IR 05000271/2009006

IR 05000271-09-006 on 04/06/09 - 04/23/09 for Vermont Yankee, Problem Identification and Resolution Inspection Report

ML091540723
Person / Time
Site:	Vermont Yankee
Issue date:	06/03/2009
From:	Racquel Powell Division Reactor Projects I
To:	Michael Colomb Entergy Nuclear Operations
powell r j
References
IR-09-006
Download: ML091540723 (27)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION une 3, 2009

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION -

NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000271/2009006

Dear Mr. Colomb:

On April 23, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed report documents the inspection results, which were discussed on April 23, 2009, with you and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commission=s rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspection team concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Vermont Yankee personnel identified problems at a low threshold and entered them into the Corrective Action Program (CAP). Vermont Yankee screened issues appropriately for operability and reportability, and prioritized issues commensurate with the safety significance of the problems.

Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. Corrective actions addressed the identified causes and were typically implemented in a timely manner. However, the team noted examples of less than adequate evaluation or documentation of evaluations, and examples where corrective actions were not timely and effective.

This report documents one NRC-identified finding of very low safety significance (Green). The finding was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), in accordance with Section VI.A.1 of the NRC=s Enforcement Policy. If you deny this non-cited violation, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at the Vermont Yankee Nuclear Power Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at the Vermont Yankee Nuclear Power Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

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/

Raymond J. Powell, Chief Technical Support & Assessment Branch Division of Reactor Projects Docket No. 50-271 License No. DPR-28 Enclosure: Inspection Report No. 05000271/2009006 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)

SUMMARY OF FINDINGS

IR 05000271/2009006; 04/06/2009 - 04/23/2009; Vermont Yankee Nuclear Power

Station; Biennial Baseline Inspection of the Identification and Resolution of Problems.

One finding was identified in the area of effectiveness of corrective actions.

This team inspection was performed by four NRC regional inspectors. One finding of very low safety significance (Green) was identified during this inspection and was classified as a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 0305, Operating Reactor Assessment Program. 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, AReactor Oversight Process,@ Revision 4, December 2006.

Identification and Resolution of Problems The team concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Vermont Yankee personnel identified problems at a low threshold and entered them into the Corrective Action Program (CAP). The team determined that Vermont Yankee screened issues appropriately for operability and reportability, and prioritized issues commensurate with the safety significance of the problems. Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. The team determined that corrective actions addressed the identified causes and were typically implemented in a timely manner. However, the team noted one example of very low safety significance involving less than adequate corrective actions resulting in an NRC-identified finding. This issue was entered into Entergys CAP during the inspection.

Entergys audits and self-assessments reviewed by the team were thorough and probing. Additionally, the team concluded that Entergy adequately identified, reviewed, and applied relevant industry operating experience (OE) to the Vermont Yankee Nuclear Power Station. Based on interviews, observations of plant activities, and reviews of the CAP and the Employees Concerns Program (ECP), the team did not identify any concerns with site personnel willingness to raise safety issues nor did the team identify conditions that could have had a negative impact on the sites safety conscious work environment.

Cornerstone: Mitigating Systems

Green.

The team identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix

B, Criterion XVI, Corrective Action, for Entergys failure to take adequate corrective actions for a condition adverse to quality involving an issue that had the potential to negatively impact the high pressure coolant injection (HPCI) system. Specifically,

Entergy failed to take timely and appropriate corrective actions commensurate with the safety significance (potential repeat functional failure of the HPCI system due to degraded direct current (DC) contactors) of the issue. Entergys short-term corrective actions included a visual inspection of several affected DC breaker cubicles, a HPCI system operability evaluation, and interim guidance to plant operators. Entergy entered the condition into their CAP (CR 2009-1489) and performed a root cause evaluation.

The finding is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the adverse condition represented a challenge to the reliability of the HPCI system due to the systems vulnerability to a repeat functional failure. The finding was determined to be of very low safety significance (Green) because it: was not a design or qualification deficiency confirmed not to result in loss of operability; did not represent a loss of system safety function; did not represent actual loss of safety function of a single train for greater than its technical specification allowed outage time; did not represent an actual loss of safety function of one or more non-technical specification trains for equipment designated as risk-significant per 10 CFR 50.65 for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program Component, because Entergy failed to take appropriate corrective actions to address a safety issue in a timely manner, commensurate with the safety significance and complexity P.1.d]. Specifically, Entergy did not take appropriate corrective actions to adequately address the extent of condition for a HPCI functional failure in June 2007 due to degraded DC contactors prior to April 2009. (Section 4OA2.1.c)

Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution (PI&R)

.1 Assessment of the Corrective Action Program (CAP) Effectiveness

a. Inspection Scope

The team reviewed Entergys procedures that describe the CAP at the Vermont Yankee Nuclear Power Station. Entergy personnel identified problems by initiating condition reports (CRs) for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, or other significant issues. Condition reports were subsequently screened for operability and reportability, categorized by significance level (A, most significant, through D, least significant), and assigned to personnel for evaluation and resolution or trending.

The team evaluated the process for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the team interviewed plant staff and management to determine their understanding of, and involvement with, the CAP.

The team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process (ROP) to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The team selected items from functional areas that included chemistry, emergency preparedness, engineering, maintenance, operations, physical security, radiation safety, and oversight programs to ensure that Entergy appropriately addressed problems identified in these functional areas. The team selected a risk-informed sample of CRs that had been issued since the last NRC PI&R inspection conducted in November 2007.

Insights from the stations risk analyses were considered to focus the sample selection and plant walkdowns on risk-significant systems and components. The corrective action review was expanded to five years for evaluation of identified concerns within CRs relative to overdue preventive maintenance (PM) activities and Entergys leak management controls, including the identification, evaluation and corrective actions associated with leaks with the potential to adversely impact risk significant structures, systems and components (SSCs).

The team selected items from various processes at Vermont Yankee to verify that they were appropriately considered for entry into the CAP. Specifically, the team reviewed a sample of engineering requests, both open and closed, operator workarounds, operability determinations, system health reports, equipment problem lists, work orders (WOs), and issues entered into the ECP.

Additionally, the team observed portions of the B emergency diesel generator (EDG)monthly surveillance test on April 21 and reviewed resolution of instrument drift issues.

Other plant areas walked down included the: seismic and non-seismic cooling tower cells, control room, torus room, service water (SW) intake, condensate storage tank (CST)enclosure, EDG fuel oil storage tank, and fuel oil transfer pump enclosure.

The team reviewed CRs to assess whether Entergy personnel adequately evaluated and prioritized identified issues. The CRs reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. A sample of CRs that were assigned lower levels of significance which did not include formal cause evaluations were also reviewed by the team to ensure they were appropriately classified. The teams review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The team assessed whether the evaluations identified likely causes for the issues and identified appropriate corrective actions to address the identified causes. As part of this review, the team interviewed various station personnel to fully understand details within the evaluations and the proposed and completed corrective actions. The team observed condition review group (CRG) meetings in which Entergy personnel reviewed new CRs for prioritization and assignment. Further, the team reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected CRs to verify these specific reviews adequately addressed equipment operability, reporting of issues to the NRC, and the extent of problems.

The teams review of CRs also focused on the associated corrective actions in order to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The team reviewed Entergys timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. Lastly, the team reviewed CRs associated with NRC NCVs and findings since the last PI&R inspection, to determine whether Entergy personnel properly evaluated and resolved the issues. Specific documents reviewed during the inspection are listed in the Attachment to this report.

b. Assessment Effectiveness of Problem Identification Based on the selected samples reviewed, plant walkdowns, and interviews of site personnel, the team determined that Entergy personnel identified problems and entered them into the CAP at a low threshold. For the issues reviewed, the team noted that problems or concerns had been appropriately documented in enough detail to understand the issues. The team observed managers and supervisors at CRG meetings appropriately questioning and challenging CRs to ensure clarification of the issues. The team determined that Entergy trended equipment and programmatic issues, and CR descriptions appropriately included reference to repeat occurrences of issues. The team concluded that personnel were identifying trends at low levels. In general, the team did not identify issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. In response to several minor issues identified by the team, Entergy personnel promptly initiated CRs and/or took immediate action to address the issue.

Effectiveness of Prioritization and Evaluation of Issues The team determined that, in general, Entergy personnel appropriately prioritized and evaluated issues commensurate with their safety significance. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The CR screening process considered human performance issues, radiological safety concerns, repetitiveness and adverse trends. The team observed managers and supervisors at CRG meetings appropriately questioning and challenging CRs to ensure appropriate prioritization.

CRs were categorized for evaluation and resolution commensurate with the significance of the issues. Based on the sample of CRs reviewed, the guidance provided by the Entergy implementing procedures appeared sufficient to ensure consistency in categorization of the issues. Operability and reportability determinations were performed when conditions warranted and the evaluations supported the conclusions. Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. During this inspection, the team noted that Entergys root cause analyses were thorough, and corrective and preventive actions addressed the identified causes. Additionally, the identified causes were well supported.

However, there were a few instances of less than adequate evaluation or documentation of evaluations within the CRs reviewed. For example, while Entergy generally identified minor leaks (a packing leak, for example) at a low threshold, promptly initiated CRs, appropriately prioritized the associated corrective actions and maintained an adequate leakage management tracking database, the team noted a weakness in Entergys monitoring of the potential aggregate impact of engineered safety feature (ESF) leakage.

Specifically, Updated Final Safety Analysis Report (UFSAR) Section 14-6 requires Entergy to implement a program to reduce leakage from systems outside of containment that would or could contain radioactive fluids during an accident to as low as practical levels. Entergys leak management program did not compare the cumulative ESF leakage to the analyzed value as described in the UFSAR. In response to the teams questions, engineering used their current Leakage List to conservatively estimate the ESF leakage, approximately one ounce per minute, and determined that it was substantially below the 0.5 GPM UFSAR threshold. Entergy entered this issue into their CAP as CR 2009-1412. Because the actual leakage was far less than the analyzed value, the inspectors determined that the failure to monitor the collective leakage was a performance deficiency of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Effectiveness of Corrective Actions The team concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, corrective actions were identified to prevent recurrence. The team concluded that corrective actions to address NRC NCVs and findings since the last PI&R inspection were timely and effective. There were, however, a few examples where corrective actions were not timely and effective, for example:

• The team noted that there had been numerous inadvertent electric fire pump (P-40-1B) starts from 2007 through 2009. Entergy entered these inadvertent starts into their CAP. Entergys focus after the inadvertent starts was to ensure the pump remained operable, determine the cause of the inadvertent starts, and perform actions to correct the cause. Entergy attempted to resolve the problem through a series of actions which included isolating relief valves, isolating fire hydrants, checking bypass valves for leaks, checking suppression systems for leaks and checking calibrations of pump pressure switches. Despite those efforts, inadvertent starts of the electric fire pump continued to occur. Entergys current planned corrective actions include installing a permanent modification to maintain the appropriate fire protection system water header pressure and replacing the check valve in the electric fire pump discharge piping. The team noted that the electric fire pump is not safety related and at no time was the electric fire pump unavailable or inoperable due to the inadvertent starts. The corrective actions for this issue are being tracked in CR 2009-0040.

• Entergy identified several issues in the Radiation Protection (RP) department associated with the planning, execution, and management oversight of the most recent refueling outage (RFO) 27. These issues included ineffective As Low As Reasonably Achievable (ALARA) planning for some activities related to the reactor reassembly which contributed to increased dose received by workers and a greater than anticipated number of personnel contamination events. The team reviewed the CRs for these issues and planned corrective actions, and found them to be adequate to correct each individual instance. However, the collective significance, potentially including management oversight, was not specifically addressed. Entergys documented corrective actions have focused on preparing the RP department for the next refueling outage. As such, the team questioned the readiness of the RP department for a forced outage, if one occurs before the next refueling outage. Plant management indicated they were aware of this concern and were planning actions in response.

The team independently evaluated the deficiencies noted above for potential significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The team determined that the issues were not findings of more than minor significance.

The team identified one additional example where corrective actions were not effective in addressing an issue. The team determined that Entergy did not implement timely and appropriate corrective actions with respect to ensuring reliability of the HPCI system as described below.

c. Findings

Introduction.

The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for Entergys failure to take adequate corrective actions for a condition adverse to quality involving an issue that had the potential to negatively impact the HPCI system. The performance deficiency associated with this finding was that Entergy did not take timely and appropriate corrective actions to address the extent of condition for a June 2007 HPCI system functional failure.

Description.

On June 8, 2007, the HPCI pump injection isolation valve (V23-19) failed to open on a manual signal during a scheduled HPCI surveillance test (see NRC Inspection Report 05000271/2007004 Section 4OA3.5). Entergy entered the condition into their CAP (CR 2007-2372) and performed a root cause evaluation. Entergy determined that one of the motor operated valve (MOV) contacts (72/C) was non-functional, causing electrical and mechanical interlocks to prevent the open contactor (82/O) from energizing. Entergy identified that the 72/C contacts were pitted and worn, causing the contact surfaces to overheat and weld together. Entergy determined the PM performed on the valve control circuitry was inadequate in that it did not contain sufficient guidance on how to determine contact wear and when the contacts should be replaced. Entergys corrective actions included: completion of an extent of condition review to identify affected contacts in this and other systems, development of a prioritized replacement schedule based on risk significance, development of criteria for replacement during PM activities, and required periodic replacement of similarly heavily loaded MOV contactors.

Entergy identified five HPCI DC valve contactors that needed to be replaced on a priority basis. They replaced two (V23-19 & V23-20) in 2007 using available replacement parts.

The other three valves (V23-14, V23-16, & V23-21) required an engineering change review (ECR) due to the unavailability of a like-for-like replacement. As such, Entergy planned the replacement for a HPCI outage in operating cycle 26 (prior to RFO-27 in November 2008). Entergy extended the replacement due date of the three critical valves to November 2009, as the ECR was not ready for implementation in November 2008.

Based on this extension into the next operating cycle, the team questioned whether Entergy had implemented the DC contactor inspection on the three critical HPCI valves using the revised inspection guidance since June 2007. Based on the teams questions, Entergy performed a prompt and thorough assessment of their corrective actions associated with the previous HPCI functional failure. Entergy determined:

(1) the corrective actions for contactor replacement were not timely and they had not inspected the critical valves since June 2007 (CR 2009-1459);

(2) the associated six year PM for the HPCI steam supply valve (V23-14) exceeded its grace period in November 2008 (CR 2009-1449);

(3) although the procedure for Motor Control Center Inspections had been revised, the corrective action to provide criteria for determining contact wear and replacement was not adequately incorporated into the procedure and the associated CR corrective action was inappropriately closed without ensuring that the procedure was adequately revised (CR 2009-1476); and

(4) they had missed several opportunities within their CAP to identify these issues sooner. In addition to the above CRs, Entergy initiated CR 2009-1489 to perform an apparent cause evaluation to assess weaknesses with the overall implementation of corrective actions associated with the DC contactor issue.

In April 2009, Entergys short-term corrective actions included: a visual inspection of the three critical DC breaker cubicles (V23-14, V23-16, & V23-21); an operability evaluation for the HPCI system; and interim guidance to plant operators (Night Orders) concerning DC contactor inspections following HPCI valve operations. The team independently inspected two DC breaker cubicles (V23-16 & V23-21) with Entergy technicians support on April 23, reviewed the visual inspection work order for the V23-14 valve (WO 191719),discussed DC breaker cubicle observations with Entergy electrical technicians, and reviewed Entergys associated operability evaluations. The team concluded that Entergys short-term actions and evaluations were reasonable and appropriate.

Analysis.

The performance deficiency associated with this finding was that Entergy did not take timely and appropriate corrective actions to address the extent of condition for a June 2007, HPCI system functional failure. The issue was reasonably within Entergys ability to foresee and correct prior to April 2009. The finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, the longstanding adverse condition represented a challenge to the reliability of the HPCI system due to the systems vulnerability to a repeat functional failure. The team reviewed this finding using the Phase 1 SDP Table 4a worksheet for Mitigating Systems and determined that the finding was of very low safety significance (Green),because it: was not a design or qualification deficiency confirmed not to result in loss of operability; did not represent a loss of system safety function; did not represent actual loss of safety function of a single train for greater than its technical specification allowed outage time; did not represent an actual loss of safety function of one or more non-technical specification trains for equipment designated as risk-significant per 10 CFR 50.65 for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program Component, because Entergy failed to take appropriate corrective actions to address a safety issue in a timely manner, commensurate with its safety significance and complexity P.1.d]. Specifically, Entergy did not take appropriate corrective actions to adequately address the extent of condition of a June 2007 HPCI functional failure due to degraded DC contactors prior to April 2009.

Enforcement.

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from June 8, 2007, to April 23, 2009, Entergy failed to take adequate corrective action for a condition adverse to quality involving a HPCI system functional failure. Since this finding was determined to be of very low safety significance (Green) and has been entered into Entergys CAP (CR 2009-1489) it is being treated as a non-cited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000271/2009006-01, Failure to Take Adequate Corrective Actions for a HPCI System Functional Failure)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team selected a sample of CRs associated with the review of industry OE to determine whether Entergy personnel appropriately evaluated the OE information for applicability to Vermont Yankee and had taken appropriate actions, when warranted. The team reviewed CR evaluations of OE documents associated with a sample of NRC generic letters and information notices to ensure that Entergy adequately considered the underlying problems associated with the issues for resolution via their CAP. The team also observed plant activities to determine if industry OE was considered during the performance of routine activities. A list of the documents reviewed is included in the to this report.

b. Assessment The team determined that Entergy appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The team determined that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations.

The team observed that industry OE was routinely discussed and considered during the performance of plant activities. For example, OE was routinely discussed at CRG meetings.

c. Findings

No findings of significance were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of Quality Assurance (QA) audits, including a review of several of the findings from the most recent audit of the CAP, and a variety of self-assessments focused on various plant programs. These reviews were performed to determine if problems identified through these assessments were entered into the CAP, when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection. A list of documents reviewed is included in the to this report.

b. Assessment The team concluded that QA audits and self-assessments were critical, thorough, and effective in identifying issues. The team observed that these audits and self-assessments were completed by personnel knowledgeable in the subject areas and were completed to a sufficient depth to identify issues that were then entered into the CAP for evaluation.

Corrective actions associated with the issues were implemented commensurate with their safety significance. Entergy managers evaluated the results and initiated appropriate actions to focus on areas identified for improvement.

c. Findings

No findings of significance were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the team assessed the safety conscious work environment (SCWE) at Vermont Yankee. Specifically, the team interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The team also interviewed the station ECP coordinator to determine what actions were implemented to ensure employees were aware of the program and its availability with regard to raising concerns. The team reviewed the ECP files to ensure that issues were entered into the CAP when appropriate.

b. Assessment During interviews, plant staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The team noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and ECP. Based on these limited interviews, the team concluded that there was no evidence of an unacceptable SCWE and no significant challenges to the free flow of information.

c. Findings

No findings of significance were identified.

.5 Assessment of Cooling Tower Work

a. Inspection Scope

The team assessed and observed work in progress on the safety related and non-safety related cooling towers. A number of repair and replacement activities were being completed in preparation of the cooling towers for service before the summer season.

The team inspected the cooling towers to ensure beams were identified for replacement as necessary, and ensured that the replacements were completed as planned.

Additionally, the team observed upgrades being completed on the cooling towers.

b. Assessment The team concluded that Entergy had properly prioritized work on the cooling towers. In addition, the inspectors determined that the repair activities in progress on the non-safety related cooling tower cells did not adversely impact the operability of the safety related alternate cooling system (ACS).

c. Findings

No findings of significance were identified.

.6 Assessment of Procedure Improvement Plan

The team reviewed Entergys plans to upgrade station procedures and interviewed the contractor responsible for the systematic improvement plan. The team concluded that it was still too early in the process to form an overall assessment of the procedure upgrade action plan. There was only one upgraded procedure in use at Vermont Yankee at the time of this inspection and that one was intended for use by the departmental procedure writers and not the general staff.

4OA6 Meetings, Including Exit

On April 23, 2009, the team presented the inspection results to Mr. Michael Colomb, Site Vice President, and to other members of the Vermont Yankee staff. The team verified that no proprietary information was documented in the report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

M Colomb Site Vice President

M. Anderson Fire Protection Engineer

H. Breite SW System Engineer & System Engineering Department Performance

Improvement Coordinator

J. Calchera Maintenance Support Superintendent

P. Corbett Quality Assurance Manager

J. Cox Radiation Protection Manager

J. Dreyfuss Director, Nuclear Safety

M. Empey Alternate Cooling System Engineer

M. Flynn Design Engineer

J. Garozzo Design Engineer

J. Geyster Supervisor RP Support

M. Gosekamp Maintenance Manager

D. Grimes Civil Design Engineer

J. Hardy Superintendent, Chemistry

D. Jefferies Electrical Supervisor, Systems Engineering

S. Jonasch RHRSW System Engineer

M. Jurkowski Preventive Maintenance Coordinator

N. Lisai High Voltage System Engineer

G. Lozier Corrective Action and Assessment Manager

D. Mannai Licensing Manager

M. McKenney Emergency Preparedness Manager

R. Meister Senior Specialist Licensing

J. Mully Emergency Diesel Generator System Engineer

B. Naeck HPCI System Engineer

K, ONeil Planning Supervisor

K. Oliver Shift Operations Manager

J. Patrick Security Operation Superintendent

W. Penniman Senior Specialist Corrective Action and Assessment

W. Pittman Assistant Operations Manager Support

R. Ramsdell Quality Assurance Lead Auditor

C. Rose Employee Concerns Program Manager

T. Silko, Site Maintenance Coordinator

K. Swanger Senior Project Manager, Dry Fuel Storage

D. Tkatch Mechanical Maintenance Superintendent

G. Wallace 125 VDC System Engineer

C. Wamser General Manager, Plant Operations

R. Wanczyk Director, Enexus Site Representative

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000271/2009006-01 NCV Failure to take adequate corrective actions for a HPCI system functional failure. (Section 4OA2.1.c)