,2005 to June 2,2008. On September 16,2011, FERC granted the licensee access to the report in Release Letter, CEil No.

CE11-181. Because the licensee was granted access, they were able to review the Vernon Dam owner's report to the FERC, as stipulated in Commitment [No.]

50."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee had the capability to perform the reviews to provide reasonable assurance that future inspection would be confirmed completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 50 may be managed using 10 CFR 50.59.

Commitment No. 51:

Entergy will perform an evaluation of operating experience at extended power uprate (EPU) levels prior to the period of extended operation to ensure that operating experience at EPU levels is properly addressed by the aging management programs. The evaluation will include Vermont Yankee (VY) and other BWR plants operating at EPU levels.

- 46 Assessment for Commitment No. 51:

By letter dated November 20,2012, Entergy stated this commitment was completed and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance that the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that although Commitment No. 51 is complete, inclusion in the UFSAR is consistent with the staff's expectation at the time of renewal. Therefore this commitment can be managed using 10 CFR 50.59.

Commitment No. 52:

Implement the Neutron Absorber Monitoring Program as described in LRA Section B.1.31. Test one coupon prior to the PEO to measure B-10 areal density and assess the geometric and physical condition of the tested coupon. If coupons are not able to be retrieved and tested or if coupons cannot be demonstrated representative of the Boral in the Holtec racks, then perform neutron attenuation testing using in-situ methods, as described in BVY 11-010, (BADGER or blackness testing method) prior to the end of 2014.

Assessment for Commitment No. 52:

This commitment states that the licensee will implement an AMP and perform testing prior to and possibly during the period of extended operation. Testing of the Boral coupons, neutron attenuation testing and implementing the Neutron Absorber Monitoring Program are performed to ensure that the Boral in the spent fuel pool racks will be able to perform its safety function in the period of extended operation. VY technical specification section 5.5 requires that the Kelf of the spent fuel pool be less than or equal to 0.95. In order to demonstrate compliance with the technical specification and the NRC regulations (10 CFR 50.68 or GDC 62), and establish the design bases, the licensee should perform tests or surveillances of the material to ensure the material can still perform its intended function, as described in the criticality analysis of record, until the next test or surveillance.

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: require a change to the technical specifications incorporated in the license; result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 52 may be managed using 10 CFR 50.59.

\\

- 47 Commitment No. 53:

During the period of extended operation, VYNPS will perform periodic volumetric examinations of small-bore Class 1 socket and butt welds. The examinations will include 10% of the Class 1 weld population greater than or equal to 1 and less than 4 inch NPS up to a total of 25 welds of each weld type. In lieu of a volumetric examination for socket welds, a destructive examination may be performed. Each destructive exam will be equivalent to two ultrasonic examinations when determining the number of completed inspections. The examination method will be a volumetric examination of the base and weld metal using a demonstrated ultrasonic examination technique. Inspection results will determine the need for additional or periodic examinations. The examinations will be performed by December 2016.

Assessment for Commitment No. 53:

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated);

create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 53 may be managed using 10 CFR 50.59.

Commitment No. 54:

Prior to the PE~, VYNPS will inspect portions of the standby gas treatment system buried piping. The inspections will consist of direct visual examination of a minimum of two sections of piping and cover the entire circumference of at least ten linear feet of piping in each section.

During the PE~, inspections of two carbon steel piping segments in the standby gas treatment system and four carbon steel piping segments in the service water system will be performed every 10 years if measured soil resistivity is > 20,000 ohm-cm and the soil corrosivity index is 10 or less using AVVWA C105. If the soil resistivity is < 20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AVVWA C 1 05, the number of inspections of the standby gas treatment system buried piping will be increased to three and the number of inspections of the service water system buried piping will be increased to six. Each of these direct visual inspections following excavation will cover the entire circumference of at least ten linear feet of piping.

During the PE~, two inspections covering at least 8% of the total length of in scope buried fuel oil piping (-40 feet) will be performed at least once every 10

- 48 years. If the soil resistivity is < 20,000 ohm-cm or the soil corrosivity index is higher than 10 points using AWWA C 105, the percentage offuel oil buried piping inspected will be increased to 12%.

Soil samples will be taken prior to the period of extended operation and at least once every 10 years thereafter to confirm the initial sample results.

Assessment for Commitment No. 54:

Commitment No. 54 was reviewed by inspectors during Phase I of the IP 71003 inspection. The results were documented in IR 05000271/2011011 which states, "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):

• Yard - Commitment 54 (Standby gas treatment system buried piping 12" SGT-1)

The inspectors determined the general conditions to be satisfactory and the Entergy activities to be in accordance with facility programs and procedures."

By letter dated November 20,2012, Entergy stated this commitment has been implemented and the UFSAR revised to include the commitment. NRC inspection confirmed visual inspections observed before the period of extended operation were satisfactory. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 54 may be managed using 10 CFR 50.59.

Commitment No. 55:

Enhance safety-related coatings programs and procedures to be consistent with the recommendations of NUREG-1801,Section XI,S8, Protective Coating Monitoring and Maintenance Program.

Assessment for Commitment No. 55:

Commitment No. 55 was reviewed by inspectors during Phase II ofthe IP 71003 inspection.

The results were documented in IR 05000271/2012008 which states, in part, "The licensee commented on the safety evaluation report by letter, dated May 19, 2011 (BVY 11-033), in which the licensee suggested 18 corrections, errata, and edits. Comment Number 18 points out "LRA Commitment No. 55 is not listed in the Appendix. It is referenced and discussed in Section 3.0.3.1.13." In this

- 49 section of the safety evaluation report: "The NRC staff also notes that the applicant committed (Commitment No. 55) to enhance the safety-related coatings program and procedures to be consistent with the recommendations of GALL AMP XI.SB." As a consequence, the omission of Commitment [No.] 55 from Appendix A of the Safety Evaluation Report, creating a new aging management program for the control of coating inside containment, was not controlled by the provisions of License Condition Q. Any modification to the commitment can be implemented using NEI 99-04 and 10 CFR 50.59. The licensee treated this commitment like all the other commitments they made that were registered in Appendix A of the safety evaluation report and entered this commitment into their commitment tracking system as A-16964 and tracked it to completion under LO LAR 2010-0367, which revised program SEP-COAT-001 and procedure EN-DC-220."

By letter dated November 20, 2012, Entergy stated this commitment was implemented and the UFSAR revised to include the commitment. NRC inspection confirmed that the licensee enhanced the programs and procedures consistent with the commitment to provide reasonable assurance that future inspection and testing activities would be completed. The 10 CFR 50.59 process provides assurance that any future modifications to the commitment described in the UFSAR would not, among other things: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the final safety analysis report (as updated); result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated; or result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The NRC staff therefore concludes that Commitment No. 55 may be managed using 10 CFR 50.59.

3.3 Summary of request to apply 10 CFR 50.59 to commitments in the UFSAR:

The NRC staff has reviewed the VY SER for license renewal, the licensee's analysis provided in its submittal dated November 20, 2012, and the results of the IP 71003 inspection as documented in IR 05000271/2011011 for Phase I and IR 05000271/201200B for Phase II.

The commitments listed in Appendix A of Supplement 2 to NUREG-1907 were relied on by the NRC staff. The NRC staff finds that the actions in Commitment Nos. 1-5, 6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 3B, 39, 42, 43, and 45-55 have been implemented andlor completed. Additionally, the actions are part of the aging management activities that the NRC staff expected to be included in the UFSAR supplement; and the 10 CFR 50.59 process is acceptable to control any changes to these actions consistent with NUREG-1BOO. Based on these findings, the NRC staff concludes that the actions in Commitment Nos. 1-5,6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 3B, 39, 42, 43, and 45-55 are acceptable to be incorporated as part of the UFSAR and managed in accordance with 10 CFR 50.59.

In VY License Amendment No. 229, dated December 19, 2012 (ADAMS Accession No. ML 1233BA236), the NRC staff approved a revision to RFOLC 3.S. The NRC staff concludes that the licensee's technical justification demonstrates that Commitment No. 37 has been superseded by RFOLC 3.S and need not be included in the UFSAR supplement or managed using 10 CFR 50.59.

- 50 3.4 Technical Evaluation of License Conditions 3.4.1 Evaluation of request to amend RFOLC 3.P:

The NRC staff has reviewed the licensee's analysis provided in its submittal dated November 20,2012, with regards to amending RFOLC 3.P. The proposed license condition for RFOLC 3.P excludes Commitment Nos. 27, 29, and 51 on the basis that the licensee indicates these actions have been completed. The actions in Commitment Nos. 27, 29, and 51 were relied upon by the NRC staff during the LRA review. According to NRR Office Instruction LlC-1 01, "License Amendment Review Procedures," Revision 4, if the NRC staff relies on an action in a commitment, the action needs to be incorporated as part of a mandated licensing basis document, such as the UFSAR, or escalated to a license condition. The NRC staff finds it acceptable to incorporate the actions in Commitment Nos. 27, 29, and 51 as part of the UFSAR for the reasons described in section 3.2 of this document. Therefore, Commitment Nos. 27, 29, and 51 will be listed in RFOLC 3.P.

By letter dated April 24, 2012, Entergy incorporated the commitments in Revision 25 of the UFSAR.

In e-mail messagesdatedMarch26.2013(ADAMSAccessionNo.ML13085A421) and April 5, 2013 (ADAMS Accession No. ML13095A278), the licensee agreed to revise the proposed changes to RFOLC 3.P. for added clarification of the license condition. Specifically, the word "and" was added to the first sentence of the license condition and"... is henceforth... " was changed to "shall be incorporated as..." to clarify that the licensee is required to incorporate the commitments into the UFSAR, and that changes to those commitments would be subject to 10 CFR 50.59 criteria. The licensee also agreed to consolidate the commitment numbers listed in RFOLC 3.P.

The NRC staff finds acceptable and approves the following wording for RFOLC 3.P:

The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21 (d), as revised during the license renewal application process, and as supplemented by Commitment Nos. 1-5,6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39, 42, 43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 shall be incorporated as part of the UFSAR which will be updated in accordance with 10 CFR 50.71 (e).

As such, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1-5,6 (as revised by Entergy Nuclear Vermont Yankee, LLC letter dated May 19, 2011), 7-36, 38, 39,42,43, and 45-55 of Appendix A of Supplement 2 of NUREG-1907 provided Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

3.4.2 Evaluation of request to amend RFOLC 3.0:

The licensee proposed to remove the phrase "... and/or during... " from license condition RFOLC 3.0. The NRC staff has reviewed the licensee's analysis provided in its submittal dated November 20, 2012, and the results of the IP 71003 inspection as

- 51 documented in IR 05000271/2011011 for Phase I and IR 05000271/2012008 for Phase II, with regards to amending RFOLC 3.0 as proposed by the licensee. The intent of the RFOLC 3.0 was to ensure that: (1) the license renewal programs and activities that were scheduled to be implemented and/or completed prior to the period of extended operation were implemented and/or completed, and (2) the NRC received notification so NRC staff could verify implementation of activities through inspection.

By letter dated March 16, 2012 (ADAMS Accession No. ML12083A068) the licensee notified the NRC that activities to be completed prior to the period of extended operation were implemented or completed and could be verified by inspection.

In supplemental correspondence dated March 29, 2013 (ADAMS Accession No. ML13092A106), the licensee proposed that RFOLC 3.0 be deleted because its previous proposed revision to RFOLC 3.0 would not apply to the period of extended operation and deletion of the historical requirement would be an administrative change.

The NRC staff finds that deletion of RFOLC 3.0 is acceptable. The commitments listed in Appendix A of Supplement 2 to NUREG-1907 have either been implemented and/or completed as documented in: (1) IR 05000271/2011011 (ADAMS Accession No. ML113560064) and IR 05000271/2012008 (ADAMS Accession No. ML12103A406) or (2) licensee correspondence submitted on November 20, 2012, under oath and affirmation. The commitments addressing license renewal activities to be completed prior to and/or during the period of extended operation have been incorporated in the UFSAR to be managed by 10 CFR 50.59 and will be governed by RFOLC 3.P.

Additionally, the licensee has entered the period of extended operation. Therefore, the NRC staff concludes that RFOLC 3.0 is no longer needed and RFOLC 3.0 can be deleted.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Vermont State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (77 FR 20074). Additionally, the amendment changes recordkeeping, reporting, or administrative procedures or requirements and changes the format of the license or otherwise makes editorial, corrective or other minor revisions.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

- 52

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: H. Jones, NRRIDLR/RSRG Date: April 17, 2013

April 17, 2013 Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT TO RENEWED FACILITY OPERATING LICENSE RE: LICENSE CONDITION 3.P AND 3.Q CHANGES (TAC NO. ME8151)

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 256 to Renewed Facility Operating License No. DPR-28 for the Vermont Yankee Nuclear Power Station (VYNPS), in response to your application dated March 5, 2012, as supplemented on November 20, 2012, March 26, March 29, and April 5, 2013.

The licensee's application for the proposed amendment revised the VYNPS License Conditions 3.P and 3.Q to clarify that the information in the updated final safety analysis report (UFSAR) supplement submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 54.21 (d), as revised during the license renewal application review process, and as supplemented by commitments of Appendix A of Supplement 2 of NUREG-1907, can be incorporated as part of the UFSAR and may be changed without prior NRC approval provided the requirements of 10 CFR 50.59 have been previously satisfied. Entergy submitted a related license amendment request by letter dated March 12,2012 (ADAMS Accession No. ML12079A031). The submittal is being reviewed under a separate technical assignment control (TAC) number.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Therefore, TAC No. ME8151 associated with this review will be closed.

Sincerely, IRA!

Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271

Enclosures:

1. Amendment No. 256 to License No. DPR-28

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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NAME RGuzman KGoldstein YDiaz-Sanabria*

MYoung SMeighan DATE 2114/13 2/14113 13/9/13 418113 4/17/13 OFFICIAL RECORD COpy