IR 05000271/1980005
| ML090280422 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 01/28/2009 |
| From: | Diane Jackson NRC/RGN-I/DRP/PB5 |
| To: | Michael Colomb Entergy Nuclear Operations |
| Jackson D RGN-I/DRP/PB2/610-337-5306 | |
| References | |
| IR-08-005 | |
| Download: ML090280422 (41) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 28, 2009
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION -
NRC INTEGRATED INSPECTION REPORT 05000271/2008005
Dear Mr. Colomb:
On December 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on January 6, 2009, with you and members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/ Original Signed By:
Donald E. Jackson, Chief Projects Branch 5 ary 28, 2009
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION -
NRC INTEGRATED INSPECTION REPORT 05000271/2008005
Dear M
SUMMARY OF FINDINGS
IR 05000271/2008005; 10/01/2008 - 12/31/2008; Vermont Yankee Nuclear Power Station;
Routine Quarterly Integrated Report.
This report covered a three month period of inspection by the resident inspectors and region based inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at approximately 100 percent power. On October 18, 2008, operators shut down the reactor to support a planned refueling outage (RFO 27). Operators subsequently took the reactor critical on November 9, 2008 following the completion of RFO 27. The reactor was returned to full power operation on November 13, 2008. On December 12, 2008 operators reduced reactor power to approximately 82 percent, as directed by the power grid operator during a winter storm. Following the storm and offsite power line restoration activities, operators returned power to approximately 100 percent on December 14, 2008 where it remained for the rest of the inspection period. Additional power reductions for rod sequence exchange and minor rod pattern adjustments were also conducted as needed throughout the period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
a.
Inspection Scope (1 sample)
The inspectors reviewed actions taken by Entergy to prepare the service water (SW),emergency diesel generator (EDG), and high pressure coolant injection (HPCI) systems for cold weather operations. The inspectors reviewed operating procedure (OP) 2196, Seasonal Preparedness, and discussed the completion of items with operations personnel to determine if actions for the selected systems had been completed or were being tracked for completion. The inspectors independently walked down applicable portions of the plant, including the condensate storage tank, to determine if selected actions to prepare for cold weather operations had been completed appropriately. The inspectors also reviewed condition reports (CRs) related to cold weather protection of the selected systems to ensure issues were properly addressed for resolution.
Additional documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial Equipment Alignment (7111.04Q)
a.
Inspection Scope (2 samples)
The inspectors performed partial system walkdowns of risk-significant systems to determine the system alignment, and to identify any discrepancies that could impact system operability. Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings (P&IDs) and OPs. The inspectors observed valve positions, power supply availability, and the general condition of selected components. Finally, the inspectors evaluated material condition, housekeeping, and component labeling. A list of documents reviewed is provided in the Attachment. The following systems were inspected:
- Fuel pool cooling system while shutdown cooling was inoperable due to planned maintenance during RFO 27; and
- HPCI system while the reactor core isolation cooling (RCIC) system was out of service for planned maintenance.
b. Findings
No findings of significance were identified.
.2 Complete Equipment Alignment (7111.04S)
a. Inspection Scope
(2 samples)
The inspectors performed a complete equipment alignment inspection of the accessible portions of two risk significant systems. The inspectors compared the actual system configuration to approved P&IDs, the Updated Final Safety Analysis Report (UFSAR),the system design basis documents, and OPs. The inspectors evaluated whether major system components were properly ventilated, hangers and supports were correctly installed and functional, ancillary equipment was placed so it would not interfere with the operation of system valves, pump oil levels were maintained in the nominal band, and deficiencies had been entered into the corrective action program. In addition, the inspectors evaluated a sample of previously identified deficiencies to determine if they had been properly addressed, and whether open items impacted system operability. A list of documents reviewed is provided in the Attachment. The following systems were inspected:
- Residual Heat Removal (RHR) system; and
- Neutron monitoring system.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
(4 samples)
The inspectors identified fire areas based on a review of Entergys Vermont Yankee Safe Shutdown Capability Analysis, the Fire Hazards Analysis, and the Individual Plant Examination for External Events (IPEEE). The inspectors toured plant areas important to safety to evaluate Entergys control of transient combustibles and ignition sources, and the material condition and operational status of fire protection systems, equipment, and barriers. The following fire areas (FAs) and fire zones (FZs) were inspected:
- Fuel oil storage tank and transfer pump house (fire area12);
- Control room (fire zone [FZ] 1);
- Reactor Building, 213 and 232 foot elevations, A emergency core cooling system (ECCS) corner room (FZ RB1); and
- Main and auxiliary transformers (no fire designation).
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
a. Inspection Scope
(2 samples)
The inspectors reviewed the results of the thermal performance tests of Reactor Recirculation Units (RRU) 7 and 8. The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria, which considered differences between test and design basis accident conditions. The inspectors also reviewed Entergys corrective action program to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned, if any, were appropriate. A list of documents reviewed is provided in the Attachment to this report.
b. Findings
No findings of significance were identified.
1R08 In-service Inspection (ISI) (IP 71111.08)
a. Inspection Scope
(1 sample)
The purpose of this inspection was to assess the effectiveness of the licensees ISI program for monitoring degradation of the reactor coolant system boundary, risk significant piping system boundaries, and the containment boundary. The inspectors assessed the ISI activities using the criteria specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI and applicable NRC Regulatory Requirements.
The inspectors selected a sample of nondestructive examination (NDE) activities for observation or review, and evaluation for compliance with the requirements of ASME Section XI. Also, the inspectors selected samples of activities associated with the repair/replacement of safety related pressure boundary components. The sample selection was based on the inspection procedure objectives, risk significance and availability. Specifically, the inspectors focused on components and systems where degradation would result in a significant challenge to the integrity of pressure boundary components.
The inspectors performed an observation of portions of one volumetric examination (ultrasonic) and performed a review of inspection records of a surface examination (liquid penetrant) inspection. In addition, the inspectors performed a documentation review of a magnetic particle surface examination. The selection included the following:
- Ultrasonic Test (UT), volumetric examination, N3B, Nozzle to Vessel Weld;
- Visual Test (VT)-3, 27-10.03-027, feedwater-16 elbow;
- General Visual Exam, Containment Inspection, RFO-27;
- VT-3, Reactor Water Cleanup (RWCU) Component CU-2; and
- Liquid Penetrant Test (PT), surface examination, RR-WB-110 sock-o-let to main line weld.
The inspectors reviewed a sample of reports from the inspection of the reactor containment. The inspectors noted that Entergy had followed their procedural guidance and documented conditions which required evaluation for continued operation.
The inspectors completed a partial review of inspection results of the remote visual examination of the steam dryer conducted during RFO 27. The inspectors reviewed CRs initiated as a result of the dryer examination and noted that all indications were acceptable for continued operation after analysis and evaluation. The inspectors selected a sample of repair/rework activities for review which required the development and implementation of an ASME Section XI repair plan. The inspectors reviewed documentation for the weld repair of an ASME code rejectable indication on a Standby Liquid Control (SLC) system piping weld, and the repair of a valve in the HPCI system which had caused suction pressure alarms during system periodic surveillances.
The inspectors reviewed the ASME Section XI plans, work scope, activity sequence, weld filler metal selection, weld procedure specifications and procedure qualification records, welder qualifications, specified non-destructive tests, acceptance criteria and post maintenance testing (PMT).
The inspectors also reviewed rejectable FW system piping support welds which were later accepted as-is for continued operation after evaluation. The inspectors walked down the steam tunnel area containing the FW and main steam supports and visually observed the conditions reported in previous inspections. Future inspections of these components are planned and the current condition was reported in CR 2008-4378.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
(1 sample)
The inspectors observed a simulator-based licensed operator requalification as found exam on November 20, 2008. The inspectors evaluated crew performance in the areas of clarity and formality of communications; ability to take timely actions; prioritization, interpretation, and verification of alarms; procedure usage; control board manipulations; and command and control. Crew performance in these areas was compared to the Instructor Guide for Simulator Scenario LOR-26-601 and Entergy management expectations and guidelines. The inspectors also compared the simulator configuration with the actual control board configuration. Finally, the inspectors observed the Entergy evaluators discuss identified weaknesses with the crew and/or individual crew members, as appropriate.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
(3 samples)
The inspectors reviewed Entergys evaluation of three degraded conditions involving structures, systems and components (SSCs) for maintenance effectiveness. The inspectors reviewed Entergys implementation of the Maintenance Rule (MR),10CFR50.65, to determine if the conditions were appropriately evaluated against applicable MR functional failure (MRFF) criteria, as found in Entergy scoping documents and procedures. For each issue, the inspectors reviewed the applicable system health report and/or discussed the issue with the MR Coordinator and responsible system engineer to determine if the condition was appropriately tracked against the system performance criteria and classified in accordance with MR implementation guidance.
Documents reviewed during the inspection are listed in the Attachment. The specific conditions reviewed were:
- B service water pump motor unscheduled maintenance repair;
- Main steam isolation valve (MSIV) local leakage rate testing (LLRT) failures; and
- Torus vent and purge valves LLRT failures.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
(1 sample)
The inspectors evaluated online risk management for one emergent maintenance activity. The inspectors reviewed maintenance risk evaluations, maintenance plans, work schedules, and control room logs to determine if concurrent or emergent maintenance activities significantly increased the plant risk. The inspectors also compared the items to the requirements in Administrative Procedure (AP) 0125, "Plant Equipment," and AP 0172, "Work Schedule Risk Management - Online." Additional documents reviewed are listed in the Attachment. The inspectors also walked down areas of the plant containing equipment that was determined to have higher risk significance during the following work activity:
- Troubleshooting stator cooling turbine trip logic.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
(2 samples)
The inspectors reviewed two operability evaluations prepared by Entergy. The inspectors evaluated the operability evaluations against Entergy procedure EN-OP-104, Operability Determinations, and the guidance contained in NRC Regulatory Issue Summary 2005-20, Revision to Guidance Formerly Contained in NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability. A list of documents reviewed is provided in the Attachment. The inspectors also discussed the conditions with operators and system and design engineers, as necessary. The inspectors reviewed evaluations of the following degraded or non-conforming conditions:
- B Service Water pump motor vibrations following replacement; and
- Three reactor core plate plugs not fully seated.
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
.1 Permanent Plant Modifications
a. Inspection Scope
(1 sample)
The inspectors reviewed modification EC 2248, Replacement of V70-1A/B and V70-2A/B, which replaced the A and B SW pumps discharge check and gate valves, to ensure it did not adversely affect the availability, reliability, or functional capability of any risk-significant SSCs. The inspectors reviewed the engineering change package and completed PMT package and observed the SW pumps in operation following the installation of the modification. A list of documents reviewed is provided in the
.
b. Findings
No findings of significance were identified.
.2 Temporary Plant Modifications
a. Inspection Scope
(1 sample)
The inspectors reviewed temporary modification EC 11321, Removal of Reactor Head Vent Valves to ensure it did not adversely affect the availability, reliability, or functional capability of any risk-significant SSCs. The inspectors reviewed the engineering change package and completed work order (WO) which installed the modification, walked down the modification installation during containment closeout inspection, and compared the installation and control of the modification to the requirements of Entergy Corporate Procedure EN-DC-136, Temporary Alterations. A list of documents reviewed is provided in the Attachment.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
(6 samples)
The inspectors reviewed Post-Maintenance Testing (PMT) activities on risk-significant systems. The inspectors either observed the PMT or reviewed completed PMT documentation to determine if the test data met the acceptance criteria contained in the WO, Technical Specifications (TS), UFSAR, and/or the in-service testing program.
When testing was directly observed, the inspectors determined whether installed test equipment was appropriate and controlled, and whether the test was performed in accordance with applicable station procedures. The inspectors also reviewed the test activities to determine if the PMT was adequate to ensure system operability and functional capability following maintenance, if the systems were properly restored following testing, and if discrepancies were appropriately documented in the Corrective Action Program (CAP). Additional documents reviewed are listed in the Attachment.
The inspectors reviewed the PMTs performed for the following maintenance activities:
- B Standby Liquid Control system maintenance;
- Reactor pressure vessel system operational pressure test following RFO 27;
- B Emergency Diesel Generator Service Water piping replacement;
- HPCI/RCIC high point vent installation;
- Cooling tower cell 2-1 inspections and member replacement; and
- HPCI 16 steam supply valve motor operator refurbishment.
b. Findings
No findings of significance were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
(1 sample)
The inspectors evaluated VY Refueling Outage (RFO) 27 activities to verify that Entergy considered risk when developing outage schedules; adhered to administrative risk reduction methodologies for plant configuration control; and adhered to their operating license, TS requirements, and approved procedures. A list of documents reviewed is provided in the Attachment. The following activities were inspected:
- Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 27 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions: electrical power availability, inventory control, decay heat removal, reactivity control, and containment. The daily risk assessments, accounting for schedule changes and unplanned activities, were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate;
- Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations. As soon as practical following the shutdown, the inspectors performed walkdown inspections of the primary containment;
- Electrical Power - The inspectors reviewed the status and configuration of safety-related buses throughout RFO 27. The inspectors ensured the electrical lineups met the requirements of Technical Specifications and the outage risk control plan. The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers, the auxiliary transformer, and the emergency diesel generators;
- Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (i.e., shutdown cooling) status on a daily basis. Monitoring included daily reviews of residual heat removal system alignment, reviews of spent fuel pool cooling system alignment, and reviews of reactor coolant system (RCS) time-to-boil calculations and results;
- Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan. The inspectors also verified that operators maintained reactor vessel and/or refueling cavity levels within established ranges;
- Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling evolutions including procedure place keeping, communications with refueling floor personnel, monitoring of source range nuclear instrumentation, and monitoring of individual control rod positions;
- Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage. The inspectors performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure. Finally, the inspectors verified primary and secondary containment had been appropriately reestablished prior to and during startup;
- Refueling Activities - The inspectors observed portions of refueling operations, including fuel handling and accounting in the reactor vessel and spent fuel pool. The inspectors also performed an independent core reload verification of 100 percent of the core;
- Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 27;
- Cooling Tower Cell 2-1 Maintenance - The inspectors observed portions of the maintenance activities associated with the pre-planned replacement of 22 wooden support columns in two of the six sections of the cooling tower cell. The inspectors reviewed deficiencies identified by Entergy during their "as-found" inspections as well as the expanded scope which resulted in 3 additional support columns being replaced. Finally, the inspectors performed a walkdown of cooling tower cell 2-1 after it was placed in service during post maintenance testing.
- Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their corrective action program.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
(5 samples)
The inspectors observed surveillance testing to determine if the specified acceptance criteria was consistent with Technical Specification and UFSAR requirements, if the test was performed in accordance with the written procedure, if the test data was complete and met procedural requirements, and if the system was properly returned to service following testing. Additional documents reviewed are listed in the Attachment. The inspectors observed selected pre-job briefings for the test activities. The inspectors also checked to determine if discrepancies were appropriately documented in the corrective action program. The inspectors reviewed the following surveillance testing:
- Realignment of electrical power via backfeed through the auxiliary transformer;
- ECCS integrated automatic initiation testing;
- HPCI actuation logic functional test; and
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System (ANS) Evaluation
a. Inspection Scope
(1 sample)
An onsite review was conducted to assess the maintenance and testing of the Vermont ANS. During this inspection, the inspectors interviewed emergency preparedness (EP)staff responsible for implementation of the ANS testing and maintenance, and reviewed CRs pertaining to the ANS for causes, trends, and Entergys corrective actions. The inspectors further discussed the ANS with the assigned technical specialist, reviewing system performance in 2007 and 2008. The inspectors reviewed the ANS procedures and the ANS design report to ensure Entergys compliance with those commitments for system maintenance and testing. Additionally, the inspectors reviewed changes to the design report and how these changes were captured. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment
.02. Planning Standard,
10 CFR 50.47(b)(5) and the related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings of significance were identified.
1EP3 Emergency Response Organization (ERO) Staffing and Augmentation System
a. Inspection Scope
(1 sample)
The inspectors conducted a review of Vermont Yankees ERO augmentation staffing requirements and the process for notifying and augmenting the ERO. This was performed to ensure the readiness of key staff to respond to an event and to ensure timely facility activation. The inspectors reviewed procedures and CRs associated with the ERO notification system and drills, and reviewed records from call-in drills. The inspectors interviewed personnel responsible for testing the ERO augmentation process, and reviewed the training records for the ERO to ensure training and qualifications were up to date. The inspectors further verified a sampling of ERO participation in exercises and drills in 2007 and 2008. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment
.03. Planning Standard,
10 CFR 50.47(b)(2) and related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings of significance were identified.
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes
a. Inspection Scope
(1 sample)
Prior to this inspection, the NRC had received and acknowledged changes made to the Vermont Yankee Emergency Plan and its implementing procedures. Entergy developed these changes in accordance with 10 CFR 50.54(q), and determined that the changes did not result in a decrease in effectiveness of the Plan. The licensee also determined that the Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. During this inspection, the inspectors conducted a review of Entergys 10 CFR 50.54(q) screenings for all the changes made to the EALs and all of the changes made to the Plan from October 2007 through September 2008 that could have potentially resulted in a decrease in effectiveness of the Plan. This review of the EAL and Plan changes did not constitute NRC approval of the changes and, as such, the changes remain subject to future NRC inspection. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment
.04. The requirements
in 10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings of significance were identified.
1EP5 Correction of Emergency Preparedness Weaknesses
a. Inspection Scope
(1 sample)
The inspectors reviewed a sampling of self-assessment procedures and reports to assess Entergys ability to evaluate their EP performance and programs. The inspectors reviewed a sampling of EP drill reports and CRs from January 2007 through September 2008, initiated by Entergy at Vermont Yankee from drills, self-assessments and audits. Additionally, the inspectors reviewed Vermont Yankee Quality Assurance audits and reports, and the 2007 and 2008 10 CFR 50.54(t) audit reports. This inspection was conducted in accordance with NRC Inspection Procedure 71114,
of 10 CFR 50 Appendix E were used as reference criteria.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)
a. Inspection Scope
(7 samples)
During October 27 through 31, 2008, the inspectors conducted the following activities to verify that the licensee was properly implementing physical, engineering, and administrative controls for access to high radiation and other radiologically controlled areas, and that workers were adhering to these controls when working in these areas.
Implementation of the access control program was reviewed against the criteria contained in 10 CFR 20, Technical Specifications, and licensee procedures.
- (1) Radiation work permits (RWPs) that provide access to exposure significant areas of the plant including high radiation areas were reviewed. Specified electronic personal dosimeter alarm set points were reviewed with respect to current radiological condition applicability and workers were queried to verify their understanding of plant procedures governing alarm response and knowledge of radiological conditions in their work area.
- (2) There were no radiation work permits for airborne radioactivity areas with the potential for individual worker internal exposures of >50 mrem Committed Effective Dose Equivalent (CEDE).
The following jobs were reviewed as having engineering controls and Total Effective Dose Equivalent as low as is reasonably achievable (ALARA)evaluations that resulted in expected levels less than the 50 mrem CEDE. At the time of this inspection there were no workers with >50 mrem CEDE.
- RWP 08-103, Reactor Disassembly Cavity Entries
- RWP 08-113, Control Rod Drive (CRD) Exchange in the Drywell
- (3) During October 27 through 31, 2008, the following radiologically significant work activities were selected; the radiological work activity job requirements were reviewed; and work activity job performance was reviewed with respect to the radiological work requirements.
- Safety Relief Valve (SRV) work in the Drywell
- Refuel floor disassembly activities
- In-vessel visual inspection (IVVI) activities
- Motor Operated Valve (MOV) work activities
- ISI activities
- CRD replacement
- RWCU heat exchanger work
- (4) During observation of the work activities listed above, the adequacy of surveys, job coverage and contamination controls were reviewed.
- (5) The adequacy of effectively monitoring occupational dose in work areas of significant dose gradients requiring relocation of dosimetry was reviewed for CRD replacement activities.
- (6) During observation of the work activities listed above, radiation worker performance was evaluated with respect to the specific radiation protection work requirements and their knowledge of the radiological conditions in their work areas.
- (7) During observation of the work activities listed above, radiation protection technician work performance was evaluated with respect to their knowledge of the radiological conditions, the specific radiation protection work requirements and radiation protection procedures.
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls (71121.02)
a. Inspection Scope
(3 samples)
During October 27 through 31, 2008, the inspectors conducted the following activities to verify that the licensee was properly maintaining individual and collective radiation exposures ALARA. Implementation of the ALARA program was reviewed against the criteria contained in 10 CFR 20.1101(b) and the licensees procedures.
- (1) The following highest exposure work activities for the fall 2008 refueling outage, RFO 27, were selected for review:
- SRV work in the Drywell
- Refuel floor disassembly activities
- IVVI activities
- MOV work activities
- ISI activities
- CRD replacement
- Staging activities, both Drywell and non-Drywell
- Drywell miscellaneous activities: Insulation, Shielding, Snubbers
- RWCU heat exchanger work
- (2) With respect to the work activities listed above, these job sites were observed to evaluate if surveys and ALARA controls were implemented as planned.
- (3) Radiation worker and radiation protection technician performance was observed during the performance of the work activities listed above to determine whether ALARA principles were demonstrated.
b. Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety (PS)
2PS1 Radioactive Effluents (71122.01)
a. Inspection Scope
(3 samples)
During the period December 1 through 17, 2008, the inspectors conducted the following activities to verify that Entergys radioactive gaseous and liquid effluent release program complied with the requirements of Technical Specifications, Offsite Dose Calculation Manual (ODCM), and 10 CFR Parts 20 and 50.
- (1) The inspectors reviewed the following documents:
- Latest revision and recent changes to the ODCM and applicable effluent and groundwater monitoring procedures;
- The last two annual radiological effluent release reports;
- The most recent Quality Assurance audit of the effluent release program; and the
- UFSAR, Chapter 9.
The radiological effluent controls procedures were reviewed with respect to requirements. A review of plant modifications over the past two years that affect the radiological effluents program were reviewed to ensure effluent releases remain ALARA.
A review of effluent monitoring instrumentation changes was performed to evaluate the adequacy of effluent monitoring and radiation monitor setpoint calculations.
The inspectors reviewed the status of the groundwater monitoring program. This included an initial site hydrogeological assessment dated June 30, 2007, which recommended 10 additional monitoring wells, as well as a follow-up annual assessment dated September 2008, that identified significant information and program gaps that remain to be completed. Additional licensee actions will be reviewed in a future NRC Groundwater Protection Initiative inspection (Temporary Instruction [TI] 2515/173, Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative).
The latest two annual radiological effluent release reports were reviewed, which indicated that there were no abnormal or anomalous results identified and no significant changes in reported dose values from previous effluent release reports. These reports were also reviewed with respect to the environmental monitoring program, which did not identify any plant-related radioactivity in the offsite environment or in any onsite groundwater monitoring wells.
- (2) The inspectors walked down the following components of the gaseous and liquid discharge systems with respect to material condition and operability: liquid radwaste discharge radiation monitor and flow rate monitor, service water radiation monitor, steam jet air ejector noble gas radiation monitor, auxiliary off gas noble gas monitor, plant stack noble gas monitor and stack flow rate monitor. Recent radiation monitor alarm and setpoint calculations were reviewed for the plant stack, steam jet air ejector, and auxiliary off gas monitors.
On December 2, 2008, the inspectors observed the weekly plant stack gaseous effluent sample collection (particulate, charcoal, tritium, and noble gas). The inspectors reviewed the subsequent laboratory counting and later reviewed the sample analysis results of the December 2nd plant stack sample collection.
There were no liquid effluent releases from Vermont Yankee during the past two years.
There were no effluent discharges made with inoperable effluent radiation monitors requiring compensatory sampling during the past two years.
The inspectors reviewed surveillance test results for high efficiency particulate air and charcoal filtration as applicable, for the following gaseous discharge systems: auxiliary off gas, radwaste building ventilation, and stand by gas treatment.
The plant stack radiation monitor and flow rate monitor calibrations were reviewed that included verification of actual ventilation flow rates with respect to plant program requirements.
The IE Bulletin 80-10 program procedure and results that were used to identify if any non-radioactive systems have become contaminated, were reviewed. These systems included: auxiliary off gas closed loop cooling water, demineralized water tank, house heating boiler, reactor building component cooling water, storm drains, turbine building clean sump, and turbine building closed loop cooling water. No indications of contamination were observed.
Recent effluent radiation monitor and laboratory counting instrument calibration and quality control chart results including any compensatory actions were reviewed for the following: auxiliary off gas monitors (3121A&B, 3123, 3125, 3126, 3127, 3128), service water monitor (17-351), radwaste discharge monitor (17-350), reactor building closed loop cooling water (17-352), house heating boiler monitor (17-1006), cooling tower influent monitor (17-359), plant stack monitors (17-156, 157), four high purity germanium gamma spectroscopy detectors, one liquid scintillation counter, two zinc-sulfide alpha detectors and two Geiger-Mueller beta detectors.
Recent 10 CFR Part 61 analyses of plant waste streams were reviewed to ensure hard-to-detect radionuclides were included as necessary in applicable effluent releases.
Meteorological data contained in the annual effluent release reports was reviewed to verify the adequacy of the highest public dose wind sectors used in the current 10-year average used to support the ODCM methodology of public dose calculations.
The land-use census for 2006 and 2007 were reviewed with respect to ODCM assumptions.
Monthly, quarterly and annual dose calculations were reviewed for 2006 - October 2008 with respect to license requirements.
The inspectors verified that there have been no recorded abnormal radioactive leaks, spills, or abnormal radioactive effluent discharges at Vermont Yankee over the past two years. Groundwater monitoring results were reviewed for the first three quarters of 2008 with no contaminants detected. Inter-laboratory cross-check comparison program results for Vermont Yankees radio-chemistry laboratory were reviewed for 2008 to verify the quality of effluent sample measurement results.
The inspectors verified that the licensee is maintaining adequate effluent sampling records in their electronic database system to support effluent release and public dose calculation results.
- (3) The inspectors reviewed the latest quality assurance audit and nine condition reports applicable to the radioactive effluent release program to verify that Entergy is adequately identifying adverse issues, properly determining operability and reporting requirements, prioritizing resolution commensurate with safety significance, identifying repetitive issues, properly identifying contributing causes, identifying and implementing corrective actions, and considering significant operational experience feedback in their corrective action program. For repetitive deficiencies, the inspectors verified that the quality assurance audit readily identified and addressed these issues.
b. Findings
No findings of significance were identified.
2PS2 Radioactive Materials Processing and Shipping (71122.02)
a. Inspection Scope
(6 samples)
During the period October 6 through 9, 2008, the inspectors conducted the following activities to verify that the licensee=s radioactive material processing and transportation programs complied with the requirements of 10 CFR 20, 61, and 71; and Department of Transportation (DOT) regulations 49 CFR 170-189.
- (1) The inspectors reviewed the solid radioactive waste system description in the UFSAR, the 2007 radiological effluent release report for information on the types and amounts of radioactive waste disposed, and the scope of the licensee=s audit program to verify that it meets the requirements of 10 CFR 20.1101.
- (2) The inspectors walked-down the liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agree with the descriptions contained in the UFSAR and in the Process Control Program (PCP); and reviewed the status of any radioactive waste process equipment that is not operational and/or is abandoned in place; verified that the changes were reviewed and documented in accordance with 10 CFR 50.59, as appropriate. The inspectors reviewed the current processes for transferring and dewatering of radioactive waste resin and sludge discharges into shipping/disposal containers to determine if appropriate waste stream mixing and/or sampling procedures, and methodology for waste concentration averaging provide representative samples of the waste product for the purposes of waste classification as specified in 10CFR61.55 for waste disposal.
- (3) The inspectors reviewed the radio-chemical sample analysis results for each of the licensee=s radioactive waste streams, reviewed the licensee=s use of scaling factors and calculations with respect to these radioactive waste streams to account for difficult-to-measure radionuclides; verified that the licensee=s program assures compliance with 10 CFR 61.55 and 10 CFR 61.56 as required by Appendix G of 10 CFR Part 20; and, reviewed the licensee=s program to ensure that the waste stream composition data accounts for changing operational parameters and thus remains valid between the annual or biennial sample analysis update.
- (4) There were no shipments during the week of October 6 through 9, 2008 with no opportunity for the region-based inspectors to observe shipment preparations (packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifests, shipping papers provided to the driver, and licensee verification of shipment readiness).
- (5) The inspectors sampled the following non-excepted package shipment records and reviewed these records for compliance with NRC and DOT requirements.
2008-05, dryer inspection equipment shipment to River Bend NPP on January 28, 2008; 2008-17, reactor cleanup resin shipment to Studsvik on April 7, 2008; 2008-19, lead blankets and scaffolding shipment to Fitzpatrick NPP on April 15, 2008; 2008-29, scrap metal shipment to EnergySolutions on May 21, 2008; 2008-48, condensate filter demineralizer filter shipment to EnergySolutions on July 22, 2008; and 2008-56, condensate phase separator resin shipment to Energy Solutions on September 9, 2008.
- (6) The inspectors reviewed the licensee=s Licensee Event Reports, special reports, audits, state agency reports, and self-assessments related to the radioactive material and transportation programs performed since the last inspection and determined that identified problems are entered into the corrective action program for resolution. The inspectors also reviewed CRs written against the radioactive material and shipping programs since the previous inspection.
The inspectors reviewed ten corrective action condition reports that were initiated between October 2007 and October 2008 and were associated with the radwaste transportation program. The inspectors verified that problems identified by these condition reports were properly characterized in the licensee=s event reporting system, and that applicable causes and corrective actions were identified commensurate with the safety significance of the radiological occurrences.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
[OA]
4OA1 Performance Indicator Verification
a. Inspection Scope
(8 samples)
Mitigating Systems Cornerstone The inspectors sampled Entergy submittals for the three Mitigating Systems Performance Index (MSPI) performance indicators (PIs) for the period from October 1, 2007, through September 30, 2008. The inspectors reviewed selected operator logs, plant process computer data, licensee event reports, maintenance rule out of service logs, criticality data, Consolidated Data Entry MSPI Derivation Reports for the unavailability index and unreliability index for each system, monitored component demands and demand failure data and discussed the PI data with responsible system engineers and licensing personnel. The PI definitions and guidance contained in Nuclear Energy Institute, Inc. (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, and AP 0094, NRC Performance Indicator Reporting, were used to verify the accuracy and completeness of the PI data reported during this period. Additional documents reviewed are listed in the Attachment. The following performance indicators were inspected:
- MSPI, Cooling Water Systems;
- MSPI, Residual Heat Removal System.
Emergency Preparedness Cornerstone The inspectors reviewed data for three EP PIs. The inspectors reviewed the Vermont Yankee PI data, its supporting documentation, and the information Entergy reported from the fourth quarter of 2007 through the third quarter of 2008, to verify the accuracy of the reported data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151. Additional documents reviewed are listed in the
. The following performance indicators were inspected:
- Drill and Exercise Performance (DEP);
- ERO Drill Participation; and
- ANS Reliability.
Additionally, the inspectors performed NRC TI 2515/175, Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review; ensured the completeness of the licensees completed Attachment 1 from the TI; and forwarded that data to NRC Headquarters.
Occupational Radiation Safety Cornerstone The inspectors reviewed implementation of the licensees Occupational Exposure Control Effectiveness PI Program. Specifically, the inspectors reviewed CRs and radiologically controlled area dosimeter exit logs for the past four
- (4) calendar quarters.
These records were reviewed for occurrences involving locked high radiation areas, very high radiation areas, and unplanned exposures to verify that all occurrences that met the NEI criteria were identified and reported as performance indicators.
Public Radiation Safety Cornerstone The inspectors reviewed a listing of relevant effluent release reports for the past four calendar quarters, for issues related to the public radiation safety PI, which measures radiological effluent release occurrences per site that exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ dose for liquid effluents; 5 mrads/qtr gamma air dose, 10 mrad/qtr beta air dose, and 7.5 mrads/qtr for organ dose for gaseous effluents.
The inspectors reviewed the following documents to ensure the licensee met all requirements of the PI:
a.
monthly projected dose assessment results due to radioactive liquid and gaseous effluent releases; b.
quarterly projected dose assessment results due to radioactive liquid and gaseous effluent releases; and c.
dose assessment procedures.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
The inspectors performed a screening of each item entered into Entergys corrective action program. This review was accomplished by reviewing printouts of each condition report, attending daily screening meetings, and/or accessing Entergys database. The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow-up. In addition, specialist inspectors in the area of radiation safety and in-service inspection examinations reviewed items entered into the corrective action program during the period and the documents reviewed are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review nominally considered the six-month period of July through December 2008. The inspectors compared their results with the results contained in Entergys quarterly trend reports, operator logs, and CRs. The corrective actions assigned to address select individual issues were reviewed for adequacy.
b. Findings
No findings of significance were identified.
.3 Annual Sample - Main Turbine Stop Valve Corrective Actions
a. Inspection Scope
(1 sample)
The inspectors reviewed actions taken by Entergy following a reactor trip on August 30, 2007 which occurred during troubleshooting activities on the bypass control mechanism of main turbine stop valve number two (TSV-2). This issue was previously documented as finding (FIN)05000271/2007004-02, Reactor Scram During Troubleshooting Due to Inadequate Main TSV Preventive Maintenance. The inspectors reviewed the associated CR 2007-3349, quarterly TSV surveillance test results since the scram, and the completed work order for maintenance performed during RFO 27. A list of documents reviewed is included in the Attachment. The inspectors also discussed implemented and additional planned corrective actions and results with the responsible system engineer.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that Entergy has taken appropriate corrective actions to date to prevent recurrence of the binding bypass control mechanism on TSV-2. Corrective actions included periodic lubrication of the mechanism during the previous cycle and establishment of a preventive maintenance task to inspect, lubricate, and rebuild the mechanism, as necessary. There have been no instances of the mechanism binding during quarterly surveillance testing since these corrective actions were implemented.
.4 Annual Sample - Torus In Leakage
a. Inspection Scope
(1 sample)
The inspectors reviewed actions taken by Entergy to identify and correct the source of in leakage into the torus. This sample was selected based on a history of torus in leakage, since at least 2005, which necessitates the operation of the safety related RHR pumps to reduce the water level in the torus to maintain its safety function. The inspectors reviewed related CRs and work orders and discussed the current torus in leakage rate as well as past corrective actions with the responsible system engineer. A list of documents reviewed is included in the Attachment.
b. Findings and Observations
No findings of significance were identified. Although the torus in leakage rate continues to vary throughout the operating cycle, the inspectors determined that Entergy has implemented reasonable corrective measures when the in leakage rate increases.
Corrective actions include troubleshooting to determine the source of the leakage, performing maintenance on RHR check valves that have been determined to be the source of the leakage, continuing to monitor the torus in leakage rate and issuing CRs and additional corrective actions as warranted.
.5 Annual Sample - Procedure and Document Quality
a.
Inspection Scope (1 sample)
The inspectors reviewed Entergys corrective actions for the increased amount of findings, observations, and condition reports in the area of complete, accurate and up-to-date design documentation and procedures during the last inspection cycle. Entergy documented this trend in CR 2008-2152, Number of NRC Cross-Cutting Inspection Issues has exceeded the Performance threshold. The inspectors reviewed the CR and Entergys procedure upgrade action plan, attended meetings and interviewed station personnel to evaluate the scope and depth of corrective actions to date.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that Entergy had taken appropriate corrective actions to date to address the procedure and document quality issue. These actions included developing a procedure upgrade action plan and presenting the plan to station personnel at various plant meetings. The procedure upgrade action plan includes the development of a new procedures writer's guide; training of new and existing station personnel; development of model procedures for each department; and a process for prioritizing which procedures will be updated first.
4OA3 Event Follow-up
.1 ALARA Planning and Controls
Elevated Concentration of Airborne Radioactive Material on Refuel Floor
a. Inspection Scope
(1 sample)
During the week of October 27, 2008, the inspectors met with licensee representatives to review and discuss the details of an incident that occurred on October 20, 2008. At approximately 18:00 hours (6 pm) refuel floor personnel were removed from the floor due to elevated concentrations of airborne radioactive material during the transfer of the reactor pressure vessel head from the reactor cavity to its storage location on the floor.
This review was conducted against the criteria contained in 10 CFR 20.
The inspectors performed a review of documents associated with the activity as well as interviews of knowledgeable personnel. A partial list of documents reviewed include; Radiological Work Permit 08-103 for Reactor Disassembly, Air-sample, contamination, dose rate, and isotopic data, instrument set-point and calibration worksheets, reactor building ventilation data, CRs 2008-4251 and 2008-4258, Health Physics and Operations log book entries.
As a result of this activity, there was no additional exposure to workers or impact to the public.
b. Findings
No findings of significance were identified.
4OA5 Other
.1 Implementation of TI 2515/176 - Emergency Diesel Generator Technical Specification
Surveillance Requirements Regarding Endurance and Margin Testing
a. Inspection Scope
The objective of TI 2515/176, Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing, is to gather information to assess the adequacy of nuclear power plant EDG endurance and margin testing as prescribed in plant-specific Technical Specifications. The inspectors reviewed EDG ratings, design basis event load calculations, surveillance testing requirements, and EDG vendors specifications and gathered information in accordance with TI 2515/176.
The inspectors assessment and information gathered while completing this TI was discussed with licensee personnel. This information was forwarded to the Office of Nuclear Reactor Regulation for further review and evaluation.
b. Findings
No findings of significance were identified.
4OA6 Meetings, including Exit
Exit Meeting Summary
On January 6, 2008, the resident inspectors presented the inspection results to Mr. Michael Colomb, Site Vice President, and other members of the VY staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Entergy Personnel
- M. Colomb, Site Vice President
- J. Dreyfuss, Director, Nuclear Safety
- D. Mannai, Licensing Manager
- M. Philippon, Operations Manager
- N. Rademacher, Director, Engineering
- C. Wamser, General Manager, Plant Operations
- S. Wender, Radiation Protection Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None.
Discussed
None.