IR 05000271/2011003

IR 05000271-11-003; 4/1/2011-6/30/2011; Vermont Yankee Nuclear Power Station; Integrated Inspection Report

ML112030850
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	07/22/2011
From:	Diane Jackson NRC/RGN-I/DRP/PB5
To:	Michael Colomb Entergy Nuclear Operations
References
IR-11-003
Download: ML112030850 (37)

Text

July 8, 2011

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED TNSPECTTON REPORT 0500027 1 1201 1 003

Dear M

SUMMARY OF FINDINGS

lR 0500027112011003; 41112011 - 61301201 1; Vermont Yankee Nuclear Power Station;

Integrated Inspection Report.

This report covered a three-month period of inspection by resident inspectors and regional-based inspectors. Based on the results of this inspection, no findings were identified.

REPORT DETAILS

Summarv of Plant Status Vermont Yankee (W) Nuclear Power Station began the inspection period operating at 100 percent power. On April 26,W performed an unplanned power reduction to approximately 78 percent at the request of the Independent System Operator of New England (lSO-NE), the bulk electric power system Regional Transmission Organization (RTO) for New England, to preserve electric grid stability following a grid perturbation unrelated to W. W increased power to 100 percent later the same day. On May 9, W performed a planned power reduction to approximately 55 percent for a control rod sequence exchange, control rod scram time testing, and main turbine valve testing. W returned to 100 percent on May 10. On June 10, VY performed a planned power reduction to approximately 83 percent for a control rod sequence exchange. W returned to 100 percent on June 1 1 and remained at or near 100 percent power for the remainder of the inspection period.

1. REACTORSAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

.1 Seasonal Readiness

a.

lnspection ScoPe (1 samPle)

The inspectors reviewed Entergy's procedures for seasonal preparations to evaluate the process for implementation of warm weather preparedness. The inspectors reviewed adverse weather information contained in the External Events Design Basis Document and compared it to the actions specified in operating procedure (OP) 2196, "Seasonal preparedness." The inspectors interviewed operators and performed a walk down of the cooiing towers with auxiliary operators and engineers. The inspectors also examined equipment specified in the OP, including service water components and control room chillers to determine if equipment readiness was maintained or adjusted to meet the onset of warm weather conditions. The inspectors reviewed a sample of seasonal preparedness-related conditions in Entergy's corrective action program to determine if they were appropriately identified and corrected. Additional documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

.2 Summer Readiness of Offsite and Alternate AC Power Svstems

a. Inspection Scope

(1 samPle)

The inspectors performed a review of Entergy's offsite and alternate AC (AAC) power system readiness for adverse weather. The inspectors reviewed Entergy's plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate. The inspection focused on Entergy's 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 reviewed Entergy's 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, and required communications between Entergy and the TSO. The inspectors also reviewed maintenance records and corrective actions to verify readiness of the offsite and alternate AC power systems for the summer period. The inspectors interviewed operators, as well as engineering and licensing personnel to verify Entergy staff understood the requirements and conditions for the offsite and alternate AC systems to provide their as designed capabilities as appropriate. Finally, the inspectors conducted a tour of the Vernon Hydroelectric Station to assess the capability to start the facility during a regional blackout to provide emergency AAC power to Vermont Yankee. A list of documents reviewed is provided in the Attachment.

b.

Findinqs No findings were identified.

1R04 Equipment Aliqnment

.1 Partial Equipment Aliqnment

a. Inspection ScoPe (2 samPles)

The inspectors performed a partial system walkdown of the systems listed below to verify correct system alignment, and to identify any discrepancies that could impact system operability. Observed plant conditions were compared to the alignment of equipment specified in applicable piping and instrumentation drawings (P&lDs) and operating procedures. 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. The documents reviewed are listed in the Attachment.

.

Fire Water System with Alternate Cooling Unavailable; and r Residual Heat Removal (RHR) System with High Pressure Coolant Injection (HPCI)

System Unavailable.

b. Findinqs No findings were identified.

.2 Complete Equipment Aliqnment

a. Inspection Scope

(1 samPle)

The inspectors performed a complete equipment alignment inspection of the accessible portions of the 12S-volt direct current system. The inspectors compared the actual system configuration to the operating procedures. Through a system walkdown, the inspectors evaluated whether system circuit breakers were in the proper alignment; batteries were properly maintained and meeting design specifications; and battery chargers were supplying adequate electrical load on the system. The inspectors also asseised housekeeping and verified proper component labeling. In addition, the inspectors reviewed deficiencies previously identified in the CAP to determine if they had been properly addressed, and discussed open items with the responsible system engineers, maintenance personnel, and plant operators to verify that Entergy was appropriately considering any adverse impacts to system operability. Documents reviewed are listed in the Attachment.

b.

Findinqs No findings were identified.

1R05 Fire Protection

Quarterlv Inspection (7 1 1 1 1

.05 O)

a. lnspection Scope (5 samPles)

The inspectors performed inspections of five fire areas based on a review of the W Safe Shutdown Capability Analysis and the Fire Hazards

Analysis.

The inspectors reviewed Entergy's fire protection program to determine the specified fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. During walkdowns of the fire areas, the inspectors verified that combustibles and ignition sourc-es were adequately controlled and passive fire barriers, manualfire-fighting equipment, and automatic detection and suppression equipment were appropriately maintained. The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3.F. The documents reviewed are listed in the

. The following fire areas were inspected:

o Intake Structure, FZ-14, FZ-15;

. Reactor Building 280', RB-s, RB-6;

.

East and West Switchgear Rooms, FA-4, FA-S;

. Plant Computer Room, ADMIN; and

. Turbine Building 232', FZ-7.

b. Findinqs No findings were identified.

==1R06 Flood Protection Measures (71 1 1 1.06) lnternal Floodinq a.

Insoection Scope (1 sample - internal)==

The inspectors reviewed Entergy's flood protection design and barriers for coping with internal flooding of the Reactor Building Northeast and Southeast Emergency Core Cooling System (ECCS) Corner Rooms. The inspectors reviewed internalflooding information contained in Vermont Yankee's Individual Plant Examination for External Events (IPEEE) and the internalflooding design basis document. The inspectors performed a walkdown of the area to ensure equipment and structures needed to mitigate an internal flooding event were as described in the IPEEE and the design basis document. Additionally, the inspectors reviewed CRs related to internalflooding to ensure identified problems were properly addressed for resolution. Documents reviewed are listed in the Attachment. These activities constituted one internal flood protection measures inspection samPle.

b. Findinqs No findings were identified.

1R07 Heat Sink Performance

Annual SamPle Review (71111.074)

a. Inspection Scope

(1 samPle)

On May 4,2011, room cooler RRU-8 for the "B" train of ECCS was tested for thermal and hybraulic performance. The inspectors reviewed the test results and discussed the surveillance results with the system engineer to determine if they met the acceptance criteria. The inspectors also reviewed past performance of RRU-8 and issues documented in Entergy's corrective action program to determine if corrective actions were appropriate. A list of documents reviewed is listed in the Attachment. These activities constituted one heat sink sample.

b. Findinqs No findings were identified.

1R1 1 Licensed Operator Requalification Proqram (71111.11)

Quarterlv Inspection (71111.1 1O)

a. Inspection Scope

(1 samPle)

'

The inspectors observed control room crew performance during licensed operator requalification exams on June 2,2011, and June 9, 2011. The inspectors assessed the performance of risk significant operator actions, including the use of emergency operating procedures. 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. The inspectors also compared the simulator configuration with the actual control room configuration. Finally, the inspectors verified that evaluators were identifying and documenting crew performance problems. The documents reviewed are listed in the Attachment.

b. Findinos No findings were identified.

1R12 Maintenance Effectiveness

Quarterlv Inspection (7 11 11

.1 20)

Inspection Scope (2 samPles)

The inspectors conducted an in-office review of the systems listed below for items such as:

(1) appropriate work practices;

(2) identifying and addressing common cause failures;

(3) scoping in accordance with 10 CFR 50.65 paragraph

(b) of the Maintenance Rule;

(4) characterizing reliability issues for performance;

(5) trending key parameters for condition monitoring;

(6) balancing reliability and unavailability (performance); (7)accounting for system or component unavailability;

(8) classification and reclassification in accordance with 1O CFR 50.65 paragraph (aX1 ) or (aX2); and

(9) appropriateness of performance criteria for structures, systems, and components (SSCs) and functions classified as paragraph (a)(2). The inspectors discussed observations with the system engineer and maintenance representatives. The documents reviewed are listed in the

. The following systems were inspected:

e Reactor Core lsolation Cooling (RCIC); and

. High Pressure Coolant Injection (HPCI).

Findinos No findings were identified.

b.

I

1R13 Maintenance Risk Assessments and Emerqent Work Control

a. lnspection Scope (3 samPles)

The inspectors evaluated three maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work. The inspectors reviewed maintenance risk evaluations, maintenance plans, work schedules, and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk. The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 50.65 paragraph (aX4) and implemented in accordance with Entergy's administrative procedures (AP) 0125, "Plant Equipment," and AP 0172,"Work Schedule Risk Management - Online." The inspectors conducted plant walkdowns to verify that appropriate risk management actions had been taken. The documents reviewed are listed in the Attachment. The following maintenance activities were inspected:

r WW1118 - CT-2-1 Unavailable during Maintenance;

. WW1 121 - HPCI Maintenance and "B" Recirc MG Set Scoop Tube Locked; and

. WW1 123 - Service Water Pressure Instrument Preventive Maintenance.

b. Findinos No findings were identified.

1R15 Operabilitv Evaluations

a. Inspection Scope

(5 samples)

The inspectors reviewed five operability evaluations associated with degraded or non-conforming conditions to assess the acceptability of the evaluations, the use and control of applicable compensatory measures, and compliance with Technical Specifications.

The inspectors reviewed and compared the technical adequacy of the evaluations with the Technical Specifications, UFSAR, associated design basis documents, and Entergy's procedure EN-OP-104, "Operability Determinations." The inspectors reviewed evaluations of the following degraded or non-conforming conditions:

. CR-WY-2011-01393 and 2011-05123 - "8" EDG Lube Oil Sump Level above the High Level Mark; o CR-WY-2011-01713 - Testing Failure of Cooling Tower 2-1 Fan Motor Cable; o CR-WY-2010-04183 - GNF2 Fuel Manufacturing Defects;

. CR-WY-2011-02013 and 2010-4052-RCIC Steam Trap ST-13-6 Failing Open; and

. CR-WY-2011-02166 and 2008-02783 - CT 2-1 Pipe Riser Wall Thickness.

b.

Findinqs No findings were identified.

1R18 Plant Modifications

a.

Inspection ScoPe (1 samPle)

The inspectors reviewed engineering change (EC) 29839, "'B' Recirculation Motor Generaior Scoop Tube Clamp to Allow Positioner Repair," to ensure that it did not adversely affect the availability, reliability, or functional capability of any risk-significant SSCs. The inspectors reviewed the engineering change packages and observed the systems in operation following the implementation of the modifications. The documents reviewed are listed in the Attachment.

b.

Findinqs No findings were identified.

1 R19 Post-Maintenance Testins (71111

.1 g)

a. Inspection Scope

(6 samPles)

The inspectors reviewed six post-maintenance test (PMT) activities on risk-significant systems. The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents. When testing was direcly observed, the inspectors determined whether installed test equipment was appropriate and controlled, and whether the test was performed in accordance with 10 CFR Part 50, Appendix B, Criterion Xl, "Test Control," and applicable station procedures. Upon completion, the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function, and evaluated whether conditions adverse to quality were entered into the CAP for resolution. The documents reviewed are listed in the Attachment. The inspectors reviewed the PMTs performed for the following maintenance activities:

o Cooling Tower 2-1 Fan Motor Cable Testing Following Maintenance to Replace Spliced Connections;

.

RCIC Electric Governor Magnetic Replacement;

.

Recirculation Pump "8" Motor-Generator Set Speed Control Maintenance;

.

HPCI Auxiliary Oil Pump Replacement;

.

HPCI Valve Limitorque Motor Preventive Maintenance; and

.

Standby Gas Treatment Fan Preventive Maintenance' b.

Findinqs No findings were identified.

==1R22 Surveillance Testinq (7 1111.22) a.

==

Inspection Scope (6 samples: 2 Routine, 3 IST and 1 RCS Leakage)

The inspectors inspected five surveillance tests and reviewed test data of selected risk-significant structures, systems and components (SSCs) to determine whether the testing adLquately demonstrated equipment operational readiness and the ability to perform the intended safety functions. The inspectors reviewed selected prerequisites and precautions to determine if they were met; evaluated whether the tests were performed in accordance with the written procedure; determined whether the test data was complete and met procedural requirements; and assessed whether SSCs were properly returned to service following testing. The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution. The documents reviewed are listed in the Attachment. The inspectors reviewed the following surveillance tests:

. Cooling Tower 2-1 Fan Motor Cable Testing;

. Reactor Coolant System Leak Detection (RCS Leakage);

. Main Steam Line lsolation Valve Closure Logic FunctionalTest;

. Main Steam lsolation Valve (MSIV) Stroke Time Testing (lST);o Standby Liquid Control Pumps (lST); and o 'B' Emergency Diesel Generator monthly testing (lST).

b. Findinqs No findings were identified.

RADIATION SAFETY

Gornerstones : Occupational Radiation Safety, Public Radiation Safety

2RS4 Occupational Dose Assessment

a.

Inspection ScoPe (1 samPle)

Inspection Planninq The inspector reviewed the results of radiation protection program audits related to internal and external dosimetry (i.e., Entergy's quality assurance (QA) audit). The inspector reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) report on the vendor's most recent results to determine the status of the vendor's external dosimetry program. Entergy's procedures associated with dosimetry operations and dose evaluations were reviewed. The inspector verified that Entergy had established procedural requirements for determining when external and internal dosimetry is required.

External Dosimetrv - NVLAP Accreditation The inspector verified that Entergy's personnel dosimeters that require processing were NVLAP accredited. This review included the approved irradiation test categories for the type of personnel dosimeter used (optically stimulated luminescent (OSL)) that were consistent with the types and energies of the radiation present, and use of the dosimeters (e.g., to measure deep dose equivalent (DDE), shallow dose equivalent (SDE), and lens dose equivalent (LDE)).

Passive Dosimeters (OSL)

The onsite storage of personnel dosimeters was evaluated by the inspector. The evaluation assessed whether the appropriate background exposure monitoring of dosimeters was performed in order to account for background dose measured when not in use.

Active Dosimeters (Electronic Dosimeters)

The inspector reviewed Entergy's use of a "correction factor" to address the response of the electronic dosimeter (ED).as compared to OSL for situations when the ED must be used to assign dose.

Internal Dosimetrv - Routine Bioassav (in vivo)

The inspector reviewed Entergy's use of passive monitoring for screening intakes. The inspector assessed Entergy's ability to adequately detect internally deposited radionuclides with portal monitors. Positive whole body count records for 2010 were reviewed and verified one internal dose assessment that was greater than 10 mrem (actual value 18 mrem).

Special Bioassav (in vitro)

During 201Q, there were no internal dose assessments requiring in vitro monitoring for inspe-tion review. The inspector reviewed and assessed the adequacy of Entergy's program for dose assessments based on airborne/derived air concentration (DAC)monitoring. This review verified that flow rates and/or collection times for fixed head air samplersbr lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs) are obtained. The inspector reviewed the adequacy of procedural guidance used to assess dose when Entergy applies protection factors.

There were no dose assessments that used airborne/DAC monitoring for 2010 to review.

Special Dosimetric Situations - Declared Preqnant Workers The inspector verified that Entergy informs workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy' There were three individuals who declared their pregnancy during the current assessment period. The inspector reviewed their exposure monitoring records and Entergy's program for limiting exposure for the declared pregnant worker for compliance with the requirements of 10 CFR Part2O.

Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures The inspector reviewed the adequacy of Entergy's methods for monitoring external dose in situations in which non-uniform fields are expected or large dose gradients will exist (e.g., control rod drive removal and diving activities). The inspector also reviewed criteria for determining dosimetry placement and the need for multi-badging.

Shallow Dose Equivalent

During 2010, there were no shallow dose equivalent dose assessments for inspection review.

Neutron Dose Assessment

The inspector reviewed Entergy's neutron dosimetry program, including dosimeter type and neutron survey instrumentation.

Problem ldentification and Resolution The inspector verified that problems associated with occupational dose assessment are being identified by Entergy at an appropriate threshold and are properly addressed for resolution in Entergy's corrective action program.

b.

Findinqs No findings were identified.

2RS7 a.

lnspection Scope (1 samPle)

The inspector reviewed the annual radiological environmental operating reports, and the results of Entergy's assessments since the last inspection, to verify that the REMP was implemented in accordance with the plant technical specifications (TS) and the off-site dose calculation manual (ODCM). The inspector reviewed the report for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, interlaboratory comparison program, and analysis of data-The inspector reviewed the ODCM to identify locations of environmental monitoring stations. The inspector reviewed the updated final safety analysis report (UFSAR) for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

The inspector reviewed the annual effluent release report and the 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine if Entergy was sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.

Site Inspection The inspector walked down air sampling stations and thermoluminescent dosimeter (TLD) monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition.

For the air samplers and TLDs selected above, the inspector reviewed the calibration and maintenance records to verify that they demonstrate adequate operability of these components. Additionally, the inspector reviewed the calibration and maintenance records of composite water samplers as available.

The inspector verified that Entergy had initiated sampling of other appropriate media upon loss of a required sampling station. The inspector observed the collection and preparation of environmental samples from different environmental media (i.e., surface water, ground water, vegetation, fish, and air). The inspector verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with procedures.

Based on direct observation and review of records, the inspector verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Regulatory Guide 1.23, "Meteorological Moniioring Programs for Nuclear Power Plants," and site procedures. The inspector verified that the meteorological data readout and recording instruments in the control room and at the tower were operable.

The inspector reviewed the annual environmental monitoring report to verify that environmental samples were identified and reported. The inspector reviewed Entergy's assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection (LLDs)). The inspector reviewed the associated radioactive effluent release data that was the source of the released material.

The inspector selected structures, systems, or components (SSCs) that involved or could reasonably involve licensed material for which there is a credible mechanism for licensed materialto reach ground water, and verified that Entergy had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to ground water.

The inspector verified that records, as required by 10 CFR 50.75(9), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.

The inspector reviewed any significant changes made by Entergy to the ODCM as the result of changes to the land census, long-term meteorological conditions, or modifications to the sampler stations since the last inspection. The inspector reviewed technicaljustifications for any changed sampling locations. The inspector verified that Entergy performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.

The inspector verified that the appropriate detection sensitivities with respect to TS/ODCM were used for counting samples (i.e., the samples meet the TS/ODCM required LLDs). The inspector reviewed quality control data for maintaining oversight of offsite laboratory radiation measurement instrument performance.

The inspector reviewed the results of Entergy's inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed by Entergy. The inspector verified that the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility.

ldentification and Resolution of Problems The inspector verified that problems associated with the REMP were identified by Entergy at an appropriate threshold and were properly addressed for resolution in the corrective action program. The inspector verified the appropriateness of the corrective actions for a selected sample of problems documented by Entergy that involved the REMP.

b.

Findinos No findings were identified.

OTHER ACTIVITIES

[OA]

4OA1 Performance Indicator (Pl) Verification (71 151)

a. Inspection Scope

(2 samPles)

Barrier Inteqritv Svstems Cornerstone The inspectors reviewed Entergy's submittals and performance indicator (Pl) data for the cornerstones listed below for the period from January 2010 to March 2011. The inspectors reviewed selected opelrator logs, plant process computer data, licensee event reports, and CRs. The Pl definitions and guidance contained in Nuclear Energy Institute lNf t; OO-OZ, "Regulatory Assessment Performance Indicator Guideline," Rev. 6 and AP 0094, "NRC Performance Indicator Reporting," Rev. 15, were used to verify the accuracy and completeness of the Pl data reported during this period. The Pls reviewed were:

b.

o Reactor coolant system activity (B101); and o Reactor coolant system total leakage (8102).

Findinos No findings were identified.

ldentification and Resolution of Problems (71152)

Reviews of ltems Entered into the Corrective Action Proqram Inspection Scope The inspectors performed a daily screening of each item entered into Entergy's corrective action program. This review was accomplished by reviewing printouts of each CR, attending daily screening meetings, and/or accessing Entergy's 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.

Findinqs No findings or observations were identified.

Semi-Annual Trend Review

Inspection Scope (1 sample)

The inspectors performed a semi-annual review of site issues, to identify trends that might indicate the existence of more significant safety issues, as required by Inspection Procedure 71152, "ldentification and Resolution of Problems." The inspectors reviewed trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance and corrective action program backlogs, looking for repetitive or closely-related issues that had not been documented in the corrective action program. The inspectors also reviewed the Vermont Yankee corrective action program database for the first and second quarters of 2Q11, to assess condition reports (CRs) written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). Operability determinations were also sampled for the first and second quarters of 2011. This sampling focused on ensuring that the aggregate effects of degraded associated structures, systems, or components were included in operability determinations. Documents reviewed are listed in the Attachment.

Findinqs and Observations No findings were identified.

4c.A2

.1 a.

b.

a.

.3 Additional scope was added to this quarterly trend review to verify that the licensee was

ensuring that all aggregate issues were included in operability determinations for the plant conditions that existed. ln the review only one operability determination had to be revised and was immediately addressed by the Shift Manager. EN-OP-104, "Operability Determination Process," ReV. 5, was reviewed to ensure adequate guidance was provided to ensure completeness in evaluation of aggregate issues.

Annual Sample: Spurious Starts of the Electric Motor Driven Fire Pump

Inspection Scope (1 sample)

The inspectors reviewed Entergy's actions to evaluate and correct the cause of numerous spurious starts of the electric motor driven fire pump resulting from low header pressure in the fire protection system. The inspectors reviewed the design features associated with maintaining the fire protection system pressurized while in a standby condition. This review included the system makeup piping from the normally operating service water system to the normally standby fire protection system and the header low pressure auto start features of the fire protection pumps.

The inspectors also reviewed condition reports to assess actions taken to address the issue including the adequacy of troubleshooting efforts and the results of an apparent cause evaluation. Additional documents reviewed included the Updated Final Safety Analysis Report (UFSAR), piping and instrumentation drawings (P&lDs), pressure recorder traces, plant maintenance and modification documents and equipment vendor manuals.

The inspectors interviewed design and system engineers to gain additional insights on the issue and performed a walkdown of the affected portions of the fire protection and service water systems to assess the current operating conditions of the equipment.

Documents reviewed are listed in the Attachment.

Findinqs and Observations No findings were identified.

The inspectors found that Entergy performed troubleshooting in an effort to determine the cause of the spurious pump starts in early 2009 in response to condition report (CR)

CR-WY-2009-00040. Based on the results of the troubleshooting, actions were initiated to ensure adequate makeup water was being supplied to the fire protection system and to reduce identified leakage from the system. Specifically, work was initiated to perform a plant modification to install a backup fill line between the service water and fire protection systems and to replace the electric fire pump discharge check valve that was identified to have significant leakage. The backup fill line was installed and put in service in January 2010 while efforts to procure and perform engineering analyses to support the valve replacement continued.

b.

40A5 1B The inspectors also reviewed CR-WY-2O10-00637 that was initiated in February 2010, and documented that spurious pump starts continued following implementation of the modification. Entergy performed an apparent cause evaluation (ACE) to evaluate the issues in this CR. The ACE reaffirmed that the leaking check valve was a contributing cause of the spurious starts and reviewed factors that affected the timeliness of the check valve replacement. The check valve replacement was subsequently completed in January 2011.

The inspectors determined that the evaluations of the cause of the spurious pump starts were thorough and corrective actions have been implemented to address identified potential causes. The inspectors also noted that actions to date have not completely eliminated the spurious pump starts. Following the check valve replacement in January 2011 several spurious starts have occurred. However, a review of plant records indicates the number or spurious starts since the check valve replacement appears to have decreased and there have been periods of time of greater than 30 days without an unexpected start of the pump. The inspectors found that the plant staff is continuing to document unexpected starts in the corrective action program and plant engineering personnel are closely monitoring the system performance. A preventive maintenance task is also being prepared to perform periodic flushes of the backup fill line piping to improve the effectiveness of the line in maintaining fire protection system pressure. (The originalfill line installation did not have provisions that would allow for periodic flushing.)

The inspectors also reviewed the pump performance trend and results of the pump motor controller preventive maintenance to assess if the spurious starts have had an adverse impact on the fire protection system availability and reliability. No adverse impact was identified during this review. However, a more extended period of system operation with the backup fill line modification and new check valve in place appears to be necessary to allow for an accurate assessment of the effectiveness of these corrective actions.

Other Activities Severe Accident Manaoement Guidelines (SAMGS)"

On May 23,2011, the inspectors completed a review of Vermont Yankee's severe accident management guidelines (SAMGs), implemented as a voluntary industry initiative in the 1990's, to determine (1 ) whether the SAMGs were available and updated,

(2) whether Entergy had procedures and processes in place to control and update its IAMGs,

(3) the nature and extent of Entergy's training of personnel on the use of SAMGs, and

(4) Entergy personnel's familiarity with SAMG implementation.

The results of this review were provided to the NRC task force chartered by the Executive Director for Operations to conduct a near-term evaluation of the need for agency actions following the Fukushima Daiichi fuel damage event in Japan. Plant-specific results for Vermont Yankee were provided in an Attachment to a memorandum

.1.2

to the Chief, Reactor Inspection Branch, Division of Inspection and Regional Support, dated May 27,2011 (ML111470361).

(Closed) NRC Temporarv Instruction 2515/183. "Followup to the Fukushima Daiichi Nuclear Station Fuel Damaoe Event" The inspectors assessed the activities and actions taken by the licensee to assess its readiness to respond to an event similar to the Fukushima Daiichi nuclear plant fuel damage event. This included

(1) an assessment of the licensee's capability to mitigate conditions that may result from beyond design basis events, with a particular emphasis on strategies related to the spent fuel pool, as required by NRC Security Order Section 8.5.b issued February 25,2002, as committed to in severe accident management guidelines, and as required by 10 CFR 50.54(hh); (2)an assessment of the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63 and station design bases;

(3) an assessment of the licensee's capability to mitigate internal and externalflooding events, as required by station design bases; and

(4) an assessment of the thoroughness of the walkdowns and inspections of important equipment needed to mitigate fire and flood events, which were performed by the licensee to identify any potential loss of function of this equipment during seismic events possible for the site.

lnspection Report 0500027112011009 (M111 1310742) documented detailed results of this inspection activity.

Meetinqs. includinq Exit Exit Meetino Summarv On July 8,2011, the resident inspectors presented the second quarter inspection results to Michael Colomb, Site Vice President, and other members of the Vermont Yankee staff. The inspectors confirmed that any proprietary information provided or examined during the inspection had been returned to the licensee.

On May 26,2011, the inspector presented the health physics-related inspection results to Mr. R. Wanczyk and other members of Entergy staff. No proprietary information is contained in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Vermont Yankee Personnel

M. Colomb, Site Vice President

C. Wamser, General Manager of Plant Operations

M. Romeo, Director of Nuclear Safety Assurance

N. Rademacher, Director of Engineering

R. Wanczyk, Licensing Manager

M. Gosekamp, Operations Manager

J. Rogers, Design Engineering Manager

S. Naeck, Outage Manager

D. Tkatch, Manager, Radiation Protection

K. Stupak, Manager, Training

G. Wierzbowski, Manager, Engineering Programs and Components

D. Jones, Assistant Operations Manager

B. Pittman, Assistant Operations Manager

D. Girrior, Planning, Scheduling and Outage Manager

M. Tessier, Manager, Maintenance

J. Hardy, Manager, Chemistry

P. Corbett, Manager, Quality Assurance

M. McKenney, Emergency Preparedness Manager

J. Devincentis, Sr. Licensing Engineer

C. Daniels, Superintendent, FIN Team

V. Ferr.izzi, Shift Manager

D. Deer, Field Support Supervisor

J. Ward, Superintendent, l&C Maintenance

J. Stasolla, Sr. System Engineer

P. Stello, Sr. Electrical l&C System Engineer

J. Anderson, Process Computer Engineer

T. Stetson, Sr. Reactor Engineer

R. Current, Sr. Electrical l&C System Engineer

M. Anderson, Fire Protection Engineer

L. Doucette, EFIN Engineer

S. Jonasch, Sr. System Engineer

B. Naeck, Sr. System Engineer

P. Couture, Licensing Specialist

J. Geyster, Superintendent, Radiation Protection

M. Morgan, Superintendent, Training

S. Skibniowski, Environmental Specialist

P. Stover, Supervisor, Radiation Protection

D. Jeffries, Supervisor, Engineering

C. Atwood, Facilities

J. Mully, System Engineer

K. Oliver, Shift Manager

M. Ramsey, Control Room SuPervisor

J. Twarog, Shift Manager

P. Johnson, Senior Design Engineer

G. Thomas, Senior Project Engineer

S. Howe, Supervisor, Electrical Maintenance

A. Wisniewski, Shift Technical Advisor

D. Pearson, BWR Fuels Engineer

S. Dunkley, Supervisor, l&C

G. Calantropio, l&C Specialist

S. Goodwin, Supervisor, Mechanical Design Engineering

A. Robertshaw, Senior Design Engineer

G. Brede, Senior Design Engineer

J. Clough, System Engineer

M. Palionis, PSA Engineer

A. Small, Control Room Supervisor

M. Griffin, FAC Engineer

W. Sparko, System Engineer

R. Mauthe, Supervisor, l&C

W. Pelzer, IST Engineer

R. Bettini, Supervisor, Electrical Maintenance

D. Grimes, Senior Design Engineer

R. Congdon, Control Room Supervisor

J. Klein, System Engineer

M. Empey, Fire Protection/Appendix R Engineer

K. Sweet, Supervisor, Components Engineering

B. Busick, Shift Manager

J. Ziguloski, Work Planner

T. Marstaller, Control Room Supervisor

P. Rose, Control Room SuPervisor

K. Murphy, Control Room SuPervisor

T. Roberts, Control Room Supervisor

A. DeOssie, Control Room OPerator

S. Lanning, Control Room OPerator

A. Perlman, Emergency Planning Instructor

J. Paradis, Superintendent, Initial Operations Training

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None

Closed

05000271/25151183 Tl Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5.1)

05000271125151184 Tl Availability and Readiness Inspection of Severe Accident Management Guidelines (Section 4C.Fr5.2)

Discussed

None