Text

IR 05000271-14-005; 10/01/2014 - 12/31/2014; Vermont Yankee Nuclear Power Station (Vy); Fire Protection, Drill Evaluation, and Follow-up of Events and Notices of Enforcement Discretion
	ML15041A558
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/10/2015
From:	Raymond Mckinley; NRC/RGN-I/DRP/PB5
To:	Wamser C; Entergy Nuclear Operations
	McKinley R
References
	IR 2014005
	Download: ML15041A558 (38)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 February 10, 2015 Mr. Christopher Wamser Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station Vernon, VT 05354 SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000271/2014005

Dear Mr. Wamser:

On December 31, 2014, 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 15, 2015, 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.

This report documents three violations of NRC requirements, all of which were of very low safety significance (Green). However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violations 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, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Vermont Yankee Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, or a finding not associated with a regulatory requirement, 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 Resident Inspector at Vermont Yankee Nuclear Power Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents 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/

Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-271 License No. DPR-28

Enclosures:

Inspection Report 05000271/2014005 w/ Attachment: Supplementary Information

REGION I==

Docket No. 50-271 License No. DPR-28 Report No. 05000271/2014005 Licensee: Entergy Nuclear Operations, Inc. (Entergy)

Facility: Vermont Yankee Nuclear Power Station Location: Vernon, VT 05354 Dates: October 1, 2014 through December 31, 2014 Inspectors: S. Rutenkroger, PhD, Senior Resident Inspector, Division of Reactor Projects (DRP)

S. Rich, Resident Inspector, DRP B. Scrabeck, Resident Inspector, DRP N. Day, Project Engineer, DRP J. Brand, Reactor Inspector, Division of Reactor Safety (DRS)

J. Furia, Senior Health Physicist, DRS Approved by: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

IR 05000271/2014005; 10/01/2014 - 12/31/2014; Vermont Yankee Nuclear Power Station (VY);

Fire Protection, Drill Evaluation, and Follow-up of Events and Notices of Enforcement Discretion.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three findings of very low safety significance (Green and/or Severity Level IV), which were non-cited violations (NCVs).

The significance of most findings is indicated by their color (i.e., greater than Green, or Green,

White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 19, 2012. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of operating license condition 3.F, Fire Protection Program, because Entergy did not implement and maintain in effect all provisions of the NRC approved fire protection program. Specifically, Entergy did not implement and maintain the required compensatory continuous fire watch in the east and west switchgear rooms when the fire detection and suppression systems were not functional for planned maintenance. Entergys corrective actions included stationing separate continuous fire watches in the east and west switchgear rooms, initiating condition report CR-VTY-2014-4019, communicating and reinforcing the fire watch requirements with all operating crews and maintenance personnel, and initiating additional training.

This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the east and west switchgear rooms are separate fire areas each containing separated trains of Appendix R safe shutdown equipment which are required to respond to initiating events to prevent undesirable consequences and the implemented compensatory fire watches were less than required by the fire protection program. The inspectors used IMC 0609, Appendix F, Fire Protection Significance Determination Process, to analyze this finding because the condition had an adverse effect on the Fire Prevention and Administrative Controls Program element in accordance with the degradation rating guidance. The inspectors determined that the finding screened as Green because the impact of the fire finding was limited to no more than one train of equipment important to safety at any given time. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution,

Resolution, because Entergy did not take effective corrective actions when this issue was self-identified in a condition report on January 5, 2013. [P.3]

Green.

The inspectors identified a self-revealing Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy did not properly implement the prescribed maintenance instructions during the installation of the copper o-ring to the Kiene valve adapter of cylinder number six of the A emergency diesel generator (EDG) on June 25, 1992. Entergys corrective actions included initiating condition report CR-VTY-2014-3503, performing a root cause evaluation, and removing and reinstalling the number six cylinder adapters using new copper o-ring gaskets with the correct applied torque. Entergy restored the A EDG to operable status on October 2, 2014. Entergy also performed cylinder air testing of all cylinders on both A and B EDGs to ensure no other leaks existed.

This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to properly install the Kiene valve adapter on June 25, 1992, resulted in the A EDG failing to start on September 29, 2014, during a quarterly surveillance.

Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that this finding required a detailed risk evaluation (DRE) because the failure of the A EDG to start on September 29, 2014, represented an actual loss of function of a single train of emergency alternating current power for greater than the technical specification allowed outage time. The Region I senior reactor analyst (SRA) used the Systems Analysis Programs for Hands-On Evaluation (SAPHIRE) Revision 8.1.0 and the Standardized Plant Analysis Risk (SPAR) Model for VY,

Version 8.19, to conduct the internal events DRE and VYs Individual Plant Examination (IPE) for Severe Accident Vulnerabilities and the Individual Plant Evaluation External Events (IPEEE) to assess the external events risk contribution for this performance deficiency. The SRA made the following assumptions and SPAR model changes to best represent the condition of the A EDG:

The exposure time was estimated using T/2 because the actual date and time the EDG became inoperable is indeterminate based upon the uncertainty of gasket coolant leak rate into the cylinder. The time between the last successful operation of the EDG and the observed failure was 36 days. Therefore, T/2 most accurately approximates the postulated exposure time, T/2 = 36/2= 18 days. Adding the unavailability time due to corrective maintenance, the total exposure time for this finding is 21 days.

Basic event EPS-DGN-FS-DGA, Diesel Generator A Fails to Start, was set to True, consistent with the Risk Assessment Standardization Project guidance, to reflect the potential for a common cause failure mechanism of both the A and B EDGs.

Based upon the observed success of plant staff to recover the EDG following the failure to start event on September 29, 2014, and the available procedure guidance and training, the SRA assumed recovery of the A EDG could reasonably be achieved under accident conditions. Accordingly, the EDG recovery basis event,

EPS-XHE-XL-NR01H, nominal probability (8.71E-1) was revised to 0.1 (1 in 10 chance of not successfully recovering the EDG).

Based upon the above stated assumptions, the increase in internal risk core damage frequency (delta CDF) associated with this performance deficiency is in the mid E-7 range, or very low safety significance (Green). The SRA examined the IPEEE and associated fire safe shutdown analysis/procedures to determine the external event risk contribution due to this finding. The SRA determined that the A EDG is credited for safe shutdown in the event a fire compromises the West Switchgear Room. Assuming worst case fire conditions, without suppression, the external fire contribution per IPEEE, Table 4.10.1 would be approximately 3.4E-7 (5.9E-6 X 21/365). The SRA also determined that the unavailability of the A EDG has no appreciable impact on seismic, flooding, and high winds associated mitigation capability. Combining the internal and external risk contributions yields a total delta CDF of high E-7 (Green). Based upon a review of the dominant cutsets (loss of offsite power initiating events with subsequent failures of high pressure injection and depressurization), the unavailability of the A EDG may result in an increased risk associated with a Large Early Release Frequency (LERF). The SRA used a 0.1 LERF factor to account for the probability that operators would procedurally take action to mitigate the consequences of a potential containment breach due to these postulated high pressure accident sequences. Consequently, the delta LERF for this finding is high E-8 (Green).

The inspectors determined that the finding did not have a cross-cutting aspect because the performance deficiency did not occur within the last three years and would not likely occur today under similar circumstances.

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a Green NCV of 10 CFR 50.54(q), Emergency Plans, because Entergys emergency action level (EAL) classification process could result in a misclassification, a deficiency related to a risk significant planning standard. Specifically,

Entergy personnel failed to correctly classify emergency conditions during an emergency preparedness drill using the applicable EAL criteria. Entergy initiated CR-VTY-2014-3990 for not recognizing the proper application of Note 1 contained in EAL AG1.1, and subsequently trained operating crews and emergency response organization (ERO)decision makers on the basis and intent of Note 1. Entergy reviewed the implementing procedures and associated basis documents and determined that applicable procedures and guidance properly described and implemented the required hierarchy of EAL AG1.1 and EAL AG1.2.

This finding is more than minor because it is associated with the ERO attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective of ensuring that Entergy is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the failure to establish an adequate EAL classification process could result in a general emergency (GE)declaration when a GE is not warranted. The inspectors determined the significance of the finding using IMC 0609, Appendix B, "Emergency Preparedness Significance Determination Process." The finding was determined to be of very low safety significance (Green) because of the following:

the drill scenario and applicable sequence of EALs applied solely to damage to spent fuel which has a lower volatile radiological inventory than fuel in the reactor, the language in EAL AG 1.1 Note 1 uses the word "should" rather than "shall," and the EAL scheme provides for the use of judgment when meeting an EAL threshold is believed to be imminent, and the likelihood of actual emergency conditions reaching EAL AG1.1 and not reaching EAL AG1.2 is considered very low.

Specifically, the inspectors considered the above extenuating circumstances and evaluated the finding in accordance with IMC 0609, Appendix B, Section 5.4, "10 CFR 50.47(b)(4),

Emergency Classification System," and concluded that the EAL issue could result in an early GE declaration, but the finding more closely fit the "would result in unnecessary classification" significance category rather than the "would result in unnecessary [protective action recommendations] PARS for the public" significance category.

The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Training, because Entergy did not ensure the knowledge and training of the trainers and ERO personnel sufficiently conveyed realistic application of radiological based EAL criteria which properly balanced the risks of radiological dose consequences with the risks associated with unnecessary protective action recommendations. [H.9]

REPORT DETAILS

Summary of Plant Status

VY began the inspection period operating at 96 percent power, coasting down in power as it approached the end of the operating cycle. On October 7, operators reduced power to 58 percent to perform control rod scram time testing and returned VY to the maximum achievable power the next day. VY continued to coast down in power and reached 74 percent power on December 29. On December 29, operators performed a controlled downpower, shutdown, and manual scram to end the operating cycle and begin the defueling outage.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 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 345 elevation refueling floor, and the station blackout diesel generator and bus 13 enclosures. The inspectors reviewed the technical specifications, engineering changes, and the corrective action program to determine what temperatures 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 and applicable operating procedures. The inspectors performed walkdowns of the selected systems 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.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Entergys preparations for the onset of cold weather on November 26. The inspectors reviewed the implementation of cold weather preparation temporary modifications before the onset of and during this adverse weather condition.

The inspectors walked down the EDGs to ensure system availability, because the steam heater for the A EDG room was out of service. The inspectors verified that operator actions defined in Entergys adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations personnel.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial System Walkdowns (71111.04Q - 5 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

B residual heat removal (RHR) and residual heat removal service water (RHRSW)during A RHR and RHRSW surveillance testing on October 6 A RHR and RHRSW after completion of valve and pump surveillance testing on October 7 A and B core spray with B RHR loop out of service for testing on October 22 B EDG during A EDG surveillance testing on November 20 B RHR while in shutdown cooling mode on December 30 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 Updated Final Safety Analysis Report (UFSAR), technical specifications, 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

Main article: IP 71111.04S

a. Inspection Scope

Starting September 7 through December 17, the inspectors performed a complete system walkdown of accessible portions of the service water (SW) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling and hanger and support functionality. 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 sampled Entergys corrective action program records to verify that they were identifying equipment alignment problems at an appropriate threshold.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

Main article: IP 71111.05Q

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, as applicable, in accordance with procedures.

Torus room, elevation 213 9 and 232 6 on October 22 Reactor building, elevation 252 on November 10 Cable vault on November 18 East switchgear room on November 18 West switchgear room on November 18

b. Findings

Introduction.

The inspectors identified a Green NCV of operating license condition 3.F, Fire Protection Program, because Entergy did not implement and maintain in effect all provisions of the NRC approved fire protection program. Specifically, Entergy did not implement and maintain the required compensatory continuous fire watch in the east and west switchgear rooms when the fire detection and suppression systems were not functional for planned maintenance.

Description.

On November 18, Entergy removed the fire detection and low pressure carbon dioxide suppression systems from service in both the east and west switchgear rooms in order to complete planned maintenance. With both detection and suppression unavailable, the technical requirements manual (TRM) 3.13.D.3 and 3.13.A.2.b, required a continuous fire watch be implemented and maintained in each fire area. Since the east and west switchgear rooms were separate fire areas, Entergy procedure AP-0042, Plant Fire Prevention and Fire Protection, defined the continuous fire watch to be continuous coverage in each area at all times with all locations within each area covered every 15 minutes. However, plant personnel misunderstood the 15 minute provision as allowing a single continuous fire watch to cover two fire areas as long as all locations within both areas were covered every 15 minutes.

The inspectors noted that this interpretation was not in accordance with positions promulgated by the Office of Nuclear Reactor Regulation (NRR) in a letter dated August 17, 1998 that was a response to NRC Region IV task interface agreement (TIA)96-008, Evaluation of Definition of Continuous Fire Watch, (ADAMS ML012400048). In that response, NRR states that the intent of a continuous fire watch is to remain in the affected area at all times and that a deviation for roving would need a technical justification. The plant specific issue in the TIA response was also delineated in Information Notice 97-48, Inadequate or Inappropriate Interim Fire Protection Compensatory Measures. The VY fire protection program, as described in AP-0042, the Fire Hazards Analysis, and the TRM did not allow for roving nor provided a technical justification for a deviation for roving.

The inspectors reviewed the operating logs and interviewed plant personnel and determined that a single fire watch was implemented for the two switchgear fire areas on multiple occasions, including May 1 and August 15, 2013, and November 12, 14, and 18, 2014. In addition, the inspectors noted that Entergy self-identified in condition report CR-VTY-2013-0097, that on January 5, 2013, a single fire watch was assigned as the continuous fire watch for both the east and west switchgear rooms at the same time contrary to the requirements in AP-0042.

Entergys corrective actions included stationing separate continuous fire watches in the east and west switchgear rooms, initiating condition report CR-VTY-2014-4019, communicating and reinforcing the fire watch requirements with all operating crews and maintenance personnel, and initiating additional training.

Analysis.

The inspectors determined that Entergys failure to implement and maintain the required compensatory continuous fire watch in the east and west switchgear rooms when the fire detection and suppression systems were unavailable for planned maintenance was reasonably within Entergys ability to foresee and correct and therefore should have been prevented and was a performance deficiency.

This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the east and west switchgear rooms are separate fire areas each containing separated trains of Appendix R safe shutdown equipment which are required to respond to initiating events to prevent undesirable consequences and the implemented compensatory fire watches were less than required by the fire protection program.

The inspectors used IMC 0609, Appendix F, Fire Protection Significance Determination Process, to analyze this finding because the condition had an adverse effect on the Fire Prevention and Administrative Controls Program element in accordance with the degradation rating guidance. The inspectors determined that the finding screened as Green because the impact of the fire finding was limited to no more than one train of equipment important to safety at any given time.

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Resolution, because Entergy did not take effective corrective actions when this issue was self-identified in a condition report on January 5, 2013. [P.3]

Enforcement.

License condition 3.F requires, in part, that Entergy shall implement and maintain in effect all provisions of the approved fire protection program. A provision of the approved fire protection program is implementing compensatory continuous fire watches in accordance with TRM 3.13.D.3 and 3.13.A.2.b. Contrary to the above, on multiple occasions, including May 1 and August 15, 2013, and November 12, 14, and 18, 2014, the fire detection and suppression systems in the east and west switchgear rooms were not functional and a continuous fire watch was not implemented in the two fire areas. Entergys corrective actions to restore compliance consisted of stationing separate continuous fire watches in the east and west switchgear rooms. Because this violation was of very low safety significance (Green) and Entergy entered this issue into their corrective action program (CR-VTY-2013-4019), this violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000271/2014005-01, Compensatory Continuous Fire Watches Not Implemented as Required)

.2 Fire Protection - Drill Observation

Main article: IP 71111.05A

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on October 24 that involved a fire in the cable vault, elevation 260 6. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Entergy personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors verified that the fire brigade:

Properly used turnout gear and self-contained breathing apparatus Properly used and laid out fire hoses Employed appropriate fire-fighting techniques Brought sufficient fire-fighting equipment to the scene Effectively used command and control Searched for victims and for propagation of the fire into other plant areas Conducted smoke removal operations Properly used pre-planned strategies Adhered to the pre-planned drill scenario Met drill objectives The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with Entergys fire-fighting strategies.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the site flooding analysis and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the corrective action program to determine if Entergy identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the Reactor Building 280' elevation to verify equipment was located above the flood line, relief paths for flood water were not blocked, and that draining flood water would not impact equipment on the floor below.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

.1 Quarterly Review of Licensed Operators Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on December 3, which involved the reactor being shut down and defueled with a crane accident damaging the intake structure, an earthquake damaging the spent fuel pool causing a loss of water, and reactor building blowout panels dislodging. 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 the shift technical advisor. 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.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed control room operators on December 29 during the planned downpower, shutdown, and manual scram and while establishing off-site power backfeed through the main transformer. The inspectors observed the pre-job briefs 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. The inspectors also verified that operators remained focused on their tasks and were not distracted by observers.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12Q

The inspectors observed performance of surveillance tests and reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, 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 EDG semi-annual fast start surveillance on October 14 B RHR and RHRSW loop quarterly surveillance on October 22 Station blackout diesel generator quarterly surveillance on October 23 Seismic monitoring system quarterly surveillance on November 4 Reactor core isolation cooling system quarterly pump surveillance on November 5 EDGs main fuel oil storage tank monthly chemistry sampling on November 19 Drywell vent and torus vent surveillance on December 17

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

Main article: IP 71114.06

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Entergy emergency drill on October 8 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 attended the simulator drill critique to compare inspector observations with those identified by Entergy staff in order to evaluate Entergys critique and to verify whether the staff was properly identifying weaknesses and entering them into the corrective action program.

Additionally, the inspectors evaluated the conduct of Entergy emergency drills on October 16 and November 12 using the limited ERO staffing that would be available during the SAFSTOR period following defueling. The inspectors observed emergency response operations in the operations support center, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.

The inspectors also attended the emergency operations facility drill critiques to compare inspector observations with those identified by Entergy staff in order to evaluate Entergys critique and to verify whether the staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50.54(q), Emergency Plans, because Entergys EAL classification process could result in a misclassification, a deficiency related to a risk significant planning standard. Specifically, Entergy personnel failed to correctly classify emergency conditions during an emergency preparedness drill using the applicable EAL criteria.

Description.

On November 12, Entergy conducted a full-participation emergency drill based upon a defueled reactor with all spent fuel contained in the spent fuel pool. The drill was designed to be initiated by an internal event in the reactor building resulting in loss of structural integrity and loss of water inventory in the spent fuel pool. In addition, the drills conditions included inhibited access to the reactor building, ineffective actions to prevent and mitigate loss of spent fuel pool water level, and no direct indications of spent fuel pool water level. As a result, the drill simulated a release of radioactive material due to spent fuel damage caused by the loss of water in the spent fuel pool.

The Emergency Director declared a GE when the stack high range monitor (Gas-3 [RM-17-155]) reading exceeded 4000 mR/hr, based on EAL AG1.1, Stack High Range Monitor (Gas 3 [RM-17-155]) reading > 4000 mR/hr for 15 min. (Note 1). EAL AG1.1, Note 1, states, in part, If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values. The inspectors noted that at the time of the GE declaration, dose assessors were continuously performing dose assessment and the dose assessment did not meet the applicable criteria for EAL AG1.2, Dose assessment using actual meteorology indicates dose > 1,000 mRem TEDE or 5,000 mRem thyroid CDE at or beyond the site boundary.

During the time of the GE declaration, the inspectors did not observe the Emergency Director conferring with the dose assessors or discussing dose assessment results in order to implement the portion of Note 1 giving preference to actual dose assessment.

Approximately 30 minutes later, due to the progression of simulated accident conditions, a dose assessment report that met AG1.2 was provided to the Emergency Director for evaluating radiological protective action recommendations. The following update notification provided to the States included both AG1.1 and AG1.2 as being applicable to the declared GE. In addition, the inspectors noted that the acceptance criteria established by the training material for the drill described declaring a GE based on meeting EAL AG1.1, when dose assessment was continuously available and the criteria of EAL AG1.2 were not met at that time.

The inspectors concluded that the requirements of 10 CFR 50.54(q)(2) were not met because Entergy was not maintaining the effectiveness of the VY Emergency Plan.

Specifically, the VY EAL classification process, which includes training, could result in an over-classification in emergency declaration with respect to EAL AG1.1 and EAL AG1.2.

The requirement is associated with emergency preparedness planning standard 10 CFR 50.47(b)(4).

Entergy initiated CR-VTY-2014-3990 for not recognizing the proper application of Note 1 contained in EAL AG1.1, and subsequently trained operating crews and ERO decision makers on the basis and intent of Note 1. Entergy reviewed the implementing procedures and associated basis documents and determined that applicable procedures and guidance properly described and implemented the required hierarchy of EAL AG1.1 and EAL AG1.2.

Analysis.

The inspectors determined that the failure to establish an EAL classification process that properly implements radiological based EALs was reasonably within Entergys ability to foresee and correct and therefore should have been prevented and was a performance deficiency. Traditional enforcement does not apply since there were no actual safety consequences, no impacts on the NRCs ability to perform its regulatory function, and no willful aspects to the finding.

This finding is more than minor because it is associated with the ERO attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective of ensuring that Entergy is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the failure to establish an adequate EAL classification process could result in a GE declaration when a GE is not warranted. The inspectors determined the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process. The finding was determined to be of very low safety significance (Green) because of the following:

the drill scenario and applicable sequence of EALs applied solely to damage to spent fuel which has lower volatile radiological inventory than fuel in the reactor, the language in EAL AG 1.1 Note 1 uses the word should rather than shall, and the EAL scheme provides for the use of judgment when meeting an EAL threshold is believed to be imminent, and the likelihood of actual emergency conditions reaching EAL AG1.1 and not reaching EAL AG1.2 is considered very low.

Specifically, the inspectors considered the above extenuating circumstances and evaluated the finding in accordance with IMC 0609, Appendix B, Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, and concluded that the EAL issue could result in an early GE declaration, but the finding more closely fit the would result in unnecessary classification significance category rather than the would result in unnecessary PARs for the public significance category.

The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Training, because Entergy did not ensure the knowledge and training of the trainers and ERO personnel sufficiently conveyed realistic application of radiological based EAL criteria which properly balanced the risks of radiological dose consequences with the risks associated with unnecessary protective action recommendations. [H.9]

Enforcement.

10 CFR 50.54(q)(2) requires, in part, that a licensee shall follow and maintain the effectiveness of an emergency plan that meets the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of 10 CFR 50.47(b). 10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification and action level scheme is in use by the nuclear facility licensee. Contrary to the above, on November 12, Entergy was not in use of a standard emergency classification and action level scheme because Entergy did not train or demonstrate proper use of EAL AG1.1 and EAL AG1.2. Entergys corrective actions to restore compliance consisted of training operating crews and ERO decision makers on the basis and intent of Note 1. Because this violation was of very low safety significance and was entered into the corrective action program (CR-VTY-2014-3990), this violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000271/2014005-02, Misclassification of Emergency Conditions Based on Radiological Criteria)

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Main article: IP 71151

Occupational Radiation Safety Cornerstone

a. Inspection Scope

The inspectors reviewed Entergys submittals for the occupational exposure control effectiveness performance indicator (PI) for the period of October 1, 2013, through September 30, 2014. The inspectors used PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7, to determine the accuracy of the PI data reported.

The inspectors reviewed a listing of Entergys condition reports for issues related to the occupational radiation safety PI. The inspectors determined if any of these issues involved significantly high dose rates, what barriers had failed, and if there were any barriers left to prevent personnel access. For unintended exposures, the inspectors determined if there were any overexposures or substantial potential for overexposure.

The inspectors determined that no PI events for occupational radiation safety had occurred during the assessment period.

b. Findings

No findings were identified.

Public Radiation Safety Cornerstone

a. Inspection Scope

The inspectors reviewed Entergys submittals for the radiological effluent release occurrences PI for the period of October 1, 2013, through September 30, 2014. The inspectors used PI definitions and guidance contained in Nuclear Energy Institute 99-02 to determine the accuracy of the PI data reported.

The inspectors reviewed a listing of Entergys condition reports for issues related to the public radiation safety PI, which measures radiological effluent release occurrences per site that exceed 10 CFR 50, Appendix I, criteria. The inspectors determined that no PI events for public radiation safety had occurred during the assessment period.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.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 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety issues, as required by Inspection Procedure 71152, "Identification and Resolution of Problems." The inspectors reviewed the VY corrective action program database for the third and fourth quarters of 2014 to assess condition reports written in various subject areas (equipment problems, human performance issues), as well as individual issues identified during the inspectors daily condition report review (Section 4OA2.1). The inspectors also reviewed Entergys departmental trend reports and the monthly report on condition report generation rate to verify Entergy was identifying trends at an appropriate threshold.

b. Findings and Observations

No findings were identified.

The inspectors noted that Entergy identified decreases in condition report generation rates in the maintenance department, but noted this was the result of a decrease in workload as the end of plant life approached. Because multiple plant systems will no longer be maintained following removal of fuel from the reactor vessel, maintenance personnel were performing fewer work planning walkdowns, fewer in-shop fabrications, and more outage assistance visits to other Entergy sites. Based on the overall results of the semi-annual trend review, the inspectors determined that Entergy was appropriately identifying and entering issues into the corrective action program, adequately evaluating the issues, and properly identifying adverse trends before they became more safety significant problems.

.3 Annual Sample: Missed Opportunities to Address Minor Equipment Issues or Extent of

Condition Evaluations in a Timely Manner Along With Weak Technical Evaluations Which Contributed to not Fully Understanding the Effects of Degraded Equipment

a. Inspection Scope

The inspectors performed an in-depth review of Entergys apparent cause analysis and corrective actions associated with condition reports CR-VTY-2013-04476 and CR-VTY-2013-06139. These condition reports were written to evaluate and determine the causes for missed opportunities to properly address previously identified minor equipment issues in a timely manner. As a result, some of the issues affected equipment operability and required significant out-of-service time to implement repairs.

The inspectors reviewed the associated condition reports and applicable corrective actions; interviewed engineering and management personnel; and assessed the identification of the contributing causes, extent of condition reviews, and the adequacy of corrective actions. In addition, the inspectors performed an in-depth review of the safety-related SFPC system to verify that no degraded equipment existed that would impact functionality of the system following full core offload into the spent fuel pool during the defueling outage. The inspectors reviewed a list of all SFPC system condition reports, interviewed the SFPC system and design engineers, and performed a walkdown of accessible areas of the SFPC system to assess the material condition and verify Entergy was properly maintaining the equipment and entering issues in their corrective action program. The inspectors also reviewed work practices and the station maintenance rule program regarding the SFPC system for identification and addressing common cause failures; scoping in accordance with 10 CFR 50.65(b) of the maintenance rule; classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and appropriateness of performance criteria. In addition, the inspectors reviewed applicable procedures to ensure that testing of the SFPC system was being performed in accordance with the current licensing basis requirements.

b. Findings and Observations

No findings were identified.

The inspectors determined that Entergy appropriately identified, characterized, and implemented corrective actions and extent-of-condition reviews associated with missed opportunities to address minor equipment issues in a timely manner. Specifically, the inspectors verified that multiple corrective actions have been implemented and found them to be adequate and reasonable. Some of the corrective actions included:

establishing weekly engineering and site work management reviews of open critical component work orders for adequacy and timeliness; performing assessments of degraded or failed equipment with a focus on the appropriateness of causal analysis and corrective actions as well as repeat failures; developing clear standards to use for risk assessments; site wide training and awareness on the revised equipment reliability process; and developing a list of all open control room alarms, operator work arounds, caution tags, long term tags, and system health report items.

During a plant walkdown of the SFPC system, the inspectors identified a minor issue regarding control room operator complacency and a deficient engineering extent of condition review for a previously identified minor degraded condition. Specifically, CR-VTY-2012-2321 evaluated a condition where 750 gallons per minute (gpm) was indicated on the B SFPC SW flow indicator FI-104-80B with no pump running and the discharge valve closed. The inspectors noted that per procedure OP-2179, Standby Fuel Pool Cooling, there were two limits:

(1) when the EDGs were required to be operable, the maximum flow to the SFPC heat exchangers shall not exceed 678 gpm, and

(2) when the EDGs are not required the maximum flow shall not exceed 1165 gpm.

With the flow indicator not working properly it was difficult to ensure the SW flow was maintained within the specified limit. At the time, to avoid exceeding the limit, operators tagged the B loop of SFPC out of service. The cause of the incorrect flow indication was air in the instrument line. This condition was properly corrected by venting, and the instrument indication returned to zero. This condition report was closed on June 15, 2012. However, the inspectors identified during the walkdown that the redundant A SFPC SW flow indicator was reading 125 gpm with no pump running and the discharge valve closed. Control room operators stated that this was a known instrument noise condition that had existed for several years. The inspectors observed that this issue was similar to the B loop issue and had not been entered into the corrective action program.

Engineering determined that once the pump was started, the flow indicator would read adequately and that operability of the SFPC was not affected. CR-VTY-2014-3806 was initiated to address the issue.

As a result of the detailed review of the safety-related SFPC system, the inspectors determined that currently, there are no deficiencies or degraded equipment that would impact functionality of the system following full core offload into the spent fuel pool during the defueling outage. Specifically, the inspectors verified the SFPC system, including pumps and heat exchangers, were in maintenance rule category a(2) with no maintenance preventable functional failures within the last two years, there were no degraded critical components, there were no open functionality concerns, there were no deferred preventive maintenance tasks, and maintenance histories and system health reports indicated no declining trends in system or component performance.

.4 Annual Sample: Review of the Operator Workaround Program

a. Inspection Scope

The inspectors reviewed the cumulative effects of the existing operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors verified there were no operator workarounds as specified in Entergy procedure EN-FAP-OP-0006, Operator Aggregate Impact Index Performance Indicator.

The inspectors reviewed Entergys process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors also toured the control room and observed reactor and turbine building rounds and discussed the current operator burdens with the operators to ensure the items were not having an excessive impact on operator roles.

b. Findings and Observations

No findings were identified.

The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.

The inspectors also verified that Entergy entered operator workarounds and burdens into the corrective action program at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.

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

Main article: IP 71153

(Closed) Licensee Event Report (LER) 0500027/2014-001-00: Inoperable Emergency Diesel Generator due to Hydraulic Lock from Internal Jacket Coolant Water Leak

a. Inspection Scope

On September 29, 2014, Entergy attempted to start the A train EDG for a scheduled monthly surveillance. The EDG failed to start due to a hydraulic lock condition between opposing pistons on compression stroke in the number six cylinder. Entergy cleared the hydraulic lock condition, repaired the necessary components, and restored the A EDG to operable status on October 2. The enforcement aspects of this issue are discussed below in this section. The inspectors identified a finding during the review of the LER.

This LER is closed.

b. Findings

Introduction.

The inspectors identified a self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy did not properly implement the prescribed maintenance instructions during the installation of the copper o-ring to the Kiene valve adapter of cylinder number six of the A EDG on June 25, 1992.

Description.

On September 29, 2014, Entergy staff performed the quarterly slow start surveillance of the A EDG. When the diesel was taken to start, local operators heard the air start system actuate. However, the diesel did not rotate and did not start.

Entergy mechanics were initially unable to manually rotate the diesel in the counter-clockwise direction (normal operating direction) but were able to rotate the diesel clockwise and then rotate the diesel counter-clockwise. Following troubleshooting and corrective maintenance, the A EDG was restored to an operable status on October 2.

Entergy performed a root cause evaluation and determined that the failure to start was due to a hydraulic lock of cylinder number six from jacket water filling the cylinder.

Entergy concluded that the hydraulic lock was most likely initiated shortly after the last surveillance run on August 25, 2014, after cool down of the engine. Specifically, jacket water leaked by a copper o-ring gasket between the cylinder liner and the adapter for the Kiene valve of the number six cylinder. Entergy determined from forensic analysis that the adapter was not torqued to the required specification required by work order 92-005457 when it was installed in 1992. The copper o-rings deform with sufficient applied torque, but this one was not crushed and was confirmed to be the correct material. Over time (22 years), the lack of compression and lack of deformation of the o-ring gasket resulted in cyclic fatigue and eventual leakage of coolant past the o-ring seal into the cylinder causing hydraulic lock.

The inspectors interviewed maintenance and engineering personnel regarding the as-found conditions. During troubleshooting Entergy personnel estimated the leak rate at eleven drops per minute. However, the inspectors determined that this leak rate may not be representative of the leak rate since shutdown of the EDG on August 25.

Specifically, establishment of the hydraulic lock, attempted start, and clearing of the hydraulic lock could reasonably cause significant changes in the leak rate. Therefore, the inspectors concluded that it was not reasonable to assign a precise time or day that the EDG became inoperable because of the hydraulic lock.

The inspectors reviewed the root cause evaluation and associated documents and interviewed maintenance and engineering personnel. The inspectors determined that Entergys conclusions were reasonable and appropriate. Entergy concluded that their staff did not follow the work order instructions to apply the required torque specified in Vermont Yankee Equipment Manual (VYEM) 0107, Emergency Diesel Generators Service Manual. The inspectors also concluded that a clear recognition of the correct torque to be applied was documented and otherwise implemented based on the quality assurance report associated with work order 92-005457 and the observed proper crush from three other copper o-rings removed from the other penetration adapters into cylinder number six. Therefore, the inspectors concluded that improvements since 1992 in human performance tools established for use during work activities, such as job-site review, self-checking, turnover, and peer coaching described in EN-HU-102, Human Performance Traps and Tools, would likely prevent the performance deficiency today under similar circumstances.

Entergys corrective actions included initiating condition report CR-VTY-2014-3503, performing a root cause evaluation, and removing and reinstalling the number six cylinder adapters using new copper o-ring gaskets with the correct applied torque.

Entergy restored the A EDG to operable status on October 2, 2014. Entergy also performed cylinder air testing of all cylinders on both A and B EDGs to ensure no other leaks existed.

Analysis.

The inspectors determined that the failure to properly implement the prescribed maintenance instructions during the installation of the number six cylinder Kiene valve adapter was reasonably within Entergys ability to foresee and correct and therefore should have been prevented and was a performance deficiency. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to properly install the Kiene valve adapter on June 25, 1992, resulted in the A EDG failing to start on September 29, 2014, during a quarterly surveillance.

Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that this finding required a DRE because the failure of the A EDG to start on September 29, 2014, represented an actual loss of function of a single train of emergency alternating current power for greater than the technical specification allowed outage time. The Region I SRA used the SAPHIRE Revision 8.1.0 and the SPAR Model for VY, Version 8.19, to conduct the internal events DRE and VYs IPE for Severe Accident Vulnerabilities and the IPEEE to assess the external events risk contribution for this performance deficiency. The SRA made the following assumptions and SPAR model changes to best represent the condition of the A EDG:

The exposure time was estimated using T/2 because the actual date and time the EDG became inoperable is indeterminate based upon the uncertainty of gasket coolant leak rate into the cylinder. The time between the last successful operation of the EDG and the observed failure was 36 days. Therefore, T/2 most accurately approximates the postulated exposure time, T/2 = 36/2= 18 days. Adding the unavailability time due to corrective maintenance, the total exposure time for this finding is 21 days.

Basic event EPS-DGN-FS-DGA, Diesel Generator A Fails to Start, was set to True, consistent with the Risk Assessment Standardization Project guidance, to reflect the potential for a common cause failure mechanism of both the A and B EDGs.

Based upon the observed success of plant staff to recover the EDG following the failure to start event on September 29, 2014, and the available procedure guidance and training, the SRA assumed recovery of the A EDG could reasonably be achieved under accident conditions. Accordingly, the EDG recovery basis event, EPS-XHE-XL-NR01H, nominal probability (8.71E-1) was revised to 0.1 (1 in 10 chance of not successfully recovering the EDG).

Based upon the above stated assumptions, the delta CDF associated with this performance deficiency is in the mid E-7 range, or very low safety significance (Green).

The SRA examined the IPEEE and associated fire safe shutdown analysis/procedures to determine the external event risk contribution due to this finding. The SRA determined that the A EDG is credited for safe shutdown in the event a fire compromises the West Switchgear Room. Assuming worst case fire conditions, without suppression, the external fire contribution per IPEEE, Table 4.10.1 would be approximately 3.4E-7 (5.9E-6 X 21/365). The SRA also determined that the unavailability of the A EDG has no appreciable impact on seismic, flooding, and high winds associated mitigation capability.

Combining the internal and external risk contributions yields a total delta CDF of high E-7 (Green). Based upon a review of the dominant cutsets (loss of offsite power initiating events with subsequent failures of high pressure injection and depressurization), the unavailability of the A EDG may result in an increased risk associated with a LERF. The SRA used a 0.1 LERF factor to account for the probability that operators would procedurally take action to mitigate the consequences of a potential containment breach due to these postulated high pressure accident sequences.

Consequently, the delta LERF for this finding is high E-8 (Green).

The inspectors determined that the finding did not have a cross-cutting aspect because the performance deficiency did not occur within the last three years and would not likely occur today under similar circumstances.

Enforcement.

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, on June 25, 1992, Entergy was performing an activity affecting quality and failed to accomplish the prescribed maintenance instructions during the installation of the number six cylinder Kiene valve adapter of the A EDG. Specifically, Entergy did not apply the torque specified in VYEM 0107 and therefore failed to compress and deform the o-ring gasket. Entergys immediate corrective actions to restore compliance included removing and reinstalling the A EDG number six cylinder adapters using new copper o-ring gaskets with the correct applied torque. Because this violation was of very low safety significance and was entered into the corrective action program (CR-VTY-2014-3503), this violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy.

(NCV 05000271/2014005-03, Failure to Follow Procedure Results in Inoperable Emergency Diesel Generator)

4OA6 Meetings, Including Exit

On January 15, the inspectors presented the inspection results to Mr. Christopher Wamser, Site Vice President, and other members of the Entergy staff who acknowledged the inspection results. 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

S. Vercelli, General Manager of Plant Operations

M. Romeo, Director of Regulatory and Performance Improvement

J. Boyle, Engineering Director

R. Busick, Senior Operations Manager

C. Chappell, Regulatory Assurance Manager

P. Corbett, Nuclear Oversight Manager

R. Felumb, Performance Improvement Manager

V. Ferrizzi, Shift Manager

E. Harms, Assistant Operations Manager

M. Janus, Senior Maintenance Manager

S. Lanning, Field Support Supervisor

M. McKenney, Emergency Preparedness Manager

S. Naeck, Senior Production Manager

J. Rogers, Design Engineering Manager

M. Rose, Design Engineer

P. Ryan, Security Manager

K. Stupak, Manager, Training and Development

D. Tkatch, Radiation Protection Manager

E. Lindsay, Reactor Engineering Supervisor

J. Ward, Maintenance Superintendant

M. Anderson, Senior Engineer

T. Marstaller, Shift Manager

A. Cardine, NSSS Systems Supervisor

J. Kaur, FIN Supervisor

S. Aprea, Assistant Operation Manager

R. Congdon, Shift Manager

K. Murphy, Control Room supervisor

T. Shultz, Shift Manager

A. Zander, Assistant Operations Manager

C. Dissinger, Senior Emergency Planner

L. Doucette, Senior Engineer

A. Cappelletti, Mechanical Superintendent

L. Jenks, Lead Plant Mechanic

LIST OF ITEMS OPENED, CLOSED, DISCUSSED AND UPDATED

Opened/Closed

05000271/2014005-01 NCV Compensatory Continuous Fire Watches Not Implemented as Required (Section 1R05)

05000271/2014005-02 NCV Misclassification of Emergency Conditions Based on Radiological Criteria (Section 1EP6)

05000271/2014005-03 NCV Failure to Follow Procedure Results in Inoperable Emergency Diesel Generator (Section 4OA3)

Closed

05000271/2014-001-00 LER Inoperable Emergency Diesel Generator due to Hydraulic Lock from Internal Jacket Coolant Water Leak (Section 4OA3)

LIST OF DOCUMENTS REVIEWED