ML062580187

2006/09/14-Audit Trip Report Regarding Entergy Nuclear Vermont Yankee, LLC, License Renewal Application for Vermont Yankee Power Station, Dated January 29, 2006

ML062580187
Person / Time
Site:	Vermont Yankee
Issue date:	09/14/2006
From:	Hamzehee H G NRC/NRR/ADES/DE/EQVB
To:	Kuo P T NRC/NRR/ADRO/DLR
Greg Galletti, NRR/DE/EQVB (301) 415-294
References
%dam200611, TAC MC9668
Download: ML062580187 (9)

Text

September 14, 2006MEMORANDUM TO:P.T. Kuo, Deputy DirectorDivision of License Renewal Office of Nuclear Reactor RegulationFROM:Hossein Hamzehee, Chief /RA/ Bill Rogers for Quality & Vendor Branch BDivision of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT TRIP REPORT REGARDING THE ENTERGY NUCLEARVERMONT YANKEE, LLC, LICENSE RENEWAL APPLICATION FOR THE VERMONT YANKEE NUCLEAR POWER STATION, DATEDJANUARY 29, 2006Plant Name:Vermont Yankee Nuclear Power StationUtility Name:Entergy Nuclear Vermont Yankee, LLC Docket No.:50-271 (DPR-28)

TAC No.:MC9668 Review Branch:Quality & Vendor Branch BDuring the week of April 24 - 28, 2006, the Quality and Vendor Branch B(EQVB)performed an audit of the Entergy Nuclear Vermont Yankee, LLC (the applicant) license renewal scoping and screening methodology developed to support the Vermont Yankee Nuclear Power Station license renewal application (LRA), dated January 29, 2006. The focusof the staff's audit was on the applicant's administrative controls governing implementation ofthe LRA scoping and screening methodology, and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components. Theaudit team also reviewed quality attributes for aging management programs and training for personnel that developed the LRA. A trip report containing a summary of the audit results is attached.

Enclosure:

As stated CONTACT:Greg S. Galletti, NRR/DE/EQVB(301) 415-1831 September 14, 2006MEMORANDUM TO:P.T. Kuo, Deputy DirectorDivision of License Renewal Office of Nuclear Reactor RegulationFROM:Hossein Hamzehee, Chief /RA/ Bill Rogers for Quality & Vendor Branch B Division of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT TRIP REPORT REGARDING THE ENTERGY NUCLEARVERMONT YANKEE, LLC, LICENSE RENEWAL APPLICATION FOR THE VERMONT YANKEE NUCLEAR POWER STATION, DATEDJANUARY 29, 2006Plant Name:Vermont Yankee Nuclear Power StationUtility Name:Entergy Nuclear Vermont Yankee, LLC Docket No.:50-271 (DPR-28)

TAC No.:MC9668 Review Branch:Quality & Vendor Branch BDuring the week of April 24 - 28, 2006, the Quality and Vendor Branch B(EQVB)performed an audit of the Entergy Nuclear Vermont Yankee, LLC (the applicant) license renewal scoping and screening methodology developed to support the Vermont Yankee Nuclear Power Station license renewal application (LRA), dated January 29, 2006. The focusof the staff's audit was on the applicant's administrative controls governing implementation ofthe LRA scoping and screening methodology, and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components. Theaudit team also reviewed quality attributes for aging management programs and training for personnel that developed the LRA. A trip report containing a summary of the audit results is attached.

Enclosure:

As stated CONTACT:Greg S. Galletti, NRR/DE/EQVB301-415-1831DISTRIBUTION:EQVB R/F RidsNrrOd JRowley, PM, JZimmerman, LLund, GGalletti ADAMS ACCESSION NO.: ML062580187 OFFICEEQV/DEBC/EQV/DENAMEGGallettiHHamzeheeDATE 09/14/06 09/14/06 OFFICIAL RECORD COPY

EnclosureAUDIT TRIP REPORT REGARDING THE ENTERGY NUCLEAR VERMONT YANKEE, LLC,LICENSE RENEWAL APPLICATION FOR THE VERMONT YANKEE NUCLEAR POWERSTATION, DATED JANUARY 29, 2006I. IntroductionDuring the week of April 24 - 28, 2006, Greg Galletti, B ill Rogers, and Steve Tingen of theQuality and Vendor Branches A & B, audited the Entergy Nuclear Vermont Yankee (the applicant) license renewal scoping and screening methodology developed to support the Vermont Yankee Nuclear Power Station (VYNPS) license renewal application (LRA). The audit was performed at the applicant's facility outside of Brattleboro, Vermont. The focus of thestaff's audit was on the applicant's administrative controls governing implementation of the LRAscoping and screening methodology and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components. The audit team alsoreviewed quality attributes for aging management programs, training for personnel that developed the LRA, and quality practices used by the applicant to develop the LRA. II. Backgr oundTitle 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54), "Requirements forRenewal of Operating Licenses for Nuclear Power Plants," Section 54.21, "Contents ofApplication - Technical Information," requires that each application for license renewal containan integrated plant assessment (IPA). Furthermore, the IPA must list and identify those structures and components (SCs) that are subject to an aging management review (AMR) from the systems, structures, and components (SSCs) that are within the scope of license renewal. 10 CFR 54.4(a) identifies the plant SSCs within the scope of license renewal. SCs within the scope of license renewal are screened to determine if they are long-lived, passive equipment that is subject to an aging management review in accordance with 10 CFR 54.21(a)(1). III. Scoping MethodologyThe scoping evaluations for the VYNPS LRA were performed by the applicant's license renewalproject personnel and contractor personnel. The audit team conducted detailed discussions with the applicant's license renewal project management personnel and reviewed documentation pertinent to the scoping process. The audit team assessed if the scoping methodology outlined in the LRA and implementation procedures was appropriately implemented and if the scoping results were consistent with current licensing basis requirements. The audit team also reviewed a sample of system scoping results for thefollowing systems: Core Spray System and Intake Structure (structural review). In general, the team determined that the applicant's overall approach to license renewal SSCscoping appeared to be adequate. However, the audit team identified several issues where additional information will be required to complete the LRA review. These issues aredocumented in a request for additional information and are briefly described below.*During the scoping and screening methodology audit, the NRC audit team questionedhow non-accident design basis events, particularly design basis events that may not be described in the Updated Final Safety Analysis Report (UFSAR), were consideredduring scoping. The NRC audit team noted that limiting the review of design basesevents to those described in the UFSAR accident analysis could result in omission of safety-related functions described in the current licensing basis. The audit team, therefore, requested the applicant to provide a list of the design basis events evaluatedas part of the license renewal scoping process, and describe the methodology used to ensure that all design bases events (including conditions of normal operation, anticipated operational occurrences, design basis accidents, external events, and natural phenomena) were addressed during license renewal scoping. *Based on a review of the LRA, the applicant's scoping and screening implementationprocedures, and discussions with the applicant, the audit team determined that additional information is required with respect to certain aspects of the applicant's evaluation of the 10 CFR 54.4(a)(2) criteria. The audit team requested that theapplicant provide supplemental information regarding how the structural boundary, which includes the portion of the non-safety piping system outside the safety-relatedpressure boundary and relied upon to provide structural support for the pressure boundary, was developed. Additionally, the team requested the applicant to defineequivalent anchors and indicate whether equivalent anchors were used to determine any plant system structural boundary.*Based on the review of the applicant's scoping evaluation related to the 10 CFR54.4(a)(3) Station Blackout (SBO) criterion as described in License renewal Project Document (LRPD)-01, "System and Structure Scoping Results," Revision 0, the NRC audit team was unable to determine the extent to which the mechanical and electrical portions of the Vernon Hydroelectric Station were evaluated as part of the scoping evaluation. As a result the team requested the applicant to describe the scoping andscreening methodology applied to the mechanical and electrical systems associatedwith the Vernon Hydroelectric Station, and identify those mechanical and electricalSSCs that are in the scope of license renewal and subject to an AMR.

IV.Screening MethodologyThe audit team reviewed the methodology used by the applicant to determine ifmechanical, structural, and electrical components within the scope of license renewal would be subject to further aging management review. The applicant provided the audit team with a detailed discussion of the processes used for each discipline and provided administrative documentation that described the screening methodology. The auditteam also reviewed the screening results reports for the Core Spray system and IntakeStructure. The team noted that the applicant's screening process was performed inaccordance with its written requirements and was consistent with the guidance provided in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications forNuclear Power Plants," Revision 1, (LR-SRP), and the Nuclear Energy Institute (NEI) 95-10, "Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," Revision 6, (NEI 95-10). The audit team determined that the screening methodology was consistent with the requirements of the Rule for theidentification of SSCs that meet the screening criteria of 10 CFR 54.21(a)(1).V.Aging Management Program Quality Assurance AttributesThe NRC audit team reviewed the applicant's Aging Management Programs (AMPs) describedin Appendix A, "Updated Safety Analysis Report Supplement," and Appendix B, "Aging Management Programs and Activities," of the Vermont Yankee Nuclear Power Station LRA In addition, the NRC audit team reviewed each individual AMP basis document to ensureconsistency in the use of the quality assurance attributes for each program. The purpose of this review was to assure that the aging management activities were consistent with the staff's guidance described in NUREG-1800, Section A.2, "Quality Assurance for Aging ManagementPrograms (Branch Technical Position IQMB-1)."Based on the NRC audit team's evaluation, the descriptions and applicability of the plant-specific AMPs and their associated quality attributes provided in Appendix A, Section A.2.1, andAppendix B, Section B.0.3, of the LRA are generally consistent with the staff's positionregarding quality assurance for aging management. However, the applicant has not sufficiently described the use of the quality assurance program and its associated attributes (corrective action, confirmation process, and administrative controls). Specifically, the applicant did not identify those AMPs which do not credit the VYNPS 10 CFR Part 50, Appendix B, QualityAssurance Program, for the corrective action, confirmation process, and administrative control attributes, or provide a description of the process used in lieu of the VYNPS Quality Assurance Program. Additionally, the NRC audit team noted that the AMP basis documents did not consistentlydescribe the application of the VYNPS 10 CFR Part 50, Appendix B, Quality AssuranceProgram, or an alternative for the corrective action, confirmation process, and administrative control attributes in each AMP. The NRC team, therefore, requested that the applicant providethe following information to address these issues:*A supplement to the description in the Appendix A, Section A.2.1, of the LRA to clearlyindicate the application of the VYNPS 10 CFR Part 50, Appendix B, Quality Assurance Program, or an alternative for the corrective action, conformation process, and administrative control attributes in each program.*If any alternative approaches are identified in Item a above in lieu of the VYNPS 10 CFRPart 50, Appendix B, Quality Assurance Program, their descriptions provided should be of sufficient detail for the staff to determine if the quality attributes for the AMPs are consistent with the review acceptance criteria contained in NUREG-1800, SectionA.2,"Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1)."*A consistent description for each AMP bases document which describes the applicationof the VYNPS 10 CFR Part 50, Appendix B, Quality Assurance Program, or an alternative for the corrective action, confirmation process, and administrative control attributes in each AMP. VI. Quality Assurance Controls Applied to LRA DevelopmentThe NRC audit team reviewed the quality controls used by the applicant to ensure that scopingand screening methodologies utilized in the LRA were adequately implemented. Although theapplicant did not develop the LRA under a 10 CFR 50, Appendix B, QA program, the applicantutilized the following quality assurance (QA) processes during the LRA development:*Implementation of the scoping and screening methodology was governed by writtenprocedures.*The applicant reviewed previous LRA NRC requests for additional information to ensurethat applicable issues were addressed in the LRA.*The LRA was reviewed by the Off-Site and On-Site Safety Review Committees prior tosubmittal to the NRC.*The applicant performed an industry peer review of the LRA.

• The applicant's QA organization performed an independent review of the LRA. Thepurpose of this review was to ensure that the technical information used to develop the LRA was updated and approved in accordance with the station's QA program, and that the issues raised by industry peer and Off-Site and On-Site Safety Review Committee were resolved and associated corrective actions implemented. The audit team concluded that these quality assurance activities, which exceeded currentregulatory requirements, provided additional assurance that LRA development activities were performed consistently with the LRA descriptions.VII.Training for License Renewal Project Personnel The audit team reviewed the applicant's training process to ensure the guidelines andmethodology for the scoping and screening activities would be performed in a consistent and appropriate manner. The NRC audit team reviewed the applicant's training process to ensurethe guidelines and methodology for the scoping and screening activities were performed in a consistent and appropriate manner. The License Renewal Project Guidelines (LRPGs) provided the guidance and requirements forthe training of the license renewal (LR) project and site personnel. The training consisted of a combination of reading and attending training sessions. The attachment specified the level of training which was required for the various groups participating in the development of the LRA and began with initial training, documented on a qualification card. The training was required for both the LR project personnel who prepared the application and for the site personnel who reviewed the application. In addition, LR refresher training was provided for the LR project and site personnel participating in the review. Refresher training included information on the LR process and information specific to the site. LR project and site personnel were required toreview applicable LR regulations, NEI 95-10 and associated procedures. The applicant developed periodic production meetings in which the LR project personnel shared their knowledge and experience of a given subject with each other. The NRC audit team reviewed completed qualification and training records of several of theapplicant's LR project personnel and also reviewed completed check lists. The audit team found these records adequately documented the required training for the LR project personnel.

Additionally, based on discussions with the applicant's LR project personnel during the audit, the audit team verified that the applicant's LR project personnel were knowledgeable on the LR process requirements and the specific technical issues within their areas of responsibility. On the basis of discussions with the applicant's license renewal project personnel responsiblefor the scoping and screening process, and a review of selected design documentation in support of the process, the audit team concluded that the applicant's LR project personnel understood the requirements of and adequately implemented the scoping and screening methodology established in the applicant's renewal application. The audit team did not identifyany concerns regarding the training of the applicant's LR project or site personnel.VIII. Exit Meeting A public exit meeting was held with the applicant on July 27, 2006, to discuss the results of thescoping and screening methodology audit. The audit team identified preliminary areas where additional information would be required to support completion of the staff's LRA review.

Requests for additional information related to the applicant's scoping and screening methodology were forwarded to the applicant on July 10, 2006 (ADAMS Accession No.ML061720212).IX.Documents Reviewed 1.AMRC-03, "Aging Management Review of the Intake Structure," Revision 0.2.AMRC-05, "Aging Management Review of Yard Structures," Revision 0.

3.AMRC-06, "Aging Management Review of Bulk Commodities," Revision 0.

4.AMRE-01, "Electrical Screening and Aging Management Reviews," Revision 0.

5.AMRM-03, "Aging Management Review of the Core Spray System," Revision 0.

6.AMRM-26, "Aging Management Review of the Main Condenser and MSIV leakage Pathway,"Revision 0.7.AMRM-30, "Aging Management Review of Nonsafety-related Systems and ComponentsAffecting Safety-related Systems," Revision 1.8.CS, "Design Basis Document for Core Spray," Revision 2 9.ENN-MS-S-009-VY, "Vermont Yankee Site Specific Guidance and System Safety FunctionSheets," Revision 0.10.ENN-DC-167, "Classification of Structures, Systems and Components," Revision 2.

11.EXEV, "Topical Design Basis Document for External Events: Earthquakes (seismic),Tornadoes, External Flooding, Low Water," Revision 2.12.IF, "Topical Design Basis Document for Internal Flooding," Revision 1.

13.License Renewal Project Document (LRPD)-01, "System and Structure Scoping Results,"Revision 0.14.LRPD-02, "Aging Management Program Evaluation Reports," Revision 1 15.License Renewal Project Guideline (LRPG)-01, "License Renewal Project Plan," Revision 1.

16.LRPG-03, "System and Structure Scoping," Revision 1.

17.LRPG-04, "Mechanical System Screening and Aging Management Reviews," Revision 1.

18.LRPG-05, "Electrical System Scoping, Screening and Aging Management Reviews," Rev. 1.

19.LRPG-06, "Structural Screening and Aging Management Reviews," Revision 1.

20.Letter from the NRC to ENTERGY, "REQUEST FOR ADDITIONAL INFORMATION FORTHE REVIEW OF THE VERMONT YANKEE NUCLEAR POWER STATION LICENSERENEWAL APPLICATION," dated July 10, 2006 (ADAMS Accession No. ML061720212).21.NUREG-1800, "Standard Review Plan for Review of License Renewal Applications forNuclear Power Plants," Revision 1, dated September 2005.22.NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - TheLicense Renewal Rule," Revision 6, dated September 2005.23.SADBD, "Topical Design Basis Document for Safety Analysis," Revision 4.

24. VYNPS License Renewal application, dated January 29, 2006.

25. VYNPS Maintenance Rule SSC Basis Documents, Change 49.

26.Vermont Yankee Environmental Qualification Program Manual, Section 6.0, "MasterEquipment List," Revision 18. X.Personnel Contacted During Methodology Audit Garry YoungENTERGY License Renewal TeamPaul RaineyVYNPS Mechanical Design Engineer Stephen VekasyVYNPS System Engineer David LachENTERGY License Renewal Ted IveyENTERGY License Renewal Team Julie JacksENTERGY License Renewal TeamMike MetellVYNPS Design EngineeringMike HamerVYNPS Licensing John HoffmanVYNPS License Renewal Project Manager Mike StroudENTERGY License Renewal Team Jim CallaghanVYNPS Design Engineering Manager Jim DeVincentisENTERGY Licensing ManagerJohnny EadsNRC License Renewal Project Manager, NRRJonathan Rowley NRC License Renewal Project Manager, NRRDevender Reddy NRC/NRR/DLRJacob Zimmerman NRC/NRR/DLR Branch Chief