ML12103A406
| ML12103A406 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/20/2012 |
| From: | Conte R Engineering Region 1 Branch 1 |
| To: | Wamser C Entergy Nuclear Operations |
| R. Conte | |
| References | |
| IR-12-008 | |
| Download: ML12103A406 (37) | |
See also: IR 05000271/2012008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA. PENNSYLVANIA 19406-1415
April 20, 2AI2
Mr. Christopher Wamser
Site Vice President
Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station
185 Old Ferry Road
P.O. Box 500
Brattleboro, VT 05302-0500
VERMONT YANKEE NUCLEAR POWER STATION - NRC INSPECTION
REPORT 0500027 1 t20 12008
Dear Mr. Wamser:
On March 20,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at the Vermont Yankee Nuclear Power Station. The enclosed report documents the results of
the inspection, which were discussed with you and other members of your staff on January 27,
March 8, and March 20,2012.
This inspection was an examination of activities under your renewed operating license related to
the completion of commitments made during the renewed license application process and your
actions to comply with the conditions of your renewed license. Under the renewed operating
license, entry into the period of extended operation occurred on March 22,2012. The
inspection was of those activities and facilities accessible during the power production. Within
these areas, the inspection involved examination of selected procedures, 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. However, as a consequence of this inspection, some of your administrative
processes, and aging management programs, required modification. Further, we noted that
license amendment changes, dated March 5 and March 12,2012, addressed needed changes
to your plans from the original license renewal application. Accordingly, we intend to implement
an additional phase of this inspection on or about the spring 2013 Refueling Outage in order to
follow-up on these issues in accordance with lnspection Procedure 71003, "PostApproval Site
Inspection for License Renewal."
C. Wamser
ln accordance with Title 10 of the Code of Federal Regulations (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
component of NRC's document system Agencywide Document Access and Management
System. The Agencywide Document Access and Management System is accessible from the
NRC Web site at http://www.nrc,gov/reading-rm/adams.html (the Public Electronic Reading
Room),
Sincerely,
,Q*l;DClb
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 12012008
cc w/enclosure: Distribution via ListServ
C. Wamser
f n accordance with Title 10 of the Code of Federal Regulations (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
component of NRC's document system Agencywide Document Access and Management
System. The Agencywide Document Access and Management System 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 lnspection Report 0500027 1 12012008
cc w/enclosure: Distribution via ListServ
Distribution: See next page
DOCUMENT NAME: C:\Documents and Settings\gmp\My Documents\05000271 2012008 VY 1P71003 Inspection Report FINAL'docx
ADAMS ACCESSION NUMBER: ML1 2103A406
V Non-Sensitive g Publicly Available
V suNstReview
n Sensitive ! Non-Publicly Available
OFFICE RI/DRS RI/DRP RI/DRS RI/DRS
NAME MModes/RJC RBellamy RConte CMiller
DATE 4112112 4t17t12 4117112 4t20t12
ICIAL COPY
C. Wamser
Distribution w/encl: (via E-mail)
W. Dean, RA (RIoRAMAIL RESOURCE)
D. Lew, DRA (RIORAMAlL RESOURCE)
J. Clifford, DRP (RIDRPMAlL Resource)
J. Trapp, DRP (RIDRPMAlL Resource)
C. Miller, DRS (RIDRSMAIL RESOURCE)
P. Wilson, DRS (RIDRSMAlL RESOURCE)
L. Chang, Rl OEDO
R. Bellamy, DRP
T. Setzer, DRP
E. Keighley, DRP
J. DeBoer, DRP
S. Rich, DRP, Rl
A. Rancourt, DRP, M
RidsNrrPMVermontYankee Resou rce
RidsNrrDorlLll -1 Resource
ROPreports Resource
D. Bearde, DRS
T. Lupold, DRS
R. Conte, DRS
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-271
0500027112012008
Entergy Nuclear Vermont Yankee, LLC
Entergy Nuclear Operations, Inc.
Facility: Vermont Yankee Nuclear Power Station
Location: Vernon, VT
Dates: January9- 13,23-27, and March 19-20,2012
Inspectors: M. Modes, Senior Reactor lnspector, Division of Reactor Safety
G. Meyer, Senior Reactor Inspector, Division of Reactor Safety
S. Chaudhary, Reactor Inspector, Division of Reactor Safety
T. O'Hara, Reactor Inspector, Division of Reactor Safety
J. Lilliendahl, Reactor lnspector, Division of Reactor Safety
Approved by: Richard J. Conte, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
lR 0500027112012008; 119 13, 1123 - 27, and 3119 - 20,2012; Vermont Yankee Nuclear
-
Power Station; Post Approval Site Inspection for License Renewal 1P71003.
The report covers three weeks of onsite inspection of the implementation of license renewal
commitments during the period from Vermont Yankee's last refueling outage and prior to
entering the period of extended operation. The inspection was conducted by five regional
based inspectors and reviewed a sample of license renewal commitments, license renewal
related license conditions, and the process for handling newly identified systems, structures,
and components in accordance with Title 10 of the Code of Federal Regulations
(10 cFR) 54.37(b).
Enclosure
REPORT DETAILS
Summarv of Plant Status
Vermont Yankee Nuclear Power Station was at power during the period of this inspection,
4. OTHER ACTIVITIES
4OA5 Post-Approval Site Inspection for License Renewal- lP 71003
On March 21, 2011 , NRC issued a renewed operating license to the licensee Entergy
Nuclear LLC, based on a review of the Vermont Yankee License Renewal Application
submitted on January 27,2006, and verification of the activities proposed by the
applicant. In March 2011, NRC issued Supplement 2 to NUREG 1907, "Safety
Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear Power
Station," listing commitments the licensee made to address the U.S. Nuclear Regulatory
Commission (NRC) concerns raised during the review process. The commitments were
aggregated in Appendix A of the Safety Evaluation Report, Supplement 2. The period of
extended operation began on March 22,2012.
By letter (BVY 12-017), dated March 16,2012, the licensee notified the NRC that
implementation of activities required to be completed prior to the period of extended
operation have been completed and can be verified by the NRC. The licensee indicated
for Commitments 3, 6, 16, and 19 the activities completed were in conformance with a
letter (BW 12-016), dated March 12,2012, requesting a modification to the license to
allow for changes in the commitments. Prior to these letters, the licensee submitted a
license amendment request (BVY 12-015), dated March 5, 2012, in order to changes to
License Conditions 3.P and 3.Q. In essence, the March 5 request, if approved by NRC
staff, would allow the license renewal commitments to be placed in the Updated Final
Safety Analysis Report (UFSAR) supplement and clarify that future activities would be as
noted in the NUREG 1907 and the UFSAR supplement'
This inspection was performed by five NRC Region I based inspectors to evaluate the
license renewal activities at the Vermont Yankee Nuclear Power Station in accordance
with lnspection Procedure (lP) 71003 "Post-Approval Site Inspection for License
Renewal." The inspection consisted of a review and observation of activities, systems,
structures, and components accessible during the period of power operation subsequent
to the last refueling outage and prior to the beginning of the extended period of
operation.
The inspectors reviewed supporting documents including completed surveillances,
conducted interviews, performed visual inspection of structures, systems, and
components and observed selected activities described below. The inspection verified
the licensee completed the necessary actions to comply with the commitments that are
made a part of the license, as well as complied with specific license conditions that are a
part of the renewed operating license.
Enclosure
2
The commitments selected were those with activities that are not part of a regular review
as part of the Reactor Oversight Program such as the American Society of Mechanical
Engineers (ASME) Section Xl Inservice Inspection program and are of heightened
regulatory interest, safety significance, or have increased risk implications.
a.1 Inspection Scope
The inspectors verified license conditions added as part of the renewed license, license
renewal commitments with associated aging management programs, and license
renewal commitments revised after the renewed license was granted, are implemented
in accordance with Title 10 of the Code of Federal Regulations (CFR) Part 54,
"Requirements for the Renewal of Operating Licenses for Nuclear Power Plants."
Commitment 2
Commitment 2: Fifteen percent of the top guide locations will be inspected using
enhanced visual inspection technique, 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
twothirds 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 (specified in the license renewal application).
By way of procedure SEP-RVl-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 EW-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.
Commitments 3 and 4
Commitment 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 4: The Diesel Fuel Monitoring Program will be enhanced to specify
ultrasonic test (UT) measurements of the fuel oil storage and fire pump diesel
storage (day) tank bottom surfaces well have acceptance criterion greater than or
equal to 60 percent of normal thickness (Tnom).
These commitments require the licensee 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 SteelTank lnstitute
Standard SP001.
Enclosure
3
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.
On March 12,2012, the licensee sent a letter to the NRC requesting an amendment to
its license to revise Commitment 3 in order to clarify that cleaning and inspecting of the
fire pump diesel storage (day) tank is not required in order to perform ultrasonic
thickness measurements of the tank bottom. The licensee proposed the commitment
language be changed to read:
The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonic
thickness measurement of the fuel oil storage tank bottom surface will be
performed every 10 years during tank cleaning and inspection. Ultrasonic
thickness measurement of the fire pump storage (day) tank bottom will be
performed every 10 years.
Qommitment 6
Commitment 6: A computerized monitoring program (e.9., FatigueProrM) will be
used to directly determine cumulative fatigue usage factors (CUF) for locations of
interest.
The licensee submitted the Vermont Yankee license renewal application on
January 27, 2006, with an enhancement to the Fatigue Monitoring Program, as
stipulated in Commitment 6, to replace the manual cycle counting in use at the time of
the application. This commitment was a part of the original application and was not in
response to any inquiry from the NRC. 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 issued as NUREG-1907 did not revise the commitment.
Before receiving its renewed license (March 21, 2011) and prior to the implementation
date of the commitment (March 21,2012) the licensee revised Commitment 6 in
January 2011 to rescind the use of computerized fatigue monitoring, i.., FatigueProrM,
replacing FatiguePro'" and use their existing method of manual cycle counting. This
was based, in part, on their review of a similar license renewal application, in which the
staff accepted the manual counting method, On May 19,2011, the licensee informed
NRC of the commitment change in licensee letter BVY 1 1-026. This modification was
made based on Safety Evaluation Report Section 1.7 (Revision 0) discussion of the
license conditions which states:
Enclosure
4
The second license condition requires future activities identified in the UFSAR
supplement to be completed prior to the period of extended operation.
The actual License Condition 3.Q issued is much different as follows:
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. The licensee Nuclear Vermont Yankee, LLC and
the licensee 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). The licensee Nuclear Vermont
Yankee, LLC or The licensee 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.
Based on these two references the licensee followed the generally established principle
that completion of the commitment listed in Appendix A was an obligation "to be
completed prior to the period of extended operation," however, the language and nature
by which the commitment was implemented could be controlled either by 10 CFR 50.59
or NEI 99-04, "Guidelines for Managing NRC Commitment Changes'(ML003680088).
However, the language of the Vermont Yankee specific license condition was not exactly
the same as previous renewed licenses and therefore needed clarification.
During the October 2011 lP 71003 Phase I inspection, the NRC staff questioned the
exact meaning of renewed License Condition 3.Q as repeated above. The licensee's
renewed license was subsequently determined to mean any commitment listed in
Appendix A of the Safety Evaluation Report, as originally worded, was a direct part of
the license condition, and therefore an obligation as defined in NEI 99-04. The licensee
was informed of this new information on March 8, 2012, and this resulted in two license
amendment requests.
As a consequence of this determination, the licensee concluded they could not make
changes to the commitment under the more flexible rules of NEI 99-04, for a
commitment, or under the rules of 10 CFR 50,59 as of Marcn 8,2012. The licensee
concluded it was now required to request a modification of the license, following the
rules of 10 CFR 50.90, for each change made to the wording of any commitment. The
licensee entered a corrective action (CR-WY-2012-00388) that included an extent-of-
condition review to determine if any other commitments had been modified without
following the rules of 10 CFR 50.90.
As a consequence of its review the licensee submitted a letter on March 12,2012 (BVY
12-016), requesting an amendment to its license to revise Commitment 6 (as well as
Commitments 3, 16, and 19) to revert to manual counting, in accordance with the
requirements of 10 CFR 50.90 and its license condition.
Enclosure
5
Prior to the letter of March 12,2012, and in response to the letter of May 19, 2011, the
NRC performed a technical review to determine the acceptability of the proposed
modification to Commitment No. 6 and preliminarily did not object to the proposed
change. The licensee proposed the commitment be revised to read:
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 licensee also submitted a request on March 5, 2012 (BVY 12-015), to modify its
license to clarify the license condition so the wording of a commitment placed in the
UFSAR, by the licensee, would be controlled by 10 CFR 50.59 while the implementation
of the commitment would remain an obligation under the license.
The request letter of March 5,2012, added the following commitment:
Vermont Yankee will include the list of License Renewal Commitments identified
in Appendix A of Supplement 2 to NUREG-1907 (excluding Commitment No. 37
and including Commitment No, 55) in the UFSAR supplement, as revised,
submitted pursuant to 10 CFR 54.21.
The licensee's amendment requests were being reviewed by NRC staff. Since the
commitment change was completed in January 2011, the commitment was not an
obligation (March 2011) and the 50.90 process was not required to be used. The
information report in May 2011 was merely an extension of the NEI 99-04 process.
Commitment 8
Commitment 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.
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.
Commitment 9
Commitment 9: Procedures will be enhanced to state that the diesel engine
sub-systems (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.
Enclosure
6
The inspectors reviewed the license renewal application, Safety Evaluation Report, the
licensee implementation plan, the revised procedures, and discussed this commitment
with applicable plant staff and license renewal personnel. 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.
Commitment 10
Commitment 10: Fire Water System Program procedures will be enhanced to
specify that in accordance with the National Fire Protection Association
(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.
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 lnspection, 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. The inspectors interviewed the
project manager to review any operating experience or implementation issues.
Commitment 11
Commitment 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.9., volumetric testing) to
identify evidence of loss of material due to corrosion/microbiologically influenced
corrosion (MlC). 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.
The inspectors reviewed the commitment completion review report and ultrasonic test
results to verify that representative samples were selected and that the test results did
not indicate any current concerns. 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
Enclosure
7
operation. The inspectors also interviewed the project manager to review any operating
experience or implementation issues,
Commitments 13 and 43
Commitment 13: lmplement the Non-Environmental Qualification Inaccessible
Medium-Voltage Cable Program as described in License RenewalApplication
Section 8.1.17 .
The program as described in the license renewal application consists of periodic
inspections of manholes for water collection and testing of medium and low voltage
cables which are exposed to significant moisture.
Commitment 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 kV/69 kV step up transformers before the period of extended
operation and at least once every 6 years after the initial test.
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 43 applied the Commitment 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.
Commitment 12
Commitment 12: lmplement the Heat Exchanger Monitoring Program as
described in License RenewalApplication (LRA) Section 8.1.17.
As documented in Inspection Report 0500027112011011, the inspectors reviewed the
conditions of three heat exchangers which were opened for cleaning and inspection
during the refueling outage in October 2011.
Enclosure
8
The inspectors reviewed the license renewalapplication, 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. lnspections 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-O01, "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.
Commitment 14
Commitment 14: lmplement the Non-Environmental Qualification
Instrumentation Circuits Test Review Program as described in LRA
Section 8.1.18.
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 lntermediate 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
lntermediate Range Monitoring or Local Power Range Monitoring cables are being
adequately managed. The inspectors reviewed W-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.
Commitment 15
Commitment 15: lmplement the Non-Environmental Qualification Insulated
Cables and Connections Program as described in LRA Section 8.1 .19.
The program as described in the license renewal application was to manage the aging
effects of cables and connections exposed to adverse localized environments by visually
inspecting a representative sample of accessible insulated cables and connections.
Enclosure
I
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 W-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.
Commitment 16
Commitment 16: lmplement the One-Time Inspection Program as described in
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
procedure for one-time inspection, the summary report of the one{ime 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{ime 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
1ow restrictors. These inspections were discussed in Amendment 16 to the License
RenewalApplication 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 one-
time inspections of the reactor vessel leak'off line should be covered under
Commitment 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 at8.1.21.
Commitment 17
Commitment 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.
The "Periodic Surveillance and Preventive Maintenance Program" includes periodic
inspections and tests that manage aging effects not managed by other aging
management programs.
Enclosure
10
The inspectors reviewed Work 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 Coilfor 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.
Commitment 18
Commitment 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 8.1.24.
This commitment, which requires writing a procedure, was implemented by revising
SEP-FTP-WY, 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-LI-102'
Commitment 19
Commitment 19: lmplement the Selective Leaching Program as described in
LRA Section 8.1.25.
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 lron 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
Enclosure
11
with testing personneland applicable license renewal staff. The licensee had applied
the ultrasonic testing to 20 fire protection system components, which were not otheruvise
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 potentialwall
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 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.l.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.
Commitment 20
Commitment 20: Enhance the Structures Monitoring Program to specify that
process facility crane rails and girders, condensate storage tank enclosure,
COz tank enclosure, N2 tank enclosure and restraining wall, condensate storage
tank pipe trench, diesel generator able trench, fuel oil pump house, service water
Enclosure
12
pipe trench, man-way seals and gaskets, and hatch seal and gaskets are
included in the program.
The applicant has enhanced the Structural Monitoring Program to specify that process
facility crane rails and girders, condensate storage tank enclosure, CO2 tank enclosure,
Nz 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. In addition,
the inspectors reviewed the previous inspection and monitoring reports to assess the
implementation and effectiveness of the program.
Commitment 22
Commitment22: 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.
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.
Commitment 24
Commitment24: System walk down 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 (aX3). 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 structures, systems,
and components that are in-scope and subject to aging management review for
license renewal in accordance with 10 CFR 54.4 (a)(2).
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.
Enclosure
13
Commitment 25
Commitment 25: lmplement the Thermal Aging and Neutron lrradiation
Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in
LRA Section 8.1.29.
Section 8.1.29 of the license renewal application states the program will be "comparable
to the program described in NUREG-1801 Section Xl.M13." The applicable edition of
Nuclear Regulatory Commission guidance in NUREG-1801, GALL Report is Revision 1.
f n 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
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.
Section 6.7 of the program states:
"The inspection recommendation given are based on the following criteria:
(1) fluence less than 3 x 1020 nlcmZ, (2) adequate toughness (> 255 kJlm2), and
(3) applied stress (< Sksi).'
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
BWRVf P 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 Xl.M13,
because the inspection threshold in the guidance is established based on a single
criterion of fluence > 1017 nlcm2 (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 Xl.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 8.1 .29 of the application, and Section B.1 .29 of
the application includes the provision to supplement the approach using "future BWRVIP
Enclosure
14
reports, EPRI reports, and other industry operating experience" to "provide additional
bases for evaluations and inspections under this program." Under the provisions of
8.1.29 the application of BWRVIP 234-2009, as an additional bases for evaluation, is
acceptable.
Commitment 26
Commitment 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."
The inspectors reviewed the license renewal application, Safety Evaluation Report, and
the licensee's implementation plan, and discussed this commitment with applicable plant
staff and license renewal personnel. 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.
Commitment 28
Commitment23: Revise program procedures to indicate that the Instrument Air
Program will maintain instrument air quality in accordance with ISA S7.3.
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.
Commitment 29
Commitment 29: Vermont Yankee Nuclear Power Station 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 two years prior to the period of extended operation for NRC
review and approval.
The licensee completed a plant specific analysis (Option 2) which demonstrated that
operation, without core plate wedges, and with periodic W-3 inspection of the core plate
bolts will maintain acceptable margin above loss of bolt preload. The analysis was
submitted to the NRC on March 18,2011, satisfying the requirement contained in this
commitment.
Enclosure
15
Commitment 30
Commitment 30: Revise System Walkdown Program to specify CO2 system
inspections every 6 months.
The inspectors conducted a walk down of the CO2 system including the COz storage
tank, associated piping and controls and alarms. The inspectors also conducted a walk
down of the vital switchgear room and the associated suppression system bottles.
The NRC determined in the Safety Evaluation Report, 3.0.3.1.9, "System Walkdown
Program," that "those portions of the applicant's System Walkdown Program for which
the applicant claimed consistency with GALL AMP Xl.M36" is "consistent with the
GALL AMP." The staff concluded the "System Walkdown Program provided assurance
that the program will manage aging effects, e.9., the loss of material and leakage, of the
external surfaces of components."
The inspectors reviewed the most recent Fire Protection System walk down report and
System Health Report completed by the Fire Protection Engineer. The inspectors also
reviewed TRM 4.13.D "Surveillance Requirements," and the National Fire Protection
Association certification inspection results for the CO2 storage tank.
The inspectors reviewed the design of the CO2 system holding tank, an ASME, Boiler
and Pressure Vessel Code,Section I 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 COz 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.
Commitment 31
Commitment 31: Revise Fire Water System Program to specify annual fire
hydrant gasket inspections and flow tests.
The inspectors reviewed the commitment completion review report and surveillance
procedures to verify that the procedures had been enhanced to include fire hydrant
gasket inspections and flow tests. The inspectors noted that OP 4103, Fire Protection
Equipment Surveillance, included a schedule, list of locations, and acceptance criteria to
adequately control the gasket inspections. The inspectors noted that OP 4105, Fire
Protection Systems Surveillance, included a schedule, list of locations, and acceptance
criteria to adequately control the flow tests. The inspectors also interviewed the project
manager to review any operating experience or implementation issues.
Enclosure
16
Commitment 32
Commitment32: lmplement the Metal-Enclosed Bus lnspection Program.
Details are provided in LRA Amendment 16, Attachment 3 and LRA Amendment
23, Attachment 7.
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 lnspection," 52298263-02, "T-2-1A Auxiliary Transformer Refuel
Outage PMs," and 52334425-0, "lsophase-bus, Outage PM - Clean Inspect and Test,"
for the recent cleaning of a section of bus ducting during the Fall 2011 refueling outage.
Commitment 33
Commitment 33: Include within the Structures Monitoring Program provisions
that will ensure an engineering evaluation is made on a periodic basis (at least
once every 5 years) of groundwater to concrete. Sample will be monitored for
sulfates, pH, and chlorides.
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.
Commitment 34
Commitment 34: lmplement the Bolting Integrity Program. Details are provided
in an LRA Amendment 16, Attachment 2, and LRA Amendment 23,
Attachment 5.
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 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-lSl-WY-001. The inspectors discussed these
Enclosure
17
enhancements with the applicant's engineering and inspection personnel to determine
the bases for the guidance.
Commitment 35
Commitment 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 Field Guide or comparable instructional guide.
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.
Commitment 36
Commitment 36: lf 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 2 years prior to the period of extended operation, WNPS will
initiate plant-specific action to resolve this issue, That plant-specific action may
be justification that the welds do not require inspection.
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 EW-1 to
continue monitoring the indications.
Because the licensee uses EW-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 BWRVIP 41 to
perform a modified W-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. lf 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 42Mlblhr. 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 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 36 above, to plant-specific action to resolve this issue, 2 years prior to the period of
Enclosure
18
extended operation, 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 l. D. A-16808 LOR-LAR-2O10-00267, the licensee
recorded their rationale for not performing an ultrasonic test of the hidden and cores
spray welds thus satisfying the commitment's requirements.
Commitment 37
Commitment 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.
As part of the application process, and in accordance with an audit finding (ltem 204),
Commitment 37 was created by the licensee in letter BVY 06-079, dated August 22,
2006, transmitting Amendment 11 of their application, to replace the Vermont Yankee
specific steam dryer monitoring program with BWRVIP 139, "Steam Dryer Inspection
and Flaw Evaluation Guidelines," if, and when, the program was approved by the NRC.
A contention, admitted for adjudication by the Atomic Safety and Licensing Board, was a
claim the aging management program for the steam dryer was inadequate. The
licensee's response was, in part, to commit to use the Boiling Water Reactor Vessel and
Internals Project procedure 139 for inspection of the steam dryer. At the time this
response was tendered, the procedure was not approved by the NRC. Acceptance of
the procedure, by the Atomic Safety and Licensing Board, would mean the intervener
could not, as part of the hearing, review the finally approved BWRVIP procedure and
challenge its adequacy. The Atomic Safety and Licensing Board resolved this by
prohibiting the applicant from using the Boiling Water Reactor Vessel and Internals
Project procedure. The Atomic Safety and Licensing Board order stipulated the
applicant amend their license in order to use the Boiling Water Reactor Vessel Internals
Project procedure.
As a consequence, Atomic Safety and Licensing Board issued order LBP-08-25, dated
November 24,2008, which required specific elements of the Vermont Yankee steam
dryer monitoring program be implemented without change. This order pointedly
excluded the use of BWRVIP 139 without amending the license, effectively negating
Commitment 37. This was done to require the licensee to apply to the NRC for a
change to the condition, a public process, which would give stakeholders an opportunity
to contest the solution.
The NRC made the ASLB order condition "S" of the license:
"ln accordance with Atomic Safety and Licensing Board Order LBP-08-25, dated
November 24, 2008, notwithstanding any other provision of this license, the
licensee, Nuclear Vermont Yankee, LLC, and the licensee Nuclear Operations,
Enclosure
19
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 the provision of the license is duly amended."
The licensee implemented a revision to OPON-3178-01 to incorporate the moisture
content monitoring requirements of the condition by way of license renewal action
LO-LAR-2011-0073 CA L The licensee further revised OP 0631 to incorporate the
moisture content monitoring requirements of the condition by way of
LO-LAR-2011-0073 CA 10, and revised EN-CY-107 to add the condition to the section
on obligations and commitments and to protect the necessary steps within the procedure
to ensure moisture content monitoring is performed in accordance with GE SIL 644
Revision 2 by way of LO-WTHQN-201 1-032 CA-069.
The inspectors reviewed Program Report SEP-RVl-006, Revision 3, showing the
scheduled implementation of this license condition until 2019. The inspectors noted the
schedule was titled "Attachment 3, Boiling Water Reactor Vessel Internals Project
Report," and the steam dryer inspection was planned in accordance with the provisions
of procedure BWRVIP 139A and General Electric notice SIL 644, Revision 2. The
schedule included notations of W1 and W3 examinations going fonvard. The
inspectors reviewed SEP-RVl-006, Revision 2, "Vermont Yankee Reactor Vessel
Internals (RVl) lnspection Program Plan" Appendix L, "Steam Dryer."
Licensee personnel implemented the steam dryer inspection program scheduling the
inspections in accordance with the intervals required by SIL 644. Vermont Yankee
folded into its procedure the additional parameters of BWRVIP 139, Revision A, as
"approved" by the NRC. The licensee is implementing the other requirements of the
license condition in accordance with the statements in the condition.
The licensee issued Condition Report CR-VTY-2O12-00227 to identify the residual
references to the BWRVIP in the procedure. The condition report noted the licensee
submitted a license amendment request on 12122111 (BVY 11-085), to implement
BWRVIP 139A. The licensee used Commitment Management Program EN-LI-110,
Revision 5, to track and change the commitment.
During the outage, subsequent to the issuance of the new license, the licensee did not
implement the BWRVIP inspections, as evidenced by portions of "lWl Final Report
GE DRF 0000-0140-1232,lWl Final Report No. GEH-7480-2FY6R4-HK1-lWl." The
licensee limited their interrogation of the dryer to previously discovered indications using
the required SIL visual examinations. These examinations were implemented as part of
the power up-rate requirements.
Commitment 38 and 39. and License Condition 3.R
Commitment 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 Staff's final SE dated March 1, 2006, for the BWRVIP 116 report.
Enclosure
20
Commitment 39: lf the WNPS 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.
BWRVIP 86 Revision 1 replaces BWRVIP 116 and is approved by the NRC'
Commitment 39 requirements are narrowed by License Condition 3.R to specify the
future use must support the re-insertion into the reactor vessel. Condition 3.R states:
"lf 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."
The licensee incorporated these commitments into SEP-FTY-WY, 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) lmplementation Plan" into the design basis.
Commitment 42 - Bolted Cable Connections
Commitment 42 lmplement the Bolted Cable Connections Program. Details are
provided in LRA Amendment 23, Attachment 7.
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 an appropriate acceptance criteria would be 125 micro-ohms based
on an evaluation of voltage drop and heating. 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
Enclosure
21
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 locations were all associated with connections made to
transformer T-3-1B. The connections were C1333C and D on Phase A, C13338 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-2010-00271CA 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-VW-2007-02605
was a loose connection to DG-3-1A output connector.
Entergy also provided the revision to W-RPT-11-00017, Bolted Cable Connection
lnspection 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
Enclosure
22
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{ime program.
Commitment 45
Commitment 45: Enhance the service water integrity program to require a
periodic visual inspection of the Residual Heat Removal Service Water (RHRSW)
pump motor cooling internal surfaces for loss of material.
As recorded in Condition Report LO-LAR-2O10-00274, 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-WY-2012-00218, "Corrective Action Plan," contains various steps to remedy
the failure. For example:
o Action A, 1. determine if a boroscope exists that can negotiate the piping elbows
of the motor cooling coils.
r Action A, 2. determine if a repair technique is available to allow the inlet and
outlet lines to be cut off for access.
r Action A, 3. determine if alternate NDE is available.
o 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.
Enclosure
23
Commitments 46 and 47
Commitment 46: Enhance the Diesel Fuel Monitoring Program to specify that
fuel oil in the fire pump diesel storage (day) tank will be analyzed in accordance
with ASTM D975-02 and for particulates per ASTM D2276. Also, fuel oil in the
John Deere diesel storage tank will be analyzed for particulates per
ASTM D2276.
Commitment 47: Enhance the Diesel Fuel Monitoring Program to specify that
fuel oil in the common portable fuel oil storage tank will be analyzed in
accordance with ASTM D975-02, per ASTM D2276 for particulates, and
ASTM D1796 for water and sediments.
The inspectors reviewed the license renewal application, Safety Evaluation Report, and
the licensee implementation plan, and discussed these commitments with applicable
plant staff and license renewal personnel. The inspectors reviewed the chemistry
procedure used to sample and test dieselfuel 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.
Commitment 49
Commitment 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.
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 4104, 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.
Commitment 50
Commitment 50: During the period of extended operation, review the Vernon
Dam owner Federal Energy Regulatory Commission (FERC) required report(s) at
a minimum of every 5 years to confirm that the Vernon Dam owner is performing
the required FERC inspections. Document deficiencies in the licensee
Corrective Action Program and evaluate operability as described in BVY 96-043
and BW 97-043, if it is determined that the required inspections are not being
performed.
Enclosure
24
f n 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, CEll No. CE1 1-181. Because the licensee was granted
access, they were able tO review the Vernon Dam owner's report to the FERC, as
stipulated in Commitment 50.
Commitment 55
Commitment 55: Enhance safety-related coatings programs and procedures to
be consistent with the recommendation of NUREB-1801, Section Xl.58,
Protective Coating Monitoring and Maintenance Program.
In Appendix B of the license renewal application, the licensee stated a Protective
Coatings inside Containment Program is not applicable. Subsequently, in Entergy
correspondence dated December 21,2010 (BVY 10-058), the licensee provided a new
aging management program for protective coatings inside containment, in order to
pievent coatings inside containment from contributing to Emergency Core Cooling
System challenges during an event during the period of extended operation.
Commitment 55 was noted in the correspondence at the bottom of Page 2 of
Attachment 2.
This program was further expanded in correspondence dated February 4,2011
(BVY 11-010). This included a lengthy description of the 10 program elements aligned
with the Standard Review Plan for License Renewal'
The NRC then developed a "supplemental Safety Evaluation Report Related to the
License Renewal of Vermont Yankee Nuclear Power Station," sending the licensee a
copy by letter dated March 21, 2011. 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. lt is referenced and discussed in
Section 3.0.3.1 .13." In this section of the safety evaluation report: "The 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
As a consequence, the omission of Commitment 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-O01 and
procedure EN-DC-220.
Enclosure
25
b.1 Findinqs/Observations
No findings were identified. The inspectors determined the licensee has completed the
reviewed commitments and is implementing the selected license conditions with the
exceptions as noted in their completion letter (BW 12-017), dated March 16,2012,
submitted in accordance with License Condition 3. Q .
a.2 lnspection Scope
The inspectors verified systems, structures, and components, "newly identified" as part
of 10 CFR 54.37(b), and Regulatory lssue Summary RIS-2007-16, are implemented in
accordance with 10 CFR Part54.
Vermont Yankee Procedure SEP-LR-WY-001, Revision 0, January 2012, describes the
method for determining if reporting is required by 10 CFR 54.37(b) and performing an
aging management review or Time Limited Aging Analysis evaluation. This procedure
was referenced in the licensee Nuclear Management Manual EN-DC-115, Revision 12,
"Engineering Change Process" in order to assure any current license basis changes
would capture systems, structures, and components that were not in the scope of
license renewal when the NRC approved the license renewal application, or would have
been in the scope of license renewal if 10 CFR 1a.a@) were applied to the systems,
structures, and components.
b.2 Findinqs/Observations
No findings were identified. The licensee is implementing the requirements of
10 cFR 54.37(b).
4OAO Exit Meetinq
The inspectors presented the inspection results to Mr. Christopher Wamser, Site Vice
President, and other members of his staff on March 20,2012. Additional discussions
occurred in interim meetings of January 26 and March 8, 2012. The inspectors
confirmed no proprietary materialwas examined during the inspection.
Enclosure
A-1
ATTACHMENT
SUPPLEM ENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
C. Wamser, W General Manager/Site Vice President
B. Wanczyk, VY Licensing Manager
G. Thomas, VY LR Project Manager
P. Guglielmino, W LR Project lmplementation Manager
J. Hoffman, VY LR Team
D. Lach, Entergy LR Team
J. DeVincentis, W Licensing Engineer
DOCUMENTS REVIEWED
Corrective Action Reports
cR-wY-2001-00829 cR-wY-2O12-40il1
cR-wY-2011-02335 LO-LAR-2010-00244
cR-wY-2012-00218 LO-LAR-2010-00246
cR-wY-2012-00297 LO-LAR-2o10-00271
cR-wY-2o12-00218 LO-LAR-2010-00250
cR-wY-2o12-00350 LO-LAR-2010-00274
cR-wY-2o04-02183 LO-LAR-2010-00026
cR-wY-2005-03653 LO-LAR-2o10-00240
cR-wY-2007-02190 LO-LAR-zo10-00248
cR-wY-2o07-02288 LO-LAR-2o11-00094
cR-wY-2o08-04297 LO-LAR-2o10-00259
cR-wY-2008-04549 LO-LAR-2010-00260
cR-wY-2008-04571 LO-LAR-2010-00261
cR-wY-2o11-03205 LO-LAR-2010-00263
cR-wY-2o11-05520 LO-LAR-2o10-00266
A.2.1.7 BWR Vessel lnternals Program
A.2.1.28 Service Water lntegrity Program
A.2.1.24 Periodic Surveillance And Preventive Maintenance Program
A.2.1.32 System Walkdown Program
8.1.22 Periodic Surveillance and preventative Maintenance Program
Attachment
A-2
Drawinos & Sketches
General Electric drawing 729E957, Revision 3; Vermont Yankee Reactor Core Support
(NY 706102-530)
General Electric drawing 919D294, Revision 8; Vermont Yankee Reactor Vessel
(NY 706102-5920-19)
General Electric drawing 729E956, Revision 0; Vermont Yankee Reactor Shroud
(NY 706102-5920-s29)
General Electric drawing 729E959, Revision 3; Vermont Yankee Core Structure
Arrangement (NY 5920-532)
The licensee Nuclear Vermont Yankee, Vernon, VT, drawing 5920-1102, R HEADS, Nuclear
Reactor, General Electric Company, CentralVermont Power Company, Vernon Dam,
Vermont (NY 5290-252)
MPR Associates drawing, Vermont Yankee Power Station, Shroud Repair, Shroud Restraint
Assembly 1249-006-01, Revision D
Engineering Evaluations, Analyses, Calculations & Standards:
GE Instructions for Recirculating Water Pump Motors, Model SK263668K1, ltem 0157
TECO, Westinghouse Engineering Study, 2N1gSN, Revision 2,2005
The licensee Nuclear Vermont Yankee (ENVY) - Upper Bearing Cooler Study
The licensee Vermont Yankee Root Cause Analysis Report, CR-WY-2004-2015,7116104;
Electrical FaulVFire
ISA-7.0.01-1996, Quality Standard for lnstrument Air, Approved 12 November 1 996
The licensee Engineering Standard, ENN-MS-S-OO4 W, Revision 5, 3/15/12; System
Categorization
Svstem & Proqram Health Reports & Svstem Enqineer Walkdown Reports
RCIC Monthly Walkdown Report, 7118111
RCf C Monthly Walkdown Report, 8111111
RCIC Monthly Walkdown Report, 912111
RHRSW Monthly Walkdown Report, 7125111
RHRSW Monthly Walkdown Report, 8117111
RHRSW Monthly Walkdown Report, 9122111
RBCCW Monthly Walkdown Report, 7122111
RBCCW Monthly Walkdown Report, 8122111
RBCCW Monthly Walkdown Report, 1015111
Fire Protection Monthly Walkdown Report, 911111
Fire Protection Monthly Walkdown Report, 10125111
The licensee System Health Report, W, Fire Protection, Period Q3-2011,92.68 (WHITE)
The licensee System Health Report, VY, lA-105 - Instrument Air, 1112112, Period Q3-2011,
98.35 (GREEN)
The licensee System Health Report, VY, SA-105 - Service Air, 1112112, Period Q3-201 1 ,
e6.70 (GREEN)
The licensee System Health Report, VY, RCIC ,1112112, Period Q3-2011,K87.32 (YELLOW)
The licensee System Health Report, VY, RHRSW, 1112112, Period Q3-201 1 , 100 (GREEN)
The licensee System Health Report, VY, RBCCW,1ll2l12,Period Q3-2011, 100 (GREEN)
Attachment
A-3
Vermont Yankee Updated Final Safetv Analvsis Report
Section 10.11 FIRE PROTECTION SYSTEM
Proqram Documents
The licensee W Heat Exchanger Program, ENN-SEP-HX-001, Revision 1
The licensee W Service Water Program, ENN-SEP-SW-001, Revision 2
The licensee W ENN Engineering Standard, ENN-MS-S-004-VY, Revision 5,3115112;
System Categorization
Procedures
Procedure RP 4620, Revision 19, Sampling and Analysis of Instrument And
Containment lnstrument Air Supplies, 1 1130110
The licensee Procedure, EN-DC-178, Revision 4, System Wall<downs (Non-Quality,
Informational Use)
Vermont Yankee Power Station Procedure RP4620, Revision 20; Sampling and Analysis of
Instrument And Containment Instrument Air Supplies
Vermont Yankee Power Station Operating Procedure 4019, Revision 30, 01/03/1 2; Surveillance
of Plant Fore Barriers and Fire Rated Assemblies
Vermont Yankee Power Station Operating Procedure 4105, Revision 48, 01 l03l12; Fue
Protection Systems Surveillance
OP 4019, Surveillance of Plant Fire Barriers and Fire Rated Assemblies, Rev.30
OP 4103, Fire Protection Equipment Surveillance, Rev, 56
OP 4104, Fire Hose Service Test Surveillance, Rev. 19
OP 4105, Fire Protection Systems Surveillance, Rev. 48
OPOP-PHEN-3127, Natural Phenomena Operating Procedure, Rev. 5
Work Orders & Work Requests
wR 0029167 wR 00248862 wR00291422
wR 0029168 wR 00248864 wR 00291425
wR 0029169 wR 00248866 wR 00291430
wR 00291970 wR 00248870 wR 00298713
wR 00261977 wR 00250475 wR 00301548
wR 00261966 wR 00250476 wR 52298615
wR 00184551 wR 00250481 wR 52298263
wR 00242340 wR 00282293 wR 52334425
wR 00245641 wR 00282294
wR 00248857 wR 00291419
Attachment
A-4
Miscellaneous Documents
NRC Generic Letter 89-13; 7118189: Service Water System Problems Affecting Safety-Related
Equipment
GE Nuclear Services Information Letter (SlL) Number 588R1, 5/18/95; TOP GUIDE AND CORE
PLATE CRACKING
Vermont Yankee UFSAR, Revision 18; Section C.2.5.2Internals Deformation Analysis General
License Renewal Application dated January 25,2006, including Appendix A
(FSAR Supplements) and Appendix B (Aging Management Programs)
NUREG 1907, Safety Evaluation Report, May 2008
NUREG 1907, Safety Evaluation Report, Supplement 1, September 2009
NUREG 1907, Safety Evaluation Report, Supplement2, March 2011
The licensee letter BVY 06-091, dated October 17,2Q06
The licensee letter BVY 07-018, dated March 23,2007
The licensee letter BVY 10-069, dated December 30, 2010
The licensee letter BVY 1 1-001, dated January 21,2011
The licensee letter BVY 1 1-007, dated February 4,2Q11
EN-DC-346, Cable Reliability Program, Revision 2
EN-DC-348, Non-EQ Insulated Cables and Connections Inspection, Revision 2
EN-FAP-LR-O27, License Renewal Sensitive lnstrumentation Circuits Review AMP, Revision 0
ENN-SEP-CBL-WY, Vermont Yankee Cable Reliability Program Plan, Revision 0
LRID-12-1, Review of the Fire Protection Aging Management Program for License Renewal
lmplementation at Vermont Yankee Nuclear Power Station, Revision 0
LRID-12-2, Review of the Fire Water System Aging Management Program for License Renewal
lmplementation at Vermont Yankee Nuclear Power Station, Revision 0
LRID-17, Review of the Non-EQ Inaccessible Medium-Voltage Cable Aging Management
Program for License Renewal lmplementation at W Nuclear Power Station, Revision 0
LRID-18, Review of Non-EQ Instrumentation Circuits Rest Review Aging Management Program
for License Renewal lmplementation at Vermont Yankee Nuclear Power Station,
Revision 0
LRID-19, Review of the Non-EQ Insulated Cables and Connections Aging Management
Program for License Renewal lmplementation at W Nuclear Power Station, Revision 1
LRID-31, Review of Bolted Cable Connections Aging Management Program for License
Renewal lmplementation at Vermont Yankee Nuclear Power Station, Revision 0
OP 5307, Electrical Checkout of Neutron Monitoring Detectors, Revision 12
PP 701 1, Vermont Yankee Fire Protection and Safe Shutdown, Revision 13
VY-RPT-1 1-00017, Bolted Cable Connection lnspection Report, Revision 0
VY-RPT-11-00018, Non-EQ Sensitive Instrumentation Circuits Cable and Connection
Evaluation, Draft Revision 0
VY-RPT-11-00019, Cable and Connection Inspection Summary Report, Revision 0
Evaluation of the Ultrasonic Testing Performed on the Diesel Fuel Oil Storage Tank, RFO-29,
Jan.20,2012 (dratt)
Evaluation of the Ultrasonic Testing Performed on the Diesel Fire Pump Fuel Oil Storage Tank,
RFO-29, Jan. 20, 2012 (draft)
Fuel Oil Storage Tank (FOST) Ultrasonic Test (UT) Results, Oct. 23,2011
Fire Pump Diesel Tank Ultrasonic Test (UT) Results, Nov. 29,2011
VYBOP-11-UT-007, UT Erosion/Corrosion Examination - TK-40-1A, Oct. 23,2011
VYBOP-11-UT-031. UT Thickness Examination - TK-43-1A, Nov. 14, 2011
Attachment
A-5
PM Basis M118, Revision 4
PM Basis M336, Revision 1
API Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction, 4th Ed., April 2009
SP001, Steel Tank Institute, Standard for the Inspection of Aboveground Storage Tanks, 4th Ed,
July 2006
OP 4105, Fire Protection Systems Surveillance, Revision 48
EN-DC-316, Heat Exchanger Performance and Condition Monitoring, Revision 3
ENN-SEP-HX-001, Heat Exchanger Program, Revision 1
ENN-SEP-HX-001, Heat Exchanger Program, Revision 2 (draft)
Heat Exchanger Program Health Report, 2011 Quarters 2,3, 4
HVAC Heat Exchanger Status Report, Jan.25,2012
EN-FAP-LR-024, One-Time Inspection, Revision 0
ER VY-RPT-11-00032, Revision 0 (draft)
One-Time lnspection Tracking Matrix, Jan. 25, 2Q12
EN-FAP-LR-025, Selective Leaching Inspection, Revision 1
VY-RPT-12-01, License Renewal Selective Leaching Inspection Summary Report,
Revision 0 (draft)
Altran Solutions Technical Report No. 1 1-2318-TR-001 , Evaluation of Selective Leaching on
Various Components in Contact with Water, Dec.2011
GZA GeoEnvironmental, Inc, Report No. 01 .25576.13, Results of Soil Corrosivity Testing -
Buried Pipe Initiative, Vermont Yankee, Dec. 12,2011
Evaluation of the Gray Cast lron Valves in the Fire Protection System Based on External
Ultrasonic Test Examinations, Jan. 18,2012
Selective Leaching Matrix, Jan. 25, 2012
PMRQ 50040601, task 3
ME163, Preventive Maintenance Basis - John Deere Diesel
Work Order 52316981, Three year PM for John Deere Diesel, completed June 16, 2011
CHOP-DIES-4613-01, Sampling and Testing of Diesel Fuel Oil, Revisions 1 & 2
Annual fuel oil analyses (John Deere Diesel) for sample of March 10,2011
Quarterly water and sediment test (John Deere Diesel) for samples on July 18,2Q11 and
Oct.22,2011
Quarterly water and sediment test (diesel fire pump) for samples on Sept. 15,2011 and
Dec.19,2011
NUREG-1801, Vol. 2, Revision 1, Xl.6 Structural Monitoring Program
AP 0205, Controlled Use Monorai
OP 5241, Lifting Fixtures and Equipment
OP 52114, Cooling Tower Structural Inspection and Repair
EN-WM- 105, Planning
VYNPS-LRID-27-2, Review of the Structural Monitoring Aging Management Program
Attachment
A-6
License Renewal Trackinq Documents
LRID-09, Review of the Diesel Fuel Monitoring Aging Management Program, Revision 0
LRID-12-1, Review of the Fire Protection Aging Management Program, Revision 0
LRID-14, Review of the Heat Exchanger Monitoring Aging Management Program, Revision 0
LRID-21, Review of the One-Time Inspection Aging Management Program, Revision 1
LRID-25, Review of the Selective Leaching Aging Management Program, Revision 0
LRID-30-1, Review of the Water Chemistry Control - Auxiliary Systems Aging Management
Program, Revision 0
LIST OF ACRONYMS
ASME American Society of Mechanical Engineers
BWRVIP Boiling Water Reactor Vessel Internals Project
CASS Cast Austenitic Stainless Steel
CFR Code of Federal Regulations
CUF Cumulative Fatigue Usage Factors
EVT.1 Enhanced Visual Inspection Technique
FERC Federal Energy Regulation Commission
GALL Generic Aging Lessons Learned
IP Inspection Procedure
ISP Integrated Surveillance Program
LRA License Renewal Application
NFPA National Fire Protection Association
NRC U.S. Nuclear Regulatory Commission
RHRSW Residual Heat Removal Service Water
UFSAR Updated Final Safety Analysis Report
UT Ultrasonic Tests
VYNPS Vermont Yankee Nuclear Power Station
Attachment