Text

IR 05000271-12-005, on 10/01/2012 - 12/31/2012, Vermont Yankee Nuclear Power Station - NRC Integrated Inspection Report
	ML13030A147
Person / Time
Site:	Vermont Yankee
Issue date:	01/30/2013
From:	Bellamy R; NRC/RGN-I/DRP/PB5
To:	Wamser C; Entergy Nuclear Operations
	BELLAMY, RR
References
	IR-12-005
	Download: ML13030A147 (36)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION ary 30, 2013

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000271/2012005

Dear Mr. Wamser:

On December 31, 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 January 23, 2013 with you 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.

The enclosed inspection report discusses a finding whose significance has not been determined. As described in Section 1R19, a self-revealing apparent violation of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, was identified because you did not promptly correct an adverse condition which later resulted in the failure of the B emergency diesel generator. Specifically, a degraded jacket water flange gasket was not promptly replaced and subsequently failed. The finding does not present an immediate safety concern because the failed component was replaced and no similar degradation is present on related components.

The final resolution of this finding will be conveyed in separate correspondence.

Since the NRC has not made a final determination in this matter, no violation is being issued for this inspection finding at this time. In addition, please be advised that the characterization may change as a result of further NRC review.

Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. 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 violations or significance of the NCV, 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. If you disagree with the cross-cutting aspect assignment 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 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 Agencywide Document Access and Management 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. DPR-28

Enclosure:

Inspection Report No. 05000271/2012005 w/ Attachment: Supplementary Information

REGION I==

Docket No.: 50-271 License No.: DPR-28 Report No.: 05000271/2012005 Licensee: Entergy Nuclear Operations, Inc.

Facility: Vermont Yankee Nuclear Power Station Location: Vernon, Vermont 05354-9766 Dates: October 1, 2012 through December 31, 2012 Inspectors: S. Rutenkroger, PhD, Senior Resident Inspector, Division of Reactor Projects (DRP)

S. Rich, Resident Inspector, DRP J. DeBoer, Acting Resident Inspector, DRP C. Newport, Operations Engineer, Division of Reactor Safety (DRS)

J. Furia, Health Physicist, DRS E. Keighley, Project Engineer, DRP J. Laughlin, Emergency Preparedness Inspector, Office of Nuclear Security and Incident Response Approved by: Ronald R. Bellamy, PhD, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000271/2012005; 10/01/2012 - 12/31/2012; Vermont Yankee Nuclear Power Station;

Post-Maintenance Testing.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One finding whose significance has not yet been determined was identified. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process dated June 2, 2011. The cross-cutting aspect for the finding was determined using IMC 0310, Components Within Cross-Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 7, 2012. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.

Cornerstone: Mitigating Systems

TBD. A self-revealing apparent violation (AV) of 10 CFR 50 Appendix B, Criterion XVI,

Corrective Action, was identified because Entergy did not promptly correct an adverse condition resulting in the failure of the B emergency diesel generator. Specifically, Entergy personnel did not promptly replace a degraded jacket water flange gasket prior to its subsequent failure. Entergys corrective actions included replacing the gasket, visually inspecting the other jacket water connections, and initiating condition report CR-VTY-2012-05044.

The finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the B emergency diesel generator failed in service due to a known degraded condition that affected the overall system redundancy and reliability and resulted in 37 days of unplanned unavailability. The significance of the finding is designated as To Be Determined (TBD) until a Phase 3 analysis can be completed. The finding had a cross-cutting aspect in the Human Performance,

Decision-Making because Entergy personnel did not use conservative assumptions in decision making in that the chosen action was to monitor the leak for a prolonged period of time H.1(b). (Section 1R19)

REPORT DETAILS

Summary of Plant Status

Vermont Yankee Nuclear Power Station (VY) began the inspection period operating at 100 percent power. On November 5, operators reduced power to 31 percent to support single-loop operation and replace brushes on the B recirculation pump motor-generator set and install a temporary clamp to address a steam leak at the orifice flange gasket for the high pressure turbine inlet drain line. Operators returned VY to 100 percent power on November 7. On November 8, operators reduced power to 69 percent for a control rod pattern adjustment and returned VY to 100 percent power the following day. On December 7, operators reduced power to 70 percent for a control rod pattern adjustment and returned VY to 100 percent power the same day. On December 30, operators reduced power to 79 percent for a control rod pattern adjustment and returned VY to 100 percent power the same 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

Main article: IP 71111.01

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of Entergys readiness for the onset of seasonal cold temperatures. The review focused on the intake structure, reactor building, and turbine building. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR),technical specifications (TS), control room logs, and the corrective action program to determine what tempera-tures 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 areas to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

Partial System Walkdowns (71111.04Q - 4 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Reactor core isolation cooling system during A emergency diesel generator (EDG)surveillance testing on October 4 1A uninterruptible power supply during 1B uninterruptible power supply maintenance on October 22 B standby gas treatment during A standby gas treatment planned maintenance on November 29 B EDG during planned maintenance on the B service water strainer on December 4 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 (CRs), 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.

1R05 Fire Protection

Main article: IP 71111.05

Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)

a. Inspection Scope

Main article: IP 71111.12

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.

Standby liquid control Automatic depressurization Demineralized water

b. Findings

In addition, the inspectors reviewed documents associated with the leak repair, the implementing work order, and the post repair monitoring to verify the work was performed without impact to plant safety and reactor coolant chemistry. The inspectors also interviewed engineering and chemistry personnel involved with the repair.

The inspectors evaluated a modification that approved the use of a single cell battery charger used to charge cells of safety related batteries. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed documents associated with the construction, approval, and procedural control of portable single cell battery chargers. The inspectors also interviewed engineering, operations, and maintenance personnel regarding the design, control, and maintenance of the chargers.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

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.

B EDG jacket water gasket replacement on October 16 1B uninterruptible power supply maintenance on October 22 and 23 Cooling tower fan CT-2-1 maintenance on October 31 Reactor core isolation cooling pump maintenance on November 15 High pressure coolant injection pump maintenance and over-speed trip testing on December 12

b. Findings

Introduction.

A self-revealing AV of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, was identified because Entergy did not promptly correct an adverse condition resulting in the failure of the B EDG. Specifically, Entergy personnel did not promptly replace a degraded jacket water flange gasket prior to its subsequent failure.

Description.

On April 16, Entergy personnel identified a small jacket water leak on the B EDG during a monthly surveillance run. Once the diesel was running, Entergy personnel identified six drops per minute leaking from the number five opposite control side jacket water outlet jumper to header flanged gasket connection and initiated CR-VTY-2012-01772. The leak stopped after 30 minutes of operation, and the diesel was operated for about three hours.

Jacket water cools the diesel engine by circulating jacket water in a closed system with a capacity that is maintained via an expansion tank. The expansion tank is maintained at least one-half full, representing over 28 gallons of additional jacket water available for the system. However, during a design basis event, the demineralized water system does not provide additional makeup water to the expansion tank. Entergy staff declared the B EDG operable based on the small rate of the leak relative to the available jacket water contained within the expansion tank. Entergy closed CR-VTY-2012-01722 to the work management process stating that the issue did not represent an adverse condition that is required to be corrected within the corrective action process. Entergy personnel monitored the leak during subsequent monthly surveillances, and the characterization remained unchanged.

On October 15, during a monthly surveillance run that started at 9:36 am, the leak commenced upon diesel start as usual, but appeared to be larger and variable in rate during the initial loading process and did not stop once the system was heated.

Subsequently, the gasket failed, resulting in a steady, pressurized stream of jacket water. The operators promptly unloaded and secured the B EDG at 10:05 am. The inspectors interviewed auxiliary operators who estimated the final leak rate at one gallon of water every ten minutes. After replacing the gasket, Entergy restored the B EDG to operable status on October 16 at 6:55 pm.

The inspectors reviewed the apparent cause evaluation and concluded the gasket connection had failed once the jacket water system cooled during the last successful surveillance on September 10, representing 37 days of unavailability. The inspectors did not find specific operating experience for sudden failures of these gasketed connections. However, the inspectors concluded that sudden failure of a leaking gasketed connection that was not designed or expected to leak is a generally reasonable outcome to foresee given sufficient time and/or system perturbations, and the time from April 16 to September 10 exceeded a reasonable time for prompt corrective action.

The inspectors determined that the original leak was a condition that could credibly impact nuclear safety, and therefore was a condition adverse to quality, in accordance with EN-LI-102, Corrective Action Process. EN-LI-102 requires conditions adverse to quality to be addressed in a manner that ensures timely correction of the originally identified condition. The inspectors also noted that EN-OP-104, Operability Determination Process, provides permissible classifications for operability with the closest example referring to oil leakage, a closed system with a limited reservoir capacity, from safety-related equipment that is assumed to require extended operation per the UFSAR. The inspectors determined that Entergys operability classification of Operable rather than Operable-Op Eval was not in accordance with EN-OP-104 and Entergys closure of the condition report citing no adverse condition and a work request was not in accordance with EN-LI-102.

Entergys corrective actions included replacing the gasket, visually inspecting the other jacket water connections, confirming no other similar leaks were present on either the A or B EDG, and initiating CR-VTY-2012-05044.

Analysis.

The inspectors determined that Entergy personnels decision not to repair the leaking jacket water outlet jumper to header flanged gasket connection prior to its failure in service was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented. The finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the B EDG failed in service due to a known degraded condition that affected the overall system redundancy and reliability and resulted in 37 days of unplanned unavailability.

In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, this finding required a phase 3 analysis because the issue resulted in an actual loss of function of the B EDG for longer than its Technical Specification allowed outage time.

The finding does not present an immediate safety concern because the failed gasket was replaced on the B EDG. The significance of this finding is To Be Determined (TBD) because the phase 3 analysis was not completed at the time of inspection report issuance.

The inspectors determined that the finding had a cross-cutting aspect in the Human Performance, Decision-Making because Entergy personnel did not use conservative assumptions in decision making in that the chosen action was to monitor the leak for a prolonged period of time instead of replacing the gasket H.1(b).

Enforcement.

10 CFR 50 Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, from September 10, 2012, to October 15, 2012, Entergy failed to promptly correct the deficient number five opposite control side jacket water outlet jumper to header flanged gasket connection. Entergys corrective action to restore compliance consisted of replacing the gasketed connection on October 15. Entergy entered the issue into the corrective action program (CR-VTY-2012-05044). The significance of this finding is TBD until completion of the Phase 3 analysis. (AV 05000271/2012005-01, Failure of the B Emergency Diesel Generator from Jacket Water Leakage Due to Inadequate Corrective Action)

1R22 Surveillance Testing

Main article: IP 71111.22

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 the 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:

A residual heat removal service water pump and valve quarterly surveillance on October 10 (in-service test)

A residual heat removal pump quarterly surveillance on October 10 (in-service test)

C service water pump quarterly surveillance on November 7 (in-service test)

Reactor core isolation cooling pump quarterly surveillance on November 8 (in-service test)

Reactivity anomalies equivalent full-power monthly surveillance on December 20

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes (IP

==71114.04 - 1 sample)

a. Inspection Scope

==

The Office of Nuclear Security and Incident Response headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession numbers ML12188A101, ML12193A233, ML12152A053, and ML12311A113.

Entergy determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational/Public Radiation Safety (PS)

2RS1 Radiological Hazard Assessment and Exposure Controls

Main article: IP 71124.01

a. Inspection Scope

During the week of November 12 to 16, the inspectors reviewed and assessed Entergys performance in assessing and implementing controls associated with radiological hazards in the workplace. The inspectors used the requirements in 10 CFR 20, Standards for Protection Against Radiation, Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas for Nuclear Plants, the TS, and Entergys procedures as criteria for determining compliance.

The inspectors reviewed the Occupational Exposure Control Effectiveness performance indicator (PI), the results of radiation protection program audits, and reports of operational occurrences related to occupational radiation safety since the last inspection.

The inspectors reviewed and observed plant operations to determine whether plant changes may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors verified that Entergy assessed the potential impact of changes and implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard.

The inspectors conducted walk downs of the facility, including radioactive waste processing, storage, and handling areas to evaluate material conditions and potential radiological conditions.

The inspectors reviewed radiation work permits (RWPs) used to access high radiation areas (HRAs) and reviewed the work control instructions or control barriers that were specified. The inspectors verified that allowable stay time or permissible dose for radiologically significant work under each RWP was clearly identified. The inspectors verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and Entergy policy.

During tours of the facility and review of ongoing work the inspectors evaluated ambient radiological conditions. The inspectors verified that existing conditions were consistent with posted surveys, RWPs, and worker briefings, as applicable.

During job performance observations, the inspectors verified the adequacy of radiological controls, such as required surveys, radiation protection job coverage, and contamination controls. The inspectors evaluated Entergys means of using EPDs in high noise areas as HRA monitoring devices.

b. Findings

No findings were identified.

2RS2 Occupational As Low As is Reasonably Achievable Planning and Controls

Main article: IP 71124.02

a. Inspection Scope

During the week of November 12 to 16, the inspectors assessed Entergys performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR 20, Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be As Low As Reasonably Achievable, Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure As Low as Reasonably Achievable, TS, and Entergys procedures as criteria for determining compliance.

The inspectors reviewed pertinent information regarding VYs collective dose history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors reviewed VYs three year rolling average collective exposure. The inspectors evaluated the site-specific trends in collective exposures and source term measurements.

The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA, which included a review of processes used to estimate and track exposures from specific work activities. The inspectors selected ALARA work packages and evaluated the assumptions and basis for the current annual collective exposure estimate for reasonable accuracy. The inspectors reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and department and station dose goals.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

Main article: IP 71124.05

a. Inspection Scope

During the week of November 12 to 16, the inspectors verified that Entergy was ensuring the accuracy and operability of radiation monitoring instruments used to monitor areas, materials, and workers to ensure a radiologically safe work environment and detect and quantify radioactive process streams and effluent releases to protect members of the public. The inspectors used the requirements in 10 CFR 20; 10 CFR 50, Appendix A, Criterion 60, Control of Releases of Radioactive Materials to the Environment; 10 CFR 50, Appendix A, Criterion 64, Monitoring Radioactivity Releases; 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water - Cooled Nuclear Power Reactor Effluents; 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations; NUREG-0737, Clarification of TMI Action Plan Requirements; TS; VYs Offsite Dose Calculation Manual; and Entergys procedures as criteria for determining compliance.

The inspectors selected portable survey instruments in use or available for issuance.

The inspectors verified calibration and source check stickers for currency and assessed material condition and operability. The inspectors walked down area radiation monitors and continuous air monitors and verified that they were appropriately positioned relative to the radiation sources or areas they were intended to monitor. The inspectors selected personnel contamination monitors (PCMs) and small article monitors and verified that the periodic source checks were performed in accordance with the manufacturers recommendations and Entergys procedures.

The inspectors verified that problems associated with radiation monitoring instrument-tation were being identified by Entergy at an appropriate threshold and were properly addressed for resolution in the corrective action program.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

Main article: IP 71151

.1 Mitigating Systems Performance Index (3 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:

Emergency AC Power Residual Heat Removal System Cooling Water System

b. Findings

No findings were identified.

.2 Occupational Radiation Safety Cornerstone (1 sample)

a. Inspection Scope

The inspectors reviewed a listing of condition reports for issues related to the Occupational Exposure Control Effectiveness performance indicator, which measures non-conformances with high radiation areas greater than 1 Roentgen/hour (R/hr) and unplanned personnel exposures greater than 100 millirem (mrem) total effective dose equivalent, 5 rem skin dose equivalent, 1.5 rem lens dose equivalent, or 100 mrem to the unborn child. The inspectors determined that no PI events for Occupational Exposure Control Effectiveness had occurred during the assessment period.

b. Findings

No findings were identified.

.3 Public Radiation Safety Cornerstone (1 sample)

b. Findings and Observations

No findings were identified.

In the second quarter 2012, NRC integrated inspection report 05000271/2012003, ML12208A067, the inspectors documented an emerging trend due to an increased number of instances in which potentially adverse conditions were documented and/or recognized by Entergy staff without initiating a CR in accordance with EN-LI-102, Corrective Action Process. Entergy initiated CR-VTY-2012-03585, performed an apparent cause evaluation, and completed corrective actions related to personnel initiating condition reports. The inspectors determined that there was a significant reduction in the number of such instances and that this emerging trend was appropriately resolved during the third and fourth quarters of 2012.

The inspectors noted that Entergy personnel had appropriately identified an adverse trend with component mispositioning in the Operations department documented in CR-VTY-2012-05493. The inspectors reviewed related CRs during 2012 and concurred that an adverse trend existed in human performance errors causing mispositioned components. The inspectors confirmed that the individual errors represented minor safety significance and verified that ongoing corrective actions were established to resolve the issue.

.3 Annual Sample: Review of Human Error Prevention Corrective Actions

a. Inspection Scope

The inspectors performed an in-depth review of Entergys evaluation and corrective actions associated with three human performance events that involved a loss of shutdown cooling on November 11, 2011, a protective tagging removal associated with the B EDG resulting in unprotected personnel and unprotected plant equipment on December 2, 2011, and a trip of the A EDG fuel rack on December 2, 2011.

To determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with these issues, the inspectors assessed Entergys:

problem identification threshold; root cause analysis for each of the three events; extent of condition reviews; and the prioritization, timeliness, and adequacy of corrective actions. The inspectors reviewed Entergys root cause evaluation for each of the events, interviewed operations and maintenance personnel, conducted walkdowns of selected systems and equipment, conducted a trend review for human performance events occurring subsequent to the initial human performance events, and reviewed Entergys corrective action process procedures and close-out documentation.

b. Findings and Observations

No findings were identified.

On November 11, 2011, during the planned maintenance outage, plant personnel inadvertently isolated power to the shutdown cooling pumps while hanging an unrelated tagout. The plant subsequently lost the primary means of shutdown cooling for approximately 12 minutes. Entergys root cause evaluation (CR-VTY-2011-04203)determined that the primary cause of the event was a combination of lack of clarity in plant equipment nomenclature and human error.

On December 12, 2011, while clearing a tagout during a planned maintenance outage of the B EDG, plant personnel inadvertently placed the B EDG in a condition allowing the engine to potentially auto start while work was still ongoing. Additionally, during the restoration of the B EDG to a safe condition, plant personnel inadvertently tripped the A EDG fuel rack, causing the unavailability of both EDGs for approximately 2 minutes.

Entergys root cause evaluations for the two events (CR-VTY-2011-05646 and CR-VTY-2011-05483) determined the cause to be a combination of inadequate procedural guidance and human error.

The inspectors determined that Entergys evaluation of the events appropriately identified the root and contributing causes. Additionally, the inspectors determined that the immediate and long term corrective actions developed as a result of the root cause evaluations were effective and adequate to correct the root and contributing causes and reasonably prevent recurrence. The inspectors conducted a review of related CRs generated in the ten months subsequent to the event, performed walkdowns of plant equipment, and interviewed personnel from the operations and maintenance departments and concluded that the corrective actions were being effectively implemented.

.4 Annual Sample: Review of Corrective Actions Related to a 10 CFR Part 21 Issued by

GE Hitachi that Identified Inadequate Circuit breaker Shoulder Bolts and Lock Washers

a. Inspection Scope

The inspectors performed an in-depth review of the adequacy of Entergys response to a 10 CFR 21, Reporting of Defects and Noncompliance, report on a potential deficiency on identified circuit breaker shoulder bolts and lock washers for GE Hitachi medium voltage circuit breakers (CR-VTY-2011-04793). Specifically, GE identified the potential for the medium voltage breakers to fail to trip when called upon in the plant. Entergy had seven of the kits identified in GEs report, five of which were already installed. One of these five was on a safety-related breaker. The inspectors evaluated whether Entergy had taken appropriate corrective actions to prevent a failure of these breakers as a result of the deficiency. Additionally, the inspectors reviewed the operability determination performed by Entergy that determined all breakers with the identified kits remained operable.

The inspectors interviewed plant personnel and reviewed test procedure results, CRs, engineering evaluations, and manufacturer data to assess Entergys problem identification, evaluation, and corrective action effectiveness with respect to the affected medium voltage breakers ability to close when necessary. Additionally, the inspectors reviewed the TS, the UFSAR, and VY licensing documents to determine the uses of the medium voltage breakers that had the potentially deficient kits installed. Finally, the inspectors evaluated whether the conclusions made by Entergy following identification of the potentially degraded condition provided reasonable assurance of the ability of the breakers to close and perform their safety related actions such that the system remained operable.

b. Findings and Observations

No findings were identified.

Entergy installed the washer and bolt kits in 2010 and 2011. During installation of one kit in 2011, Entergy personnel identified that the bolt could not be torqued to the required amount in accordance with the procedure. As a result, Entergy identified that the bolt was not threaded per specifications and notified GE Hitachi of the potential for a required 10 CFR 21 notification. When the report was issued, Entergy identified five kits that were installed on in-service breakers. Entergy reviewed the procedure for breaker overhauls and determined that the included torque requirement would have identified an unacceptable condition on any other kits. In addition, Entergy personnel cycle breakers after overhauls several times such that an unacceptable condition would also be identified from the cycling. In addition, the safety related breaker had been successfully cycled after installation in the plant. Therefore, Entergy concluded that there was reasonable assurance that the installed kits were not affected by this deficiency. The inspectors reviewed the evaluations performed by Entergy that assessed past operability of the breakers and concurred with the assessment and corrective actions to install conforming kits at the next scheduled breaker overhauls.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 (Closed) LER 05000271/2012-001-00 and 05000271/2012-001-01, Potential to Flood

Switchgear Room Due to Missing Conduit Flood Seal On May 16, Entergy personnel performed a periodic manhole flood seal inspection and discovered a spare four inch conduit that was missing a flood seal. The personnel installed a new seal on the same day. On May 24, Entergy personnel performed a follow-up inspection at the other end of the spare conduit in the manhole located in the switchgear rooms and confirmed that a flood seal was not installed on that end of the conduit.

The missing flood seal was previously inspected on November 2, 2010 and was found to be in place at that time. Entergy personnel determined that the flood seal specified for use in the conduit did not provide an adequate seal to prevent the flood seal from loosening and becoming dislodged. However, the UFSAR describes that the maximum flood level at VY would reach a maximum elevation of 252.5 feet, at a time of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> into the precipitation event. VYs procedures require the operators to shutdown the plant if river elevation exceeds 230 feet with deteriorating conditions. In addition, the procedures require monitoring of the switchgear manholes and staging of portable pumps in the switchgear room which are tested and maintained available.

Entergy replaced the mechanical seal with a silicone elastomer seal. The enforcement aspects of this issue are discussed in Section 4OA7. The inspectors did not identify any new issues during the review of the LER. This LER is closed.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/187 - Inspection of Near-Term Task Force

Recommendation 2.3 Flooding Walkdowns

a. Inspection Scope

The inspectors verified that Entergys walkdown packages for the east and west switchgear rooms, the simulations of temporary flood protection feature installation, and the B emergency diesel generator room contained the elements as specified in Nuclear Energy Institute (NEI) 12-07, Walkdown Guidance document.

The inspectors accompanied Entergy personnel on their walkdown of the east and west switchgear rooms and verified that Entergy confirmed the following flood protection features:

External visual inspections for indications of degradation of the flood protection features were performed of the flood seals in the walls For the flood seals on the electrical conduits, past inspections were appropriately credited Critical SSC dimensions were measured, including openings above the design basis flood level Available physical margin, where applicable, was determined Temporary flood protection feature functionality was determined using either visual observation or by review of other documents A reasonable simulation of temporary flood protection feature installation was performed The inspectors independently performed their walkdown of the B emergency diesel generator room and verified that the flood seals on floor penetrations were in place and showed no signs of degradation. The inspectors also verified that all penetrations appeared on the design drawings.

The inspectors verified that non-compliances with current licensing requirements, and issues identified in accordance with the 10 CFR 50.54(f) letter, Item 2.g of Enclosure 4, were entered into Entergys corrective action program. In addition, issues identified in response to Item 2.g that could challenge risk significant equipment and Entergys ability to mitigate the consequences will be subject to additional NRC evaluation.

b. Findings

No findings were identified.

.2 (Closed) Temporary Instruction 2515/188 - Inspection of Near-Term Task Force

Recommendation 2.3 Seismic Walkdowns

a. Inspection Scope

The inspectors accompanied Entergy personnel on their seismic walkdowns on October 1, 2, and 11, in the A emergency diesel generator room and associated day tank room and the reactor building, 252 foot elevation, and verified that Entergy confirmed that the following seismic features associated with the A emergency diesel generator neutral transformer cabinet, the 480 volt alternating current motor control center MCC-9C, the 125 volt direct current station battery on bus DC-2AS, and the nitrogen bottles for backup safety relief valve supply, were free of potential adverse seismic conditions:

Anchorage was free of bent, broken, missing or loose hardware Anchorage was free of corrosion that is more than mild surface oxidation Anchorage was free of visible cracks in the concrete near the anchors Anchorage configuration was consistent with plant documentation SSCs will not be damaged from impact by nearby equipment or structures Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls are secure and not likely to collapse onto the equipment Attached lines have adequate flexibility to avoid damage The area appears to be free of potentially adverse seismic interactions that could cause flooding or spray in the area The area appears to be free of potentially adverse seismic interactions that could cause a fire in the area The area appears to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding).

The inspectors independently performed their walkdowns on November 16, 21, and 22 and verified that the C service water pump in the intake structure service water pump room, the B containment air dilution panel in the control room, and the fuel oil storage tank in the yard and fuel oil storage tank enclosure, were free of potential adverse seismic conditions listed above.

The inspectors verified that Entergy entered adverse conditions into the corrective action program for evaluation. Additionally, the inspectors verified that items that could allow the spent fuel pool to drain down rapidly were added to the seismic walkdown equipment list and these items were walked down by Entergy.

b. Findings

No findings were identified.

4OA6 Meetings, including Exit

On November 16, the inspector presented the radiation safety inspection results to Mr.

Scott Dorval, Acting Radiation Protection Manager, 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 January 23, the inspectors presented the 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.

4OA7 Licensee Identified Violations

The following violation of very low safety significance (Green) was identified by Entergy and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that the design basis is correctly translated into specifications. Contrary to the above, the design basis was not correctly translated into specifications in that the specification for the mechanical flood seal used in spare four inch conduit was not adequate such that a design basis flood could have penetrated the conduit and allowed water intrusion into the switchgear rooms. Entergy entered this issue into the corrective action program as CR-VTY-2012-02391. The inspectors determined that the finding was of very low safety significance (Green) because the missing conduit seal would not cause a plant trip or an initiating event, degrade two or more trains of a multi-train system, degrade one or more trains of a system that supports a risk significant system, or involve the total loss of any safety function. Specifically, Entergy procedures direct a plant shutdown and staging of portable pumps to remove water from the manholes within the switchgear rooms during a design basis flood. The calculated flow rate of water through the conduit was bounded by the capacity of the two portable pumps.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Vermont Yankee Personnel

C. Wamser, Site Vice President

M. Richey, General Acting Manager of Plant Operations

V. Fallacara, General Manager of Plant Operations

M. Romeo, Director of Nuclear Safety

J. Boyle, Engineering Director

J. Bengtson, CA&A Manager

W. Bliss, Auxiliary Operator

R. Busick, Asst. Operations Manager

P. Corbett, Quality Assurance Manager

S. Dorval, Acting Radiation Protection Manager

J. Hardy, Chemistry Manager

E. Harms, Asst. Operations Manager

D. Hensel, Work Week Manager

D. Jones, Operations Manager

T. Marstaller, Shift Manager

M. McKenney, Emergency Preparedness Manager

J. Mully, System Engineer

J. Rogers, Design Engineering Manager

G. Ruczko, Auxiliary Operator

P. Ryan, Security Manager

K. Stupak, Manager, Training and Development

D. Tkatch, Radiation Protection Manager

R. Wanczyk, Licensing Manager

A. Zander, Shift Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000271/2012005-01 AV Failure of the B Emergency Diesel Generator from Jacket Water Leakage Due to Inadequate Corrective Action (Section 1R19)

Closed

05000271/2012-001- LER Potential to Flood Switchgear Room Due to 00&01 Missing Conduit Flood Seal (Section 4OA3)

05000271/2515/187 TI Inspections of Near-Term Task Force Recommendation 2.3 - Flooding Walkdowns (Section 4OA5)

05000271/2515/188 TI Inspections of Near-Term Task Force Recommendation 2.3 - Seismic Walkdowns (Section 4OA5)

LIST OF DOCUMENTS REVIEWED