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{{Adams
#REDIRECT [[IR 05000271/2011011]]
| number = ML113560064
| issue date = 12/22/2011
| title = IR 05000271/2011011; 10/17/2011 - 12/1/2011; Vermont Yankee Nuclear Power Station; Review of License Renewal Activities
| author name = Conte R J
| author affiliation = NRC/RGN-I/DRS/EB1
| addressee name = Wamser C
| addressee affiliation = Entergy Nuclear Operations, Inc
| docket = 05000271
| license number = DPR-028
| contact person =
| document report number = IR-11-011
| document type = Inspection Report, Letter
| page count = 12
}}
See also: [[followed by::IR 05000271/2011011]]
 
=Text=
{{#Wiki_filter:UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION I475 ALLENDALE ROADKING OF PRUSSIA, PA 19406-1415December 22, 20lLMr. Christopher WamserEntergy Nuclear Operations, Inc.Vermont Yankee Nuclear power Station185 Old Ferry RoadP.O. Box 500Brattleboro, VT 05302-0500SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATEDINSPECTION REPORT 0500027 1 t2ol 1 01 1Dear Mr. Wamser:on october 20,2011, the U.S. NuclearRegulatory Commission (NRC) completed an inspectionat the Vermont Yankee Nuclear Power Staiion. the enctosed report documbnts the results ofthe inspection, which were discussed on october 20, and December z 2011, wrth you and othermembers of your staff.This inspection was an examination of activities under your renewed operating license related tothe completion of commitments made during the renewed lic"nre apptication f,rocess andcompliance with the conditions of your licenie. Under the renewed operating license, entry intothe period of extended opelations is planned for March 22,2012. Th; inap;tion was directedtoward those activities and facilities accessible during the refueling outate. -witnin 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 thisinspection' We plan to continue to review Commitment Nos. 6, 12,aid 2s, along with yourprocess for commitment change management during future planned license renewal teaminspections, prior to March 22.20112.
C. Wamser 2tn accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document systemAgencywide Document Access and Management System (ADAMS). ADAMS is accessible fromthe NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic ReadingRoom).Sincerely,/Z,tr*J>MRichard J. Conte, ChiefEngineering Branch 1Division of Reactor SafetyDocket No. 50-271License No. DPR-28Enclosure:NRC lnspection Report 0500027 1 1201 101 1cc w/enclosure: Distribution via ListServ
C. Wamser 2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document systemAgencywide Document Access and Management System (ADAMS). ADAMS is accessible fromthe NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic ReadingRoom).Sincerely,/RNRichard J. Conte, ChiefEngineering Branch 1Division of Reactor SafetyDocket No. 50-271License No. DPR-28Enclosure:NRC Inspection Report 05000271 1201 1011cc w/enclosure: Distribution via ListServDistribution 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 OEDOR. Bellamy, DRPT. Setzer, DRPE. Keighley, DRPK. Dunham, DRPS. Rutenkroger, DRP, SRIS. Rich, DRP, RlA. Rancourt, DRP, OARidsNrrPMVermontYankee ResourceRidsNrrDorlLl 1 -1 ResourceROPreportsResource@nrc.qovSUNST Review complete: RJc (Reviewer's Initials) ADAMS ACCESSION NO': ML1 13560064DOCUMENT NAME: G:\DRS\Engineering Branch 1\-- Meyer\W Lic Renewal\2o111206 05000271 2011011 VY 1P71003 Inspection Report'docxAfter declaring this document "An Official Agency Record" it will be released to the Public.To receive a copy of this document, indicate in the box: "C" = Copy without attachmenVenclosure "E" = Copy with attachment/enclosure "N" = NoOFFICE RI/DRS12112111DATE 1219111OFFICIAL RECORD COPY
Docket No.:License No.:Report No.:Licensee:Facility:Location:Dates:Inspectors:Approved By:U.S. NUCLEAR REGULATORY COMMISSIONREGION I50-271DPR.280500027112011011Entergy Nuclear Operations, Inc. (Entergy)Vermont Yankee Nuclear Power StationVernon, VTOctober 17 - 20, and December 1, 2011G. Meyer, Senior Reactor Inspector, Division of Reactor SafetyM. Modes, Senior Reactor Inspector, Division of Reactor SafetyRichard J. Conte, ChiefEngineering Branch 1Division of Reactor SafetyEnclosure
SUMMARY OF FINDINGSlR 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 activitiesduring the Vermont Yankee refueling outage. lt was performed by two region basedengineering inspectors under lnspection Procedure 71003.Enclosure
4.4042RePort DetailsoTHER ACTTVIilES (OA)Other - License RenewalActivitiesOn March 21,2011, NRC issued a renewed operating license for the facility, based onreview of the Vermont Yankee License RenewalApplication (LRA) submitted onJanuary 27 , 2006. ln March 2011, NRC issued Supplement 2 to NUREG 1907, "SafetyEvaluation Report Related to the License Renewal of Vermont Yankee Nuclear PowerStation," which contained Appendix A, Commitment Listing, listing 55 commitments. Theapplicant made the commitments to provide aging management programs to manageaging effects on structures, systems, and components (SSC) prior to and during theperiod of extended operation, as well as other information. The period of extendedoperation 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 thelicense renewal activities at the Vermont Yankee Nuclear Power Station in accordancewith Inspection Procedure (lP) 71003. The inspection was directed toward thoseactivities and facilities accessible during the refueling outage in order to determine iflicense renewal commitments were being met.b. Findinos and ObservationsNo findings were identified.b. 1 In-plant ObservationsThe inspectors observed ongoing activities and inspected the general condition of SSCswithin the scope of license renewal. The inspectors performed reviews in the followingareas, 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 andConnections Program)The inspectors determined the general conditions to be satisfactory and the Entergyactivities to be in accordance with facility programs and procedures.Enclosure
2b.2 Commitments ReviewedCommitment 6 - Computerized fatigue monitoringIn the March 2011 SER Supplement, Commitment 6 states, "A computerized monitoringprogram (e.9., FatiguePro) will be used to directly determine cumulative fatigue usagefactors (CUF) for locations of interest."The inspectors determined that Entergy had removed the use of FatiquePro as a part ofCommitment 6. Specifically, Entergy submitted the Vermont Yankee license renewalapplication on January 27,2006, with an enhancement to the Fatigue MonitoringProgram, which stated that "A computerized monitoring program (e.9., FatiguePro) willbe used to directly determine CUFs for locations of interest." On March 30, 2007, NRCissued "Safety Evaluation Report with Confirmatory ltems Related to the LicenseRenewal of Vermont Yankee Nuclear Power Station," which contained Appendix A,Commitment Listing, in which Commitment 6 was recorded. Subsequent versions of theSafety Evaluation Report (SER) as NUREG-1907 did not revise the commitment.Entergy approved the removal of FatiguePro on January 6,2011. The renewed licensewas issued March 21, 2011. In letter BVY 1 1-026 dated May 19, 2011, Entergyinformed NRC that Commitment 6 had been changed to be "Manual cycle counting willbe used to track and compare accumulated cycles against allowable values to determineif cumulative usage factors are required to be updated." The inspectors noted that thischange, in essence, rescinded the commitment, as manualcycle counting had been theexisting method at the time of the application submittal and would not have necessitatedan enhancement and subsequent commitment. Also, the Entergy letter did not requestapproval of the rescinding, as indicated by the statement that no action was required ofNRC.The inspectors could not clearly determine whether Entergy had met the expectations ofthe commitment change processes as specified in the license conditions of the renewedVermont Yankee license, NRC-endorsed NEI 99-04 "Guidelines for Managing NRCCommitment Changes,' (ML003680088), and Entergy procedure EN-LI-1 1 0,Commitment Management Program, Revision 4. The key concern is whether NEI 99-04and EN-Ll-110 were consistent in pointing Entergy towards NRC notification versus NRCapproval in making changes to its commitments. The answer was not apparent in thissituation due to various possible interpretations of the two guidance documents,particularly on how the commitment was considered during the staffs review and theimplementation timing of the commitment (scheduled for March 22,2012).The inspectors noted that the significance of the above concerns was minimal in thisparticular case. Manual cycle counting has represented an acceptable method in someapplications. The Pilgrim license renewal application, which was submitted concurrentlywith the Vermont Yankee license renewal application, had used manual cycle counting,and NRC issued the Pilgrim Safety Evaluation Report and supplements without acommitment for fatigue monitoring. Other plants with renewed licenses have hadmanual cycle counting. Also, Entergy chose to notify NRC in writing of the commitmentchange.Enclosure
3In response to inspector questioning, Entergy wrote a condition report(CR-HON-2011-1213) to address the commitment change guidance regarding NRCnotification 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) thatrequires Vermont Yankee to use the process stipulated in Title 10 of the Code of FederalRegulations (10 CFR) 50.59 for changes to the updated final safety analysis report(UFSAR) supplement submitted as part of a license renewal application pursuant to10 CFR 54.21(d). 10 CFR 50.59 is required for any changes made to the information inthe UFSAR supplement if the changes are made in the supplement prior to the UFSARsupplement being incorporated into the next UFSAR update. The UFSAR update isscheduled in compliance with 10 CFR 50.71(e) without regard to the date the newlicense is issued. Because Commitment 6 is not referenced in the information in theUFSAR supplement, the license condition does not apply.The inspectors determined that the revised Commitment 6 was being implemented. Thereview of the May 19, 2011,letter is pending further NRC staff review.Commitments 21 and 23 - Structural examinations of cooling towerCommitment 21 states that "Guidance for performing structural examinations of wood toidentify loss of material, cracking, and change in material properties will be added to theStructures Monitoring Program" by March 21,2012. Commitment 23 states that"Guidance for performing structural examinations of PVC cooling tower fill to identifycracking and change in material properties will be added to the Structures MonitoringProgram procedure" by March 21, 2012.The inspectors reviewed the commitment completion review report, the structuralmonitoring program procedure, and the cooling tower inspection procedure. In addition,the inspectors inspected the general condition of the cooling towers and discussed themost recent inspection records and repairs with the responsible engineer. Theinspectors reviewed condition reports from 2009, 2010, and 2011 related to identifiedconditions and repairs for the cooling towers.The inspector determined that Commitments 21 and 23 had been completed.Commitment 25 - Cast Austenitic Stainless Steel ProgramCommitment 25 states "lmplement the ThermalAging and Neutron lrradiationEmbrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in LRASection 8.1.29." Section 8.1.29 states the program will be "comparable to the programdescribed 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 addressingcritical elements of CASS aging, Section 8.1.29 states: "EPRI, the BWR Owners Groupand other industry groups are focused on reactor vessel internals to ensure a betterunderstanding of aging effects. Future Boiling Water Reactor Vessel Internals Project(BWRVIP) reports, Electric Power Research Institute (EPRI) reports, and other industryoperating experience will provide additional bases for evaluations and inspections underEnclosure
4this program. This program will supplement reactor vessel internals inspections requiredby the BWR Vessel Internals Program to assure that aging effects do not result in loss ofthe intended functions of reactor vessel internals during the period of extendedoperation."The inspectors determined that in response to later guidance from the BWRVIP,Entergy's revised program for: CASS aging management program was technicallyacceptable. Specifically, after the details of the Vermont Yankee license renewalapplication were established, the programmatic details of the thermal aging and neutronirradiation embrittlement of cast austenitic stainless steelwere resolved and specified inthe Boiling Water Reactor Vessels lnternal Program (BWRVIP 234-2009). Section 6,7 ofthe VIP states: "The inspection reco-mmendation given are based on the followingcriteria: (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 tomanage the aging effect of thermal aging and neutron irradiation embrittlement of castaustenitic stainless steelwithin procedures and specifications in the CASS agingmanagement program. Using the BWRVIP 234-2009 thresholds, all of VermontYankee's CASS components that were within the scope of the original application werebelow the stress threshold of the VIP procedure. Thus the components screened out ofthe aging management program and needed no inspection.However, the inspector noted a contradiction between the current program and whatEntergy had submitted in the application, including Commitment 25. More specifically,the inspectors determined that use of the BWRVIP 234-2009 contradicted theapplication, because GALL Report, Section Xl.M13, Revision 1 , stipulates the thresholdfor inspection be established based on a single criterion of fluence > 10'' n/cm2 (forE > 1 MeV), which is three orders of magnitude, i.e., 1,000 times, lower than thethreshold used in BWRVIP 234-2009. lt should be noted that all of Vermont Yankee'sCASS components that were within the scope of the original application were below thislower stress threshold also. The inspectors noted that GALL Report, Section Xl.M13,Revision 2had established BWRVIP 234-2009 as an acceptable aging managementapproach, but the inspectors also noted that an appropriate method of changing thecommitment had not come to completion using at least the commitment change processbased on NEI 99-04 (LO-LAR-2010-256). Also, in this case, the inspector observed thatthe license condition 3.P that required the use of the 10 CFR 50.59 process for theinterim period between the issuance of the license and the extended period would haveapplied to the changes to the commitment. On December 1,2011, the NRC stafflearned 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 andtrack the approval by the NRC, if needed, for the upgraded use of the VIP procedure intheir current program.The inspectors determined that Commitment 25 and related change process will befurther reviewed in the next commitment inspection.Enclosure
5Commitment 12 - Heat Exchanger Monitoring ProgramCommitment 12 provides that Entergy will "lmplement the Heat Exchanger MonitoringProgram as described in LRA Section 8.1.14' by March 21, 2012.The inspectors reviewed the commitment completion review report, the heat exchangerprogram procedure, and the heat exchanger monitoring procedure. In addition, theinspectors inspected the general condition of the 1A and 1B motor generator lubricatingoil coolers (E-40-1A and E-40-18) and the turbine lubricating oil cooler (E-25-1A), whichwere undergoing cleaning and inspection during the outage.The inspectors determined that additional NRC review was appropriate onCommitment 12 in general and Entergy corrective actions for any identified degradationsin particular during planned NRC inspections prior to the period of extended operations.c. SummaryNo findings were identified and general conditions in the plant areas observed weresatisfactory. The inspectors determined that Entergy actions on Commitments Nos. 23and 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 MeetinoThe inspectors presented the inspection results to Mr. Michael Colomb, then Site VicePresident; Mr. Steve Wamser, then Plant Manager; and other members of the staff onOctober 20,2011. The inspectors confirmed that no proprietary material was examinedduring the inspection.On December 1, 2011, Mr. Richard Conte, NRC, led a discussion with Mr. RobertWanczyk, Manager of Licensing, and other Entergy staff on the observations related tothe 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 INFORMATIONEnclosure
A-1ATTACHMENTSUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicensee PersonnelM. ColombN. RademacherC. WamserB. WanczykG. ThomasP. GuglielminoJ. HoffmanD. LachJ. DeVincentisSite Vice PresidentW engineering directorW general managerW licensing managerVY LR project managerVY LR project implementation managerW LR teamEntergy LR teamW licensing engineerAMPBWRBWRVIPCASSCRCUFEPRIEQGALLIPtslLRANEIRFOSERSSCUFSARUTWOGeneralLIST OF ACRONYMSAging Management ProgramBoiling Water ReactorBoiling Water Reactor Vessel Internals ProjectCast Austentic Stainless SteelCondition ReportCumulative Fatigue Usage FactorsElectric Power Research InstituteEnvironmental QualificationGeneric Aging Lessons Learnedlnspection ProcedureInservice InspectionLicense Renewal ApplicationNuclear Energy InstituteRefueling OutageSafety Evaluation ReportStructure, Systems, and ComponentsUpdated Final Safety Analysis ReportUltrasonic TestWork OrderW License Renewal Commitment and Program lmplementation, October 17,2011Attachment
A-2LIST OF DOCUMENTS REVIEWEDIn-plant ObservationsEN-DC-348, Non-EQ lnsulated Cables and Connections lnspection, Rev. 2Commitment 6EN-Ll-110 Rev. 4, Entergy Management Manual "Commitment Management Program"Letter BVY 1 1-026, Entergy Vermont Yankee to NRC, Dated May 19, 2011LRSICMS A-16774LRSICMS A-16775LRSICMS A.16776LO-LAR-2101-00236LO-LAR-2101-00237LO-LAR-2101-00238Commitment 12 (Heat Exchanqer Monitorinq Proqram)VYNPS-LRID-14, Review of the Heat Exchanger Monitoring Aging Management Program forLicense Renewal lmplementation, Rev. 0ENN-SEP-HX-001, Heat Exchanger Program, Rev. 1EN-DC-316, Heat Exchanger Performance and Condition Monitoring, Rev. 3wo 52298380Commitments 21 and 23 (Coolinq tower structural examinations)VYNPS-LRID-?7-2, Review of the Structural Monitoring Aging Management Program forLicense Renewal lmplementation, Rev. 1EN-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. 4cR -2009-03034cR-2010-02853cR-2010-03793cR-2010-03799cR-2010-03833Commitment 25LO LAR 2010 00256VYNPS-LRID-29 "Vermont Yankee Nuclear Power Station, ThermalAging and Neutronlrradiation Embrittlement of Cast Austentic Stainless Steel (CASS) Program Reviewfor License Renewal lmplementation"BWRVIP-234 "BWR Vessel and Internals Project Thermal Aging and Neutron Embrittlement."Commitment 54BVY 11-010Attachment
 
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