IR 05000271/2011008

IR 05000271/2011008; 04/04/2011-04/21/2011; Vermont Yankee Nuclear Power Station Biennial Baseline Inspection of Problem Identification and Resolution (Pi&R)

ML111530359
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/02/2011
From:	Diane Jackson NRC/RGN-I/DRP/PB5
To:	Michael Colomb Entergy Nuclear Operations
References
IR-11-008
Download: ML111530359 (24)

Text

June 2, 2011

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION -

NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 0500027 I 1201 1 008

Dear Mr. Colomb:

On April 21, 2011, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed report documents the inspection results discussed with Mr. C. Wamser, General Manager, Plant Operations and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your 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). ln most cases, 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.

During the course of this inspection one self-revealing non-cited violation (NCV) of very low security significance (Green) was identified. As this finding is related to the Physical Security Cornerstone, the details of the finding are being documented in Security inspection report 0500027112011404 which will be issued in parallel with this report. lf you contest the NCV discussed in this report, you should follow the instructions for responding to the NCV or cross cutting aspect assigned to the finding contained in the 0500027112011404 inspection report cover letter.

ln accordance with 10 CFR 2.390 of the NRC's "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 NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.qov/readino-rm/adams.html (the Public Electronic Reading Room).

Sincerely, FOR, Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Docket No. 50-271 License No. DPR-28 Enclosure: InspectionReportNo. 0500027112011008 M Attachment: Supplemental Information cc w/encl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500027 112011008; 4lO4l2O11 - 4t211201 1; Vermont Yankee Nuclear Power Station;

Biennial Baseline Inspection of Problem ldentification and Resolution (Pl&R). One finding was identified in the area of problem identification.

This Nuclear Regulatory Commission (NRC) team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified one finding of very low security significance (Green) during this inspection and classified this finding as a non-cited violation (frfICU. The significance oi most findings is indicated by their color (Green, White, Yellow, Red)using'NRC Inspection Manual Chapter (lMC) 0609, "significance Determination Process" (SDF). Findings for which the SDP does not apply may be Green or assigned a severity level itter tlnC manigement review, Cross-cutting aspects associated with findings are determined using IMC 0310, "Components Within the Cross-Cutting Areas." The NRC's program for overieeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Problem ldentification and Resolution The inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel generally identified problems, entered them into the Conectiie Action Program (CAP) at a low threshold, and prioritized issues commensurate with their safety significanCe. In most cases, Entergy appropriately screened issues for operability and reportabiiity, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Entergy typically implemented corrective actions (CAs) to address the problems identified in the CAP in aiimelymanner. However, the inspectors identified a violation of NRC requirements, in the area of corrective Action Program - Problem ldentification.

The inspectors concluded that, in general, Entergy adequately identified, reviewed, and applied relevani industry operating experience to Vermont Yankee (W) operations. ln addition, based on those items ielected for review, the inspectors determined that Entergy's self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual CAP and employee concerns program issues, the inspectors did not identify any indications that site personnelwere unwilling to raise safety concerns, nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.

Cornerstone: Physical SecuritY.

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The inspectors identified a finding of very low security significance (Green) involving a trtcv of 10 CFR 73.55 (kX2) and the W Physical Security Plan. The details of this finding are documented in Security lnspection Report 0500027112011404. This finding has a cross-cutting aspect in the area of Human Performance-Work Practices-Human Performance Error preve-ntion Techniques because Entergy staff failed to conduct proper peer and self checking techniques which would have identified and precluded the issue. IH.a.(a)l

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REPORT DETAILS

oTHER ACTTVTTIES (OA)

Problem ldentification and Resolution (7 11528)

This inspection constitutes one biennial sample of Pl&R as defined by Inspection Procedure 71152. Alldocuments reviewed during this inspection are listed in the to this report.

Assessment of Corrective Action Proqram Effectiveness Inspection Scope The inspectors reviewed the procedures that described Entergy's CAP at W. To assess the effectiveness of the CAP, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and CA imptementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and Entergy procedure EN-LI-102, "Corrective Action Program,"

Revision 16. For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed condition reports (CRs) selected across the seven cornerstones of sifety in the NRCs Reactor Oversight Process. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.

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(1) Effectiveness of Problem ldentification===

The team reviewed Entergy's procedures that describe the CAP at the Vermont Yankee Nuclear Power Station (VYNPS). Entergy personnel identified problems by initiating CRs for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, or other significant issues. CRs were subsequently screened for operability and reportability, categorized by significance level (A, most significant, through D, ieast significant), and assigned to personnelfor evaluation and resolution or tren-ding. The inipectors reviewed CRs, system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of accessible portions of various systems on site, including the high pressure coolant injection system (HPCI), the reactor core isolation cooling system (RCIC) and the automatic depressurization system (ADS). Addjtionally, the inspectors reviewed a sample of CRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Entergy entered conditions adverse to quatity into their CAP as appropriate'

(2) Effectiveness of Prioritization and Evaluation of lssues 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. The inspectors reviewed the evaluation and prioritization of a sample of CRs issued since the last NRC biennial Pl&R inspection completed in April 2009. The inspectors also reviewed CRs that were assigned lower leveis of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned sighificance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate CAs to address the identified causes. The team observed condition review group (CRG) meetings in which Entergy personnel reviewed new CRs for prioritization and assignment, and Station Oversight Review Committee (SORC) meeiings which reviewed the quality of all root cause analysis (RCAs) and select apparent cause evaluations (ACEs). 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 condition and extent of cause reviews of problems, when warranted.

(3) Effectiveness of Corrective Actions The inspectors reviewed Entergy's completed CAs through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CRs for adverse trends and repetitive problems to determine whether CAs were effective in addressing the broader issues. The inspectors reviewed Entergy's timeliness in implementing CAs and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with selected NCVs and findings to verify that Entergy personnel properly evaluated and resolved these issues. ln addition, the inspectors expanded the CA review to five years to evaluate Entergy actions related to HPCI and ADS systems. Systems for the five year review were selected based upon plant risk significance and systems selected during previous Pl&R inspections.

b. Assessment

(1) Effectiveness of Problem ldentification The inspectors determined that Entergy's performance was adequate in the area of problem ldentification. This was based on the selected samples reviewed, plant walkdowns, and interviews of site personnel. The inspectors determined that, in general, Entergy personnel identified problems and entered them into the CAP at a low threshold. foiine issues reviewed, the inspectors noted that problems or concerns had been appropriately documented in enough detail to understand the issues. The inspectors observed managers and supervisors at CRG meetings appropriately questioning and challenging CRs to ensure clarification of the issues. The inspectors determined that Entergytrended equipment and programmatic issues, and CR descriptions appropriately included reference to repeat occurrences of issues. The inspectors concluded that personnel were identifying trends at low levels. In general, the inspectors 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. However, the inspectors did identify one finding in this area' The finding is related to the Physical Security Cornerstone and is documented in Security I nspection Report 0500027 1 1201 1 404.

The inspectors identified a potential trend where plant operators were not consistently entering unexpected control room alarms into the CAP. This trend was also discussed in NRClnspection Report 0500027112010005 (ML110390550). In some instances, unexpected control room alarms associated with known conditions were documented only in the control room logs and not in the CAP. Specifically, a review of operator logs conducted by the resident inspectors over a two year period identified that alarms caused by the electric fire pump starting due to system deficiencies were inconsistently documenied in the CAP. Approximately 25o/o of the unexpected alarms sampled by the residents were not documented in the CAP. Although Entergy has developed corrective actions to address this potential trend after the residents brought this potential trend to their attention, the team noted a few examples where unexpected alarms caused by water leakage into the.hydraulic control unit accumulators were not entered into the CAP. Effective condition trending cannot be performed if all occurrences are not being documented. The issue was evaluated using NRC IMC 0612 Appendix B, "lssue Screening," and Appendix E, "Minor lssues," and was determined to be a minor violation of Entergy's CAP procedure EN-LI-102, "Corrective Action Program," since plant operators responded to the alarms and took the required actions to ensure equipment, availability and operabilitY.

The inspectors also identified examples over the inspection period where Entergy failed to identify issues during the performance of infrequently performed evolutions, maintenance activities, and post maintenance testing (PMT) which contributed to plant events and/or resulted in violations of station and NRC requirements'

. NRC fnspection Report 050002712010003 (M1102100320) documented a self-revealing, Green NCV of Technical Specification (TS) 6.4, "Procedures." On May 17,2010, operators inadvertently drained water from the reactor pressure vesiel (RPV) during integrated emergency core cooling system (ECCS) testing.

Specifically, Entergy failed to establish the initial plant conditions necessary to perform iniegrated ECCS testing without causing an inadvertent drain down of the vesselthrough the main steam lines, the HPCIand the RCIC turbines, and into the torus. Plant conditions had been established to perform the integrated ECCS test but were subsequently changed to support core reassembly and not reestablished prior to commencing the test resulting in the test occurring with RCS water level above the main steam lines with the steam plugs removed, which resulted in an unplanned reactor coolant system (RCS) level transient.

. NRC lnspection Report 0500027112011002 (M1102100320), documents a self-revealing, Green NCV of TS 6.4, "Procedures," in which maintenance and planning personnel did not involve engineering personnel as required by Entergy procedures, resulting in the incorrect material being used to replace the gasket on the flange of HpCl steam trap 23T-3. On February 16, 2011 the HPCI steam trap gasket failed resulting in HPCI having to be isolated and the HPCI space and reactor building being temporarily evacuated. One of the contributing causes to this event (CR-VTY-2011-00667) was an inadequate post maintenance test (PMT). Due to known leakage past LCV-53 and leakage through the steam trap internals, system pressure could not be built up during the PMT. These conditions were known and recently documented in the CAP (CR-VYT-2011-0404); however, this was not recognized how it affected the PMT. As a result the PMT was inadequate to demonstrate system integrity. When the quarterly HPCI surveillance was conducted days later, full system pressure was applied to the steam trap and the gasket failec.

. CR-WT-2010-03660 identified that during the inspection period a programmatic issue related to quality control (QC) hold point inspections were not completed or were performed by non-qualified inspectors. This was done as a part of the corporate review of concerns raised by the NRC. At W, five instances during refueling outage (RFO) 28 were identified where QC hotd point inspections were completed by non qualified personnel or had been marked as "not applicable" and not completed. This was not identified by the work package closeout review. The NRC documented a Green NCV against 10 CFR 50 Appendix B Criteria X, "f nspections," in NRC Inspection Report 0500027112010005 (M1110390550) for Entergy Corporation wide issues related to QC hold point inspections.

(2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that Entergy's performance in this area was adequate. This was based upon the observation that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.

Entergy screened CRs for operability and reportability, categorized the CRs by signifftnce, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of CRs reviewed, the inspectors noted that the guidance provided by Entergy's CAP implementing procedures appeared sufficient to ensure consistency in categoriiation of issues. Operability and reportability determinations were generally perf&med when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectorJ did note some observations in Entergy's prioritization and evaluation of the following issues:

HPCI Steam Trap 23T-3 NRC fnspection Report 0500027112011002 (ML102100320), documents a self-revealing, Green NCV of TS 6.4, "Procedures," in which maintenance and planning personnel did not involve engineering personnel as required by Entergy procedures, iesulting in the incorrect material being used to replace the gasket on tfre_ flange of HPCI steam tiap 23T-3. On February 16, 2011the HPCI steam trap gasket failed resulting in HPCI having to be isolated and the HPCI space and reactor building being temporarily evacuated.

On February 1,2011, the HPCI system was removed from service to repair a small steam leak in non-safety related one-inch piping downstream of steam trap 23T-3. The flange on the steam trap had to be disassembled to access and replace the piping with the iteam leak. The flange was originally sealed with a spiral wound flexitallic gasket.

This type of gasket was not readily available and the licensee determined that a Garlock 9g20 gasket was an acceptable replacement. The decision was made by maintenance supervision based on a previous technical evaluation (04-00600 Revision 0) provided in the work package by the planning department. This technical evaluation states that this material should not be used in systems greater than 250 psig. This limitation was misinterpreted and the Garlock 9920 gasket was put into place on 23T-3. In addition, the maintenance personnel incorrectly applied OP 0212, "General Bolting Requirements," by using the table for a flexitallic gasket. This resulted in the torque values used being inadequate. Thus as a result of this inadequate equivalent part evaluation, an improper gasket material was used and insufficient torque values were applied. This resulted in the HPCI steam trap gasket failing when full system pressure was applied on February 16,2011.

HPCI Steam TraP lnternals:

CR 201 1-0404 was written on February 1, 2011 for a hole discovered in the HPCI steam Trap 23T-3 internals. Steam Trap 23T-3 is the ASME code class 2 boundary and a defect in an ASME code piping system would be a degraded condition and require an operability review. However, this CR was incorrectly classified as a 'D' CR and no evaluation of current operability was performed even though a decision was made to restore the system with this known degraded condition. Following the February 16, 2011 HpCl steam trap gasket failure event discussed above, Engineering Management identified that an operability determination had not been performed for the steam trap internals and wrote a new CR (CR-VYT-2011-711). lt was determined that HPCI system safety function and integrity was not affected and the safety related piping system was determined to be operable but degraded. The issue was evaluated using NRC IMC 0612 Appendix B, "lssue SCreening," and Appendix E, "MinOr lSSUeS," and waS determined to be a minor violation of Entergy's CAP procedure EN-LI-102, "Corrective Action Program," since when the operability determination was completed, the non-conforming condition was not determined to adversely impact the system safety function or operability.

SRV Evaluation:

LER 0500027112010-002-00&01: Inoperability of Main Steam Safety Relief Valves (SRVs) Due to Degraded Thread Seals. During the 2010 RFO, the pneumatic actuators ior the'four SRVs were tested and leakage was identified through the shaft-to-piston thread seal that was in excess of the design requirement on two of the four SRVs. The inspectors determined that the licensee's evaluation did not specifically identify two apparent causes or significant contributing causes. The SRV vendor did not submit a part Zt report for the SRV issue due to the Type 2 actuator being used in an application outside of two design parameters. The design deficiencies were:

. Design ambient temperature for the Type 2 actuator is 150 degrees F according to the vendor design documents. The actuators at W are exposed to an ambient temperature environment up to 185-190 degrees F according to the CR. This would result in a 35-40 degree F loss of margin for the BUNA N thread sealant (rated at 210-250 degrees F.)

. The Type 2 actuator has cooling slots, where as the Type 1 actuator does not.

These cooling slots were not accounted for when the Type 1 actuator was replaced with the Type 2 actuator and the cooling slots were covered by insulation. This caused the designed convection cooling of the actuator internals to be lost. As a result, the BUNA-N thread seal material was exposed to high temperature for a longer period, which increased the potential for degradation of the BUNA-N thread seals.

These concerns have not been addressed in the current plant configuration, as the Type 2 actuators are currently in use with the same insulation configuration. The current operability determination is based on empirical leak rate data measured from the degraded actuators following the 2010 RFO. This operability determination was reviewed by the inspectors and provides a reasonable basis for continued operability until the Fall2011 RFO, due to sufficient margin being available in the safety-related nitrogen back up supply for the pneumatic actuation system to overcome worst case leakJge for all design cases. ln addition, this supply is routinely monitored via operator roundi. Corrective actions planned by the licensee include replacing the Type 2 actuator with a new design which is less temperature sensitive and modifying the insulation package around the actuator. Although not developed specifically for these apparent causes or contributing causes (ACslCCs), the CAs will address these design issues. The issue was evaluated using NRC IMC 0612 Appendix B, "lssue Screening" and Appendix E, "Minor lssues," and was determined to be a minor violation of Entergy's CAP procedure EN-LI-l02, "Corrective Action Program." NRC Inspection Report 00000271/2011002 documents an LER closeout review and two Licensee ldentified Violations related to the discovery of the SRV issue. Since the previously unidentified ACs/CCs would not result in current operability being drawn into question and CAs are in place which would also address these causes, the issue is considered to be a minor violation of 10 CFR 50 Appendix B Criterion XVl, "Corrective Action."

The inspectors identified a potentialtrend based upon significant plant events which Entergy may have been abie to prevent by conducting more rigorous reviews of vendor modifications and equivalency evaluations:

. NRC f nspection Report 0500027112010003 documents in Section 4OA3 that on May 25,201d, the WNPS experienced a main generator trip and lockout due to a high differential current on a 345KV tie line. This resulted in a main turbine trip and reactor scram. Prior to the main generator trip, the licensee was raising reactor power from 70 percent to74.5 percent at 1 percent every 3 minutes. This was the hignest power level reached after tying in the new Vermont Electric Power Company ryELCO) switchyard to 345KV system. Entergy determined that the main generator irip was initiated by a high differential current caused by differences in the winding ralios between thecurrent sensors in the W switchyard and the new VELCO switchyard. As the generator power was raised, the current sensors deviated sufficiently to cause the main generator to trip. While the resident inspectors determined that no performance deficiency existed since this was VELCO metering equipment and a VELCO modification to that equipment, it was recognized that Entergy Engineering did not conduct a rigorous review of the switchyard modification due to poor commuhication between VELCO and W staff regarding the scope of VELCO's modification. Entergy likely would have been able to identify the plant trip risk and taken actions to prevent the scram had they been better aware of the scope of work involved.

. NRC Inspection Report 0500027112011002 documents an LER closeout review and two Licensee ldentified Violations related to inoperability of Main Steam Safety Relief Valves (SRVs) due to degraded thread seals. During the 2010 RFO: the pneumatic actuatois for the four SRVs were tested and leakage was identified through the shaft-to piston thread seal that was in excess of the design requirement on two of the four SRVs. Material testing determined that the apparent cause of the degraded thread seal condition was thermal degradation. During RFO27, Entergy discovered that the SRV Vendor no longer supported the Type-1 SRV actuators which W had.

The vendor recommended replacing the Type 1 actuators with a Type 2 actuator.

The Type 1 actuator has silicone thread sealants which are rated up to -390 degrees F while a Type 2 actuator uses BUNA-N polymer which is rated up to 210-250 degrees F. Entergy Engineering staff overly relied upon the vendor's

,eCommendation ind did not conduct an appropriate equivalency review on their own. Thus when the Type 2 actuator was used at W, the valve was exposed to higher temperatures which resulted in thermal degradation and air leakage from the actuator. This issue is discussed further above'

(3) Effectiveness of Corrective Actions The inspectors determined that Entergy's performance in this area was adequate. This was based upon the observation that CAs for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Enteigy identified actions to prevent recurrence. The inspectors concluded that CAs to addreis the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. The inspectors did observe some weaknesses in Entergy's resolution of degraded conditions' For example:

Compoundino of Corrective Actions:

The inspectors identified a trend related to CAs and corrective actions to prevent recurrence (CAPRs) not being completed due to compounding CAs. Compounding or

'Daisy Chaining" is where a CA from one CR is linked to another CR such that the origin-al CR can be closed out. Compounding can involve multiple station level CRs (HSrizontal) or involve CAs being moved from the station level to the corporate level and back (Vertical). This practice creates a vulnerability where CAs get lost in the CAP and the associated work orders are allowed to be cancelled and deferred and the CA or CApR is not completed. Entergy's staff conducting CR closeout reviews and Quality Assurance Staff conducting reviews of NCVs and RCAs identified a number of CAs and three CAPR which were either not completed or the CAs taken did not meet the intent of the original CAs/CAPR. Since the CR closeout reviews are a credited part of the CAP, Entergy's program did identify these missed CAs/CAPR, and the actions were subse-quenflylcheduled or completed, there is no violation of regulatory requirements; however, the relatively large number of issues identified by the final closure reviews indicates a potential vulneiability which needs to be addressed. This is a long standing concern which was also discussed during the 2009 Pl&R team inspection.

Corporate Procedures Chanqe Removed CAPR:

ln 2008, Entergy received a Notice of Violation (NOV) for a Greater than Green security finding. Entergy's RCA for the finding documented in CR-WT-2008-1146 developed a CAPR to revise a corporate security procedure EN-NS-204. These actions were completed and EN-NS-204 Revision 1 was issued containing the procedure revisions specified by the CAPR. W Security personnel identified during the closure review of a 2011 Corporate CR that the current revision of EN-NS-204 Revision 6 no longer contained the guidance specified by the 2008 CAPR. This issue was entered into the station and corporate CAPs. lt was discovered that there were no process controls in place to prevent a CAPR from being revised in a corporate procedure. Such a process does exist for station level procedures. The corporate procedure was being revised to reinstate the guidance of the 2008 CAPR. The issue was evaluated using NRC IMC 0612 Appendix B, "lssue Screening" and Appendix E, "Mingr lSSueS," and was determined to be a minor violation of Entergy's CAP procedure EN-Ll-102, "Corrective Action Program." The issue was determined to be minor because there was no repetition of tne 2008 performance deficiency as a result of the CAPR being removed from the procedure.

Lono Term Corrective Actions (LTCAS):

The inspectors noted a potential weakness under timely and effective CAs. Entergy's CA process allows CAs to remain open for greater than six months without a long term CA review as long as they do not require a design change, NRC review, multiple training cycles or a plant outage to be implemented. ln addition, the inspectors found several examples oi actions that had their due dates extended past the six month mark without documentation stating why the extension was acceptable. This allows conditions to go uncorrected for an eitended period of time without a documented review to determine if compensatory actions are needed, The issue was evaluated using NRC IMC 0612 Appendix B, ';lssue SCreening," and Appendix E, "Minor lSSueS," and waS determined to be'a minor violation of Entergy's CAP procedure EN-Ll-1 02, "Corrective Action program." The issue was determined to be minor because there were no instances iOentifieO where this practice challenged operability of safety related equipment Additionally, Entergy tracked the status of these LTCAs, and extensions had been approved in accordance with Entergy's CAP procedures. Entergy entered the inspector's observation into their CAP as CR-WY-2O11-0'1639.

Findinqs The inspectors identified a finding of very low security significance (Green) involving a NCV of 10 CFR 73.55 (kX2) and the W Physical Security Plan. The details of this finding are documented in Security Inspection Report A500027112011404. This finding has aiross-cutting aspect in the area of Human Performance-Work Practices-Human Performance Error Prevention Techniques because Entergy staff failed to conduct proper peer and self checking techniques which would have identified and precluded the issue. [H.4.(a)]

No other findings were identified.

.2 Assessment of the Use of Operatinq Experience

Inspection Scope The inspectors reviewed a sample of CRs associated with review of industry operating experience to determine whether Entergy appropriately evaluated the operating experience information for applicability to W and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Entergy adequately considered the underlying problems associated with the issues for resolulion via their CAP. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

Assessment The inspectors determined that Entergy's performance in this area was good. This was based on the observation that Entergy appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings and pre-job briefs. Entergy also effectively used operational experience in the development bf f b Cfn S0.65(a)(1) action plans and as a part of higher level ACEs and RCAs.

Findinqs No findings were identified.

Assessment of Self-Assessments and Audits Inspection Scope The inspectors reviewed a sample of audits, including the most recent audit of the CAP, departmental self-assessments, and assessments performed by independent organizations. lnspectors performed these reviews to determine if Entergy entered pr6bbms identified through these assessments into the CAP, when appropriate, and whether they initiated CAa to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

Assessment The inspectors determined that Entergy's performance in this area was good. This was based on the observation that Entergy's self-assessments, audits, and other internal Entergy assessments were generally critical, thorough, and effective in identifying issueJ. The inspectors observed that Entergy personnel knowledgeable in the subject a.

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completed these audits and self-assessments in a methodical manner. Entergy completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the CAP for evaluation. ln general, the station implemented CAs associated with the identified issues commensurate with their safety significance.

Findinqs No findings were identified.

Assessment of Safetv Conscious Work Environment Inspection Scope During interviews with station personnel, the inspectors assessed the safety conscious work environment at W. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Entergy entered issues into the CAP when appropriate.

Assessment During interviews, Entergy staff expressed a willingness to use the CAP to identify plant issuei and deficiencies and stated that they were willing to raise safety issues. The inspectors 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 the Employee Concerns Program. Based on these interyiews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

Findinqs No findings were identified.

Event Follow-up (71153-1 samPle)

On February 16,2Q11, with the plant at 100 percent power, W was preparing to perform a scheduled quarterly surveillance on the HPCI system. During initial startup of the HPCI system, audible and visual indications of steam leakage were obserygd Py personnel in the vicinity of the HPC! room. A local fire alarm was received in the control ioom and operators were dispatched and confirmed that the alarm was due to the steam leak in the HPCI room. The HPCI steam supply was isolated and an eight-hour notification was made to the NRC per 10 CFR 50.72(bX3)(vXD).

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c.

40A3 Pressure Coolant Iniection Svstem Due to Failure to Follow Procedures.

The investigation determined that a flanged connection associated with steam trap 23T-3 was the source of the leak. The event was attributed to a maintenance activity that was performed on February 1,2011 where the steam trap was disassembled to facilitate a piping weld repair. Following the pipe repair, the steam trap was reassembled using a Garlock 9920 gasket material because there was no spiral wound gasket material available. The investigation determined that the Garlock 9920 gasket was not appropriate for this application. In addition, post maintenance testing was performed but it was subsequently determined that the system configuration did not expose the affected flanges to full operating pressure and temperature. This event was determined to be reportable per 10 CFR 50.73 (aX2XvXD) as an event or condition that could have prevented fulfillment of a safety function needed to mitigate the consequences of an accident and since the condition existed longer that the limiting condition for operability of the HPCI system (i.e., 14 days), the event is also reportable under 10 CFR 50.73 (a)(2)(i)(B) as a condition prohibited by TSs.

N RC I nspection report O5OOO27 I 1201 1 002 ( ML102100320), documents a self-revealing, Green NCV of TS 6.4, "Procedures," in which maintenance and planning personnel did not involve engineering personnel as required by Entergy procedures, resulting in the incorrect material being used to replace the gasket on the flange of HPCI steam trap 23T-9. The inspectors reviewed this LER. No additional violations were noted. This LER is closed.

4OAG Meetinqs, Includino Exit On April 21,2011, the inspectors presented the inspection results to Mr. C. Wamser, General Manager, Plant Operations, and other members of the W staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTALINFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

A. Johnson, Security Supervisor

H. Swaby, System Engineer

J. Devincentis, Senior Lead Licensing Engineer

J. Patrick, Superintendent Security Operations

P. Ryan, Manager Security Operations

J. Hardy, Chemistry Manager

J. Rogers, Design Engineering Manager

D. Jeffries, Electrical and l&C Engineering Supervisor

M. Brown, Radiation Operations Supervisor

D. Grimes, Civil Design Engineer

W. Sparko, Balance of Plant Engineer

B. Naeck, Mechanical Systems Engineer

B. Pittman, Assistant Operations Manager

R. Current, System Engineer

B. Wanczyk, Licensing Manager

P. Corbett, QA Manager

A. Bradford, Reactor OPerator

W. Manning, Senior Reactor Operator

D. Boyce, Auxiliary OPerator

R. Booth, System Engineer

S. Goodwin, System Engineer

D. McElwee, Employee Concerns Representative.

NRC Personnel

L. Lewin, NRR

R. Bernardo, NRR

A. Ziedonis, Acting VY SRI

D. Spindler, VY SRI

J. Trapp, Region I

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

None Closed:

LER 0500027 1 12011 -001 -00 LER Inoperability of the High Pressure Coolant lnjection System due to Failure to Follow Procedures.

Discussed:

05000271 12011404-01 NCV Physical Security Cornerstone Finding