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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 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 - NRC INTEGRATED
INSPECTION
REPORT 0500027 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
was directed toward 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 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.To receive a copy of this document, indicate in the box: "C" = Copy without attachmenVenclosure "E" = Copy with attachment/enclosure "N" = No OFFICE RI/DRS 12112111 DATE 1219111 OFFICIAL RECORD COPY
Docket No.: License No.: Report No.: Licensee: Facility: Location: Dates: Inspectors:
Approved By: U.S. NUCLEAR REGULATORY
COMMISSION
REGION I 50-271 DPR.28 0500027112011011
Entergy Nuclear Operations, Inc. (Entergy)Vermont Yankee Nuclear Power Station Vernon, VT October 17 - 20, and December 1, 2011 G. Meyer, Senior Reactor Inspector, Division of Reactor Safety M. Modes, Senior Reactor Inspector, Division of Reactor Safety 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
4.4042 RePort Details oTHER ACTTVIilES (OA)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 N. Rademacher
C. Wamser B. Wanczyk G. Thomas P. Guglielmino
J. Hoffman D. Lach J. DeVincentis
Site Vice President W engineering
director W general manager W licensing
manager VY LR project manager VY LR project implementation
manager W LR team Entergy LR team W licensing
engineer AMP BWR BWRVIP CASS CR CUF EPRI EQ GALL IP tsl LRA NEI RFO SER SSC UFSAR UT WO General LIST OF ACRONYMS Aging Management
Program Boiling Water Reactor Boiling Water Reactor Vessel Internals
Project Cast Austentic
Stainless
Steel Condition
Report Cumulative
Fatigue Usage Factors Electric Power Research Institute Environmental
Qualification
Generic Aging Lessons Learned lnspection
Procedure Inservice
Inspection
License Renewal Application
Nuclear Energy Institute Refueling
Outage Safety Evaluation
Report Structure, Systems, and Components
Updated Final Safety Analysis Report Ultrasonic
Test Work Order 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
}}

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