IR 05000271/2005006

IR 05000271-05-006 on 09/12/2005 - 09/29/2005 for Vermont Yankee Nuclear Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML053040245
Person / Time
Site:	Vermont Yankee
Issue date:	10/20/2005
From:	Anderson C NRC/RGN-I/DRP/PB5
To:	Thayer J Entergy Nuclear Operations
References
IR-05-006
Download: ML053040245 (19)

Text

ber 20, 2005

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION PROBLEM IDENTIFICATION AND RESOLUTION NRC INSPECTION REPORT NO. 05000271/2005006

Dear Mr. Thayer:

On September 29, 2005, the US Nuclear Regulatory Commission (NRC) completed a team inspection at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection findings, which were discussed at an exit meeting on September 29, 2005, with you and members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that the implementation of the corrective action program at Vermont Yankee was generally good with respect to problem identification, evaluation of issues, and effectiveness of corrective actions.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Clifford J. Anderson, Chief Projects Branch 5 Division of Reactor Projects

Mr. Jay Docket No. 50-271 License No. DPR-28 Enclosure: Inspection Report No. 05000271/2005006 w/Attachment: Supplemental Information cc w/encl:

M. R. Kansler, President, Entergy Nuclear Operations, Inc.

G. J. Taylor, Chief Executive Officer, Entergy Operations J. T. Herron, Senior Vice President and Chief Operating Officer C. Schwarz, Vice-President, Operations Support O. Limpias, Vice President, Engineering J. M. DeVincentis, Manager, Licensing, Vermont Yankee Nuclear Power Station Operating Experience Coordinator, Vermont Yankee Nuclear Power Station J. F. McCann, Director, Licensing C. D. Faison, Manager, Licensing M. J. Colomb, Director of Oversight, Entergy Nuclear Operations, Inc.

T. C. McCullough, Assistant General Counsel, Entergy Nuclear Operations, Inc.

J. H. Sniezek, PWR SRC Consultant M. D. Lyster, PWR SRC Consultant S. Lousteau, Treasury Department, Entergy Services, Inc.

Administrator, Bureau of Radiological Health, State of New Hampshire Chief, Safety Unit, Office of the Attorney General, Commonwealth of Mass.

J. E. Silberg, Pillsbury, Winthrop, Shaw, Pittman LLP G. D. Bisbee, Esquire, Deputy Attorney General, Environmental Protection Bureau J. Block, Esquire J. P. Matteau, Executive Director, Windham Regional Commission D. Katz, Citizens Awareness Network (CAN)

R. Shadis, New England Coalition Staff G. Sachs, President/Staff Person, c/o Stopthesale Commonwealth of Massachusetts, SLO Designee State of New Hampshire, SLO Designee State of Vermont, SLO Designee

Mr. Jay

SUMMARY OF FINDINGS

IR 05000271/2005-006; 09/12/2005 - 09/29/2005; Vermont Yankee Nuclear Power Station;

Biennial Baseline Inspection of the Identification and Resolution of Problems This team inspection was performed by four regional inspectors and one resident inspector. No findings of significance were identified.

Identification and Resolution of Problems The team determined that implementation of the corrective action program (CAP) at Vermont Yankee was generally good. The team determined that Entergy was effective at identifying problems and entering them in the CAP. Once entered into the system, the items were screened and prioritized in a timely manner using established criteria. Items entered into the CAP were properly evaluated commensurate with their safety significance. The causal evaluations for equipment issues/events and for human performance/process issues reasonably identified the causes of the problems and developed appropriate corrective actions.

Corrective actions were typically implemented in a timely manner.

a.

NRC Identified and Self-Revealing Findings

No findings of significance were identified.

b.

Licensee-Identified Violations

None.

ii

REPORT DETAILS

4OA2 Problem Identification and Resolution (Biennial - IP 71152B)

Effectiveness of Problem Identification

a. Inspection Scope

The inspection team reviewed the procedures, listed in the Attachment to this report, describing the corrective action program (CAP) at Entergys Vermont Yankee Nuclear Power Station (VYNPS). Entergy identifies problems by initiating Condition Reports (CRs) for conditions adverse to quality, human performance problems, equipment nonconformances, industrial or radiological safety concerns, and other significant issues. The CRs are subsequently screened for operability, categorized by priority and significance (A through D), and assigned for evaluation and resolution. The station uses the Entergy Paperless Condition Reporting System (PCRS).

The team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Program to determine if problems were being properly identified, characterized, and entered into the CAP for evaluation and resolution. The team selected items from the maintenance, operations, engineering, emergency planning, security, radiological control, training, and oversight programs to ensure that Entergy was appropriately considering problems identified in each functional area. The team used this information to select a risk-informed sample of CRs that had been issued since the last NRC Problem Identification and Resolution (PI&R) inspection, which was completed in June 2003.

In addition to CRs, the team selected items from other processes at Vermont Yankee to verify that they appropriately considered problems identified in these areas for entry into the corrective action program. Specifically, the team reviewed a sample of work orders, engineering requests, operator log entries, control room deficiency and work-around lists, operability determinations, engineering system health reports, completed surveillance tests, current temporary configuration change packages, and training requests. The documents were reviewed to ensure that underlying problems associated with each issue were appropriately considered for resolution via the corrective action process. In addition, the team interviewed plant staff and management to determine their understanding of and involvement with the PCRS. The CRs and other documents reviewed, and a list of key personnel contacted, are listed in the Attachment to this report.

The team reviewed a sample of Entergys Quality Assurance audits, including the most recent audit of the CAP, the CAP quarterly trend reports, and the departmental self-assessments. This review was performed to determine if problems identified through these evaluations were entered into PCRS, and whether the corrective actions were properly completed to resolve the deficiencies. The effectiveness of the audits and self-assessments was evaluated by comparing audit and self-assessment results against self-revealing and NRC-identified findings, and current observations during the inspection.

The team considered risk insights from the NRCs and Entergys risk analyses to focus the sample selection and plant tours on risk-significant components. The team determined that the five highest risk-significant systems were the high pressure coolant injection system, reactor core isolation cooling system, residual heat removal system, emergency core cooling system low pressure interlock, and depressurization logic. For the selected risk-significant systems, the team reviewed the applicable system health reports, and a sample of work requests, engineering documents, plant log entries, and results from surveillance tests and maintenance tasks.

b. Findings

and Assessments No findings of significance were identified.

The team concluded that Entergy was generally effective at problem identification at the Vermont Yankee station. The station staff had appropriate knowledge of PCRS and the CAP, and identified problems and entered them into the program at an appropriate threshold. There were approximately 4,000 CRs initiated per year. Station staff promptly initiated CRs, as appropriate, in response to deficiencies or issues raised by the inspection team. The team did not identify any significant issues in the maintenance, engineering, or training tracking systems which did not have a CR associated with them, as appropriate. The team considered the audits and self-assessments to be generally good, with some significant issues identified and entered into the CAP.

However, the team did discover one minor example of a failure to identify a condition adverse to quality. The team noted during the review of an audit of radiation protection (QA-14-2004-VY-01) that a contractor alarmed the exit portal monitors (PM-7) twice, but did not notify the radiation protection (RP) department as required by procedure and a local posting. The contractor exited the site with his tools and other personal items, took the items to his car, and then returned to the site and informed RP he had alarmed the PM-7. Follow-up surveys by RP of the contractor and the items in the car found no contamination. The event follow-up was witnessed by a Quality Assurance (QA) auditor.

Neither the RP technician nor the QA auditor initiated a CR to document the violation of their radiation worker practices policy. Condition Reports 2005-2761 and 2005-2762 were written to document the teams observations.

2. Prioritization and Evaluation of Issues

a. Inspection Scope

The inspection team reviewed the CRs listed in the attachment to the inspection report to assess whether Entergy adequately evaluated and prioritized the identified problems.

The team selected the CRs to cover the seven cornerstones of safety identified in the NRCs Reactor Oversight Program. The team also considered risk insights from the Vermont Yankee Probabilistic Risk Analysis to focus the CR sample. The review was expanded to five years for Entergys evaluation of problems associated with thermal overloads on motor operated valves, including incorporation of industry operating experience information for applicability to their facility.

The CRs reviewed encompassed the full range of Entergy evaluations, including root cause analysis, apparent cause evaluations, and most probable cause. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, the timeliness of the resolutions. For significant conditions adverse to quality, the team reviewed Entergys corrective actions to preclude recurrence. The team observed the Condition Report Group (CRG) meeting, in which Entergy managers reviewed incoming CRs for prioritization, and evaluated preliminary corrective action assignments, analyses, and plans. The team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems. The team assessed the backlog of corrective actions, including the backlog in the maintenance and engineering departments, to determine, individually and collectively, if any represented an increased risk due to delays in implementation. The team further reviewed equipment performance results and assessments documented in completed surveillance procedures, operator log entries, and trend data to determine whether the equipment performance evaluations were technically adequate to identify degrading or non-conforming equipment.

b. Findings

and Assessments No findings of significance were identified.

The team concluded that Entergy screened the CRs appropriately and properly classified them for significance. There were no items in the engineering and maintenance backlogs that were risk significant, individually or collectively. The team noted that significant conditions adverse to quality were classified as Category A and received a formal root cause analysis and an extent-of-condition review. Less significant conditions, Category B and C, typically received an apparent cause evaluation or a most probable cause review. The majority (.99%) of the CRs written were for less significant issues. The quality of the causal analyses was generally good.

The causal analysis for equipment issues and events were thorough. Noteworthy is the fact that causal analyses for softer issues, such as human performance and process, were also of good quality.

However, the team did note an example where the causal analysis did not have documentation to support some of the conclusions. The team reviewed Entergys actions related to an NRC finding (FIN 2004009-02 - Failure to Assign Continuous On-Shift Capability to Read the Facility Seismic Monitoring System for Emergency Classification Purposes) concerning the inability to implement, in a timely manner, a portion of the Emergency Plan to determine if an earthquake exceeded the emergency action level (EAL) for an Alert declaration. The licensee had relied on off-shift personnel to respond to the station to obtain data from the seismic monitoring instrumentation to determine whether a seismic event had exceeded the operational basis earthquake (OBE) levels at the site. The licensee initially reviewed the issue in CR-2004-2420, and determined that their interpretation was in compliance with the requirements of 10CFR50.47(b)(2). Nonetheless, they trained the shift technical advisors (STAs) to obtain the data to determine whether the OBE levels were exceeded. After the inspection report was issued, the licensee wrote CR-2004-3483 to document that the original CR did not adequately address the NRC conclusion. Overall, their response was acceptable since both portions of the EAL could be implemented using on-shift resources. However, while the corrective actions were acceptable, the causal evaluations for both CRs did not address what Entergy process weakness allowed the deficiency to occur. Further, the CR responses did not address an extent-of-condition (EOC) review, or evaluate that the additional duty would not conflict with the STAs primary role to monitor the plant conditions during emergencies. Based on discussions with the licensee, the team determined that the EOC reviews and evaluation of the STAs duties had been completed, but not documented. The licensee concluded the additional STA task would not detract from STAs duties during transients. In addition, the team verified Entergys determination that on-shift resources were adequate to implement all other EALs. Condition Reports 2005-2827 and 2005-2829 were written to document the teams observations.

3. Effectiveness of Corrective Actions

a. Inspection Scope

(1) The team reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for repetitive problems to determine whether previous corrective actions were effective. The team also reviewed Entergys timeliness in implementing corrective actions and their effectiveness in precluding recurrence of significant conditions adverse to quality. The team reviewed the CRs associated with selected non-cited violations and findings to determine whether Entergy properly evaluated and resolved these issues.

(2) The team reviewed Entergys corrective actions for four of the non-cited violations (NCVs) identified during the engineering team inspection in August 2004, using Temporary Instruction (TI) 2515/158, as documented in NRC Inspection Report 05000271/2004008. For each NCV, the team verified that the licensee had entered the issue into the corrective action program, had completed an adequate causal analysis and extent-of-condition review, and had taken appropriate corrective actions. In cases where corrective actions had not yet been completed at the time of this inspection, the team verified that Entergy had established and documented plans for completion in a time frame commensurate with risk.

b. Findings

and Assessments

(1) No findings of significance were identified.

The team concluded that Entergy generally determined corrective actions that were appropriate, effective, and completed in a timely manner. For significant conditions adverse to quality, corrective actions were identified to prevent recurrence. In addition, Entergy conducted effectiveness reviews to determine if the corrective actions were still adequate. The team noted the incorporation of industry operating experience information in the determination of the corrective actions, as appropriate. However, the team noted two minor examples of inadequate corrective actions.

Entergy personnel identified (CR 2004-2370) that the weld rod used during a modification on the residual heat removal service water piping, was drawn from an uncontrolled weld rod oven. The oven was originally controlled by a contractor; when Entergy changed contractors, control of the oven was lost. Although they believed that the oven was always turned on, Entergy addressed the issue of potential weld porosity as if the oven was not on at the time the weld rod was drawn. Their conclusion was that weld porosity would result from delayed hydrogen cracking, which would be visible on the surface of the weld within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and would only require visual inspection.

Hydrogen cracking is a potential failure mechanism, but it is not the only potential failure mechanism; subsurface weld porosity could also be the result of weld rod that was not maintained hot. However, since Entergys investigation into the issue determined that there was reasonable assurance that the weld rod oven was always energized, the NRC does not have a concern with the welds. Condition Report 2005-2837 was written to document the teams observation.

In September 2003, a packing leak on a reactor head vent manual valve forced the plant to shut down. The root cause was determined to be inadequate consolidation of the valve packing. The associated maintenance procedure had been changed due to a similar packing leak in 2001; however, at that time, the reactor head vent valve was not identified as also being packed incorrectly. As a result of the 2003 leak, Entergy compiled a list of all the manual valves which needed to have the packing consolidated.

In addition, all the torque values for the gland nuts were calculated by engineering and added to the list. The root cause analysis recommended that the torque values be incorporated into the procedure to prevent recurrence; however, the corrective action failed to incorporate the values into the procedure. Condition Report 2005-2818 was written to document the teams observation.

(2) No findings of significance were identified.

In the case of NCV 2004008-01 (Availability of Power from the Vernon Station), the licensee had completed an acceptable evaluation of the time needed to restore the Vernon Hydro-Electric Station following a grid-centered station blackout (SBO). The licensee's evaluation concluded that, in the worst case, it would take approximately two hours to make this source available to supply power to the plant. The licensee had also completed calculations showing that the station could cope with, and recover from, an a SBO lasting for at least two hours. Calculations had been completed for both present conditions, and for the conditions that would exist following the licensees proposed extended power uprate (EPU). The calculations were found to consider all appropriate inputs, and contained reasonable and conservative assumptions. The team did not identify any deficiencies with Vermont Yankees corrective actions for this violation.

However, this issue is still under review by the NRCs Office of Nuclear Reactor Regulation (NRR) as part of the EPU review.

In response to NCV 2004008-09 (Failure to Establish Adequate Motor-Operated Valve (MOV) Periodic Test Program), the team found that the licensee had completed actions to revise their MOV testing program to provide for validation of the motor control center test method. The validation program included periodic verification of the test method over an extended interval. Additionally, the licensee formalized their program for trending and evaluating MOV performance. The revised test program included evaluation of MOV test results against applicable design requirements. The team reviewed Entergys procedures for implementation of both the MOV test program and the trending and data evaluation programs, and found them to be adequate. The time frame for implementation of the revised MOV program was consistent with the guidance contained in NRC Generic Letter (GL) 89-10 (Safety-Related Motor-Operated Valve Testing and Surveillance), and GL 96-05 (Periodic Verification of Design-Basis Capability of Safety-Related Power-Operated Valves). The teams review of Entergys corrective actions found them to be acceptable. However, this issue remains under review by NRR as part of the EPU review process.

The teams review of the two violations related to the reactor core isolation cooling (RCIC) system lube oil cooling supply (NCV 2004008-05, Cooling Water Supply Portion of RCIC System Not Installed per Design Basis, and NCV 2004008-06, Failure to Correct Non-Conforming RCIC Pressure Control Valve) identified that Entergy had not completed actions to correct these deficiencies. The team reviewed the evaluation that Entergy had completed to show that the RCIC system remained operable, and found it to be acceptable. Entergy had completed an adequate causal analysis, including an extent-of-condition review, but at the time of the inspection, had not corrected the deficiencies nor developed a formal design change plan. Entergy had originally planned to replace the non-conforming valve during the upcoming refueling outage; but because of unexpected complexity in the design, the corrective actions had been deferred until the end of the year. The team reviewed the guidance contained in GL 91-18 (Resolution of Degraded and Nonconforming Conditions) and determined that while the licensees actions could have been completed earlier, the issue did not constitute a violation because deferral of the corrective actions was reasonable, and was appropriately documented and justified based on risk. The NRC will review the licensees corrective actions after the modification package has been approved for installation.

4. Assessment of Safety Conscious Work Environment

a. Inspection Scope

During the interviews with station personnel, the team assessed the safety conscious work environment (SCWE) at the Vermont Yankee station. Specifically, the team assessed whether people were hesitant to raise safety concerns to their management and/or the NRC. The team also reviewed Entergys Employee Concerns Program (ECP) to determine if employees were aware of the program and had used it to raise concerns. The team also reviewed a sample of the ECP files to ensure that issues were entered into the corrective action program.

b. Findings

and Assessments No findings of significance were identified.

The team determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. All of the personnel interviewed had an adequate knowledge of the CAP and ECP. No one interviewed had experienced retaliation for safety issues raised. Based on these limited interviews, the team concluded that there was no evidence of an unacceptable SCWE.

4OA6 Meetings, including Exit

On September 29, 2005, the team presented the inspection results to Mr. Jay Thayer, Vermont Yankee Site Vice President, and other members of the Vermont Yankee staff, who acknowledged the findings. The inspectors confirmed that no proprietary information reviewed during inspection was retained.

ATTACHMENT: Supplemental Information In addition to the documentation that the inspectors reviewed (listed in the attachment), copies of information requests given to the licensee are in ADAMS, under accession number ML052870443.

ATTACHMENT -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

W. Aho, Operating Experience Engineer

R. Booth, Component Engineer - Relief & Check Valves

J. Callaghan, Manager, Design Engineering

J. DeVincentis, Manager, Licensing

J. Dreyfuss, Director, Engineering

K. Farabaugh, Supervisor, System Engineering

R. Felumb, Technical Support Coordinator

V. Ferrizzi, Control Room Supervisor

B. Finn, Manager, Corrective Action Program

J. Geyster, Superintendent of Radiation Control

M. Gosekamp, Operations Training Superintendent

C. Hansen, Design Engineer - Components

D. Hensel, Radiation Protection Manger

W. McQuire, General Manager Plant Operations

R. Morrisett, ALARA Engineer

M. Palionis, Probabilistic Risk Assessment Engineer

A. Pallang, Technical Support Coordinator

W. Penniman, Self-Assessment Coordinator

N. Rademacher, Director, Nuclear Safety

A. Robertshaw, Design Engineer - Fluid Systems

J. Rogers, Supervisor, Design Fluid Systems

P. Ryan, Manager, Security Operations

J. Thayer, Site Vice President

J. Twarog, Operations Standards Supervisor

C. Wamser, Manager, Operations

R. Wanczyk, Manager, Nuclear - Employee Concerns Program

T. White, Manager, Quality Assurance

M. Wilson, Manager, Emergency Preparedness

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Discussed

05000271/2004008-01 NCV Availability of Power from the Vernon Station

05000271/2004008-05 NCV Cooling Water Supply Portion of RCIC Not Installed per Design Basis

05000271/2004008-08 NCV Failure to Correct Non-Conforming RCIC Pressure Control Valve

05000271/2004008-09 NCV Failure to Establish Adequate MOV Periodic Test Program