ML113560064

IR 05000271/2011011; 10/17/2011 - 12/1/2011; Vermont Yankee Nuclear Power Station; Review of License Renewal Activities

ML113560064
Person / Time
Site:	Vermont Yankee
Issue date:	12/22/2011
From:	Conte R Engineering Region 1 Branch 1
To:	Wamser C Entergy Nuclear Operations
References
IR-11-011
Download: ML113560064 (12)

See also: IR 05000271/2011011

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA, PA 19406-1415

December 22, 20lL

Mr. Christopher Wamser

Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear power Station

185 Old Ferry Road

P.O. Box 500

Brattleboro, VT 05302-0500

SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION

INSPECTION REPORT 0500027

- NRC INTEGRATED

1 t2ol 1 01 1

Dear Mr. Wamser:

on october 20,2011, the U.S. NuclearRegulatory Commission (NRC) completed

an inspection

at the Vermont Yankee Nuclear Power Staiion. the enctosed report documbnts the results of

the inspection, which were discussed on october 20, and December

z 2011, wrth you and other

members of your staff.

This inspection was an examination of activities under your renewed

operating license related to

the completion of commitments made during the renewed lic"nre

apptication f,rocess and

compliance with the conditions of your licenie. Under the renewed

operating license, entry into

the period of extended opelations is planned for March 22,2012. Th;

inap;tion

-witninwas directed

toward those activities and facilities accessible during the refueling

outate. these areas,

the inspection involved examination of selected proc6dur"s and representative

records,

observations of activities, and interviews with personnel.

on the basis of the samples selected for review, there were no findings identified

during this

inspection' We plan to continue to review Commitment Nos. 6, 12,aid

2s, along with your

process for commitment change management during future planned

license renewal team

inspections, prior to March 22.20112.

C. Wamser 2

tn accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from

the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading

Room).

Sincerely,

/Z,tr*J>M

Richard J. Conte, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-271

License No. DPR-28

Enclosure:

NRC lnspection Report 0500027 1 1201 101 1

cc w/enclosure: Distribution via ListServ

C. Wamser 2

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from

the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading

Room).

Sincerely,

/RN

Richard J. Conte, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-271

License No. DPR-28

Enclosure:

NRC Inspection Report 05000271 1201 1011

cc w/enclosure: Distribution via ListServ

Distribution w/encl:

W. Dean, RA (RIORAMAIL RESOURCE)

D. Lew, DRA (RIORAMAIL RESOURCE)

D. Roberts, DRP (RIDRPMAIL RESOURCE)

D. Ayres, DRP (RIDRPMAIL RESOURCE)

C. Miller, DRS (RIDRSMAIL RESOURCE)

P. Wilson, DRS (RIDRSMAlL RESOURCE)

M. Franke, Rl OEDO

R. Bellamy, DRP

T. Setzer, DRP

E. Keighley, DRP

K. Dunham, DRP

S. Rutenkroger, DRP, SRI

S. Rich, DRP, Rl

A. Rancourt, DRP, OA

RidsNrrPMVermontYankee Resource

RidsNrrDorlLl 1 -1 Resource

ROPreportsResource@nrc.qov

SUNST Review complete: RJc (Reviewer's Initials) ADAMS ACCESSION NO': ML1 13560064

DOCUMENT NAME: G:\DRS\Engineering Branch 1\-- Meyer\W Lic Renewal\2o111206 05000271 2011011 VY 1P71003 Inspection Report'docx

After declaring this document "An Official Agency Record" it will be released to the Public.

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OFFICE RI/DRS

DATE 1219111 12112111

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-271

License No.: DPR.28

Report No.: 0500027112011011

Licensee: Entergy Nuclear Operations, Inc. (Entergy)

Facility: Vermont Yankee Nuclear Power Station

Location: Vernon, VT

Dates: October 17 - 20, and December 1, 2011

Inspectors: G. Meyer, Senior Reactor Inspector, Division of Reactor Safety

M. Modes, Senior Reactor Inspector, Division of Reactor Safety

Approved By: Richard J. Conte, Chief

Engineering Branch 1

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

-

lR 0500027112011011; 1011712011 121112011; Vermont Yankee Nuclear Power Station;

Review of License Renewal Activities.

The report covers a one week inspection of the implementation of license renewal activities

during the Vermont Yankee refueling outage. lt was performed by two region based

engineering inspectors under lnspection Procedure 71003.

Enclosure

RePort Details

4. oTHER ACTTVIilES (OA)

4042 Other - License RenewalActivities

On March 21,2011, NRC issued a renewed operating license for the facility, based on

review of the Vermont Yankee License RenewalApplication (LRA) submitted on

January 27 , 2006. ln March 2011, NRC issued Supplement 2 to NUREG 1907, "Safety

Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power

Station," which contained Appendix A, Commitment Listing, listing 55 commitments. The

applicant made the commitments to provide aging management programs to manage

aging effects on structures, systems, and components (SSC) prior to and during the

period of extended operation, as well as other information. The period of extended

operation begins on March 22,2012, upon expiration of the plant's original license term.

lnspection Scope (lP 71003)

This inspection was performed by two NRC Region I based inspectors to evaluate the

license renewal activities at the Vermont Yankee Nuclear Power Station in accordance

with Inspection Procedure (lP) 71003. The inspection was directed toward those

activities and facilities accessible during the refueling outage in order to determine if

license renewal commitments were being met.

b. Findinos and Observations

No findings were identified.

b. 1 In-plant Observations

The inspectors observed ongoing activities and inspected the general condition of SSCs

within the scope of license renewal. The inspectors performed reviews in the following

areas, as related to commitments and aging management programs (AMP):

o Drywell- Inservice Inspection (lSl) Program

. Service Water System - Commitment24 (System Walkdown Program)

. Reactor Building - Commitment 12 (Heat Exchanger Monitoring Program)

. Turbine Building - Commitmenl24 (System Walkdown Program)

. Cooling Tower - Commitments 21 and 23 (Cooling tower structural examinations)

. Yard - Commitment 1 (Offgas system buried piping 24'OG-5 and 16" OG-2)

. Yard - Commitment 54 (Standby gas treatment system buried piping 12'SGT-1)

. Advanced Offgas Building - Commitment 15 (Non-EQ Insulated Cables and

Connections Program)

The inspectors determined the general conditions to be satisfactory and the Entergy

activities to be in accordance with facility programs and procedures.

Enclosure

2

b.2 Commitments Reviewed

Commitment 6 - Computerized fatigue monitoring

In the March 2011 SER Supplement, Commitment 6 states, "A computerized monitoring

program (e.9., FatiguePro) will be used to directly determine cumulative fatigue usage

factors (CUF) for locations of interest."

The inspectors determined that Entergy had removed the use of FatiquePro as a part of

Commitment 6. Specifically, Entergy submitted the Vermont Yankee license renewal

application on January 27,2006, with an enhancement to the Fatigue Monitoring

Program, which stated that "A computerized monitoring program (e.9., FatiguePro) will

be used to directly determine CUFs for locations of interest." On March 30, 2007, NRC

issued "Safety Evaluation Report with Confirmatory ltems Related to the License

Renewal of Vermont Yankee Nuclear Power Station," which contained Appendix A,

Commitment Listing, in which Commitment 6 was recorded. Subsequent versions of the

Safety Evaluation Report (SER) as NUREG-1907 did not revise the commitment.

Entergy approved the removal of FatiguePro on January 6,2011. The renewed license

was issued March 21, 2011. In letter BVY 1 1-026 dated May 19, 2011, Entergy

informed NRC that Commitment 6 had been changed to be "Manual cycle counting will

be used to track and compare accumulated cycles against allowable values to determine

if cumulative usage factors are required to be updated." The inspectors noted that this

change, in essence, rescinded the commitment, as manualcycle counting had been the

existing method at the time of the application submittal and would not have necessitated

an enhancement and subsequent commitment. Also, the Entergy letter did not request

approval of the rescinding, as indicated by the statement that no action was required of

NRC.

The inspectors could not clearly determine whether Entergy had met the expectations of

the commitment change processes as specified in the license conditions of the renewed

Vermont Yankee license, NRC-endorsed NEI 99-04 "Guidelines for Managing NRC

Commitment Changes,' (ML003680088), and Entergy procedure EN-LI-1 1 0,

Commitment Management Program, Revision 4. The key concern is whether NEI 99-04

and EN-Ll-110 were consistent in pointing Entergy towards NRC notification versus NRC

approval in making changes to its commitments. The answer was not apparent in this

situation due to various possible interpretations of the two guidance documents,

particularly on how the commitment was considered during the staffs review and the

implementation timing of the commitment (scheduled for March 22,2012).

The inspectors noted that the significance of the above concerns was minimal in this

particular case. Manual cycle counting has represented an acceptable method in some

applications. The Pilgrim license renewal application, which was submitted concurrently

with the Vermont Yankee license renewal application, had used manual cycle counting,

and NRC issued the Pilgrim Safety Evaluation Report and supplements without a

commitment for fatigue monitoring. Other plants with renewed licenses have had

manual cycle counting. Also, Entergy chose to notify NRC in writing of the commitment

change.

Enclosure

3

In response to inspector questioning, Entergy wrote a condition report

(CR-HON-2011-1213) to address the commitment change guidance regarding NRC

notification vs. approval and disparities between the step-by-step form and a flowchart.

Further the renewed Vermont Yankee license includes a license condition (No. 3.P) that

requires Vermont Yankee to use the process stipulated in Title 10 of the Code of Federal

Regulations (10 CFR) 50.59 for changes to the updated final safety analysis report

(UFSAR) supplement submitted as part of a license renewal application pursuant to

10 CFR 54.21(d). 10 CFR 50.59 is required for any changes made to the information in

the UFSAR supplement if the changes are made in the supplement prior to the UFSAR

supplement being incorporated into the next UFSAR update. The UFSAR update is

scheduled in compliance with 10 CFR 50.71(e) without regard to the date the new

license is issued. Because Commitment 6 is not referenced in the information in the

UFSAR supplement, the license condition does not apply.

The inspectors determined that the revised Commitment 6 was being implemented. The

review of the May 19, 2011,letter is pending further NRC staff review.

Commitments 21 and 23 - Structural examinations of cooling tower

Commitment 21 states that "Guidance for performing structural examinations of wood to

identify loss of material, cracking, and change in material properties will be added to the

Structures Monitoring Program" by March 21,2012. Commitment 23 states that

"Guidance for performing structural examinations of PVC cooling tower fill to identify

cracking and change in material properties will be added to the Structures Monitoring

Program procedure" by March 21, 2012.

The inspectors reviewed the commitment completion review report, the structural

monitoring program procedure, and the cooling tower inspection procedure. In addition,

the inspectors inspected the general condition of the cooling towers and discussed the

most recent inspection records and repairs with the responsible engineer. The

inspectors reviewed condition reports from 2009, 2010, and 2011 related to identified

conditions and repairs for the cooling towers.

The inspector determined that Commitments 21 and 23 had been completed.

Commitment 25 - Cast Austenitic Stainless Steel Program

Commitment 25 states "lmplement the ThermalAging and Neutron lrradiation

Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in LRA

Section 8.1.29." Section 8.1.29 states the program will be "comparable to the program

described in NUREG-1801 Section Xl.M13." The applicable edition of NUREG-1801

(GALL Report) at the time of the application was Revision 1. In addition to addressing

critical elements of CASS aging, Section 8.1.29 states: "EPRI, the BWR Owners Group

and other industry groups are focused on reactor vessel internals to ensure a better

understanding of aging effects. Future Boiling Water Reactor Vessel Internals Project

(BWRVIP) reports, Electric Power Research Institute (EPRI) reports, and other industry

operating experience will provide additional bases for evaluations and inspections under

Enclosure

4

this program. This program will supplement reactor vessel internals inspections required

by the BWR Vessel Internals Program to assure that aging effects do not result in loss of

the intended functions of reactor vessel internals during the period of extended

operation."

The inspectors determined that in response to later guidance from the BWRVIP,

Entergy's revised program for: CASS aging management program was technically

acceptable. Specifically, after the details of the Vermont Yankee license renewal

application were established, the programmatic details of the thermal aging and neutron

irradiation embrittlement of cast austenitic stainless steelwere resolved and specified in

the Boiling Water Reactor Vessels lnternal Program (BWRVIP 234-2009). Section 6,7 of

the VIP states: "The inspection reco-mmendation given are based on the following

criteria: (1 ) fluence less than 3 x 10" nlcm', (2) adequate toughness (>. 255 kJ/m'), and

(3) applied stress (< Sksi). Entergy used BWRVIP 234-2009 as the method necessary to

manage the aging effect of thermal aging and neutron irradiation embrittlement of cast

austenitic stainless steelwithin procedures and specifications in the CASS aging

management program. Using the BWRVIP 234-2009 thresholds, all of Vermont

Yankee's CASS components that were within the scope of the original application were

below the stress threshold of the VIP procedure. Thus the components screened out of

the aging management program and needed no inspection.

However, the inspector noted a contradiction between the current program and what

Entergy had submitted in the application, including Commitment 25. More specifically,

the inspectors determined that use of the BWRVIP 234-2009 contradicted the

application, because GALL Report, Section Xl.M13, Revision 1 , stipulates the threshold

for inspection be established based on a single criterion of fluence > 10 n/cm2 (for

E > 1 MeV), which is three orders of magnitude, i.e., 1,000 times, lower than the

threshold used in BWRVIP 234-2009. lt should be noted that all of Vermont Yankee's

CASS components that were within the scope of the original application were below this

lower stress threshold also. The inspectors noted that GALL Report, Section Xl.M13,

Revision 2had established BWRVIP 234-2009 as an acceptable aging management

approach, but the inspectors also noted that an appropriate method of changing the

commitment had not come to completion using at least the commitment change process

based on NEI 99-04 (LO-LAR-2010-256). Also, in this case, the inspector observed that

the license condition 3.P that required the use of the 10 CFR 50.59 process for the

interim period between the issuance of the license and the extended period would have

applied to the changes to the commitment. On December 1,2011, the NRC staff

learned that Entergy had revised LO LAR 2010 0256 by Corrective Action No. CA-006;

and this change was made in order to implement the necessary corrective actions and

track the approval by the NRC, if needed, for the upgraded use of the VIP procedure in

their current program.

The inspectors determined that Commitment 25 and related change process will be

further reviewed in the next commitment inspection.

Enclosure

5

Commitment 12 - Heat Exchanger Monitoring Program

Commitment 12 provides that Entergy will "lmplement the Heat Exchanger Monitoring

Program as described in LRA Section 8.1.14' by March 21, 2012.

The inspectors reviewed the commitment completion review report, the heat exchanger

program procedure, and the heat exchanger monitoring procedure. In addition, the

inspectors inspected the general condition of the 1A and 1B motor generator lubricating

oil coolers (E-40-1A and E-40-18) and the turbine lubricating oil cooler (E-25-1A), which

were undergoing cleaning and inspection during the outage.

The inspectors determined that additional NRC review was appropriate on

Commitment 12 in general and Entergy corrective actions for any identified degradations

in particular during planned NRC inspections prior to the period of extended operations.

c. Summary

No findings were identified and general conditions in the plant areas observed were

satisfactory. The inspectors determined that Entergy actions on Commitments Nos. 23

and 25 were complete and met regulatory expectations as reflected in the staff's SER.

Additional NRC staff review is needed for the others noted in this report.

4OAO Exit Meetino

The inspectors presented the inspection results to Mr. Michael Colomb, then Site Vice

President; Mr. Steve Wamser, then Plant Manager; and other members of the staff on

October 20,2011. The inspectors confirmed that no proprietary material was examined

during the inspection.

On December 1, 2011, Mr. Richard Conte, NRC, led a discussion with Mr. Robert

Wanczyk, Manager of Licensing, and other Entergy staff on the observations related to

the commitment tracking process and how it was used for Commitment Nos. 6 and 25.

The results of this review were discussed under Commitment Nos. 6 and 25.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

A-1

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Colomb Site Vice President

N. Rademacher W engineering director

C. Wamser W general manager

B. Wanczyk W licensing manager

G. Thomas VY LR project manager

P. Guglielmino VY LR project implementation manager

J. Hoffman W LR team

D. Lach Entergy LR team

J. DeVincentis W licensing engineer

LIST OF ACRONYMS

AMP Aging Management Program

BWR Boiling Water Reactor

BWRVIP Boiling Water Reactor Vessel Internals Project

CASS Cast Austentic Stainless Steel

CR Condition Report

CUF Cumulative Fatigue Usage Factors

EPRI Electric Power Research Institute

EQ Environmental Qualification

GALL Generic Aging Lessons Learned

IP lnspection Procedure

tsl Inservice Inspection

LRA License Renewal Application

NEI Nuclear Energy Institute

RFO Refueling Outage

SER Safety Evaluation Report

SSC Structure, Systems, and Components

UFSAR Updated Final Safety Analysis Report

UT Ultrasonic Test

WO Work Order

General

W License Renewal Commitment and Program lmplementation, October 17,2011

Attachment

A-2

LIST OF DOCUMENTS REVIEWED

In-plant Observations

EN-DC-348, Non-EQ lnsulated Cables and Connections lnspection, Rev. 2

Commitment 6

EN-Ll-110 Rev. 4, Entergy Management Manual "Commitment Management Program"

Letter BVY 1 1-026, Entergy Vermont Yankee to NRC, Dated May 19, 2011

LRSICMS A-16774

LRSICMS A-16775

LRSICMS A.16776

LO-LAR-2101-00236

LO-LAR-2101-00237

LO-LAR-2101-00238

Commitment 12 (Heat Exchanqer Monitorinq Proqram)

VYNPS-LRID-14, Review of the Heat Exchanger Monitoring Aging Management Program for

License Renewal lmplementation, Rev. 0

ENN-SEP-HX-001, Heat Exchanger Program, Rev. 1

EN-DC-316, Heat Exchanger Performance and Condition Monitoring, Rev. 3

wo 52298380

Commitments 21 and 23 (Coolinq tower structural examinations)

VYNPS-LRID-?7-2, Review of the Structural Monitoring Aging Management Program for

License Renewal lmplementation, Rev. 1

EN-DC-150, Condition Monitoring of Maintenance Rule Structures, Rev. 1 and Rev. 2 (dratt)

MTMP-CTS-52114-10, Cooling Tower Structural Inspection and Repair, Rev. 4

cR -2009-03034

cR-2010-02853

cR-2010-03793

cR-2010-03799

cR-2010-03833

Commitment 25

LO LAR 2010 00256

VYNPS-LRID-29 "Vermont Yankee Nuclear Power Station, ThermalAging and Neutron

lrradiation Embrittlement of Cast Austentic Stainless Steel (CASS) Program Review

for License Renewal lmplementation"

BWRVIP-234 "BWR Vessel and Internals Project Thermal Aging and Neutron Embrittlement."

Commitment 54

BVY 11-010

Attachment