IR 05000271/2012008
| ML15331A156 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Vermont Yankee  |
| Issue date: | 04/20/2012 |
| From: | Conte R J Engineering Region 1 Branch 1 |
| To: | Wamser C Entergy Nuclear Operations |
| SECY RAS | |
| References | |
| RAS 23737, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 IR-12-008 | |
| Download: ML15331A156 (37) | |
Text
April 20, 2AI2Mr. Christopher WamserSite Vice PresidentEntergy Nuclear Operations, Inc.Vermont Yankee Nuclear Power Station185 Old Ferry RoadP.O. Box 500Brattleboro, VT 05302-0500VERMONT YANKEE NUCLEAR POWER STATION - NRC INSPECTIONREPORT 0500027 1 t20 12008
Dear Mr. Wamser:
On March 20,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspectionat the Vermont Yankee Nuclear Power Station. The enclosed report documents the results ofthe 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 tothe completion of commitments made during the renewed license application process and youractions to comply with the conditions of your renewed license. Under the renewed operatinglicense, entry into the period of extended operation occurred on March 22,2012. Theinspection was of those activities and facilities accessible during the power production. Withinthese areas, the inspection involved examination of selected procedures, representativerecords, observations of activities, and interviews with personnel.On the basis of the samples selected for review, there were no findings identified during thisinspection. However, as a consequence of this inspection, some of your administrativeprocesses, and aging management programs, required modification. Further, we noted thatlicense amendment changes, dated March 5 and March 12,2012, addressed needed changesto your plans from the original license renewal application. Accordingly, we intend to implementan additional phase of this inspection on or about the spring 2013 Refueling Outage in order tofollow-up on these issues in accordance with lnspection Procedure 71003, "PostApproval SiteInspection for License Renewal."
C. Wamserln 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 forpublic inspection in the NRC Public Document Room or from the Publicly Available Recordscomponent of NRC's document system Agencywide Document Access and ManagementSystem. The Agencywide Document Access and Management System is accessible from theNRC Web site at http://www.nrc,gov/reading-rm/adams.html (the Public Electronic ReadingRoom),
Sincerely,,Q*l;DClbRichard J. Conte, ChiefEngineering Branch 1Division of Reactor SafetyDocket No. 50-271License No. DPR-28
Enclosure:
NRC lnspection Report 0500027 1 12012008cc w/enclosure: Distribution via ListServ C. Wamserf 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 forpublic inspection in the NRC Public Document Room or from the Publicly Available Recordscomponent of NRC's document system Agencywide Document Access and ManagementSystem. The Agencywide Document Access and Management System is accessible from theNRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic ReadingRoom).
Sincerely,/RNRichard J. Conte, ChiefEngineering Branch 1Division of Reactor SafetyDocket No. 50-271License No. DPR-28
Enclosure:
NRC lnspection Report 0500027 1 12012008cc w/enclosure: Distribution via ListServDistribution: See next pageDOCUMENT NAME: C:\Documents and Settings\gmp\My Documents\05000271 2012008 VY 1P71003 Inspection Report FINAL'docxADAMS ACCESSION NUMBER: ML1 2103A406V suNstReviewVnNon-SensitiveSensitiveg!Publicly AvailableNon-Publicly AvailableOFFICERI/DRSRI/DRPRI/DRSRI/DRSNAMEMModes/RJCRBellamyRConteCMillerDATE41121124t17t1241171124t20t12ICIALCOPY C. WamserDistribution w/encl: (via E-mail)W. Dean, RAD. Lew, DRAJ. Clifford, DRPJ. Trapp, DRPC. Miller, DRSP. Wilson, DRSL. Chang, Rl OEDOR. Bellamy, DRPT. Setzer, DRPE. Keighley, DRPJ. DeBoer, DRPS. Rutenkroger, DRP, SRIS. Rich, DRP, RlA. Rancourt, DRP, MRidsNrrPMVermontYankee Resou rceRidsNrrDorlLll -1 ResourceROPreports ResourceD. Bearde, DRST. Lupold, DRSR. Conte, DRS(RIoRAMAIL RESOURCE)(RIORAMAlL RESOURCE)(RIDRPMAlL Resource)(RIDRPMAlL Resource)(RIDRSMAIL RESOURCE)(RIDRSMAlL RESOURCE)
Facility:Location:Dates:Inspectors:Approved by:U.S. NUCLEAR REGULATORY COMMISSIONREGION I50-271DPR-280500027112012008Entergy Nuclear Vermont Yankee, LLCEntergy Nuclear Operations, Inc.Vermont Yankee Nuclear Power StationVernon, VTJanuary9- 13,23-27, and March 19-20,2012M. Modes, Senior Reactor lnspector, Division of Reactor SafetyG. Meyer, Senior Reactor Inspector, Division of Reactor SafetyS. Chaudhary, Reactor Inspector, Division of Reactor SafetyT. O'Hara, Reactor Inspector, Division of Reactor SafetyJ. Lilliendahl, Reactor lnspector, Division of Reactor SafetyRichard J. Conte, ChiefEngineering Branch 1Division of Reactor SafetyEnclosure SUMMARY OF FINDINGSlR 0500027112012008; 119 - 13, 1123 - 27, and 3119 - 20,2012; Vermont Yankee NuclearPower Station; Post Approval Site Inspection for License Renewal 1P71003.The report covers three weeks of onsite inspection of the implementation of license renewalcommitments during the period from Vermont Yankee's last refueling outage and prior toentering the period of extended operation. The inspection was conducted by five regionalbased inspectors and reviewed a sample of license renewal commitments, license renewalrelated 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 DETAILSSummarv of Plant StatusVermont Yankee Nuclear Power Station was at power during the period of this inspection,4. OTHER ACTIVITIES4OA5 Post-Approval Site Inspection for License Renewal- lP 71003On March 21, 2011 , NRC issued a renewed operating license to the licensee EntergyNuclear LLC, based on a review of the Vermont Yankee License Renewal Applicationsubmitted on January 27,2006, and verification of the activities proposed by theapplicant. In March 2011, NRC issued Supplement 2 to NUREG 1907, "SafetyEvaluation Report Related to the License Renewal of Vermont Yankee Nuclear PowerStation," listing commitments the licensee made to address the U.S. Nuclear RegulatoryCommission (NRC) concerns raised during the review process. The commitments wereaggregated in Appendix A of the Safety Evaluation Report, Supplement 2. The period ofextended operation began on March 22,2012.By letter (BVY 12-017), dated March 16,2012, the licensee notified the NRC thatimplementation of activities required to be completed prior to the period of extendedoperation have been completed and can be verified by the NRC. The licensee indicatedfor Commitments 3, 6, 16, and 19 the activities completed were in conformance with aletter (BW 12-016), dated March 12,2012, requesting a modification to the license toallow for changes in the commitments. Prior to these letters, the licensee submitted alicense amendment request (BVY 12-015), dated March 5, 2012, in order to changes toLicense Conditions 3.P and 3.Q. In essence, the March 5 request, if approved by NRCstaff, would allow the license renewal commitments to be placed in the Updated FinalSafety Analysis Report (UFSAR) supplement and clarify that future activities would be asnoted in the NUREG 1907 and the UFSAR supplement'This inspection was performed by five NRC Region I based inspectors to evaluate thelicense renewal activities at the Vermont Yankee Nuclear Power Station in accordancewith lnspection Procedure (lP) 71003 "Post-Approval Site Inspection for LicenseRenewal." The inspection consisted of a review and observation of activities, systems,structures, and components accessible during the period of power operation subsequentto the last refueling outage and prior to the beginning of the extended period ofoperation.The inspectors reviewed supporting documents including completed surveillances,conducted interviews, performed visual inspection of structures, systems, andcomponents and observed selected activities described below. The inspection verifiedthe licensee completed the necessary actions to comply with the commitments that aremade a part of the license, as well as complied with specific license conditions that are apart of the renewed operating license.Enclosure a.12The commitments selected were those with activities that are not part of a regular reviewas part of the Reactor Oversight Program such as the American Society of MechanicalEngineers (ASME) Section Xl Inservice Inspection program and are of heightenedregulatory interest, safety significance, or have increased risk implications.Inspection ScopeThe inspectors verified license conditions added as part of the renewed license, licenserenewal commitments with associated aging management programs, and licenserenewal commitments revised after the renewed license was granted, are implementedin 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 2Commitment 2: Fifteen percent of the top guide locations will be inspected usingenhanced visual inspection technique, enhanced visual inspection technique(EVT-1), within the first 18 years of the period of extended operation, with at leastone-third of the inspections to be completed within the first 6 years and at leasttwothirds within the first 12 years of the period of extended operation. Locationsselected for examination will be areas that have exceeded the neutron fluencethreshold (specified in the license renewal application).By way of procedure SEP-RVl-006, Revision 2, Section 2.1.2 parts (a), (b), and (c), theapplicant committed to inspect 5 percent of the top guide locations using an EW-1during the first 6 years of extended operation, with an additional 5 percent in subsequent6 year intervals for a total of 15 percent by the end of 18 years.Commitments 3 and 4Commitment 3: The Diesel Fuel Monitoring Program will be enhanced to ensureultrasonic thickness measurement of the fuel oil storage and fire pump dieselstorage (day) tank bottom surfaces will be performed every 10 years during tankcleaning and inspection.Commitment 4: The Diesel Fuel Monitoring Program will be enhanced to specifyultrasonic test (UT) measurements of the fuel oil storage and fire pump dieselstorage (day) tank bottom surfaces well have acceptance criterion greater than orequal to 60 percent of normal thickness (Tnom).These commitments require the licensee enhance the Diesel Fuel Monitoring Program toperform UTs of the bottoms of the fuel oil storage tank and the fire pump diesel storagetank every 10 years. The acceptance criteria for these tests will be in accordance withthe American Petroleum Institute Standard 653 and the SteelTank lnstituteStandard SP001.Enclosure 3The inspectors reviewed the license renewal application, Safety Evaluation Report, andthe licensee's implementation plan, and discussed these commitments with applicableplant staff and license renewal personnel. The inspectors reviewed the ultrasonic testingreports, testing results evaluations, and applicable industry standards. For both the fueloil storage tank and the fire pump diesel day tank, the tank bottom thickness resultswere greater than the acceptance criteria. Also, evaluations of the effect of corrosion onthe tank bottoms determined that the thicknesses were projected to remain above theacceptance 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 andfound it to be acceptable.On March 12,2012, the licensee sent a letter to the NRC requesting an amendment toits license to revise Commitment 3 in order to clarify that cleaning and inspecting of thefire pump diesel storage (day) tank is not required in order to perform ultrasonicthickness measurements of the tank bottom. The licensee proposed the commitmentlanguage be changed to read:The Diesel Fuel Monitoring Program will be enhanced to ensure ultrasonicthickness measurement of the fuel oil storage tank bottom surface will beperformed every 10 years during tank cleaning and inspection. Ultrasonicthickness measurement of the fire pump storage (day) tank bottom will beperformed every 10 years.Qommitment 6Commitment 6: A computerized monitoring program (e.9., FatigueProrM) will beused to directly determine cumulative fatigue usage factors (CUF) for locations ofinterest.The licensee submitted the Vermont Yankee license renewal application onJanuary 27, 2006, with an enhancement to the Fatigue Monitoring Program, asstipulated in Commitment 6, to replace the manual cycle counting in use at the time ofthe application. This commitment was a part of the original application and was not inresponse to any inquiry from the NRC. On March 30,2007, NRC issued "SafetyEvaluation Report with Confirmatory ltems Related to the License Renewal of VermontYankee Nuclear Power Station," which contained Appendix A, "Commitment Listing," inwhich Commitment 6 was recorded. Subsequent versions of the Safety EvaluationReport issued as NUREG-1907 did not revise the commitment.Before receiving its renewed license (March 21, 2011) and prior to the implementationdate of the commitment (March 21,2012) the licensee revised Commitment 6 inJanuary 2011 to rescind the use of computerized fatigue monitoring, i.*., FatigueProrM,replacing FatiguePro'" and use their existing method of manual cycle counting. Thiswas based, in part, on their review of a similar license renewal application, in which thestaff accepted the manual counting method, On May 19,2011, the licensee informedNRC of the commitment change in licensee letter BVY 1 1-026. This modification wasmade based on Safety Evaluation Report Section 1.7 (Revision 0) discussion of thelicense conditions which states:Enclosure 4The second license condition requires future activities identified in the UFSARsupplement 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 theperiod of extended operation. The licensee Nuclear Vermont Yankee, LLC andthe licensee Nuclear Operations, Inc. shall complete these activities inaccordance with Appendix A of Supplement 2 to NUREG-1907, "SafetyEvaluation Report Related to the License Renewal of Vermont Yankee NuclearPower Station," issued March 2011 (excluding Commitment No. 37, which issuperseded by the steam dryer license condition). The licensee Nuclear VermontYankee, LLC or The licensee Nuclear Operations, Inc. shall notify the NRC inwriting when activities to be completed prior to the period of extended operationare complete and can be verified by NRC inspection.Based on these two references the licensee followed the generally established principlethat completion of the commitment listed in Appendix A was an obligation "to becompleted prior to the period of extended operation," however, the language and natureby which the commitment was implemented could be controlled either by 10 CFR 50.59or NEI 99-04, "Guidelines for Managing NRC Commitment Changes'(ML003680088).However, the language of the Vermont Yankee specific license condition was not exactlythe same as previous renewed licenses and therefore needed clarification.During the October 2011 lP 71003 Phase I inspection, the NRC staff questioned theexact meaning of renewed License Condition 3.Q as repeated above. The licensee'srenewed license was subsequently determined to mean any commitment listed inAppendix A of the Safety Evaluation Report, as originally worded, was a direct part ofthe license condition, and therefore an obligation as defined in NEI 99-04. The licenseewas informed of this new information on March 8, 2012, and this resulted in two licenseamendment requests.As a consequence of this determination, the licensee concluded they could not makechanges to the commitment under the more flexible rules of NEI 99-04, for acommitment, or under the rules of 10 CFR 50,59 as of Marcn 8,2012. The licenseeconcluded it was now required to request a modification of the license, following therules of 10 CFR 50.90, for each change made to the wording of any commitment. Thelicensee entered a corrective action (CR-WY-2012-00388) that included an extent-of-condition review to determine if any other commitments had been modified withoutfollowing the rules of 10 CFR 50.90.As a consequence of its review the licensee submitted a letter on March 12,2012 (BVY12-016), requesting an amendment to its license to revise Commitment 6 (as well asCommitments 3, 16, and 19) to revert to manual counting, in accordance with therequirements of 10 CFR 50.90 and its license condition.Enclosure 5Prior to the letter of March 12,2012, and in response to the letter of May 19, 2011, theNRC performed a technical review to determine the acceptability of the proposedmodification to Commitment No. 6 and preliminarily did not object to the proposedchange. The licensee proposed the commitment be revised to read:Manual Cycle counting will be used to track and compare accumulated cyclesagainst allowable values to determine if cumulative usage factors are required tobe updated.The licensee also submitted a request on March 5, 2012 (BVY 12-015), to modify itslicense to clarify the license condition so the wording of a commitment placed in theUFSAR, by the licensee, would be controlled by 10 CFR 50.59 while the implementationof 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 identifiedin Appendix A of Supplement 2 to NUREG-1907 (excluding Commitment No. 37and 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 thecommitment change was completed in January 2011, the commitment was not anobligation (March 2011) and the 50.90 process was not required to be used. Theinformation report in May 2011 was merely an extension of the NEI 99-04 process.Commitment 8Commitment 8: Procedures will be enhanced to specify that fire damper framesin fire barriers will be inspected for corrosion. Acceptance criteria will beenhanced to verify no significant corrosion.The inspectors reviewed the commitment completion review report and licenseeprocedure OP 4019, "Surveillance of Plant Fire Barriers and Fire Rated Assemblies," toverify that the surveillance procedure had been enhanced to include fire damper frameinspections. The inspectors noted that OP 4019 included a schedule, list of dampers,and acceptance criteria to adequately control the required inspections. The inspectorsalso interviewed the project manager to review any operating experience orimplementation issues.Commitment 9Commitment 9: Procedures will be enhanced to state that the diesel enginesub-systems (including the fuel supply line) will be observed while the pump isrunning. Acceptance criteria will be enhanced to verify that the diesel engine didnot exhibit signs of degradation while it was running; such as fuel oil, lube oil,coolant, or exhaust gas leakage.Enclosure 6The inspectors reviewed the license renewal application, Safety Evaluation Report, thelicensee implementation plan, the revised procedures, and discussed this commitmentwith applicable plant staff and license renewal personnel. The inspectors noted therevised monthly surveillance procedure contained steps specifying observation of the firepump diesel and its sub-systems, and stipulated acceptance criteria for theseobservations. The 18-month surveillance procedure contained steps specifyingobservation of the fire pump diesel and its sub-systems, but did not specify relatedacceptance criteria. The licensee issued a procedure change request, which providedthe appropriate acceptance criteria for the 18-month surveillance procedure. Theinspectors verified the proposed procedure change specified acceptance criteria for the18-month surveillance. The inspectors observed the general condition of the fire pumpdiesel and its sub-systems, and found the conditions to be acceptable.Commitment 10Commitment 10: Fire Water System Program procedures will be enhanced tospecify that in accordance with the National Fire Protection Association(NFPA) 25 (2002 edition), Section. 5.3.1.1.1, when sprinklers have been in placefor 50 years a representative sample of sprinkler heads will be submitted to arecognized testing laboratory for field service testing. This sampling will berepeated every 10 years.The inspectors reviewed the commitment completion review report and applicable fireprotection work orders to verify that all sprinkler systems which will reach 50 years ofage during the period of extended operation will be subjected to testing in accordancewith NFPA 25-2002, "Standard for the lnspection, Testing, and Maintenance of Water-Based Fire Protection Systems." The inspectors noted that the installation date wasdetermined for all sprinkler systems to determine the required initial test date. Theinspectors also noted documentation tracking the scheduling of the inspections at10 year intervals after the initial 50 year inspection. The inspectors interviewed theproject manager to review any operating experience or implementation issues.Commitment 11Commitment 11: The Fire Water System Program will be enhanced to specifythat wall thickness evaluations of fire protection piping will be performed onsystem components using non-intrusive techniques (e.9., volumetric testing) toidentify evidence of loss of material due to corrosion/microbiologically influencedcorrosion (MlC). These inspections will be performed before the end of thecurrent operating term and during the period of extended operation. Results ofthe initial evaluations will be used to determine the appropriate inspection intervalto ensure aging effects are identified prior to loss of intended function.The inspectors reviewed the commitment completion review report and ultrasonic testresults to verify that representative samples were selected and that the test results didnot indicate any current concerns. The inspectors noted that based upon worst casetest results and conservative estimates of corrosion rates, all samples are expected tobe above the minimum required wall thickness at the end of the period of extendedEnclosure 7operation. The inspectors also interviewed the project manager to review any operatingexperience or implementation issues,Commitments 13 and 43Commitment 13: lmplement the Non-Environmental Qualification InaccessibleMedium-Voltage Cable Program as described in License RenewalApplicationSection 8.1.17 .The program as described in the license renewal application consists of periodicinspections of manholes for water collection and testing of medium and low voltagecables which are exposed to significant moisture.Commitment 43: Establish and implement a program that will require testing ofthe two 13.8 kV cables from the two Vernon Hydro Station 13.8 kV switchgearbuses to the 13.8 kV/69 kV step up transformers before the period of extendedoperation and at least once every 6 years after the initial test.The inspectors reviewed the commitment completion review reports, manhole inspectionresults, and cable test results to verify that potential aging effects to inaccessible cableswere being adequately managed. The inspectors reviewed tan delta and insulationresistance test results to verify that cable testing frequencies were established based oncable performance. The inspectors verified that the cable testing program includedmedium and low voltage cables.The inspectors also reviewed the manhole inspection results and determined that all ofthe manholes had been inspected and future work orders were designed to inspect themanholes on appropriate frequencies and at least once every year. The inspectorsreviewed OP-PHEN-3127, "Natural Phenomena Operating Procedure," to verify that themanholes will be inspected under conditions of high river level or after heavy rain. Theinspectors also interviewed the project manager to review any operating experience orimplementation issues.Commitment 43 applied the Commitment 13 cable testing program to the cablesbetween Vermont Yankee and the Vernon Hydro Station. The inspectors reviewed thecable testing program to ensure that the cables between Vermont Yankee and VernonHydro Station were included in the cable testing program, the cables had been testedsatisfactorily, and the cable testing frequency was set at 6 years.Commitment 12Commitment 12: lmplement the Heat Exchanger Monitoring Program asdescribed in License RenewalApplication (LRA) Section 8.1.17.As documented in Inspection Report 0500027112011011, the inspectors reviewed theconditions of three heat exchangers which were opened for cleaning and inspectionduring the refueling outage in October 2011.Enclosure 8The inspectors reviewed the license renewalapplication, Safety Evaluation Report, thelicensee implementation plan, and discussed this commitment with applicable plant staffand license renewal personnel. The inspectors reviewed the licensee's corporate andVermont Yankee site procedures for the heat exchanger monitoring program. The heatexchanger monitoring program is an existing program that organizes the heat exchangerinspections and maintenance activities, previously performed individually, within thepreventive maintenance program. As part of the license renewal application processadditional heat exchangers were added to the program. lnspections of these heatexchangers are planned in the next few years. The inspectors reviewed the three mostrecent Heat Exchanger Program Health Reports and corrective action documentsassociated 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 clearregarding heat exchangers being covered and the inspection approaches for baselineand periodic inspections, largely due to non-specific use of "samples" and "sampling."The inspectors reviewed Revision 2 of the procedure which included clear, specificguidance and resolved the concern.Commitment 14Commitment 14: lmplement the Non-Environmental QualificationInstrumentation Circuits Test Review Program as described in LRASection 8.1.18.The program, as described in the license renewal application, consists of enhancing theIntermediate Range Monitoring and Local Power Range Monitoring detector testingprograms to collect data sufficient to verify the adequacy of the lntermediate RangeMonitoring and Local Power Range Monitoring cables.The inspectors reviewed the commitment completion review report, revised testprocedure, and initial test results to verify that any potential aging effects in thelntermediate Range Monitoring or Local Power Range Monitoring cables are beingadequately managed. The inspectors reviewed W-RPT-00018, "Non-EQ SensitiveInstrumentation Circuits Cable and Connection Evaluation," to verify the initial testresults demonstrated adequate performance of the associated cables. The inspectorsalso interviewed the project manager to review any operating experience orimplementation issues.Commitment 15Commitment 15: lmplement the Non-Environmental Qualification InsulatedCables and Connections Program as described in LRA Section 8.1 .19.The program as described in the license renewal application was to manage the agingeffects of cables and connections exposed to adverse localized environments by visuallyinspecting a representative sample of accessible insulated cables and connections.Enclosure IThe inspectors reviewed the commitment completion review report and inspectionresults to verify that potential aging effects to cables and connections are beingadequately managed. The inspectors reviewed W-RPT-11-00019, "Cable andConnection Inspection Summary Report," which documented the inspection of the plantfor adverse localized environments and aging effects to cables and connections. Theinspectors reviewed the work orders and condition reports that were generated as aresult of the walk down to verify that conditions adverse to quality were being identifiedand resolved.Commitment 16Commitment 16: lmplement the One-Time Inspection Program as described inLRA SectionB.1.21.The inspectors reviewed the license renewal application, Safety Evaluation Report, thelicensee implementation plan, and discussed this commitment with applicable plant staffand license renewal personnel. The inspectors reviewed the licensee's corporateprocedure for one-time inspection, the summary report of the one{ime inspectionprogram (draft and final), and inspection testing matrix. The inspectors reviewedinspection reports, material/environment evaluations, and condition reports furtherevaluating discrepancies. The licensee concluded that one{ime inspectionsdemonstrated that no additional aging management activities were needed.The inspectors noted that the "One-Time Inspection Program as described in LRASection 8.1.21" included inspection of the cast austenitic stainless steel main steam line1ow restrictors. These inspections were discussed in Amendment 16 to the LicenseRenewalApplication submitted by the licensee and in the Safety Evaluation Report. Theinspectors noted the inspection matrix listed these inspections as not applicable, and thelicensee had not initiated any regulatory process to revise its commitment.The licensee personnel stated that preparations for the inspections had determined thatthe inspections were impractical. In addition, the licensee determined that plans for one-time inspections of the reactor vessel leak'off line should be covered underCommitment 53. In letter BVY 12-016, dated March 12,2012, the licensee addressedthese concerns by modifying License Renewal Application Section A.2.1.23 whichdescribes the application of the One-Time Inspection Program at8.1.21.Commitment 17Commitment 17: Enhance the Periodic Surveillance and PreventiveMaintenance Program to assure that the effects of aging will be managed asdescribed in LRA Section 8.1.22.The "Periodic Surveillance and Preventive Maintenance Program" includes periodicinspections and tests that manage aging effects not managed by other agingmanagement programs.Enclosure 10The inspectors reviewed Work Order 52295664-01, cleaning and inspection (mechanicaland electrical) of reactor recirculation ventilation unit-7 in the reactor building completedduring the fall 2011 refueling outage. The inspectors reviewed Work Order52329127-01, cleaning and inspection of Aircon SAC-1 Control Room Air Conditioner(Package Fan Coilfor the Control Room HVAC Filters and Cooling System) completedin August 2011. Inspection of the reactor building crane rails and girders is scheduledfor completion during February 2012.This program has resulted in revisions to the included equipment maintenanceprocedures to specify that the inspection procedure is fulfilling a license renewal agingmanagement commitment.Commitment 18Commitment 18: Enhance the Reactor Vessel Surveillance Program toproceduralize the data analysis, acceptance criteria, and corrective actionsdescribed in the program description in LRA Section 8.1.24.This commitment, which requires writing a procedure, was implemented by revisingSEP-FTP-WY, Revision 1, "Reactor Vessel Fracture Toughness and SurveillanceMaterial Testing At Vermont Yankee," to stipulate data analysis, and acceptance criteria,by incorporating Boiling Water Reactor Vessel Internals Project (BWRVIP) 86 andBWRVIP 135. After determining the effects on plant operating parameters caused bynew data provided by the BWRVIP 135 program, the revised procedure was enhancedto clarify that significant departures from expected performance should be entered intothe corrective action program in accordance with EN-LI-102'Commitment 19Commitment 19: lmplement the Selective Leaching Program as described inLRA Section 8.1.25.The inspectors reviewed the license renewal application, Safety Evaluation Report, thelicensee implementation plan, and the licensee commitment closure verification, anddiscussed this commitment with applicable plant staff and license renewal personnel.The inspectors reviewed the licensee's corporate selective leaching procedure, the draftand final selective leaching summary report, inspection sample matrix, inspectionreports, and technical report with destructive examinations of some copper alloycomponents.During review of the sample matrix, the licensee identified that some samples for graycast iron in a raw water environment were actually copper alloy materialmischaracterized as gray cast iron; this necessitated additional samples. Later theinspectors reviewed the two additional samples inspected.The inspectors reviewed the "Evaluation of the Gray Cast lron Valves in the FireProtection System Based on External Ultrasonic Test Examinations," datedJanuary 18,2012, and a later version dated March 20,2012, discussed the evaluationEnclosure 11with testing personneland applicable license renewal staff. The licensee had appliedthe ultrasonic testing to 20 fire protection system components, which were not otheruviseaccessible for selective leaching inspection. A sample of gray cast iron material withselective leaching from another Entergy facility had been used to qualify the ultrasonictest method. The evaluation of each component determined the wall thicknesses,calculated a maximum possible leaching thickness, and projected potentialwallthickness loss over 20 years. In all but one case, the licensee determined that theremaining wall thicknesses would exceed the design minimum wall thickness. For theone valve with insufficient calculated wall thickness, the licensee planned to repeat theinspection in 5 years.The inspectors determined the licensee's ultrasonic test method had a sound technicalbasis. The results of the test, when combined with the multiple conservatisms of theevaluations, and the visual and hardness inspections of other gray cast iron valves,supports a conclusion that aging management activities for selective leaching are notrequired. The inspectors requested a repeat inspection on a second valve with the leastcalculated margin (8 percent) above the design minimum wall thickness. The licenseedetermined that visual inspecting the two valves by March 21,2014, would be moreappropriate 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 Licenseestatements made in their license renewal application at Section B.l.25 "SelectiveLeaching Program" have no provision for ultrasonic testing for selective leaching. Inletter BW 12-016, dated March 12,2012, the licensee addressed this concern bymodifying the aging management program the commitment refers to in the originalrenewal 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 andanalysis 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 tooccur on the buried valves, the visual inspection would be superfluous, and theexcavation to enable the inspection unnecessary. The inspectors determined thisapproach had a reasonable technical basis and was conservative. However, the NRCguidance in NUREG-1801, Revision 1, GALL Report and licensee statements made inthe license renewal application at Section B.1.25 "Selective Leaching Program" have noprovision for soil corrosivity testing for selective leaching, nor had the licensee initiatedany 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 originalapplication.Commitment 20Commitment 20: Enhance the Structures Monitoring Program to specify thatprocess facility crane rails and girders, condensate storage tank enclosure,COz tank enclosure, N2 tank enclosure and restraining wall, condensate storagetank pipe trench, diesel generator able trench, fuel oil pump house, service waterEnclosure 12pipe trench, man-way seals and gaskets, and hatch seal and gaskets areincluded in the program.The applicant has enhanced the Structural Monitoring Program to specify that processfacility crane rails and girders, condensate storage tank enclosure, CO2 tank enclosure,Nz tank enclosure and restraining wall, condensate storage tank pipe trench, dieselgenerator cable trench, fuel oil pump house, service water pipe trench, man way sealsand gaskets, and hatch seals and gaskets are included in the program'The inspectors reviewed the commitment completion review report, the StructuralMonitoring Program documents and program procedure. Specifically, inspectorsreviewed the procedure EN-DC-150, "Condition Monitoring of Maintenance RuleStructures" to verify the procedure was updated to identify the specific structures andcomponents. Attachment 9.17, of the procedure, listed the structures, components, andequipment covered by the monitoring program and monitoring procedure. In addition,the inspectors reviewed the previous inspection and monitoring reports to assess theimplementation and effectiveness of the program.Commitment 22Commitment22: 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 MonitoringProgram procedure.The inspectors reviewed the revised and updated procedures to verify that guidance forperforming structural examinations of elastomers (seals and gaskets) to identify crackingand change in material properties (cracking when manually flexed) had been enhancedin the structural monitoring program.Procedure EN-DC-150, Sections 5.9 and 8.0 have been revised and updated to provideguidance for inspection and monitoring of elastomers.Commitment 24Commitment24: System walk down guidance documents will be enhanced toperform periodic system engineer inspections of systems in-scope and subject toaging management review for license renewal in accordance with10 CFR 54.4 (a)(1) and (aX3). Inspections shall include areas surrounding thesubject systems to identify hazards to those systems. Inspections of nearbysystems that could impact the subject system will include structures, systems,and components that are in-scope and subject to aging management review forlicense renewal in accordance with 10 CFR 54.4 (a)(2).The licensee modified Procedure EN-DC-178, "System Walk down Program" andProcedure ENN-MS-S-004, 'VYNPS System Categorization" to require periodic walkdowns to inspect for the effects of aging on system equipment and components.Enclosure 13Commitment 25Commitment 25: lmplement the Thermal Aging and Neutron lrradiationEmbrittlement of Cast Austenitic Stainless Steel (CASS) Program as described inLRA Section 8.1.29.Section 8.1.29 of the license renewal application states the program will be "comparableto the program described in NUREG-1801 Section Xl.M13." The applicable edition ofNuclear 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 reactorvessel internals to ensure a better understanding of aging effects. FutureBWRVIP reports, EPRI reports, and other industry operating experience willprovide additional bases for evaluations and inspections under this program.This program will supplement reactor vessel internals inspections required by theBWR Vessel Internals Program to assure that aging effects do not result in lossof the intended functions of reactor vessel internals during the period of extendedoperation."After the details of the Vermont Yankee license renewal application were established,the programmatic details of the thermal aging and neutron irradiation embrittlement ofcast 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 agingeffect of thermal aging and neutron irradiation embrittlement of CASS and proceduralizethe specifications in the CASS aging management program. Using theBWRVf P 234-2009 thresholds, all of Vermont Yankee's CASS components, within thescope of the original application, were below the stress threshold of the selection criteriaestablished in BWRVIP 234-2009. Thus, the components screened out of the agingmanagement program and needed no inspection.The criteria used in BWRVIP 234-2009 is different than the criteria stipulated in the NRCguidance 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 singlecriterion of fluence > 1017 nlcm2 (for E > 1 MeV). This threshold is three orders ofmagnitude lower than the threshold used in BWRVIP 234-2009 for fluence. Theinspectors noted Revision 2 of NUREG-1801, GALL Report, Section Xl.M13, acceptedBWRVIP 234-2009 as an aging management.The licensee revised LO LAR 2010 0256 to resolve the criteria differences. Thecommitment was to implement Section 8.1 .29 of the application, and Section B.1 .29 ofthe application includes the provision to supplement the approach using "future BWRVIPEnclosure 14reports, EPRI reports, and other industry operating experience" to "provide additionalbases for evaluations and inspections under this program." Under the provisions of8.1.29 the application of BWRVIP 234-2009, as an additional bases for evaluation, isacceptable.Commitment 26Commitment 26: Procedures will be enhanced to flush the John Deere DieselGenerator cooling water system and replace the coolant and coolant conditionerevery three years."The inspectors reviewed the license renewal application, Safety Evaluation Report, andthe licensee's implementation plan, and discussed this commitment with applicable plantstaff and license renewal personnel. The inspectors reviewed the revised preventivemaintenance procedures, and the work order for the three-year preventive maintenanceof this diesel generator completed on June 11,2011. The licensee's inspection is on a3 year cycle. The inspectors observed the general condition of the John Deere dieselgenerator and its cooling systems, and found the conditions to be acceptable.Commitment 28Commitment23: Revise program procedures to indicate that the Instrument AirProgram 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 samplingcriteria for air quality. Also, the licensee has added a supervisory review of the samplingresults to ensure that the criteria of ISA S7.3 are met during sampling analysis.Commitment 29Commitment 29: Vermont Yankee Nuclear Power Station will perform one of thefollowing: (1) Install core plate wedges, or (2) Complete a plant-specific analysisto determine acceptance criteria for continued inspection of core plate hold downbolting in accordance with BWRVIP 25 and submit the inspection plan andanalysis to the NRC two years prior to the period of extended operation for NRCreview and approval.The licensee completed a plant specific analysis (Option 2) which demonstrated thatoperation, without core plate wedges, and with periodic W-3 inspection of the core platebolts will maintain acceptable margin above loss of bolt preload. The analysis wassubmitted to the NRC on March 18,2011, satisfying the requirement contained in thiscommitment.Enclosure 15Commitment 30Commitment 30: Revise System Walkdown Program to specify CO2 systeminspections every 6 months.The inspectors conducted a walk down of the CO2 system including the COz storagetank, associated piping and controls and alarms. The inspectors also conducted a walkdown 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 WalkdownProgram," that "those portions of the applicant's System Walkdown Program for whichthe applicant claimed consistency with GALL AMP Xl.M36" is "consistent with theGALL AMP." The staff concluded the "System Walkdown Program provided assurancethat the program will manage aging effects, e.9., the loss of material and leakage, of theexternal surfaces of components."The inspectors reviewed the most recent Fire Protection System walk down report andSystem Health Report completed by the Fire Protection Engineer. The inspectors alsoreviewed TRM 4.13.D "Surveillance Requirements," and the National Fire ProtectionAssociation certification inspection results for the CO2 storage tank.The inspectors reviewed the design of the CO2 system holding tank, an ASME, Boilerand Pressure Vessel Code,Section I pressure vessel, and determined that it was notpossible to visually inspect the steel walls to detect signs of aging in the form ofcorrosion. The COz tank walls are made of steel and are covered with insulation and asheet metal cover. The sheet metal cover is designed to protect the insulation and thetank 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 metalcover is visually inspected to detect signs of aging. Should aging effects becomeevident, the licensee will enter the condition into the corrective action process andaddress the condition based upon appropriate engineering guidance. The evidence ofaging affects at the insulation cover gives sufficient time to respond to the deteriorationof the tank so that the effect of the aging is managed.Commitment 31Commitment 31: Revise Fire Water System Program to specify annual firehydrant gasket inspections and flow tests.The inspectors reviewed the commitment completion review report and surveillanceprocedures to verify that the procedures had been enhanced to include fire hydrantgasket inspections and flow tests. The inspectors noted that OP 4103, Fire ProtectionEquipment Surveillance, included a schedule, list of locations, and acceptance criteria toadequately control the gasket inspections. The inspectors noted that OP 4105, FireProtection Systems Surveillance, included a schedule, list of locations, and acceptancecriteria to adequately control the flow tests. The inspectors also interviewed the projectmanager to review any operating experience or implementation issues.Enclosure 16Commitment 32Commitment32: lmplement the Metal-Enclosed Bus lnspection Program.Details are provided in LRA Amendment 16, Attachment 3 and LRA Amendment23, Attachment 7.The licensee revised plant component procedures to include steps to conduct cleaningand inspection of metal-enclosed bus ducting. These changes were made to ensure themonitoring of aging effects on metal-enclosed bus ducting is included in maintenanceprocedures. The inspectors reviewed Work Orders 52298615-04, "T-1-1A MainTransformer Outage lnspection," 52298263-02, "T-2-1A Auxiliary Transformer RefuelOutage 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 33Commitment 33: Include within the Structures Monitoring Program provisionsthat will ensure an engineering evaluation is made on a periodic basis (at leastonce every 5 years) of groundwater to concrete. Sample will be monitored forsulfates, pH, and chlorides.The inspectors noted that the groundwater monitoring program implemented by theapplicant was included within the structural monitoring program to ensure an engineeringevaluation was made on a periodic basis of at least once every 5 years of groundwatersamples. The periodic ground water sample assessment evaluates the aggressivenessof 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-aggressivegroundwater as having: pH > 5.5, sulfates < 1500 ppm, and chlorides < 500 ppm. Acondition report would be initiated to assess the effects of groundwater if it exceededthese thresholds. The inspectors reviewed groundwater test results to assess theimplementation and effectiveness of the program.Commitment 34Commitment 34: lmplement the Bolting Integrity Program. Details are providedin an LRA Amendment 16, Attachment 2, and LRA Amendment 23,Attachment 5.The Bolting Integrity Program is another program included within the StructuralMonitoring Program, The Structural Monitoring Procedure has been enhanced andupdated to clarify and provide additional guidance for assuring bolting integrity atpresent, and also during the Period of Extended Operation. The inspectors reviewedrevised and updated procedures to verify the extent, clarity, and appropriateness of theguidance. Procedures reviewed included: EN-DC-150, "Condition Monitoring ofMaintenance 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 theseEnclosure 17enhancements with the applicant's engineering and inspection personnel to determinethe bases for the guidance.Commitment 35Commitment 35: Provide within the System Walkdown Training Program aprocess to document biennial refresher training of Engineers to demonstrateinclusion of the methodology for aging management of plant equipment asdescribed 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 systemengineers to train the engineers in the methodology of detection of aging mechanisms.This program requires periodic refresher training in the same subject areas.Commitment 36Commitment 36: lf technology to inspect the hidden jet pump thermal sleeve andcore spray thermal sleeve welds has not been developed and approved by theNRC at least 2 years prior to the period of extended operation, WNPS willinitiate plant-specific action to resolve this issue, That plant-specific action maybe justification that the welds do not require inspection.The licensee discovered indications in six jet pumps by ultrasonic testing in 1996 andrepeated 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 tocontinue monitoring the indications.Because the licensee uses EW-1 to monitor indications in six jet pumps originallydiscovered by ultrasonic testing, they do not strictly follow the guidance contained inBWRVIP 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 ofinaccessible, or hidden, welds until a delivery system for ultrasonic testing can bedevised. This means the licensee does not follow the guidance of BWRVIP 41 toperform a modified W-1 of 100 percent of the hidden welds over two 6-year inspectioncycles 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 thehidden jet pump welds are far enough into the nozzle that failure at these welds wouldnot result in the thermal sleeve disengaging from the nozzle before the riser contactedthe shroud. lf the jet pump thermal sleeve or riser piping severed, it would be detectedthrough jet pump monitoring, which alarms if the riser pipe moves more than 10 percentwhile at or above a core flow of 42Mlblhr. Therefore, deferral of inspection of theinaccessible welds is justified in keeping with the guidance.In addition, during the review of the aging management program implementing thiscommitment, the staff noted the safety evaluation report that accompanied the NRC'sacceptance of BWRVIP 41 stated an aging management review of the nozzle thermalsleeve should be provided by users of the procedure, The licensee committed, as statedin 36 above, to plant-specific action to resolve this issue, 2 years prior to the period ofEnclosure 18extended operation, if technology to inspect the hidden jet pump thermal sleeve andcore 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 thesafety evaluation report associated with BWRVIP 41. In addition, in CommitmentClosure Verification Form, LRS/CMS l. D. A-16808 LOR-LAR-2O10-00267, the licenseerecorded their rationale for not performing an ultrasonic test of the hidden and coresspray welds thus satisfying the commitment's requirements.Commitment 37Commitment 37: Continue inspections in accordance with the steam dryermonitoring plan, Revision 3 in the event that the BWRVIP 139 is not approvedprior 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 Yankeespecific steam dryer monitoring program with BWRVIP 139, "Steam Dryer Inspectionand 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 aclaim the aging management program for the steam dryer was inadequate. Thelicensee's response was, in part, to commit to use the Boiling Water Reactor Vessel andInternals Project procedure 139 for inspection of the steam dryer. At the time thisresponse was tendered, the procedure was not approved by the NRC. Acceptance ofthe procedure, by the Atomic Safety and Licensing Board, would mean the intervenercould not, as part of the hearing, review the finally approved BWRVIP procedure andchallenge its adequacy. The Atomic Safety and Licensing Board resolved this byprohibiting the applicant from using the Boiling Water Reactor Vessel and InternalsProject procedure. The Atomic Safety and Licensing Board order stipulated theapplicant amend their license in order to use the Boiling Water Reactor Vessel InternalsProject procedure.As a consequence, Atomic Safety and Licensing Board issued order LBP-08-25, datedNovember 24,2008, which required specific elements of the Vermont Yankee steamdryer monitoring program be implemented without change. This order pointedlyexcluded the use of BWRVIP 139 without amending the license, effectively negatingCommitment 37. This was done to require the licensee to apply to the NRC for achange to the condition, a public process, which would give stakeholders an opportunityto 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, datedNovember 24, 2008, notwithstanding any other provision of this license, thelicensee, Nuclear Vermont Yankee, LLC, and the licensee Nuclear Operations,Enclosure 19Inc. shall continue to perform and implement the continuous parametermonitoring, moisture content monitoring, and visual inspections specified in theSDMP at the intervals specified in General Electric Services InformationLetter 644, Revision 2. These shall continue for the full term of the period ofextended operation unless the provision of the license is duly amended."The licensee implemented a revision to OPON-3178-01 to incorporate the moisturecontent monitoring requirements of the condition by way of license renewal actionLO-LAR-2011-0073 CA L The licensee further revised OP 0631 to incorporate themoisture content monitoring requirements of the condition by way ofLO-LAR-2011-0073 CA 10, and revised EN-CY-107 to add the condition to the sectionon obligations and commitments and to protect the necessary steps within the procedureto ensure moisture content monitoring is performed in accordance with GE SIL 644Revision 2 by way of LO-WTHQN-201 1-032 CA-069.The inspectors reviewed Program Report SEP-RVl-006, Revision 3, showing thescheduled implementation of this license condition until 2019. The inspectors noted theschedule was titled "Attachment 3, Boiling Water Reactor Vessel Internals ProjectReport," and the steam dryer inspection was planned in accordance with the provisionsof procedure BWRVIP 139A and General Electric notice SIL 644, Revision 2. Theschedule included notations of W1 and W3 examinations going fonvard. Theinspectors reviewed SEP-RVl-006, Revision 2, "Vermont Yankee Reactor VesselInternals (RVl) lnspection Program Plan" Appendix L, "Steam Dryer."Licensee personnel implemented the steam dryer inspection program scheduling theinspections in accordance with the intervals required by SIL 644. Vermont Yankeefolded into its procedure the additional parameters of BWRVIP 139, Revision A, as"approved" by the NRC. The licensee is implementing the other requirements of thelicense condition in accordance with the statements in the condition.The licensee issued Condition Report CR-VTY-2O12-00227 to identify the residualreferences to the BWRVIP in the procedure. The condition report noted the licenseesubmitted a license amendment request on 12122111 (BVY 11-085), to implementBWRVIP 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 notimplement the BWRVIP inspections, as evidenced by portions of "lWl Final ReportGE DRF 0000-0140-1232,lWl Final Report No. GEH-7480-2FY6R4-HK1-lWl." Thelicensee limited their interrogation of the dryer to previously discovered indications usingthe required SIL visual examinations. These examinations were implemented as part ofthe power up-rate requirements.Commitment 38 and 39. and License Condition 3.RCommitment 38: The BWRVIP 116 report, which was approved by the staff, willbe implemented at VYNPS with the conditions documented in Sections 3 and 4of the Staff's final SE dated March 1, 2006, for the BWRVIP 116 report.Enclosure 20Commitment 39: lf the WNPS Standby Capsule is removed from the reactorvessel without the intent to test it, the capsule will be stored in a manner whichmaintains it in a condition which would permit its future use including during theperiod 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 thefuture 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, thesecapsules must be stored in a manner which maintains them in a condition whichwould support re-insertion into the reactor pressure vessel, if necessary."The licensee incorporated these commitments into SEP-FTY-WY, Revision 1, issuedJanuary 3,2012, "Reactor Vessel Fracture Toughness and Surveillance Material Testingin Vermont Yankee." The inspectors noted the procedure also incorporated the otherrequirements of the license condition, including the requirement to submit to the NRC,for approval, any changes made to the capsule withdrawal schedule. The procedurealso incorporates the requirement to incorporate changes affecting the time ofwithdrawal, as stipulated in BWRVIP 86, "Updated BWR Integrated SurveillanceProgram (lSP) lmplementation Plan" into the design basis.Commitment 42 - Bolted Cable ConnectionsCommitment 42 lmplement the Bolted Cable Connections Program. Details areprovided in LRA Amendment 23, Attachment 7.The program, as described in the LRA, is a one-time program to confirm that looseningof bolted connections is not occurring.The inspectors reviewed the commitment completion review report and associated workorders to verify that the inspection program demonstrated that the loosening of boltedcable connections was not occurring.The inspection program evaluated a sample of bolted cable connections by inspectingthem visually and testing the connection resistances. Connection resistances weremeasured prior to and after maintenance which disconnected and reconnected thebolted cable connection. The acceptance criteria for connection resistances were thatthe 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 thebasis for the factor of five acceptance criteria. Entergy reviewed the acceptance criteriaand determined that an appropriate acceptance criteria would be 125 micro-ohms basedon an evaluation of voltage drop and heating. 125 micro-ohms is the result of abounding calculation using the maximum loaded conductor connection at VermontYankee which is the 3750 kVA T-Vernon-Hydro Transformer at full load compared to thevoltage-drop criteria used for a voltage sensitive connection at Vermont Yankee, such asEnclosure 21the 50 mV criteria used for the Station Battery installation. The inspectors reviewed theevaluation for the revised value and determined that there was a sufficient technicalbasis for the new acceptance criteria.The total bolted connection population was determined and the sampling program ofEPRI Report TR-107514 was applied. The confidence level criteria applied to a randompopulation would have resulted in a minimum sample of 25 bolted connections. Theguidance, however, gives selection criteria for circuit loading, adverse location, such ashigh temperature, high humidity, vibration, etc., that resulted in 220 bolted connectionsbeing selected.After reviewing the data, the inspectors questioned samples recorded on a scale ofohms instead of micro-ohms. After reviewing the documented test equipment used todevelop the data, Entergy determined some samples were taken with instrumentsincapable of reporting values in micro-ohms. Entergy agreed the samples performedwith incorrect instruments were not valid samples for demonstrating that connectionswere adequate or inadequate, and subsequently removed the samples from theevaluation. The inspectors determined that removing the invalid samples wasappropriate.The inspectors questioned other samples recorded with large resistances. Entergyreviewed this issue and identified six samples in excess of the 125 micro-ohmsthreshold. The locations were all associated with connections made totransformer T-3-1B. The connections were C1333C and D on Phase A, C13338 and Cof Phase B, and C1333C and E on Phase C, Entergy reviewed the associated workorders to verify the documented visual inspections of the connections did not report anysigns of overheating. Overheating would have been expected for a connection withlarge resistance. Based on the lack of reported overheating and the location of thesamples, Entergy suggested the large resistances were due to poor measuringtechniques. To verify this, Entergy created a corrective action(LO-LAR-2010-00271CA 4) to re-measure the connections during the next scheduledmaintenance on the connections with high recorded resistances. The inspectorsreviewed Entergy's evaluation and the work orders and agreed that there is reasonableassurance that the connections were not loose and that re-measuring the connections isappropriate.In light of the previous concerns, the inspectors questioned the adequacy of the dataavailable to provide reasonable assurance that this one-time program had demonstratedthat the loosening of bolted connections was not occurring. Entergy provided theinspectors with operating experience reviews in the form of condition report searches,which showed that between January 1, 1998, and February 29,2012, there were onlytwo potential examples of bolted electrical connections loosening. CR-VTY-2007-02196was a loose connection in the main transformer control panel and CR-VW-2007-02605was a loose connection to DG-3-1A output connector.Entergy also provided the revision to W-RPT-11-00017, Bolted Cable Connectionlnspection Report, which documented 220 diverse samples. Of the samples, only six didnot meet the initial acceptance criteria; but all six met the visual inspection acceptanceEnclosure 22criteria and all six will be re-measured to confirm the results. The inspectors reviewedthe operating experience results and revised report and agreed that Entergy haddemonstrated reasonable assurance of the effectiveness of this one{ime program.Commitment 45Commitment 45: Enhance the service water integrity program to require aperiodic 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 "VermontYankee Heat Exchanger Program" (EN-SEP-HX-001) to include the periodic visualinspection of the RHRSW pump motor cooling internal surfaces and to flush the RHRSWPump Motor Coolers. Procedure OPOP-RHR-2124 "Residual Heat Removal System"has been revised to add Attachment 7 - "Coil Flush." This "Residual Heat RemovalService Water Pump Motor Cooling" attachment provides a procedure for performing apre-inspection flush of the RHRSW Pump Motor Coolers.Work Orders (00291967-01, 00291968-01, 00291969-01, and 00291970-01) wereinitiated to perform baseline cooler flushes and visual inspections. The licenseedocumented, via CR-VTY-2012-00218, efforts to perform a boroscopic visual inspectionon a mockup of the RHRSW pump motor cooler. The boroscopic examination failedand CR-WY-2012-00218, "Corrective Action Plan," contains various steps to remedythe failure. For example:o Action A, 1. determine if a boroscope exists that can negotiate the piping elbowsof the motor cooling coils.r Action A, 2. determine if a repair technique is available to allow the inlet andoutlet 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 inspectorsnoted that replacement of the coils, without a destructive visual examination ofthe existent coils would require revising the commitment because no visualinspection would be performed.The licensee stated that, although these motor coolers are original plant equipmentsubject to aging effects, the coolers are periodically inspected during operator roundsand no leakage has been detected visually.Although no visual examination of the internal surface of the RHRSW pump motorcooling internal surfaces has been performed, the commitment to enhance the servicewater integrity program to require the inspection has been completed, Because thecoolers currently meet design and operational requirements without leakage, and arevisually inspected on a regular basis, there is adequate time for the licensee to find andimplement an alternate solution.Enclosure 23Commitments 46 and 47Commitment 46: Enhance the Diesel Fuel Monitoring Program to specify thatfuel oil in the fire pump diesel storage (day) tank will be analyzed in accordancewith ASTM D975-02 and for particulates per ASTM D2276. Also, fuel oil in theJohn Deere diesel storage tank will be analyzed for particulates perASTM D2276.Commitment 47: Enhance the Diesel Fuel Monitoring Program to specify thatfuel oil in the common portable fuel oil storage tank will be analyzed inaccordance with ASTM D975-02, per ASTM D2276 for particulates, andASTM D1796 for water and sediments.The inspectors reviewed the license renewal application, Safety Evaluation Report, andthe licensee implementation plan, and discussed these commitments with applicableplant staff and license renewal personnel. The inspectors reviewed the chemistryprocedure used to sample and test dieselfuel oil, which had been revised to include thefire pump diesel, John Deere diesel, and common portable fuel oil storage tanks per theapplicable standards. The inspectors reviewed five completed fuel oil analyses for thefire pump and John Deere diesels. The common portable fuel oil storage tank is storedempty and used only as needed; no usage has occurred subsequent to theenhancement.Commitment 49Commitment 49: Revise station procedures to specify fire hydrant hose testing,inspection, and replacement, if necessary, in accordance with NFPA codespecifications for fire hydrant hoses.The inspectors reviewed the commitment completion review report and applicablesurveillance procedure to verify that the procedures had been enhanced to includeguidance in accordance with NFPA 1962-2008, Standard for the Inspection, Care, andUse of Fire Hose, Couplings, and Nozzles and the Service Testing of Fire Hose. Theinspectors noted that OP 4104, Fire Hose Service Test Surveillance, included therequirements of NFPA 1962. The inspectors also interviewed the project manager toreview any operating experience or implementation issues.Commitment 50Commitment 50: During the period of extended operation, review the VernonDam owner Federal Energy Regulatory Commission (FERC) required report(s) ata minimum of every 5 years to confirm that the Vernon Dam owner is performingthe required FERC inspections. Document deficiencies in the licenseeCorrective Action Program and evaluate operability as described in BVY 96-043and BW 97-043, if it is determined that the required inspections are not beingperformed.Enclosure 24f n a letter dated July 3, 2007, the licensee committed to confirm the Vernon Dam owneris performing the required FERC inspections based on a review of the Vernon Damowner's report to FERC. On July 14, 2011, the licensee submitted a request FERC for acopy 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 tothe report in Release Letter, CEll No. CE1 1-181. Because the licensee was grantedaccess, they were able tO review the Vernon Dam owner's report to the FERC, asstipulated in Commitment 50.Commitment 55Commitment 55: Enhance safety-related coatings programs and procedures tobe 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 ProtectiveCoatings inside Containment Program is not applicable. Subsequently, in Entergycorrespondence dated December 21,2010 (BVY 10-058), the licensee provided a newaging management program for protective coatings inside containment, in order topievent coatings inside containment from contributing to Emergency Core CoolingSystem challenges during an event during the period of extended operation.Commitment 55 was noted in the correspondence at the bottom of Page 2 ofAttachment 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 alignedwith the Standard Review Plan for License Renewal'The NRC then developed a "supplemental Safety Evaluation Report Related to theLicense Renewal of Vermont Yankee Nuclear Power Station," sending the licensee acopy by letter dated March 21, 2011. The licensee commented on the safety evaluationreport by letter, dated May 19,2011 (BVY 11-033), in which the licensee suggested18 corrections, errata, and edits. Comment Number 18 points out "LRA CommitmentNo. 55 is not listed in the Appendix. lt is referenced and discussed inSection 3.0.3.1 .13." In this section of the safety evaluation report: "The staff also notesthat the applicant committed (Commitment No. 55) to enhance the safety-relatedcoatings program and procedures to be consistent with the recommendations ofGALL AMP XI.S8."As a consequence, the omission of Commitment 55 from Appendix A of the SafetyEvaluation Report, creating a new aging management program for the control of coatinginside containment, was not controlled by the provisions of License Condition Q. Anymodification to the commitment can be implemented using NEI 99-04 and10 CFR 50.59, The licensee treated this commitment like all the other commitmentsthey made that were registered in Appendix A of the safety evaluation report andentered this commitment into their commitment tracking system as A-16964 and trackedit to completion under LO-LAR-2010-0367, which revised program SEP-COAT-O01 andprocedure EN-DC-220.Enclosure b.1a.225Findinqs/ObservationsNo findings were identified. The inspectors determined the licensee has completed thereviewed commitments and is implementing the selected license conditions with theexceptions as noted in their completion letter (BW 12-017), dated March 16,2012,submitted in accordance with License Condition 3. Q .lnspection ScopeThe inspectors verified systems, structures, and components, "newly identified" as partof 10 CFR 54.37(b), and Regulatory lssue Summary RIS-2007-16, are implemented inaccordance with 10 CFR Part54.Vermont Yankee Procedure SEP-LR-WY-001, Revision 0, January 2012, describes themethod for determining if reporting is required by 10 CFR 54.37(b) and performing anaging management review or Time Limited Aging Analysis evaluation. This procedurewas referenced in the licensee Nuclear Management Manual EN-DC-115, Revision 12,"Engineering Change Process" in order to assure any current license basis changeswould capture systems, structures, and components that were not in the scope oflicense renewal when the NRC approved the license renewal application, or would havebeen in the scope of license renewal if 10 CFR 1a.a@) were applied to the systems,structures, and components.b.2 Findinqs/ObservationsNo findings were identified. The licensee is implementing the requirements of10 cFR 54.37(b).4OAO Exit MeetinqThe inspectors presented the inspection results to Mr. Christopher Wamser, Site VicePresident, and other members of his staff on March 20,2012. Additional discussionsoccurred in interim meetings of January 26 and March 8, 2012. The inspectorsconfirmed no proprietary materialwas examined during the inspection.Enclosure A-1ATTACHMENTSUPPLEM ENTAL INFORMATIONKEY POINTS OF CONTACTLicensee PersonnelC. Wamser, W General Manager/Site Vice PresidentB. Wanczyk, VY Licensing ManagerG. Thomas, VY LR Project ManagerP. Guglielmino, W LR Project lmplementation ManagerJ. Hoffman, VY LR TeamD. Lach, Entergy LR TeamJ. DeVincentis, W Licensing EngineerDOCUMENTS REVIEWEDCorrective Action ReportscR-wY-2001-00829cR-wY-2011-02335cR-wY-2012-00218cR-wY-2012-00297cR-wY-2o12-00218cR-wY-2o12-00350cR-wY-2o04-02183cR-wY-2005-03653cR-wY-2007-02190cR-wY-2o07-02288cR-wY-2o08-04297cR-wY-2008-04549cR-wY-2008-04571cR-wY-2o11-03205cR-wY-2o11-05520cR-wY-2O12-40il1LO-LAR-2010-00244LO-LAR-2010-00246LO-LAR-2o10-00271LO-LAR-2010-00250LO-LAR-2010-00274LO-LAR-2010-00026LO-LAR-2o10-00240LO-LAR-zo10-00248LO-LAR-2o11-00094LO-LAR-2o10-00259LO-LAR-2010-00260LO-LAR-2010-00261LO-LAR-2010-00263LO-LAR-2o10-00266License Renewal ApplicationA.2.1.7 BWR Vessel lnternals ProgramA.2.1.28 Service Water lntegrity ProgramA.2.1.24 Periodic Surveillance And Preventive Maintenance ProgramA.2.1.32 System Walkdown Program8.1.22 Periodic Surveillance and preventative Maintenance ProgramAttachment A-2Drawinos & SketchesGeneral Electric drawing 729E957,(NY 706102-530)General Electric drawing 919D294,(NY 706102-5920-19)General Electric drawing 729E956,Revision 3; Vermont Yankee Reactor Core SupportRevision 8; Vermont Yankee Reactor VesselRevision 0; Vermont Yankee Reactor Shroud(NY 706102-5920-s29)General Electric drawing 729E959, Revision 3; Vermont Yankee Core StructureArrangement (NY 5920-532)The licensee Nuclear Vermont Yankee, Vernon, VT, drawing 5920-1102, R HEADS, NuclearReactor, General Electric Company, CentralVermont Power Company, Vernon Dam,Vermont (NY 5290-252)MPR Associates drawing, Vermont Yankee Power Station, Shroud Repair, Shroud RestraintAssembly 1249-006-01, Revision DEngineering Evaluations, Analyses, Calculations & Standards:GE Instructions for Recirculating Water Pump Motors, Model SK263668K1, ltem 0157TECO, Westinghouse Engineering Study, 2N1gSN, Revision 2,2005The licensee Nuclear Vermont Yankee (ENVY) - Upper Bearing Cooler StudyThe licensee Vermont Yankee Root Cause Analysis Report, CR-WY-2004-2015,7116104;Electrical FaulVFireISA-7.0.01-1996, Quality Standard for lnstrument Air, Approved 12 November 1 996The licensee Engineering Standard, ENN-MS-S-OO4 W, Revision 5, 3/15/12; SystemCategorizationSvstem & Proqram Health Reports & Svstem Enqineer Walkdown ReportsRCIC Monthly Walkdown Report, 7118111RCf C Monthly Walkdown Report, 8111111RCIC Monthly Walkdown Report, 912111RHRSW Monthly Walkdown Report, 7125111RHRSW Monthly Walkdown Report, 8117111RHRSW Monthly Walkdown Report, 9122111RBCCW Monthly Walkdown Report, 7122111RBCCW Monthly Walkdown Report, 8122111RBCCW Monthly Walkdown Report, 1015111Fire Protection Monthly Walkdown Report, 911111Fire Protection Monthly Walkdown Report, 10125111The 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-3Vermont Yankee Updated Final Safetv Analvsis ReportSection 10.11 FIRE PROTECTION SYSTEMProqram DocumentsThe licensee W Heat Exchanger Program, ENN-SEP-HX-001, Revision 1The licensee W Service Water Program, ENN-SEP-SW-001, Revision 2The licensee W ENN Engineering Standard, ENN-MS-S-004-VY, Revision 5,3115112;System CategorizationProceduresProcedure RP 4620, Revision 19, Sampling and Analysis of Instrument AndContainment lnstrument Air Supplies, 1 1130110The 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 ofInstrument And Containment Instrument Air SuppliesVermont Yankee Power Station Operating Procedure 4019,of Plant Fore Barriers and Fire Rated AssembliesVermont Yankee Power Station Operating Procedure 4105,Protection Systems SurveillanceOP 4019, Surveillance of Plant Fire Barriers and Fire RatedOP 4103, Fire Protection Equipment Surveillance, Rev, 56OP 4104, Fire Hose Service Test Surveillance, Rev. 19OP 4105, Fire Protection Systems Surveillance, Rev. 48OPOP-PHEN-3127, Natural Phenomena Operating Procedure, Rev. 5Work Orders & Work RequestswR 0029167wR 0029168wR 0029169wR 00291970wR 00261977wR 00261966wR 00184551wR 00242340wR 00245641wR 00248857wR 00248862wR 00248864wR 00248866wR 00248870wR 00250475wR 00250476wR 00250481wR 00282293wR 00282294wR 00291419Revision 30, 01/03/1 2; SurveillanceRevision 48, 01 l03l12; FueAssemblies, Rev.30wR00291422wR 00291425wR 00291430wR 00298713wR 00301548wR 52298615wR 52298263wR 52334425Attachment A-4Miscellaneous DocumentsNRC Generic Letter 89-13; 7118189: Service Water System Problems Affecting Safety-RelatedEquipmentGE Nuclear Services Information Letter (SlL) Number 588R1, 5/18/95; TOP GUIDE AND COREPLATE CRACKINGVermont Yankee UFSAR, Revision 18; Section C.2.5.2Internals Deformation Analysis GeneralLicense Renewal Application dated January 25,2006, including Appendix A(FSAR Supplements) and Appendix B (Aging Management Programs)NUREG 1907, Safety Evaluation Report, May 2008NUREG 1907, Safety Evaluation Report, Supplement 1, September 2009NUREG 1907, Safety Evaluation Report, Supplement2, March 2011The licensee letter BVY 06-091, dated October 17,2Q06The licensee letter BVY 07-018, dated March 23,2007The licensee letter BVY 10-069, dated December 30, 2010The licensee letter BVY 1 1-001, dated January 21,2011The licensee letter BVY 1 1-007, dated February 4,2Q11EN-DC-346, Cable Reliability Program, Revision 2EN-DC-348, Non-EQ Insulated Cables and Connections Inspection, Revision 2EN-FAP-LR-O27, License Renewal Sensitive lnstrumentation Circuits Review AMP, Revision 0ENN-SEP-CBL-WY, Vermont Yankee Cable Reliability Program Plan, Revision 0LRID-12-1, Review of the Fire Protection Aging Management Program for License Renewallmplementation at Vermont Yankee Nuclear Power Station, Revision 0LRID-12-2, Review of the Fire Water System Aging Management Program for License Renewallmplementation at Vermont Yankee Nuclear Power Station, Revision 0LRID-17, Review of the Non-EQ Inaccessible Medium-Voltage Cable Aging ManagementProgram for License Renewal lmplementation at W Nuclear Power Station, Revision 0LRID-18, Review of Non-EQ Instrumentation Circuits Rest Review Aging Management Programfor License Renewal lmplementation at Vermont Yankee Nuclear Power Station,Revision 0LRID-19, Review of the Non-EQ Insulated Cables and Connections Aging ManagementProgram for License Renewal lmplementation at W Nuclear Power Station, Revision 1LRID-31, Review of Bolted Cable Connections Aging Management Program for LicenseRenewal lmplementation at Vermont Yankee Nuclear Power Station, Revision 0OP 5307, Electrical Checkout of Neutron Monitoring Detectors, Revision 12PP 701 1, Vermont Yankee Fire Protection and Safe Shutdown, Revision 13VY-RPT-1 1-00017, Bolted Cable Connection lnspection Report, Revision 0VY-RPT-11-00018, Non-EQ Sensitive Instrumentation Circuits Cable and ConnectionEvaluation, Draft Revision 0VY-RPT-11-00019, Cable and Connection Inspection Summary Report, Revision 0Evaluation 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. 23,2011Fire Pump Diesel Tank Ultrasonic Test (UT) Results, Nov. 29,2011VYBOP-11-UT-007, UT Erosion/Corrosion Examination - TK-40-1A, Oct. 23,2011VYBOP-11-UT-031. UT Thickness Examination - TK-43-1A, Nov. 14, 2011Attachment A-5PM Basis M118, Revision 4PM Basis M336, Revision 1API Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction, 4th Ed., April 2009SP001, Steel Tank Institute, Standard for the Inspection of Aboveground Storage Tanks, 4th Ed,July 2006OP 4105, Fire Protection Systems Surveillance, Revision 48EN-DC-316, Heat Exchanger Performance and Condition Monitoring, Revision 3ENN-SEP-HX-001, Heat Exchanger Program, Revision 1ENN-SEP-HX-001, Heat Exchanger Program, Revision 2 (draft)Heat Exchanger Program Health Report, 2011 Quarters 2,3, 4HVAC Heat Exchanger Status Report, Jan.25,2012EC 33601EN-FAP-LR-024, One-Time Inspection, Revision 0ER VY-RPT-11-00032, Revision 0 (draft)One-Time lnspection Tracking Matrix, Jan. 25, 2Q12EN-FAP-LR-025, Selective Leaching Inspection, Revision 1VY-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 onVarious Components in Contact with Water, Dec.2011GZA GeoEnvironmental, Inc, Report No. 01 .25576.13, Results of Soil Corrosivity Testing -Buried Pipe Initiative, Vermont Yankee, Dec. 12,2011Evaluation of the Gray Cast lron Valves in the Fire Protection System Based on ExternalUltrasonic Test Examinations, Jan. 18,2012Selective Leaching Matrix, Jan. 25, 2012PMRQ 50040601, task 3ME163, Preventive Maintenance Basis - John Deere DieselWork Order 52316981, Three year PM for John Deere Diesel, completed June 16, 2011CHOP-DIES-4613-01, Sampling and Testing of Diesel Fuel Oil, Revisions 1 & 2Annual fuel oil analyses (John Deere Diesel) for sample of March 10,2011Quarterly water and sediment test (John Deere Diesel) for samples on July 18,2Q11 andOct.22,2011Quarterly water and sediment test (diesel fire pump) for samples on Sept. 15,2011 andDec.19,2011NUREG-1801, Vol. 2, Revision 1, Xl.6 Structural Monitoring ProgramAP 0205, Controlled Use MonoraiOP 5241, Lifting Fixtures and EquipmentOP 52114, Cooling Tower Structural Inspection and RepairEN-WM- 105, PlanningVYNPS-LRID-27-2, Review of the Structural Monitoring Aging Management ProgramAttachment A-6License Renewal Trackinq DocumentsLRID-09, Review of the Diesel Fuel Monitoring Aging Management Program, Revision 0LRID-12-1, Review of the Fire Protection Aging Management Program, Revision 0LRID-14, Review of the Heat Exchanger Monitoring Aging Management Program, Revision 0LRID-21, Review of the One-Time Inspection Aging Management Program, Revision 1LRID-25, Review of the Selective Leaching Aging Management Program, Revision 0LRID-30-1, Review of the Water Chemistry Control - Auxiliary Systems Aging ManagementProgram, Revision 0ASMEBWRVIPCASSCFRCUFEVT.1FERCGALLIPISPLRANFPANRCRHRSWUFSARUTVYNPSLIST OF ACRONYMSAmerican Society of Mechanical EngineersBoiling Water Reactor Vessel Internals ProjectCast Austenitic Stainless SteelCode of Federal RegulationsCumulative Fatigue Usage FactorsEnhanced Visual Inspection TechniqueFederal Energy Regulation CommissionGeneric Aging Lessons LearnedInspection ProcedureIntegrated Surveillance ProgramLicense Renewal ApplicationNational Fire Protection AssociationU.S. Nuclear Regulatory CommissionResidual Heat Removal Service WaterUpdated Final Safety Analysis ReportUltrasonic TestsVermont Yankee Nuclear Power StationAttachment