IR 05000271/2012004
| ML12305A153 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/31/2012 |
| From: | Ronald Bellamy NRC/RGN-I/DRP/PB5 |
| To: | Wamser C Entergy Nuclear Operations |
| Bellamy R | |
| References | |
| IR-12-004 | |
| Download: ML12305A153 (47) | |
Text
October 31, 2012
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000271/2012004
Dear Mr. Wamser:
On September 30, 2012 the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on October 15, 2012, with Mr. Michael Gosekamp and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding and one self-revealing finding of very low safety significance (Green). One of these findings was determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because the issue has been entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the 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 Vermont Yankee. In addition, if you disagree with the cross-cutting aspect assigned to 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 Vermont Yankee.
In accordance with 10 Code of Federal Regulations (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/
Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects
Docket No.
50-271 License No.
Enclosure:
Inspection Report No. 05000271/2012004 w/ Attachment: Supplementary Information
REGION I==
Docket No.:
50-271
License No.:
Report No.:
Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Vermont Yankee Nuclear Power Station
Location:
Vernon, Vermont 05354-9766
Dates:
July 1, 2012 through September 30, 2012
Inspectors:
S. Rutenkroger, PhD, Senior Resident Inspector, Division of Reactor Projects (DRP)
S. Rich, Resident Inspector, DRP T. Burns, Reactor Inspector, Division of Reactor Safety (DRS)
K. Mangan, Reactor Inspector, DRS B. Dionne, Health Physicist, DRS T. Fish, Senior Operations Engineer, DRS C. Crisden, Emergency Preparedness Inspector, DRS J. DeBoer, Project Engineer, DRP
Approved by:
Ronald R. Bellamy, PhD, Chief
Reactor Projects Branch 5
Division of Reactor Projects
SUMMARY OF FINDINGS
IR 05000271/2012004; 07/01/2012 - 09/30/2012; Vermont Yankee Nuclear Power Station;
Maintenance Effectiveness, Surveillance Testing.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One NRC-identified finding and one self-revealing finding of very low safety significance (Green) were identified, one of which was determined to be a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Cornerstone: Initiating Events
- Green.
A self-revealing, Green finding (FIN) was identified because Entergy failed to implement a preventive maintenance procedure. Specifically, Entergy personnel classified the discovery status code for the minor motor inspection on the A recirculation pump motor generator set drive motor incorrectly, as B - satisfactory or normal wear, instead of D -
abnormal wear, which resulted in a missed opportunity to replace degraded components that caused the A recirculation pump to trip and an unplanned entry into single recirculation loop operation. Entergys corrective actions included cleaning the motor and the junction box, replacing components that had been damaged by an arc flash, and testing the circuit to verify no other components were degraded prior to restarting the motor. In addition, Entergy initiated condition report CR-VTY-2012-02811 and issued a corrective action to reinforce the requirements of Entergy Procedure EN-DC-324 among maintenance staff. Entergy also plans to add all large motor and generator junction boxes to the predictive maintenance program and to perform thermography on a six month frequency.
The inspectors determined that the issue was more than minor because it resulted in a transient, i.e. an event that upset plant stability (an unplanned entry into single recirculation loop operation). In particular, the issue is associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability during power operations. The inspectors determined the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The finding was determined to be of very low safety significance (Green) because the finding was a transient initiator that did not cause a reactor trip. The inspectors determined that the finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Entergy did not sufficiently define and effectively communicate expectations regarding procedural compliance for the selecting of the discovery status code and personnel did not follow procedures. H.4(b). (Section 1R12)
Cornerstone: Barrier Integrity
- Green.
The inspectors identified an NCV of technical specification (TS) 6.4, Procedures, for Entergys failure to implement a surveillance activity in accordance with the written procedure. Specifically, the inspectors identified that during a surveillance test, dedicated operators required to maintain operability of primary containment left the immediate vicinity of open manual containment isolation valves. Entergys corrective actions included restoring the administrative controls required to maintain primary containment operability during the subject surveillance test, initiating condition report CR-VTY-2012-03561, sending a memorandum to and discussing the issue with all operating crew shift managers explaining the error and the requirements of a dedicated operator, and issuing a temporary night order further explaining these requirements. Additional corrective actions included implementing and tracking training for all operators on these requirements, and revising licensed operator training on primary containment to specifically describe these requirements.
The inspectors determined that the issue was more than minor because it is associated with the Human Performance attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the dedicated operators were required to be stationed in the immediate vicinity of the valve controls to rapidly close the valves when primary containment isolation is required during accident conditions, but the operators were significantly beyond the required immediate vicinity when they left the reactor building.
The inspectors determined the significance of the finding using IMC 0609, Appendix H,
Containment Integrity Significance Determination Process. The finding was determined to be of very low safety significance (Green) using Appendix H, Table 6.2, Phase 2 Risk Significance - Type B Findings at Full Power, because primary containment was inoperable for 37 minutes, i.e. less than 3 days. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because the training of personnel did not describe specific requirements of dedicated operators, including the definition of immediate vicinity. H.2(b). (Section 1R22)
REPORT DETAILS
Summary of Plant Status
Vermont Yankee Nuclear Power Station (VY) began the inspection period operating at 100 percent power. On July 6, operators reduced power to 74 percent for a control rod pattern adjustment and returned VY to 100 percent power the same day. On July 30, operators reduced power to 55 percent for a control rod pattern adjustment and returned VY to 100 percent power the following day. On August 1, operators reduced power to 79 percent for a control rod pattern adjustment and returned VY to 100 percent power the following day. The plant remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of Entergys readiness for the onset of seasonal high temperatures. The review focused on the reactor building, reactor water cleanup, and service water. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), TS, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Entergys seasonal weather preparation procedure. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Impending Adverse Weather
a. Inspection Scope
On July 26, the inspectors reviewed Entergys procedures and preparations following issuance of a Tornado Watch by the National Weather Service for the local area. The inspectors reviewed adverse weather information contained in the External Event Procedure Design Basis Document and UFSAR, and compared it to the actions specified in OPOP-PHEN-3127, Natural Phenomenon, Revision 8. The inspectors also performed a walkdown of the protected area and the areas near the switchyard to verify items were tied down or stored so they would not be affected by high winds.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
High pressure coolant injection during reactor core isolation cooling system maintenance on August 7
B emergency diesel generator during A emergency diesel generator surveillance testing on September 4
4 kiloVolt (kV) alternating current system (buses one through four and Vernon Tie)during B emergency diesel generator surveillance testing on September 10
The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TS, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.
The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
The inspectors performed a complete system walkdown of accessible, safety-related portions of the service water system to verify the existing equipment lineup was correct.
The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, recent condition reports, the system health report and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports to ensure Entergy appropriately evaluated and resolved any deficiencies. The inspectors discussed the systems condition with the system engineer.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Entergy controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, in accordance with procedures.
Turbine building feedwater pump room, on August 16
Turbine building turbine lube oil tank and storage room, on August 16
Intake structure service water pump room, on September 11
Fuel oil storage tank and transfer pump house, on September 11
Control room, on September 28
b. Findings
No findings were identified.
==1R07 Heat Sink Performance (711111.07A - 2 samples)
a. Inspection Scope
==
The inspectors reviewed the A residual heat removal heat exchanger and the B emergency diesel generator jacket water heat exchanger to determine their readiness and availability to perform their safety functions. The inspectors reviewed the design basis for both components and verified Entergys commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment. The inspectors reviewed the results of previous inspections of the heat exchangers. The inspectors discussed the results of the most recent inspections with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that Entergy initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchangers did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Biennial Inspection
a. Inspection Scope
The inspectors performed the following inspection activities using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and Inspection Procedure Attachment 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance.
Examination Results
The inspectors reviewed the requalification exam results (operating test) for 2012 to determine whether pass/fail rates were consistent with the guidance of IMC 0609, Appendix I, Operator Requalification Human Performance SDP. The inspectors verified that:
Individual pass rate on the dynamic simulator scenarios was greater than 80 percent. (Pass rate was 97.6 percent)
Individual pass rate on the job performance measures of the operating exam was greater than 80 percent. (Pass rate was 100 percent)
Individual pass rate on the written examination was greater than 80 percent. This result is not applicable, because there was no written examination this year.
More than 80 percent of the individuals passed all portions of the requalification exam. (Pass rate was 97.6 percent)
Crew pass rate was greater than 80 percent. (Pass rate was 100 percent)
Written Examination Quality
The inspectors reviewed a sample of comprehensive written exams that facility staff previously administered to the operators in June and July 2011.
Operating Test Quality
The inspectors reviewed operating tests (scenarios and job performance measures)associated with three different examination weeks.
Licensee Administration of Operating Tests
The inspectors observed facility training staff administering dynamic simulator exams and job performance measures during the week of July 23. These observations included facility evaluations of crew and individual operator performance during the simulator exams and individual performance of job performance measures.
Exam Security
The inspectors assessed whether facility staff properly safeguarded exam material, and whether test item repetition was excessive.
Remedial Training and Re-examinations
The inspectors did not evaluate this area since no operators had failed an exam (operating test or comprehensive written exam) during the most recent 2 year requalification training cycle.
Conformance with License Conditions
The inspectors reviewed license reactivation records to ensure that 10 CFR 55.53, Conditions of Licenses, and applicable program requirements were met. The inspectors also reviewed a sample of records for requalification training attendance, and a sample of medical examinations for compliance with license conditions and NRC regulations.
Simulator Performance
The inspectors reviewed simulator performance and fidelity for conformance to the reference plant control room. The inspectors also reviewed a sample of simulator deficiency reports to ensure facility staff addressed identified modeling problems.
Problem Identification and Resolution
The inspectors reviewed recent operating history documentation found in inspection reports, licensee event reports, Entergys corrective action program, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from Entergys corrective action program that indicated possible training deficiencies to verify that training had been appropriately addressed.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operators Requalification Testing and Training
(71111.11Q - 1 sample)
a. Inspection Scope
The inspectors observed licensed operator simulator training on August 20, which included a small break loss of coolant accident followed by a loss of the condensate and feedwater systems coincident with a failure of control rods to fully insert. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and shift technical advisor and the TS action statements entered. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.3 Quarterly Review of Licensed Operator Performance in the Main Control Room
(71111.11Q - 1 sample)
a. Inspection Scope
The inspectors observed control room operators during a high pressure coolant injection pump surveillance on September 20, including lining up the residual heat removal system in torus cooling mode to prepare for the surveillance. The inspectors observed the pre-job briefings to verify that roles and responsibilities, critical steps, expected results and hold points were discussed. The inspectors verified that procedure use, crew communications, and response to alarms met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the Maintenance Rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the Maintenance Rule in accordance with 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and verified that the paragraph (a)(2) performance criteria established by Entergy staff were reasonable. Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Condensate system
A recirculation pump motor generator set
b. Findings
Introduction.
A self-revealing, Green, FIN was identified because Entergy failed to implement a preventive maintenance procedure. Specifically, Entergy personnel classified the discovery status code for the minor motor inspection on the A recirculation pump motor generator set drive motor incorrectly, as B - satisfactory or normal wear, instead of D - abnormal wear, which resulted in a missed opportunity to replace degraded components that caused the A recirculation pump to trip and an unplanned entry into single recirculation loop operation.
Description.
During refueling outage 29 in October 2011, Entergy staff performed a minor motor inspection on the A recirculation pump motor generator set drive motor.
Entergy personnel observed overheating and oxidation on the neutral bus bar (located adjacent to the T6 motor-lead-to-crimped-lug connection), replaced the bus bar, and wrote a condition report. When closing the work order for the preventive maintenance task, the staff chose to grade the condition of the drive motor as B - satisfactory or normal wear. However, Entergy procedure EN-DC-324, Preventive Maintenance Program, specified that if replacement parts were used that were not required by the preventive maintenance task, the condition should be classified as D - abnormal wear.
An abnormal wear condition would have prompted an engineering review for additional necessary maintenance which would likely have identified the need to replace affected components adjacent to the overheated bus bar, such as the T6 motor-lead-to-crimped-lug connection.
On June 18, an arc flash occurred inside the drive motor junction box of the A recirculation pump motor generator set. The electrical transient caused the motor generator set and recirculation pump to trip. The reduction in core flow consequently reduced reactor power from 100 percent to approximately 67 percent. By procedure, control room operators then inserted control rods to further reduce power to 45 percent to stabilize the plant in single recirculation loop operation. Entergy staff determined the most probable cause of the arc flash was overheating on the T6 connection inside the motor junction box.
Entergys corrective actions included cleaning the motor and the junction box, replacing components that had been damaged by the arc flash, and testing the circuit to verify no other components were degraded prior to restarting the motor. In addition, Entergy initiated CR-VTY-2012-02811 and issued a corrective action to reinforce the requirements of EN-DC-324 among maintenance staff. Entergy also plans to add all large motor and generator junction boxes to the predictive maintenance program and to perform thermography on a six month frequency.
Analysis:
The inspectors determined that Entergy personnels incorrect grading of the A recirculation pump motor generator set drive motor condition was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented. Traditional enforcement does not apply since there were no actual safety consequences, impacts on the NRCs ability to perform its regulatory function, or willful aspects to the finding.
The inspectors reviewed IMC 0612, Appendix E, Examples of Minor Issues, and found that there were no sufficiently similar examples to the issue. The inspectors determined that the issue was more than minor because it resulted in a transient, i.e. an event that upset plant stability (an unplanned entry into single recirculation loop operation). In particular, the issue is associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability during power operations. The inspectors determined the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The finding was determined to be of very low safety significance (Green) because the finding was a transient initiator that did not cause a reactor trip.
The inspectors determined that the finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Entergy did not sufficiently define and effectively communicate expectations regarding procedural compliance for the selecting of the discovery status code and personnel did not follow procedures. H.4(b)
Enforcement:
This finding does not involve enforcement action because no regulatory requirement violation was identified. Because this finding does not involve a violation and is of very low safety significance, it is identified as a finding. FIN 05000271/2012004-01, Incorrect Assessment of Equipment Condition Resulted in Single Recirculation Loop Operation.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. The inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations work week manager to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
B emergency diesel generator monthly surveillance and B residual heat removal quarterly surveillance - workweek(WW) 1229
A service water pump and B control rod drive pump emergent maintenance - WW 1234
High pressure coolant injection system instrumentation testing - WW 1235
B emergency diesel generator semi-annual surveillance, B standby liquid control maintenance, and A service water pump maintenance - WW 1237 High pressure coolant injection pump quarterly surveillance and B core spray maintenance - WW 1238
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Weeping from weld on the upstream side of the service water isolation valve for the motor cooling of the A and C residual heat removal service water pumps, condition report initiated on July 25
Teflon sealed ball valves for isolating flush taps on the residual heat removal service water to residual heat removal emergency fill line were not qualified for the potential lifetime and accident radiation dose, condition report initiated on August 9
A service water pump had potential indication of throttle bushing degradation, condition report initiated on August 23
A startup transformer nitrogen pressure gauge failed low, condition report initiated on September 6
The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Entergys evaluations to determine whether the components or systems were operable. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors evaluated a modification to the steam supply line drain piping of the reactor core isolation cooling system. The inspectors verified that the design bases, licensing bases, and performance capability of the reactor core isolation cooling system was not degraded by the modification to replace the inverted bucket steam trap and check valve with a thermostatic steam trap. The inspectors reviewed modification documents associated with the design change, the implementing work order and the post modification test procedure to verify that the modification could be performed on line without impact to plant safety. The inspectors also interviewed engineering and maintenance personnel involved with the modification.
The inspectors evaluated a temporary leak repair on the motor bearing cooling line to the A and C residual heat removal service water pumps. The line had a pinhole leak caused by microbiologically induced corrosion that was upstream of the associated isolation valve. Since the location was unable to be characterized by ultrasonic examination, the leak rendered the residual heat removal service water pumps inoperable. Entergy installed a temporary clamp to ensure the structural integrity of the cooling line, stop the leak, and restore the operability of the pumps. The inspectors verified that the installed clamp complied with the design bases and licensing bases and the performance capability of the residual heat removal service water system was not degraded. The inspectors reviewed modification documents associated with the temporary leak repair, the implementing work order, and the post-repair visual inspection requirements to verify that the temporary leak repair had no impact on plant safety. The inspectors also interviewed engineering, operations, and chemistry personnel involved with the modification.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
A reactor building closed cooling water heat exchanger planned cleaning and maintenance on July 23
Reactor core isolation cooling pump discharge flow controller replacement on August 7
Reactor core isolation cooling pump trip and throttle valve planned maintenance on August 9
B standby liquid control pump accumulator drain valves replacement on September 10
A service water pump repack and shaft inspection on September 11
A emergency diesel generator number 14 cylinder oil booster pump air line replacement on September 13
b. Inspection Scope
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Entergys procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
B fuel oil transfer pump and discharge check valve quarterly surveillance on July 16 (in-service test)
C residual heat removal pump quarterly surveillance on July 25
A emergency diesel generator fast start surveillance on September 4
Reactor coolant system leak detection surveillance, the week of September 10 (reactor coolant system)
Standby liquid control pump comprehensive surveillance on September 27 (in-service test)
b. Findings
Introduction.
The inspectors identified a Green NCV of TS 6.4, Procedures, for Entergys failure to implement a surveillance activity in accordance with the written procedure. Specifically, the inspectors identified that during a surveillance test, dedicated operators required to maintain operability of primary containment left the immediate vicinity of open manual containment isolation valves.
Description.
On July 25, Entergy personnel were performing the quarterly residual heat removal pump C surveillance in accordance with OPST-RHR-4124-13C, RHR Pump C Operability Test (Quarterly). A limitation described within the procedure states that when opening a manual containment isolation valve that is within the primary containment boundary when containment integrity is required, Entergy shall either enter the TS limiting condition of operation (TS 3.7.A.8) or apply administrative controls. The administrative controls must consist of a dedicated operator stationed in the immediate vicinity of the valve controls to rapidly close the valve when directed by the control room and establishment of immediately available communications with the control room.
Then, prior to the step directing the opening of the C residual heat removal pump suction pressure test connection isolation valve and discharge pressure test connection isolation valve, the procedure includes a Caution followed by an initial block step text that directs when primary containment is required, a dedicated operator is to be stationed at each valve, with immediately available communications to the control room, before opening the two valves.
During the surveillance, the inspectors identified that the dedicated operators left the immediate vicinity of the valve controls. The inspectors were unable to locate the dedicated operators and questioned the shift manager regarding the status of the dedicated operators and operability of primary containment. The shift manager paged the operators who stated that they had left the reactor building and were waiting in the radwaste control room, a low dose area, until further actions were required. The shift manager instructed the operators to return, and remain within the room containing the isolation valves as long as the valves were open. The time during which the valves were open and the operators were not within the immediate vicinity was 37 minutes.
However, due to the temporary instrumentation connected to the open isolation valves, residual heat removal system valves which could be closed to reduce adverse leakage, and the valves location providing a water seal from the torus, any potential leakage from containment would have been limited.
On January 19, 1999, the NRC issued a TS amendment for VY that included provision for not declaring primary containment inoperable given circumstances as described above. The submittal correspondence defined immediate vicinity to include no physical barriers between the dedicated operator and the subject valve, such as ladders, stairs, doors, and distances greater than several feet. In the absence of maintaining the administrative controls, TS 3.7.A.8 would apply, requiring an orderly shutdown to be initiated and the reactor to be in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. After followup questioning, the inspectors and Entergy personnel determined that there was a general and variable misunderstanding of these requirements within the operations department.
Entergys corrective actions included restoring the administrative controls required to maintain primary containment operability during the subject surveillance test, initiating CR-VTY-2012-03561, sending a memorandum to and discussing the issue with all operating crew shift managers explaining the error and the requirements of a dedicated operator, and issuing a temporary night order further explaining these requirements.
Additional corrective actions included implementing and tracking training for all operators on these requirements and revising licensed operator training on primary containment to specifically describe these requirements.
Analysis.
The inspectors determined that Entergy personnels failure to remain within the immediate vicinity of open manual containment isolation valves was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented. Traditional enforcement does not apply since there were no actual safety consequences, impacts on the NRCs ability to perform its regulatory function, or willful aspects to the finding. This finding is more than minor because it is associated with the Human Performance attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the dedicated operators were required to be stationed in the immediate vicinity of the valve controls to rapidly close the valves when primary containment isolation is required during accident conditions, but the operators were significantly beyond the required immediate vicinity when they left the reactor building.
The inspectors determined the significance of the finding using IMC 0609, Appendix H, Containment Integrity Significance Determination Process. The finding was determined to be of very low safety significance (Green) using Appendix H, Table 6.2, Phase 2 Risk Significance - Type B Findings at Full Power, because primary containment was inoperable for 37 minutes, i.e. less than 3 days.
The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because the training of personnel did not describe specific requirements of dedicated operators, including the definition of immediate vicinity H.2(b).
Enforcement.
TS 6.4, Procedures, requires, in part, that written procedures be established, implemented, and maintained covering surveillance and testing requirements. Contrary to the above, on July 25, Entergy did not implement surveillance procedure OPST-RHR-4124-13C. Entergys corrective action to restore compliance consisted of returning the dedicated operators to the immediate vicinity of the open manual containment isolation valves. Because this violation was of very low safety significance and was entered into the corrective action program (CR-VTY-2012-03561),this violation is being treated as an NCV, consistent with the NRC Enforcement Policy.
(NCV 05000271/2012004-02, Dedicated Operators Required for Operability under Applied Administrative Controls Left Immediate Vicinity of Open Valves).
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation (71114.02 - 1 Sample)
a. Inspection Scope
An onsite review was conducted to assess the maintenance and testing of the alert and notification system (ANS). The inspectors conducted a review of the ANS testing and maintenance programs. The inspectors reviewed the associated ANS procedure and the Federal Emergency Management Agency approved ANS design report to ensure compliance with design report commitments for system maintenance and testing. 10 CFR 50.47, Emergency Plans, (b)(5) and the related requirements of 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, were used as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03 - 1 Sample)
a. Inspection Scope
The inspectors conducted a review of VYs emergency response organization (ERO)augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to verify the readiness of key Entergy staff to respond to an emergency event and to verify Entergys ability to activate their emergency response facilities (ERF) in a timely manner. The inspectors reviewed the VY emergency plan for ERF activation and ERO staffing requirements, the ERO duty roster, Entergys procedures, communication test reports, the most recent drive-in drill report, and condition reports. The inspectors also reviewed a sample of ERO responder training records to verify training and qualifications were up to date. 10 CFR 50.47 (b)(2)and related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP5 Maintaining Emergency Preparedness (71114.05 - 1 Sample)
a. Inspection Scope
The inspectors reviewed a number of activities to evaluate the efficacy of Entergys efforts to maintain the VY emergency preparedness program. The inspectors reviewed:
letters of agreement and/or memorandums of understanding with offsite agencies; 10 CFR 50.54, Conditions of Licenses,
- (q) emergency plan change process and practice; Entergys maintenance of equipment important to emergency preparedness; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternate ERF maintenance. The inspectors conducted a walkdown of the control room to inspect equipment important to emergency preparedness, which included interviews with control room staff on the process for identifying and managing out-of-service equipment. The inspectors also verified Entergys compliance at VY with new NRC emergency preparedness regulations regarding: emergency action levels for hostile action events; the emergency operations facility performance-based approach; emergency response organization augmentation at alternate ERFs; event declaration within 15 minutes; and protective actions for on-site personnel during events.
The inspectors further evaluated Entergys ability to maintain their emergency preparedness program through their identification and correction of emergency preparedness weaknesses, by reviewing a sample of drill reports, actual event reports, self-assessments, a 10 CFR 50.54(t) audit, and condition reports. The inspectors reviewed a sample of relevant condition reports initiated at VY from August 2010 through August 2012. 10 CFR 50.47(b) and the related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors evaluated the conduct of a routine emergency drill on September 5 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also reviewed condition reports initiated following the drill to compare inspector observations with those identified by Entergy staff in order to evaluate Entergys critique and to verify that Entergy staff was properly identifying weaknesses and entering them into the corrective action program.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
During the week of July 9 to 12, the inspectors verified that in-plant airborne concentrations were being controlled consistent with as low as reasonably achievable (ALARA) principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR 20, Standards for Protection Against Radiation, Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection, Regulatory Guide 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, the TS, and Entergys procedures as criteria for determining compliance.
.1 Inspection Planning
a. Inspection Scope
The inspectors reviewed the UFSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. This review included instruments used to identify changing airborne radiological conditions such that actions to prevent an overexposure may be taken. The review included an overview of the respiratory protection program and a description of the types of devices used. The inspectors reviewed the UFSAR, TS, and emergency planning documents to identify location and quantity of respiratory protection devices stored for emergency use. The inspectors reviewed Entergys procedures for maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus (SCBA), as well as procedures for air quality maintenance. The inspectors reviewed reported performance indicators to identify any related to unintended dose resulting from intakes of radioactive material.
b. Findings
No findings were identified.
.2 Engineering Controls
a. Inspection Scope
The inspectors reviewed Entergys use of permanent and temporary ventilation to determine whether Entergy uses ventilation systems as part of its engineering controls to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems to reduce dose and assessed whether the systems are used, to the extent practicable, during high-risk activities.
The inspectors selected two installed ventilation systems (standby gas treatment and advanced off-gas) used to mitigate the potential for airborne radioactivity. The inspectors evaluated whether the ventilation system operating parameters were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne radioactive material area. The inspectors selected one temporary ventilation system used to support work in contaminated areas. The inspectors assessed whether the use of this system was consistent with Entergy procedural guidance and ALARA principles.
The inspectors reviewed airborne monitoring protocols by selecting two installed systems (containment particulate and gas and advanced off-gas particulate and gas radiation monitors) used to monitor and warn of changing airborne concentrations in the plant. The inspectors evaluated whether the alarms and setpoints were sufficient to prompt actions to ensure that doses are maintained within the limits of 10 CFR 20 and ALARA. The inspectors assessed whether Entergy had established threshold criteria for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.
b. Findings
No findings were identified.
.3 Use of Respiratory Protection Devices
a. Inspection Scope
The inspectors evaluated whether Entergy had established means (such as routine bioassay) to determine that the level of protection (protection factor) provided by the respiratory protection devices during use was at least as good as that assumed in Entergys work controls and dose assessment. The inspectors assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration or approved by the NRC. The inspectors reviewed records of air testing for supplied-air devices and SCBA bottles to assess whether the air used in these devices meets or exceeds Grade D quality. The inspectors reviewed plant breathing air supply systems to determine whether they meet the minimum pressure and airflow requirements for the devices in use.
The inspectors selected five individuals qualified to use respiratory protection devices, and assessed whether they were deemed qualified to use the devices by successfully passing an annual medical examination, respirator fit-test, and relevant respiratory protection training. The inspectors reviewed training curricula for users of respiratory protection devices. The inspectors chose three respiratory protection devices staged and ready for use in the plant. The inspectors assessed the physical condition of the device components and reviewed records of equipment inspection for each type of equipment. The inspectors selected several of the devices and reviewed records of maintenance on the vital components. The inspectors verified that onsite personnel assigned to repair respiratory protection equipment had received vendor-provided training.
b. Findings
No findings were identified.
.4 SCBA for Emergency Use
a. Inspection Scope
The inspectors reviewed the status and surveillance records of selected SCBAs staged in-plant for use during emergencies. The inspectors reviewed Entergys capability for refilling and transporting SCBA air bottles to and from the control room and the operations support center during emergency conditions.
The inspectors selected three individuals on control room shift crews and from designated departments currently assigned emergency duties to assess whether control room operators and other emergency response and radiation protection (RP) personnel were trained and qualified in the use of SCBA. The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task. The inspectors determined whether appropriate mask sizes and types were available for use.
The inspectors determined whether on-shift operators and radiation workers had no facial hair that would interfere with the sealing of the mask to the face and whether vision correction mask inserts were available.
The inspectors reviewed the past two years of maintenance records for one SCBA unit to verify that any maintenance and repairs on the unit were performed by individuals certified by the manufacturer of the device to perform the work. For the SCBAs that were ready for use, the inspectors verified that the required periodic air cylinder hydrostatic testing was documented and up to date.
b. Findings
No findings were identified.
.5 Problem Identification and Resolution
a. Inspection Scope
The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by Entergy at an appropriate threshold and were properly addressed for resolution in Entergys corrective action program. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by Entergy.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
During the week of July 9 to 12, the inspectors verified that occupational dose was appropriately monitored and assessed. The inspectors used the requirements in 10 CFR 20, Regulatory Guide 8.13, Instructions Concerning Prenatal Radiation Exposures, Regulatory Guide 8.36, Radiation Dose to Embryo Fetus, Regulatory Guide 8.40, Methods for Measuring Effective Dose Equivalent from External Exposure, the TS, and Entergys procedures as criteria for determining compliance.
.6 Inspection Planning (02.01)
a. Inspection Scope
The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report on Entergys vendors most recent results to determine the status of the accreditation. The inspectors reviewed Entergys procedures associated with dosimetry operations, including issuance/use of external dosimetry, assessment of internal dose, and evaluation of, and dose assessment for, radiological incidents. The inspectors evaluated whether Entergy had established procedural requirements for determining when external dosimetry and internal dose assessments are required.
b. Findings
No findings were identified.
.7 External Dosimetry
a. Inspection Scope
The inspectors verified that Entergys dosimetry vendor is NVLAP accredited and that the approved irradiation test categories for each type of personnel dosimeter used were consistent with the types and energies of the radiation present and the way the dosimeter was used. The inspectors evaluated the onsite storage of dosimeters before issuance, during use, and before processing/reading. The inspectors also reviewed the guidance provided to radiation workers with respect to care and storage of dosimeters.
The inspectors assessed the use of electronic personnel dosimeters (EPD) to determine if Entergy uses a correction factor to address the response of the EPD as compared to the dosimeter of legal record for situations when the EPD is used to assign dose and whether the correction factor is based on sound technical principles. The inspectors reviewed corrective action program documents for five dosimetry events for adverse trends related to EPDs. The inspectors assessed whether Entergy had identified any adverse trends and implemented appropriate corrective actions.
b. Findings
No findings were identified.
.8 Internal Dosimetry
Routine Bioassay (In Vivo)
a. Inspection Scope
The inspectors reviewed Entergys procedures used to assess the dose from internally deposited radionuclides using whole body counting (WBC) equipment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, determining the route of intake, and the assignment of dose. The inspectors reviewed the whole body count process to determine if the frequency of measurements was consistent with the biological half-life of the radionuclides available for intake.
The inspectors reviewed Entergy's evaluation for the use of portal radiation monitors as a passive monitoring system. The inspectors assessed whether instrument minimum detectable activities were adequate to determine the potential for internally deposited radionuclides. The inspectors selected a WBC measurement and evaluated whether the counting system had sufficient counting time/low background to ensure appropriate sensitivity to radionuclides of interest. The inspectors evaluated how Entergy accounts for hard-to-detect radionuclides in their internal dose assessments.
b. Findings
No findings were identified.
Special Bioassay (In Vitro)
a. Inspection Scope
The inspectors selected one internal dose assessment obtained using WBC. There was no internal dose assessment obtained using urinalysis or fecal sample results for the inspectors to review. The inspectors reviewed the vendor laboratory quality assurance program. The inspectors verified the laboratory participated in an industry recognized cross-check program that included reviewing, evaluating, and resolving out-of-tolerance results.
b. Findings
No findings were identified.
Internal Dose Assessment - Airborne Monitoring
a. Inspection Scope
Entergy did not perform any internal dose assessments using airborne/derived air concentration monitoring during the period reviewed.
b. Findings
No findings were identified.
Internal Dose Assessment - WBC Analyses
a. Inspection Scope
The inspectors reviewed a dose assessment performed by Entergy using the results of WBC analyses. The inspectors verified that affected personnel were properly monitored with calibrated equipment and that internal exposures were assessed consistent with Entergy's procedures.
b. Findings
No findings were identified.
.9 Special Dosimetric Situations
Declared Pregnant Workers
a. Inspection Scope
The inspectors assessed whether Entergy informed workers, as appropriate, 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.
The inspectors reviewed the dosimetry records for the one individual who had declared pregnancy during the current assessment period and verified that Entergys radiological monitoring program (internal and external) for declared pregnant workers was technically adequate to assess the dose to the embryo/fetus. The inspectors reviewed exposure results and monitoring controls that Entergy implemented.
b. Findings
No findings were identified.
Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures
a. Inspection Scope
The inspectors reviewed Entergy's methodology for monitoring external dose in non-uniform radiation fields or where large dose gradients exist. The inspectors evaluated Entergy's criteria for using alternate monitoring, such as multi-badging.
b. Findings
No findings were identified.
Shallow Dose Equivalent
a. Inspection Scope
There were no dose assessments for shallow dose equivalent available for review. The inspectors evaluated Entergys method (e.g., VARSKIN or similar code) for calculating shallow dose equivalent from distributed skin contamination or discrete radioactive particles.
b. Findings
No findings were identified.
Neutron Dose Assessment
a. Inspection Scope
The inspectors evaluated Entergys neutron dosimetry program, including dosimeter types and/or radiation survey instrumentation. There were no neutron doses measured above the minimum sensitivity for review during the reporting period.
b. Findings
No findings were identified.
Assigning Dose of Record
a. Inspection Scope
The inspectors reviewed special dosimetric situations and assessed Entergys process for assigning dose of record for total effective dose equivalent, shallow dose equivalent, and lens dose equivalent. The inspectors assessed external and internal monitoring results, supplementary information on individual exposures, and radiation surveys when dose assignment was based on these techniques.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
.1 Safety System Functional Failures (1 sample)
a. Inspection Scope
The inspectors sampled Entergys submittals for the Safety System Functional Failures performance indicator for the period of July 1, 2011, through June 30, 2012. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Entergys operator narrative logs, operability assessments, maintenance rule records, condition reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index (2 samples)
a. Inspection Scope
The inspectors reviewed Entergys submittal of the Mitigating Systems Performance Index for the following systems for the period of July 1, 2011 through June 30, 2012:
High Pressure Injection System
Heat Removal System
To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI 99-02. The inspectors also reviewed Entergys operator narrative logs, operating procedures, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.3 EP Performance Indicators (3 samples)
a. Inspection Scope
The inspectors reviewed data for the three emergency preparedness performance indicators, which are:
- (1) Drill and Exercise Performance;
- (2) ERO Drill Participation; and
- (3) ANS Reliability. The last NRC emergency preparedness inspection at Vermont Yankee was conducted in the second calendar quarter of 2011. Therefore, the inspectors reviewed supporting documentation from emergency preparedness drills and equipment tests from the second calendar quarter of 2011 through the second calendar quarter of 2012 to verify the accuracy of the reported PI data. The acceptance criteria documented in NEI 99-02 were used as reference criteria.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy entered issues into their corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report review group meetings.
b. Findings
No findings were identified.
.2 Annual Sample:
Automatic Depressurization System Actuator Leakage
a. Inspection Scope
The inspectors performed an in-depth review of Entergys apparent cause analyses and corrective actions associated with the issue of actuator stem leakage on valves in the automatic depressurization system (ADS). Specifically, Entergy identified repeat occurrences of leakage around actuator stems during the 2009 and 2011 refueling outages. The inspectors determined whether Entergy had taken appropriate corrective actions to prevent recurrence of the leakage. Additionally, the inspectors reviewed an operability determination performed during the previous operating cycle following the discovery by Entergy that the seal installed on the ADS actuator stems did not meet environmental qualification requirements.
The inspectors interviewed plant personnel and reviewed test procedure results, condition reports, engineering evaluations, root cause analyses, and manufacturer data to assess Entergys problem identification, evaluation, and corrective action effectiveness with respect to the ADS actuator leakage. Specifically, the inspectors reviewed the documents to determine if the seal material used on the ADS actuator stems from 2008 to 2011 should be attributed as the root cause of the 2009 and 2011 stem leakage and to verify that the replacement seal material now installed was qualified for the expected environmental conditions. Additionally, the inspectors reviewed the TS, the UFSAR, and Vermont Yankee licensing documents to assess adverse impact due to the leakage with respect to design basis requirements. Finally, the inspectors evaluated whether the compensatory actions taken by Entergy following identification of the degraded condition provided reasonable assurance of operation of the ADS system during a design basis event and that Entergys conclusion that the system remained operable with the degraded condition was correct.
b. Findings and Observations
No findings were identified.
Entergy modified the actuator system in 2008. However, in consultation with the manufacturer, Entergy incorrectly concluded that the changes to the actuators were like for like replacement of components. Entergy failed to determine that the seal material for the actuator stem nut had been changed from Silicon to Buna-N. This change resulted in the temperature rating of the seal dropping from 400 degrees Fahrenheit (F)to 225 degrees F. During the 2009 refueling outage, Entergy found nitrogen to be leaking from the actuators and determined the actuator stem nut seals were degraded.
However, Entergys evaluation of the seal incorrectly concluded that the seal material was defective and a new Buna-N seal was installed. Entergy performed a subsequent evaluation of the seal material and determined that the material was Buna-N, not defective, and the failure of the material was due to exceeding the thermal rating (225 degrees F) of Buna-N. Following identification that the seal material did not meet environmental conditions, Entergy performed an operability determination which concluded that the ADS system was operable, but degraded. These performance deficiencies were previously evaluated by the NRC in inspection reports 05000271/2011002 and 05000271/2011008.
The ADS system consists of four 3-stage safety relief valves with an actuator attached to the valves so that they can be opened using a nitrogen gas supply. The UFSAR states that nitrogen for the actuation of the valves is stored in accumulators installed in the drywell that are sized to ensure sufficient gas is available for the required number of ADS valve actuations following a design basis accident. This system was credited to respond to design basis accidents and was required to be operable by TS. Additionally, nitrogen bottles were installed outside the drywell to actuate the ADS system following a design basis seismic event. The bottles were sized to allow operators to control reactor pressure using the ADS system for several days following the event. The inspectors determined that this portion of the system had not been evaluated or licensed for design basis accidents other than seismic events.
The inspectors reviewed the evaluations performed by Entergy that assessed past operability of the system prior to the 2011 refueling outage and the operability determination performed during the operating cycle. By crediting the use of the nitrogen bottles, Entergy determined that an adequate nitrogen supply would be available to respond to design basis accidents and events even with the additional loss of inventory from the accumulator stem leakage. Entergy concluded that the ADS system had remained operable because there was adequate nitrogen inventory available. The inspectors questioned whether the bottles and piping would be available for all design basis accidents. In response, Entergy performed an evaluation and concluded the bottle system had been designed to survive the required design basis accidents and would be available. The inspectors reviewed and concurred with the assessment, but noted that the evaluation was not done prior to crediting the system in the 2011 operability determination.
Finally, the inspectors evaluated the corrective action that replaced the Buna-N seal material with Viton, a flouroelastomer, during the 2011 refueling outage. The inspectors found that this material had the same properties as the previously installed silicon seal, with a temperature rating of 400 degrees F, and met the environmental requirements for the system.
4OA5 Other Activities
.1 Temporary Instruction 2515/182, Review of the Industry Initiative to Control Degradation
of Underground Piping and Tanks, Phase 1 (2515/182 - 1 Sample)
a. Inspection Scope
The inspectors reviewed Entergys buried piping and underground piping and tanks program in accordance with paragraphs 03.01a through 03.01c of Temporary Instruction 2515/182. The inspectors concluded that Entergys program met all applicable aspects of NEI 09-14, Guideline for the Management of Underground Piping and Tank Integrity, Revision 1, as set forth in Table 1 of Temporary Instruction 2515/182.
b. Findings
No findings were identified.
.2 Temporary Instruction 2515/187 - Inspection of Near-Term Task Force
Recommendation 2.3 - Flooding Walkdowns
On September 24, inspectors commenced activities to independently verify that Entergy conducted external flood protection walkdown activities using an NRC-endorsed walkdown methodology. These flooding walkdowns are being performed at all sites in response to Enclosure 4 of a letter from the NRC to licensees entitled, Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, dated March 12, 2012 (ADAMS Accession No. ML12053A340). The results of this temporary instruction will be documented in a future inspection report.
.3 Temporary Instruction 2515/188 - Inspection of Near-Term Task Force
Recommendation 2.3 - Seismic Walkdowns
On October 1, inspectors commenced activities to independently verify that Entergy conducted seismic walkdown activities using an NRC-endorsed seismic walkdown methodology. These seismic walkdowns are being performed at all sites in response to 3 of a letter from the NRC to licensees entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, dated March 12, 2012 (ADAMS Accession No.
ML12053A340). When complete, the results of this temporary instruction will be documented in a future inspection report.
.4 Independent Spent Fuel Storage Installation (60855.1 - 1 sample)
a. Inspection Scope
The inspectors reviewed routine operational surveillance data, including radiological surveillance and ventilation exhaust temperatures for the vertical storage modules, located at the Independent Spent Fuel Storage Installation (ISFSI) facility at VY. The inspectors toured the facility and made independent radiation measurements at the facility. The inspectors reviewed monitoring data from the TLDs on the owner controlled area fence, dose rates from the ISFSI radiation surveys, and temperature readings on the exhaust vents at the vertical storage modules. The inspectors evaluated the data against 10 CFR 20, the ISFSI TS, and applicable Entergy procedures.
b. Findings
No findings were identified.
4OA6 Meetings, including Exit
On July 12, the inspectors presented the radiation safety baseline inspection results to Mr. Christopher Wamser, Site Vice President, and other members of the Entergy staff.
The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On July 19, the inspectors presented the Temporary Instruction 2515/182, Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks, Phase 1, inspection results to Mr. Michael Gosekamp, General Manager of Plant Operations, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On July 27, the inspectors presented the licensed operator requalification inspection results to Mr. Kevin Stupak, Manager of Training and Development, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On August 17, the inspectors presented the automatic depressurization system actuator leakage annual sample inspection results to Mr. Michael Romeo, Director of Nuclear Safety Assurance, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On September 14, 2012, the inspectors presented the emergency preparedness program inspection results to Mr. Christopher Wamser, Site Vice President, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On October 15, the inspectors presented the inspection results to Mr. Michael Gosekamp, General Manager of Plant Operations, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel
- C. Wamser, Site Vice President
- M. Gosekamp, General Manager of Plant Operations
- M. Romeo, Director of Nuclear Safety
- K. Stupak, Manager, Training and Development
- G. Wierzbewski, Acting Engineering Director
- S. Aprea, Shift Manager
- J. Bengtson, CA&A Manager
- R. Busick, Asst. Operations Manager
- T. Capelletti, Mechanical Superintendent
- M. Castronova, Manager of Projects
- P. Corbett, Quality Assurance Manager
- D. Deer, Control Room Supervisor
- V. Ferrizzi, Shift Manager
- S. Goodman, Mechanical Maintenance Supervisor
- J. Hardy, Chemistry Manager
- E. Harms, Asst. Operations Manager
- R. Heathwaite, Chemistry Supervisor
- D. Jones, Operations Manager
- M. McKenney, Emergency Preparedness Manager
- P. McKenney, Material, Purchasing and Contracts Manager
- J. Rogers, Design Engineering Manager
- P. Ryan, Security Manager
- K. Sweet, Programs and Components Engineering Supervisor
- J. Taylor, Operations Training Superintendent
- D. Tkatch, Radiation Protection Manager
- R. Wanczyk, Licensing Manager
- K. Whippie, Chemistry Supervisor
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
- 05000271/2012004-01 FIN Incorrect Assessment of Equipment Condition Resulted in Single Recirculating Loop Operation (Section 1R12)
- 05000271/2012004-02 NCV Dedicated Operators Required for Operability under Applied Administrative Controls Left Immediate Vicinity of Open Valves (Section 1R22)