IR 05000271/2008003
| ML082180854 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/05/2008 |
| From: | Norris B NRC/RGN-I/DRP/PB5 |
| To: | Ted Sullivan Entergy Nuclear Operations |
| NORRIS, BS, 610-337-5111 | |
| References | |
| IR-08-003 | |
| Download: ML082180854 (26) | |
Text
August 5, 2008
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION -
NRC INTEGRATED INSPECTION REPORT 05000271/2008003
Dear Mr. Sullivan:
On June 30, 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 July 10, 2008, 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.
This report documents one NRC identified finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Manual. If you contest the NCV in this report, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the United States Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555-0001; and the NRC Resident Inspector at Vermont Yankee Nuclear Power Station.
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 /
Barry S. Norris, Acting Chief Projects Branch 5 Division of Reactor Projects
Docket No. 50-271 License Nos. DPR-28
Enclosure:
Inspection Report No. 05000271/2008003
w/ Attachment: Supplemental Information
cc w/encl:
Vice President, Operations, Entergy Nuclear Operations Senior Vice President, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety & Licensing, Entergy Nuclear Operations Senior Vice President and COO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations Manager, Licensing, Entergy Nuclear Operations G. Edwards S. Lousteau, Treasury Department, Entergy Services, Inc.
D. O Dowd, Administrator, Radiological Health Section, DPHS, State of New Hampshire W. Irwin, Chief, CHP, Radiological Health, Vermont Department of Health Chief, Safety Unit, Office of the Attorney General, Commonwealth of Mass.
D. Lewis, Pillsbury, Winthrop, Shaw, Pittman LLP G. D. Bisbee, Esquire, Deputy Attorney General, Environmental Protection Bureau J. Block, Esquire J. P. Matteau, Executive Director, Windham Regional Commission D. Katz, Citizens Awareness Network (CAN)
R. Shadis, New England Coalition Staff G. Sachs, President/Staff Person, c/o Stopthesale J. Volz, Chairman, Public Service Board, State of Vermont Chairman, Board of Selectman, Town of Vernon C. Pope, State of New Hampshire, SLO D. O'Brien, State of Vermont, SLO J. Giarrusso, SLO, MEMA, Commonwealth of Massachusetts U. Vanags, State Nuclear Engineer, Vermont Department of Public Service S. Shaw
SUMMARY OF FINDINGS
IR 05000271/2008003; 04/01/2008 - 06/30/2008; Vermont Yankee Nuclear Power Station;
Maintenance Effectiveness.
This report covered a 13-week period of inspection by the resident inspectors and region based inspectors. One Green NRC-identified finding was identified, which was classified as a non-cited violation (NCV). The significance of most findings is indicated by their color (Green,
White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. 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
Cornerstone: Initiating Events
- Green.
The NRC identified a non-cited violation for Entergys failure to take timely corrective action, as required by 10CFR50.65(a)(1), after the reactor building crane (RBC) exceeded reliability performance goals. Specifically, from April 12, 2007, when the RBC was classified as (a)(1), until May 12, 2008, when the RBC brakes failed to function during the movement of a spent fuel storage cask, Entergy failed to take corrective actions in response to the RBC not meeting established goals. This issue was entered into the licensee's corrective action program as Condition Report CR 2008-2043.
The issue is greater than minor because the failure to implement timely corrective actions resulted in the failure of the RBC brakes during the movement of a spent fuel storage cask. The finding is not suitable for evaluation under the Significance Determination Process, but has been reviewed by NRC management and was determined to be a finding of very low safety significance (Green) because the spent fuel storage cask was in an approved load path, and the refuel floor allowed the brakes to engage when sufficient load was removed from the hoist. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, in that Entergy failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. P.1(d)
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 April 1, Entergy reduced power to 44 percent to repair a minor tube leak in the main condenser; Entergy returned to full power on April 4, without repairing the tube leak because they were unable to identify the exact leak location. On May 26, Entergy reduced power to 72 percent because of reduced river flow and cooling tower unavailability due to maintenance; Entergy returned to 100 percent power on May 28, after completion of cooling tower maintenance. In addition, Entergy performed several power reductions for rod sequence exchange and minor rod pattern adjustments throughout the period. VY finished the inspection period operating at approximately 100 percent power.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1 External Flooding
a.
Inspection Scope (1 sample)
The inspectors reviewed Entergys flood protection barriers and procedures for coping with external flooding in the switchgear rooms. The inspectors reviewed external flooding information contained in the External Events Design Basis Document (DBD)and compared it to the actions specified in operating procedure (OP) 3127, Natural Phenomena. The inspectors performed walkdowns of the switchgear rooms and examined the equipment specified in the OP (sump pumps, floor drain plugs, etc.) to determine if it was available for use. The inspectors also reviewed a sample of external flooding-related conditions identified in Entergys corrective action program to determine if they were appropriately identified and corrected. Additional documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Alternating Current (AC) Power System Readiness
a.
Inspection Scope (1 sample)
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather. The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate. The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system. The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply, compensatory actions to be taken if it were not possible to predict grid conditions, reassessment of plant risk based on maintenance activities which could affect grid reliability, and required communications between Entergy and the TSO. A list of documents reviewed is provided in the Attachment.
b. Findings
No findings of significance were identified.
.3 Seasonal Preparedness
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 warm weather operations. The inspectors reviewed OP 2196, Preparations for Cold Weather Operations, (Form VYOPF 2196.02, Cold Weather Restoration Operations Checklist); 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; and independently walked down applicable portions of the plant, including the condensate storage tank, to determine if selected actions to prepare for warm weather operations had been completed appropriately.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
a.
Inspection Scope (3 samples)
The inspectors performed partial system walkdowns of the following 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 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.
- SW system while the alternate cooling system was out of service for planned maintenance;
- B Standby Gas Treatment (SBGT) system while B SBGT system was out of service for planned maintenance; and
- A and B Standby Liquid Control (SLC) trains following maintenance on the A SLC pump
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a.
Inspection Scope (5 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. A list of additional documents reviewed is provided in the Attachment to this report. The following fire areas (FAs) and fire zones (FZs) were inspected:
- East Switchgear Room (FA-4);
- West Switchgear Room (FA-5);
- Cable Vault (FZ-2);
- Battery Room (FZ-3); and
- 345 KV Relay House (no fire designation)
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a.
Inspection Scope (1 sample)
The inspectors reviewed Entergys flood protection barriers and procedures for coping with internal flooding in the EDG equipment rooms. The inspectors reviewed internal flooding design information associated with this location in Entergys IPEEE, the Updated Final Safety Analysis Report (UFSAR), and in the Internal Flooding DBD. The inspectors conducted a walk down of the area to determine if equipment and structures needed to mitigate an internal flooding event were available, as described in Entergy design documents. A listing of documents reviewed is provided in the Attachment of this report.
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 exam on June 2, 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 (2 samples)
The inspectors reviewed Entergys evaluation of two 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:
- HPCI controller output drifting below 100 percent; and
- Reactor building crane (RBC) failure to stop while lowering cask to the refuel floor
b. Findings
Introduction:
A non-cited violation (NCV) was identified for Entergys failure to take timely and appropriate corrective action prescribed per paragraph (a)(1) of 10CFR50.65, when the RBC exceeded the licensee-established reliability performance goals. As a result, the RBC brakes failed to function during the movement of a spent fuel storage cask on May 12, 2008.
Discussion: The RBC (CR-1-1A) is within the scope of the MR (10CFR50.65 (b)(2)(ii)and (iii)) and is tracked as a subsystem of the hoist system. The RBC is a non-safety related, non-risk significant SSC whose failure could prevent safety-related SSCs from fulfilling their safety-related function or whose failure could cause a reactor scram or actuation of a safety-related system. In this case, the failure of the RBC could result in a heavy load impacting components in the B Train of the emergency core cooling systems and has the potential to cause a reactor scram by impacting the reactor building structure. The RBC is used during outages to disassemble and reassemble the reactor containment and reactor vessel components. It is also used to transfer spent fuel storage casks from the spent fuel pool to the ground elevation of the reactor building. The RBC consists of a bridge that rides rails set into the reactor building structure. The RBC is controlled from a cubicle mounted on the bridge.
In April 2007, condition report (CR) 2007-1153 documented that the hoist system had entered MR category (a)(1) when it accrued seven MRFFs within a three year period, exceeding the maximum performance acceptance criteria. Entergys evaluation established performance goals of zero spurious electrical control, hoist/load cell, and drive unit trips within the nine month monitoring period following implementation of corrective actions. Corrective actions included actions to improve crane performance and a review of the preventive maintenance basis documentation and the operating procedures to identify, clean, repair and/or change out components, as necessary.
On November 26, 2007, the RBC experienced additional MRFFs (CR 2007-4383) during preparations for dry fuel storage, requiring Entergy to revise the performance evaluation and action plan. Subsequently, on May 12, 2008, the RBC hoist failed while lowering a fully loaded spent fuel storage cask to the refuel floor. Specifically, the RBC hoist failed to respond to the stop signal with the cask four inches above the floor, and the cask continued to slowly lower to the floor. In the apparent cause evaluation (ACE), Entergy determined the failure to respond to the stop command was due the brake relay (2VR-H) not de-energizing and the backup relay (1VR-H) not energizing to actuate the brakes. The relay failures were determined to be due to setpoint drift.
The inspectors reviewed CRs, work orders (WOs), and ACE reports. The inspectors determined that corrective actions established following entry into MR (a)(1) had not been effective in preventing additional MRFFs. The May 12 failure was due to the setpoint drift of the relays. The inspectors determined that Entergy failed to take appropriate corrective actions when system performance goals were not met, prior to moving spent fuel.
Analysis:
The inspectors determined that the performance deficiency was failure to take timely corrective action when exceeding a licensee established reliability goal.
Specifically, Entergy used the RBC to move spent fuel storage casks before the development and implementation of a corrective action plan in accordance with the requirements of 10CFR50.65 (a)(1). The issue is greater than minor because the failure to implement timely corrective actions resulted in the failure of the RBC brakes during the movement of a spent fuel storage cask. The finding is not suitable for evaluation under the Significance Determination Process, but has been reviewed by NRC management and was determined to be a finding of very low safety significance (Green)because the spent fuel storage cask was in an approved load path, and the refuel floor allowed the brakes to engage when sufficient load was removed from the hoist.
This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, in that Entergy failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. P.1(d)
Enforcement:
10CFR50.65 (a)(1), requires the holders of an operating license to monitor the performance or condition of SSCs within the scope of the MR, as defined by 10CFR50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions.
The established goals shall be commensurate with safety. When the performance or condition of a SSC does not meet established goals, appropriate corrective action shall be taken. Contrary to the above, from April 12, 2007, when the hoist system (RBC)exceeded its reliability criteria and was classified as (a)(1), until May 12, 2008, when the RBC failed while moving a loaded spent fuel storage cask, Entergy failed to take timely corrective action when the RBC did not meet established goals. However, because the violation was determined to be of very low safety significance (Green) and has been entered into Entergys corrective action program (CAP), the violation is being treated as a Non-Cited Violation (NCV), consistent with VI.A.1 of the NRC Enforcement Policy.
(NCV 05000271/2008003-01, Ineffective Reactor Building Crane Maintenance)
1R13 Maintenance Risk Assessments and Emergent Work Control
a.
Inspection Scope (5 samples)
The inspectors evaluated online risk management for three planned and two emergent maintenance activities. 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 activities:
- Planned downpower for condenser tube leakage troubleshooting;
- Planned maintenance on cooling tower (CT) 2-1;
- Emergent troubleshooting for turbine generator emergency trip test switch failure;
- Planned maintenance rendering A EDG unavailable and B EDG inoperable; and,
- Emergent placement of alternate cooling in service on dry fuel storage cask 1
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a.
Inspection Scope (5 samples)
The inspectors reviewed five 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:
- Reactor building fire panel failed battery test;
- Portion of engineering fix not installed on CT 2-1/2-2 partition wall;
- HPCI flow controller output drifting down;
- Degraded column identified in CT 2-1; and,
- Reactor building crane hit rail stop
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 CAP.
Additional documents reviewed are listed in the Attachment. The inspectors reviewed the PMTs performed for the following maintenance activities:
- CT 2-1 fan motor control time delay relay replacement;
- CT 2-1 inspection and structural repairs;
- Feedwater regulating valve 12B positioner replacement;
- HPCI flow controller troubleshooting and calibration;
- HPCI flow controller replacement; and,
- Electronic pressure regulator failure troubleshooting and repair.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a.
Inspection Scope (6 samples)
The inspectors observed surveillance testing to determine if the specified acceptance criteria was consistent with TS 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 CAP. The inspectors reviewed the following surveillance testing:
- B residual heat removal (RHR) quarterly pump surveillance;
- B residual heat removal service water (RHRSW) quarterly pump surveillance;
- main steam isolation valve full closure timing and reactor protection system relay actuation functional test;
- main steam line high flow functional test;
- reactor core isolation cooling (RCIC) quarterly pump and valve test; and,
- torus-to-drywell vacuum breakers breakaway and opening force test
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a.
Inspection Scope (1 sample)
On April 3, 2008, the inspectors observed an emergency plan management team response to a simulator-based event during emergency plan training activities. The inspectors discussed the performance expectations and results with the lead controller.
The inspectors focused on the ability of the team to perform event classifications and make proper notifications in accordance with station procedures.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)a.
Inspection Scope (9 samples)
During May 27-30, 2008, the inspector conducted the following activities to evaluate the operability and accuracy of radiation monitoring instrumentation, and the adequacy of the respiratory protection program for issuing self-contained breathing apparatus (SCBA) to emergency response personnel. Implementation of these programs was reviewed against the criteria contained in 10CFR20, applicable industry standards, and the licensees procedures. Additional documents reviewed are listed in the attachments.
1) UFSAR Sections 9.2, Liquid Radwaste System; 9.3, Solid Radwaste System; and 9.4, Gaseous Radwaste System, were reviewed to identify applicable radiation monitors associated with transient high radiation areas in the plant for review.
2) The radiation protection (RP) instrument issue area provided for the selection of portable RP instruments that were available for use for job coverage of radiologically significant areas.
3) Current calibration records and applicable calibration procedures were reviewed for the following plant radiation monitors and portable RP instruments. In addition, the applicable calibrators utilized were reviewed for National Institute of Standards and Technology standard traceability.
Plant Radiation Monitors
- traversing in-core probe room area radiation monitor
- east and west refuel floor area radiation monitors
- spent fuel pool area radiation monitor
- reactor water clean up phase separator area radiation monitor
- reactor building ventilation and refueling area zone monitors
- steam jet air ejector off-gas radiation monitors
Portable RP Instruments
- 3 radiation survey instruments
- 2 extendable probe survey instruments
- 2 continuous air monitors
- 3 air samplers
- 2 personal lapel air samplers
- 10 electronic dosimeters
- 1 neutron radiation survey instrument
Calibrators
- shepherd 89 survey instrument calibrator
- technical operations 682 instrument calibrator
- 2 air sampler flow calibrators
- 1 area radiation monitor calibrator
4) Radiological incidents involving internal exposures identified by condition reports were reviewed for 2008. In addition, dosimetry electronic records were queried for any internal exposures >50 mrem committed effective dose equivalent. None were identified for further review.
5) The inspector reviewed twelve condition reports initiated between November 2007, and May 2008, relative to the radiation protection program and radiation monitoring instrument deficiencies to determine if the deficiencies were appropriately characterized and corrected commensurate with their safety significance. The inspector verified that problems identified by these CRs were properly characterized in the licensees event reporting system, and that applicable causes and corrective actions were identified commensurate with the safety significance of the occurrences.
6) Based on the condition reports reviewed, no repetitive deficiencies were identified for further follow-up.
7) With respect to the RP portable instruments listed in 3) above, the instrument calibration expiration and response check stickers were reviewed. The applicable response check beta-source and instrument sign-out procedures were also reviewed.
8) Emergency plan designated SCBA equipment and qualified users were sampled.
This included inspection of selected SCBAs in the main control room, administration building hallway, alternate brigade room, and turbine building decon booth. Selected SCBA qualification records for on-shift reactor operators were verified for current use qualification.
9) Selected SCBA units in the main control room and in the administration building were examined for periodic air cylinder hydrostatic testing and maintenance records.
Review of approved replacement parts documentation and certification of the repair personnel was performed.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
[OA]
4OA1 Performance Indicator Verification
a.
Inspection Scope (2 samples)
Barrier Integrity Cornerstone
The inspectors sampled Entergy submittals for the performance indicators (PIs) listed below for the period from April 2007 to March 2008. The inspectors reviewed portions of operator rounds surveillances, monthly reactor coolant iodine isotopic reports, and related CRs. The inspectors discussed the methods for compiling the data with the responsible operations and chemistry personnel. The PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline, 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 attachment.
- Reactor Coolant System Activity; and
- Reactor Coolant System Leakage
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 CAP. 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.
b. Findings
No findings of significance were identified.
.2 Semi-Annual Trend Review
a.
Inspection Scope (1 sample)
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 January through June 2008. The inspectors compared their results with the results contained in Entergys quarterly trend reports, operation logs, and CRs. The corrective actions assigned to address select individual issues were reviewed for adequacy.
b.
Assessment and Observations
No findings of significance were identified.
.3 Annual Sample - HPCI/RCIC Flow Oscillations
a.
Inspection Scope (1 Sample)
The inspectors reviewed Entergys corrective actions associated with RCIC and HPCI system flow oscillations during response to a plant trip on July 25, 2005. The inspection focused on the Entergys actions and evaluations performed relative to assuring that HPCI and RCIC could provide injection flow rates consistent with those credited in postulated transient and accident analyses. The NRC previously documented a finding with Entergys evaluation of system operability given the potential for flow oscillation conditions (NCV 05000271/2006007-03). Entergy initiated CR 2006-2524 in response to the finding. This current review focused on Entergys troubleshooting and corrective actions in response to the NCV.
The inspectors reviewed the basis for the revised operability evaluation associated with CR 2006-2524, to assess the depth and technical adequacy, and the associated ACE.
The inspectors reviewed the adequacy of the compensatory actions, including procedure changes to aid the operators in responding to potential oscillating flow conditions (i.e., placing the flow controllers in the manual mode of operation). Licensed operator training lesson plans were reviewed to see if the flow oscillation event had been incorporated into the internal operating experience section. The inspectors reviewed flow rate data from the original event and relevant industry information regarding system operation in the automatic mode below rated flow rates. The inspectors reviewed the results of Entergys RCIC turbine control system oil inspection and the actions taken with regard to contaminants found in the oil system during cleaning and flushing activities performed in April 2007. A list of documents reviewed is included in the attachment.
The inspectors reviewed flow controller settings, inner speed loop control settings, and calibration activities for the RCIC and HPCI systems, to determine if the settings were reasonable, and to identify any significant deviations from the original tuning parameters. The inspectors reviewed RCIC test data from May 2007, to determine if system response indicated stability while injecting to the reactor vessel. In addition, HPCI flow controller performance test data from March 2008, was reviewed to determine if system flow rates became divergent and unstable during flow rate step changes, in the manual and automatic mode of flow control operation, and at high flow rate and low flow rate conditions.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that Entergys evaluation for CR 2006-2524 was adequate, in that it addressed the overall HPCI/RCIC system operability issues. The inspectors also noted that during Entergys review, they self-identified a potential adverse trend with respect to the rigor of performing operability determinations. Entergy initiated CR 2006-2863 to address this as part of their ACE report addressing the original insufficient documentation of the operability basis for the HPCI and RCIC systems.
With respect to the potential for system flow oscillations, the inspectors agreed with Entergys conclusion that both systems remained operable and there was reasonable assurance that the systems would provide the required flow in response to postulated transients and accident conditions. The inspectors noted that the flow oscillations during the 2005 plant trip occurred when the HPCI flow controller was in automatic, with flow below 75 percent of rated. This is consistent with industry operating experience.
The inspectors noted that oscillations have not recurred during surveillance test when the system was at or near design flow. The inspectors determined that operating procedures and the licensed operator training program lesson plans have been appropriately revised.
The inspectors noted that Entergy had not shared the operating experience, internally or externally, about the particulate found in the RCIC oil reservoir in April 2007. In addition, the inspectors noted that Entergy had initiated a preventive maintenance task to clean the reservoir during major overhauls, but the task was not formally tracked. Entergy initiated CR 2008-1100.
.4 Annual Sample - Challenges to Feed and Condensate System
a.
Inspection Scope (1 Sample)
The inspectors reviewed Entergys corrective actions associated with the C reactor feed pump (RFP) trip on August 4, 2007, and the A condensate pump seal failure on August 27, 2007. Both events impacted the operation of the station and potentially challenged safe plant operation. The RFP trip caused an automatic runback and subsequent reduction of reactor power to 80 percent. The condensate pump seal leak prevented operations from performing power ascension.
b. Findings and Observations
No findings of significance were identified. Entergy determined that the RFP trip was the result of the failure of a Hancock Model 5500 valve in the RFP low suction flow instrumentation line. The valve disc separated from the stem because of the failure of a locking ring; the ring holds the disc and stem together. Because of the large number of valves of this type at VY, Entergy developed specific factors to determine the extent of condition and scope of repair of the valves, including the valve orientation; valve position; service use; preventive maintenance history; and applications with unacceptable consequences should the valve fail. Corrective actions included inspecting all the valves which met all the criteria. Inspection of the other RFP flow instrumentation isolation valves has been scheduled for the upcoming outage.
Entergy determined that the apparent causes for the condensate pump seal failure were a greater than normal rate of wear on the carbon seal face and a lack of adequate flushing of the seal by the seal water injection source to remove the seal wear debris.
Entergy identified that there was significant history of condensate pump seal failures; however, there had only been two in the last nine years, and that the seals are changed out on a four and one half year preventive maintenance basis. During steady state plant operations, the seals demonstrate satisfactory performance; however, when the pumps are started, the seal face is subject to potential misalignment caused by debris between the seal faces. Corrective actions included an engineering change to replace the existing condensate pump seal design. The inspector determined that the problem investigation, extent of condition, and corrective actions were appropriate; however, the inspector noted that the engineering change has not been scheduled for implementation.
4OA6 Meetings, including Exit
Exit Meeting Summary
On July 10, 2008, the resident inspectors presented the inspection results to Mr. Theodore Sullivan, 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
- J. Dreyfuss, Director, Nuclear Safety
- D. Mannai, Licensing Manager
- M. Philippon, Operations Manager
- N. Rademacher, Director, Engineering
- T. Sullivan, Site Vice President
- C. Wamser, General Manager, Plant Operations
- S. Wender, Radiation Protection Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000271/2008003-01 NCV Ineffective Reactor Building Crane Maintenance
(Section IR12)
Discussed
- 05000271/2006007-03 NCV Inadequate Corrective Actions for HPCI/RCIC Terry Turbine Controller Flow Oscillations (Section 40A2.3)