IR 05000271/2010002

IR 05000271-10-002; 01/01/2010 - 03/31/2010; Vermont Yankee Nuclear Power Station; Maintenance Effectiveness, Maintenance Risk Assessments and Emergent Work Control, and Identification and Resolution of Problems

ML101300363
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/10/2010
From:	Diane Jackson NRC/RGN-I/DRP/PB5
To:	Michael Colomb Entergy Nuclear Operations
Jackson D E, RGN-I/DRP/PB5/610-337-5306
References
IR-10-002
Download: ML101300363 (33)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406-1415 May 10, 2010 Mr. Michael Colomb 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 05000271/2010002

Dear Mr. Colomb:

On March 3'1, 2010 the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection rE~sults, which were discussed on April 20, 2010, with you and other members of your staff.

The inspection examined activities performed under your license as they relate to safety and compliance with the Commission's 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 NRC-identified findings of very low safety significance (Green).

These findings were determined to involve violations of NRC requirements. 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 (NCVs), in accordance with Section VLA.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of thi~ inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001: with copies to the Regional Administrator, Region I: the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, W.ashington, D.C.

20555¥0001: and the NRC Senior Resident Inspector at the Vermont Yankee Nuclear Power Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagre'ement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at Vermont Yankee Nuclear Power Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely, Ut Donald E. Jac on, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-271 License Nos. DPR-28

Enclosure:

Inspection Report No. 05000271/2010002 wi Attachment: Supplemental Information

REGION I==

Docket No.: 50-271 License No.: DPR-28 Report No.: . 05000271 f201 0002 Licensee: Entergy Nuclear Operations, Inc.

Facility: Vermont Yankee Nuclear Power Station Location: Vernon, Vermont 05354-9766

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Dates: January 1, 2010 through March 31, 2010 Inspectors: S. Rutenkroger, Acting Sr, Resident Inspector, DRP i*

D. Spindler, Sr. Resident Inspector, DRP H. Jones, Resident Inspector, DRP Approved by: Donald E. Jackson, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

I.

SUMMARY OF FINDINGS

IR 05000271/2010002; 01/01/2010 - 03/31/2010; Vermont Yankee Nuclear Power Station;

Maintenanc:e Effectiveness, Maintenance Risk Assessments and Emergent Work Control, and Identification and Resolution of Problems.

This report covered a three-month period of inspection by resident inspectors. Three Green NRC-identified findings determined to be non-cited violations (NCVs), were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMe) 0609, "Significance Determination Process" (SDP). The cross-cutting aspect for each finding was determined using IMC 0310, "Components Within The Cross-Cutting Areas," dated February 2010. Findings for which the SOP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified an NCV of very low safety significance (Green) of technical specification 3.5.E, "High Pressure Coolant Injection (HPCI) System," because Entergy staff failed to identify that HPCI was inoperable, enter the required limiting condition for operation, and immediately verify that the reactor core isolation \

cooling (RCIC) system was operable. Entergy initiated CR-VTY-2010-01420 and CR-VTY-2010-01506 to address the issues, issued standing orders to ensure HPCI and RCle are considered inoperable when not aligned to the condensate storage and transfer system (CST), and initiated corrective actions to ensure design basis analysis associated with power uprate is properly incorporated into various documents, including technical specifications (TS) and the updated final safety analysis report (UFSAR).

This finding is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent .

undesirable consequences (i.e. core damage). Specifically, the availability of the CST to provide water for core cooling to HPCI during transient and emergency situations was affected. The inspectors determined the significance of the finding using IMe 0609, Appendix A, "Determining the Significance of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the exposure time associated with the HPCI suction valves being not properly aligned to the CST was 45 minutes, i.e. less than three days. The inspectors determined this finding had a cross-cutting aspect in the area of problem identification and resolution within the corrective action program (CAP) component because Entergy personnel did not completely and accurately identify the issues associated with HPCI being aligned to the torus instead of to the CST. (P.1(a>> (Section 1R12)

• .Qreen. The inspectors identified an NCV of very low safety significance (Green) of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Entergy staff did not assess and manage the increase in risk due to surveillance testing activities that impacted the availability of the 'A' emergency diesel generator (EOG) in accordance with 10 CFR 50.65 (a)(4).

Entergy initiated CR-VTY-2010-01019 to address the issue, issued a standing order to enSure the EDGs are properly considered unavailable during future surveillance tE~sts, and commenced an extent of condition review to determine the staffs effectiveness at properly accounting for unavailability in accordance with 10 CFR 50.65 (a)(4) for the EOGs and other risk significant systems.

This finding Is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically. the availability of the 'A'

EDG was affected arid Entergy's risk assessment did not consider risk significant structures, systems and components (SSCs) (i.e., EDGs) that were unavailable during the maintenance activity and did not take risk management actions. The inspectors determined the significance of the finding using IMC 0609 Appendix K,

"Maintenance Risk Assessment and Risk Management Significance Determination Process," The finding was determined to be of very low safety Significance (Green)because the incremental core damage probability deficit for the time the 'A' EDG was unavailable was less than 1.0E-6. The inspectors determined this finding had a cross-cutting aspect in the area of human performance within the work control component because Entergy did not appropriately plan and incorporate risk insights in work activities that impacted the availability of the 'A' EDG. (H.3(a)} (Section 1R13) .

Green.

The inspectors identified an NCV of very fow safety significance (Green) of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," because Entergy did not select and review safety-related cables suitable for application in the environment in which they were found. Specifically. Entergy allowed the continuous submergence of safety-related cables that were not qualified for continuous submergence and failed to demonstrate that the cables would remain operable. Entergy initiated CR-VTY-2009-04142 and CR-VTY-2010-01422 to address the issues, commenced dewatering of the affected manholes, and initiated a preventive maintenance plan to ensure proper conditions. .

This finding is more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern.

Specifically, the inspectors noted that the insulation of continuously submerged cables would degrade more than dry or periodically wetted cables which would lead to failures. The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The finding was determined to be of very low safety significance (Green) because it was a design or qualification deficiency which was confirmed to have not resulted in a Joss of operability or functionality. Specifically, the continuously submerged cables were not designed or qualified for that environment but were still fully capable of performing their design functions. The inspectors determined this finding had a cross-cutting aspect in the area of problem identification and resolution within the CAP component because Entergy personnel did not thoroughly evaluate the problem when submerged cabling was identified. (P.1(c)) (Section 40A2)

REPORT DETAILS

Summary; of Plant Status Vermont Yankee (VY) Nuclear Power Station began the inspection perlod operating at 100 percent power. On January 6,2010, VY commenced an unplanned power reduction to approximately 60 percent to facilitate repairs of a broken insulator on one of the 345 kV lines.

The station returned to 100 percent power on January 7, 2010. On January 11, 2010, VY commenced! a planned power reduction to approximately 47 percent due to planned maintenance and testing. The station returned to 100 percent power on January 12, 2010.

With the exception of scheduled power reductions for control rod pattern adjustments, the plant continued to operate at or near full power for the remainder of the inspection period.

REACTOR SAFETY

[R]

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 AdVerse Weather Protection (71111.01 1 sample)

.1 Adv~rse

Weather (System/Seasonal}

a. Inspection Scope

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The iinspectors reviewed actions taken by Entergy to prepare for a series of snow storms dUring the week of February 22, 2010. The inspectors reviewed operating procedure (OP) 2196, "Seasonal Preparedness," as well as OP 3127, "Natural Phenomena," and discussed the completion of items with operations personnel to determine if .actions for the selected systems had been completed or were being tracked for completion. The inspectors independently walked down applicable portions of the plant, including the fuel oil storage tank enclosure and the intake structure to determine if sel*ected actions to prep.are for cold weather operations had been completed appropriately. The inspectors also reviewed condition reports (eRs) related to cold weather protection of the selected systems to ensure issues were properly addressed for resolution. The documents reviewed are listed in the Attachment.

These activities constituted one inspection sample for seasonal adverse weather conditions.

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b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial Equipment Alignment

a. Inspection Scope

The inspectors performed partial system walkdowns to verify correct system alignment, and to identify any discrepancies that could impact system operability. Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and OPs. The inspectors verified valve positions and the general condition of selected components. Finally, the inspectors evaluated material condition, housekeeping, and component labeling. The following systems were inspected:

• 'A' and 'B' EDG during work in the switchyard;

• RCIC during HPCI unavailability;

• HPCI during RCIC unavailabillty; and

• '6' residual heat removal and residual heat removal service water during planned inspections and maintenance on cooling tower CT-2-1.

These activities constituted four partial equipment alignment inspection samples.

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No findings of significance were identified,

.2 Complete Equipment Alignment

a. Inspection Scope

The inspectors performed a complete eqUipment alignment inspection of the accessible portions of the core spray system. The inspectors compared the actual system configuration to approved drawings, the UFSAR, the system design basis documents, and OPs. The inspectors evaluated whether major system components were properly ventilated, hangers and supports were correctly installed and functional, ancillary equipment was placed so it would not interfere with the operation of system valves, and that deficiencies had been entered into the CAP; In addition, the inspectors evaluated a sample of previously identified deficiencies to determine if they had been properly addressed, and whether open items Impacted system operability.

These activities constituted one complete equipment alignment inspection sample.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.050 - 8 samples)

The inspectors performed inspections of eight fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis, the Fire Hazards Analysis, and the Individual Plant Examination for External Events (IPEEE). The inspectors reviewed Entergy's fire protection program to determine the specified fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. The inspectors verified, consistent with applicable administrative procedures, that combustibles and ignition sources were adequately controlled; passive fire barriers, manual fire-fighting equipment, and detection and suppression equipment were appropriately maintained; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with Entergy's fire protection program. The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3.F. The documents reviewed are listed in the Attachment. The following fire areas were inspected:

• Fire Area ASD, zone 2, elevation 262', cable vault;

• Fire Area ASD, zone 3. elevation 262', battery room;

• Fire Area 4, elevation 248', east switchgear room;

• Fire Area 5, elevation 248', west switchgear room;

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• Fire Area 12, fuel oil storage tank and transfer pump house;

• Fire Area INTAKE, zone 14, circulating water pump room;

• Fire Area INTAKE, zone 15, service water pump room; and

• Advanced off gas building (not identified as a fire area).

Thes.e activities constituted eight quarterly fire protection inspection samples.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

Intemal Flooding a.

InspHction Scope The inspectors reviewed Entergy's flood protection design and barriers for coping With internal flooding in plant areas containing risk significant systems, structures and components (SSCs). The inspectors reviewed internal flooding information contained in Vermont Yankee's IPEEE and the internal flooding design basis document. The inspE~ctors performed a walkdown of the areas to ensure equipment and structures needed to mitigate an internal flooding event were as described in the IPEEE and the deSign basis document. Additionally, the inspectors reviewed eRs related to internal flooding to ensure Identified problems were properly addressed for resolution. The following systems were Inspected:

• Reactor building elevation 232', upper RCIC room; and

• Reactor building elevation 213', northeast emergency core cooling system corner room.

These activities constituted two internal flood protection measures inspection samples.

b. Findings

No findings of significance were identified.

1R 11 Licensed Operator Regualification Program Licensed Operator Regualification Program - Quarterly <71111.11 Q - 1 sam pie}

a. Inspection Scope

The inspectors observed a simulator~based licensed operator requalification exam on January 11, 2010. The inspectors assessed the performance of risk significant operator actions, including the use of emergency operating procedures. The inspectors evaluated crew performance\in the areas of:

• Clarity and formality of communications;

• Event classification and emergency response actions;

• Ability to take tlmely actions;

• Prioritization, interpretation, and verification of alarms;

• Procedure usage;

• Control board manipulations; and

• Command and control.

The inspectors also compared the simulator configuration with the actual control board configuration. Finally. the inspectors verified that evaluators were identifying and documenting crew performance problems.

These activities constituted one quarterly licensed operator requalification training program inspection sample.

b. Findings

No findings of significance were identified.

1R 12 Maintenance Effectiveness (71111.120 .:.... 3 samples)

a. Inspection Scope

The inspectors reviewed performance-based problems involving selected in-scope SSCs to assess the effectiveness of the maintenance program. The reviews focused on the following aspects when applicable:

• Proper Maintenance Rule scaping in accordance with 10 CFR 50.65;

• Characterization of reliability issues;

• Changing system and component unavailability;

• 10 CFR 50.65 (a)(1) and (a)(2) classifications;

• Identifying and addressing common cause failures;

• Trending of system flow and temperature values;

• Appropriateness of performance criteria for SSCs cfassified (8)(2); and

• Adequacy of goals and corrective actions for SSCs classified (a){1).

The Inspectors reviewed the applicable system health reports, maintenance backlogs, and Maintenance Rule basis documents. The following systems were inspected:

• CST;

• HPCI; and

• RCIC.

These activities constituted three maintenance effectiveness inspection samples.

Introduction:

. The inspectors identified a non-cited violation (NCV) of very low safety significance (Green) of TS 3.5.E, "HPCI System,'~ because Entergy staff failed to comply with the TS required actions for an inoperable HPCI system. Specifically, Entergy personnel failed to identify that HPCl was inoperable, enter the required limiting condition for operation, and immediately verify that the RCIC system was operable.

Description:

On August 20,2007, Entergy personnel identified that the CST suction path to HPCl swapped from the CST to the torus. As a result, the normally open suction valve from the CST, V23-17, closed. Entergy's operators determined that the swap had been caused by spurious signals generated by welding activity in the affected area. The welding caused instrumentation associated with the CST level control loop to experience voltage spikes in the level transmitter circuitry. LT-107-5A, which actuated the low level switch. Subsequently, the welders ceased the welding activity, and the operators restored the normal suction path to the CST 45 minutes later. Entergy staff had concluded that having HPCI suction aligned to the torus rather than the CST had no effect upon t~e operability of HPCI and did not enter the appropriate limiting condition for operation and did not take listed actions, such as immediately verify RCIC was operable.

Subsequently, in responding to the inspectors' questions regarding sources and temperatures of available water supplies, Entergy personnel identified that design analysis supporting an extended power uprate amendment to VY's license, effective March 2, 2006, credited the CST as the first source of water in order to mitigate design basis accidents. Specifically, Entergy staff realized that calculation VYC-2421, "Analysis of Suppression Pool Temperature for Relief Valve Discharge Transient at 20% Power Uprate with Enhanced Cooling," credited the relatively cooler water of the CST as being injeclted first in order to maintain net positive suction head reqUirements for pump operation and counteract the effects of HPCI operation and automatic depressurization system actuation which add significant heat to the suppression pool.

In addition, as examples, Entergy staff noted that "Design Basis Document for Safety Analysis (SADBD)," revision 10, described the following:

• Within section 2.2.5.3.3, "Assumptions - Loss of Auxiliary Power, Part B Containment System Analysis," which stated "vessel inventory is assumed to continue for the first 60 seconds at feedwater enthalpyand thereafter with CST water at 135F until vessel pressure reaches 165 psia;" and,

• Within section 2.2.5.4, "Assumptions -Inadvertent Opening of Safety Relief Valves, Part B Containment System Analysis, n which stated "if vessel depressurization is required and the main turbine system (bypass and/or condenser) is not available, it is assumed that the operator will use, in the order listed, HPCI (CST suction), RCtC \

(CST suction) and then the safety relief valves (SRVs) to depressurize the vesseL" Therefore, the inspectors determined that Enter'gy personnel had failed to correctly determine that having the HPCI suction aligned to the torus rather than the CST had an effect upon the operability of HPCI, enter the appropriate limiting condition for operation, and take the required actions, such as. immediately verifying RCIC was operable.

Entergy initiated CR-VTY-201 0-0 1420 and CR-VTY-2010-01506 to address the issues, issued standing orders to ensure HPCI and RCIC are considered inoperable when not aligned to the CST, and initiated corrective actions to ensure design basis analysis assoGiated with the power uprate is properly incorporated into various documents, including TS and the UFSAR.

Analvsis: The inspectors identified a performance deficiency because Entergy staff failedl to identify that HPCI was inoperable, enter the required limiting condition for operation, and immediately verify that the RCIC system was operable in accordance with TS 3.5.E. The issue was within Entergy's ability to foresee and correct and should have been prevented. Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence. had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of IMC 0612, Appendix E, "Minor Examples," revealed that the finding was similar to Example 3.1; in that the accident analysiS assumed that HPCI suction is aligned to the CST and the accident analysiS requirements were not met with HPCI aligned to the torus. Additionally, the inspectors determined that the finding is more than minor because it affected the equipment performance attribute of the Mitigating I

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I Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (Le. core damage). Specifically, the availability of the CST system to provide water for core cooling to HPCI during transient and emergency situations was affected.

I The inspectors performed an initial screening of the finding in accordance with IMC I'

I 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors concluded that there was a loss of HPCI system safety function during the time the HPCI suction valves were not properly aligned to the CST. Therefore, the inspectors dete!rmined the significance of the finding using fMC 0609, Appendix A, "Determining the I Significance of Reactor Inspection Findings for At-Power Situations." The finding was determined to be of very low safety significance (Green) because the exposure time I

associated with the HPCI suction valves being not properly aligned to the CST was for 45 minutes, Le., less than three days.

The inspectors determined this finding had a cross-cutting aspect in the area of problem I

identification and resolution within the CAP component because Entergy personnel did not completely and accurately identify the issues associated with HPCI being aligned to the torus instead of to the CST. (P.1(a>>

Enforcement:

Technical Specification 3.5.E, "High Pressure Coolant Injection (HPCI)

System," requires, in part, that whenever irradiated fuel is in the reactor vessel and reactor steam pressure is greater than 150 psig, from and after the date that the HPCI sysh:!m is made or found to be inoperable for Gtny reason, reactor operation is permissible only during the succeeding

.14 days unless such system is sooner made

operable, provided that the RCle system is immediately verified by administrative means to be operable. Contrary to the above, on August 20, 2007, Entergy staff failed to immediately verify that the RCIC system was operable when the HPCI system was made inoperable while irradiated fuel was in the reactor vessel and reactor steam pressure was greater than 150 psig. Entergy's corrective actions included issuing standing orders to ensure HPCI and RCIC are considered inoperable when not aligned to the CST.

Because this violation was of very low safety significance and was entered into Entergy's corrective action program (CR-VTY-2010-01420 and CR-VTY-2010-01506),this violation is being treated as a NCV, consistent with section VI.A1 of the NRC Enforcement Policy. (NCV 0500027112010002-01: High Pressure Coolant Injection Inoperable Due to Spurious Suction Valve Swap and Technical Specification Actions Not Performed)

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Insp 9ction Scope

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The inspectors evaluated five maintenance risk assessments for planned and emergent maintenance activities and verified that the appropriate risk assessments were performed prior to removing equipment for work. The inspectors reviewed maintenance risk evaluations, maintenance plans, work schedules, and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk. The inspectors verified that risk assessments were performed as required by 10CFR 50.65(a)(4) and implemented in accordance with Entergy's administrative procedures (AP) 0125, "Plant Equipment," and AP 0172, "Work Schedule Risk Management - Online." When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The following maintenance activities were inspected:

• The week of January 4,2010, which. included emergent work due to a broken insulator on a 345 kV line;

• The week of January 18,2010, which included increased plant risk due to planned HPCllogic testing;

• The week of January 25, 2010, which included emergent work on the 'A' service water strainer backwash valve, a high wind advisory, and planned testing and calibrations on the undervoltage relays associated with the '6' emergency diesel generator;

• The week of February 22, 2010, which included increased plant risk due to planned

'A' EDG maintenance and continuing excavation work around underground lines associated with the EDG fuel oil transfer system; and

• The week of March 8, 2010, which included 'A' EDG surveillance testing.

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Thes43 activities constituted five maintenance risk assessments and emergent work contn:ll inspection samples.

b. Findings

Introduction:

The inspectors identified an NCVof very low safety significance (Green) of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Entergy staff did not assess and manage the increase in risk due to surveillance testing activities that impacted the availability of the 'A' EDG in accordance with 10 CFR 50.65 (a)(4).

DescriQtion: On February 8,2010, Entergy conducted a slow start operability test of the

'A' EDG. Entergy operations personnel declared the 'A' EDG inoperable during the test and entered the appropriate limiting condition of operation in the TS. The inspectors noted that the Entergy had assessed risk for the day as in the "green" category; however, the 'A' EDG test had not been included as part of the risk assessment.

Therefore, the inspectors questioned the accuracy of the risk assessment.

The inspectors identified that during the surveillance test, the 'A' EDG was unavailable in addition to being inoperable. The EDG should have been considered unavailable, because the EDG would not have been automatically restored to the conditions necessary to support an automatic emergency start. Additionally, the EDG surveillance procedures did not include the risk management actions and compensatory measures necessary to have manually restored the EDG to support an emergency start demand.

Additionally, operators were not dedicated nor stationed at specific locations to perform the restoration actions that would have to be taken outside the control room and the pre-job brief did not cover restoration actions. Further, the inspectors noted that personnel would have to diagnose the restoration activities that would need to occur at the time of an emergency start demand based upon the creyv's location within the surveillance test procedure. Therefore, the inspectors concluded that the EDG would not have been able to perform its design function within the time assumed in the site's probabilistic risk assessment.

Entergy initiated CR~VTY~2010~01019 to address the issue. Entergy's initial actions included issuing a standing order to ensure the EDGs are properly considered unavailable during future surveil.lance tests and commencing an extent of condition review to determine the staffs effectiveness at properly accounting for unavailability in accordance with 10 CFR 50.65 (a)(4) for the EDGs and other risk significant systems.

Additionally, Entergy re-performed their risk assessment for February 8, 2010, and determined that the risk would have been in the "yellow" category if the unavailability of the 'A' EDG had been appropriately considered.

Analysis:

The inspectors identified a performance deficiency because Entergy staff did not properly assess and manage the increase in risk due to surveillance testing activities that impacted the availability of the 'A' EDG in accordance with 10 CFR 50.65 (a)(4).

The issue was within Entergy's ability to foresee and correct and should have been prevented. Traditional Enforcement did not apply, as the !sslte did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of IMC 0612, Appendix E, "Minor Examples," revealed that the finding was similar to Example 7.f, in that the overall elevated plant risk would put the plant into a higher licensee~estab[jshed risk category. Specifically, the overall elevated plant risk due to the unavailability of the 'A' EDG during surveillance test would have moved VY from the "green" to "yellow" risk category and would have required additional risk manelgement activities if the ptant risk had been properly assessed. Additionally, the inspedors determined the finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating even1ts to prevent undesirable consequences (Le. core damage). Specifically, the availabitity of the 'A' EDG was affected and Entergy's risk assessment did not consider risk significant SSCs (i.e. EDGs) that were unavailable during maintenance activities and did not take adequate risk management actions.

The inspectors determined the significance of the finding using IMC 0609 Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," Flowchart 1, "Assessment of Risk Deficit." The finding was determined to be of velY low safety significance (Green) because the incremental core damage probability deficit for the time the 'A' EDG was unavailable was less than 1.0E-6.

The inspectors determined this finding had a cross-cutting aspect in the area of human performance within the work control component because Entergy did not appropriately plan and incorporate risk insights in work activities. Specifically, Entergy's risk assessment did not consider the unavailability of the 'A' EDG during maintenance activities and did not take adequate risk management actions. (H.3(a>>

Enforcement:

10 CFR 50.65 (a}(4) requires, in part, that before performing maintenance activities (including surveillance testing) licensees shall assess and man.age the increase in risk that may result from the proposed maintenance activities.

Contrary to the above, on February 8, 2010, Entergy did not assess and manage the increase in risk that resulted from maintenance activities that impacted the availability of the 'A' EDG. Entergy's corrective actions included issuing a standing order to ensure the EOGs are properly considered unavailable during future surveillance tests.

Because this violation was of very low safety significance and was entered into Entergy's corrective action program (CR-VTY-2010-01019), this violation is being treated as a NCV, consistent with section VI.A.1 of the NRC Enforcement Policy, (NCV 050(10271/2010002-02: Emergency Diesel Generator Surveillance Testing Not Risk Assessed in Accordance with 10 CFR 50.65 (a)(4).)

1R15 Ooerability Evaluations

a. Inspection Scope

The inspectors reviewed six operability evaluations associated with degraded or non conforming conditions to assess the acceptability of the evaluations, the use and control of applicable compensatory measures, and compliance with TS. The inspectors reviewed and compared the technical adequacy of the evaluations with the TS, .UFSAR, associated design basis documents, and Entergy's procedure EN-OP-104. "Operability Determinations." The inspectors reviewed evaluations of the following degraded or non conforming conditions:

• CR 2010-00374, steadily lowering flow through the 'C' residual heat removal service water pump motor cooling coil;

• CR 2010-00498, shaft coating on a refurbished head shaft on the '0' service water pump, P-7-1 D, may be inadequate relating to Part 21 issued by Sulzer Pumps;

• CR 2010-00405, door ACD-116-308 from the 252 foot level of the reactor building to the northeast corner room for access to RCIC is unable to be opened using the claar's security card reader;

• CR 2010-0418, 'B' EDG annunciator issues during battery charger swap;

• CR 2010-01024, HPCI operability during intemal flooding event; and

• CR 2010-01319, seal water leak on 'B' Service Water Pump.

These activities constituted six operability evaluation inspection samples.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

.1 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary modifications to ensure they did not adversely affect the availability, reliability, or fUnctional capability of any risk-significant 88Cs and assessed the adequacy of the 10 CFR 50.59 evaluations. The inspectors reviewed the engineering change package, walked down the area, interviewed various personnel, and compared the installation and control of the modification to the procedural requirements. The inspectors also verified that the installation was consistent with the modification documentation; that the drawings and procedures were updated as applicable; and that thepost-instaifation testing was adequate.

• Temporary modification 20014 (and related modifications 20174,20175, and 20193)was installed for the excavation and shoring of soil around the advanced offgas (AOG) drain pit exterior area. Entergy performed the excavation to assist in the identification of the specific source of tritium entering the subsurface soil.

• Temporary modification 20160 for staging and contingency preparations to provide for an available alternate temporary transfer method of providing fuel oil from the fuel oil storage tank to the associated EDG day tanks. Entergy performed this work

\ in order to implement a risk mitigation measure considering the excavation and lifting work associated with temporary modification 20014.

These activities constituted two temporary plant modification inspection samples.

b. Findings

No findings of significance were identified.

1

R19 Post-Maintenance Testing

a.

InS(2ection Scope The inspectors reviewed five post-maintenance testing (PMT) activities on risk significant systems. The inspectors reviewed these activities to determine whether test acceptance criteria were clear, demonstrated operational readiness. and were consistent with design basis documents. The inspectors verified that the test data met the acceptance criteria contained in the work order (WO). TS, UFSAR, and the in service testing (1ST) program. When testing was directly observed, the inspectors determined whether installed test equipment was appropriate and controlled. and whether the test was performed in accordance with 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," and applicable station procedures. Upon completion, the inspectors verified that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quafity were entered into the CAP for resolution. The inspectors reviewed the PMTs performed for the following maintenance activities:

• On January 11, 2010, containment atmosphere dilution system relief valve NG-34A planned replaceroent;

• On February.S, 2010, 'B' circulating water pump planned maintenance on the pump and motor;

• On February 11, 2010, 'A' normal fuel pool cooling pump seal replacement;

• On March 11, 2010, 'B' condensate demineralizer solenoid stack planned reiplacement; and

• On March 19,2010, '8' AOG pre-heater drain trap discharge re-route.

Thesl:: activities constituted five post maintenance testing inspection samples.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing {71111.22 - 6 samples}

a. Inspection Scope

The inspectors observ~d six surveillance tests and/or reviewed test data of selected risk-siignificant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions.

The inspectors reviewed selected prerequisites and precautions to determine if they were met, evaluated whether the tests were performed in accordance with the written procedure, determined whether the test data was complete and met procedural reqUirements, and assessed whether SSCs were properly returned to service following testing. The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution. The documents reviewed are listed in the Attachment. The inspectors reviewed the following surveillance tests:

• 'A' EDG monthly slow start operability test;

• 'A' EDG monthly starting air system test;

• 8C-1-1A battery charger load test;

• 'A' EDG eight hour operability test;

• RCIC pump operability and full flow test (1ST); and

• 'A' EDG fast start operability test.

These activities constituted six surveillance testing inspection samples.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a.

InspE~ction Scope The inspectors observed an emergency preparedness (EP) drill on March 24, 2010, and reviewed the player and lead controller critiques. Entergy's EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI). The inspectors discussed the performance expectations and results with Entergy's EP staff to confirm correct implementation of the PI program. The inspe,ctors focused on the ability of licensed operators to perform event classifications and make proper notifications in accordance with Entergy's procedures and industry guidance. The inspectors evaluated the drill for conformance with the requirements of 10 CIFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production n

and Utilization Facilities. The inspectors compared Entergy's self-identified issues with obsel"Vations from the inspectors' review to ensure that performance issues were propE~rly identified and documented. The documents reviewed are listed in the These activities constituted one drill evaluation inspection sample.

b. Findings

\

No findings of significance were identified.

OTHER ACTIVITIES

LOA]

40A1 Performance Indicator (PI) Verification (71151 - 3 samples) Initiating Events Cornerstone

a. Inspection Scope

The inspectors reviewed Entergy's submittals and PI data for the cornerstones listed below for the period from January 2009 to December 2009. The inspectors reviewed selected operator logs, plant process computer data, licensee event reports, and CRs.

The PI definitions and guidance contained in Nuclear Energy Institute (NE1) 99-02, "Regulatory Assessment Performance Indicator Guideline" and AP 0094, "NRC Performance Indicator Reporting," were used to verify the accuracy and completeness of the PI data reported during this period. The Pis reviewed were:

• Unplanned scrams per 7000 critical hours;

• Unplanned power changes per 7000 critical hours; and

• Unplanned scrams with complications.

No fl'ndings of significance were identified.

40A2 Identification and Resolution of Problems (71152)

.1 Reviews of Items Entered into the Corrective Action Program

a.

Inspl~ction Scope The inspectors performed a daily screening of each item entered into Entergy's CAP.

This review was accomplished by reviewing printouts of each CR, attending daily screl~ning meetings, and/or accessing Entergy's database. The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow-up.

b. Findings

No findings of significance were identified .

.2 Annual Sample: Review of Submerged Safety-related Cables

a. Inspection Scope

(1 sample) 1 The inspectors selected CR-VTY-2009-04142 as a sample for a detailed follow-up review. CR-VTY-2009-04142 documented the identification of safety-related cables found submerged in water on November 28, 2009, for an indefinite period of time. The issue was identified during Entergy's inspection of the underground cable access points.

The inspectors assessed Entergy's problem identification threshOld, operability determination, extent of condition review, and the prioritization and timeliness of corrective actions. The review was co'nducted to determine whether Entergy personnel were appropriately identifying, characterizing, and correcting problems associated with these Issues and whether the planned or completed corrective actions were appropriate to prevent recurrence. Additionally, the inspectors observed manhole and cable inspections and interviewed engineering personnel. The inspectors reviewed the speCification, testing and long term moisture resistance qualification report for the subject cables. The documents reviewed are listed in the Attachment.

b. Findings

Intr.oduction: The inspectors identified an NCV of very low safety significance (Green) of 10 CFR Part 50, Appendix S, Criterion III, "Design Contro!," because Entergy did not select and review safety-related cables suitable for application in the environment in which they were found. Specifically, Entergy allowed the continuous submergence of safety-related cables that were not qualified for continuous submergence and failed to demonstrate that the cables would remain operable.

Description:

On November 28, 2009, Entergy personnel completed an inspection of underground cable access points to assess the condition of the cables and supports and determine if there was evidence of water intrusion. Entergy's staff concluded that of the 57. manholes or hand holes that were inspected, 12 manholes or hand holes contained cablEts that were submerged. Two manholes, MH-32(SII) and MH-33(SII) contained safety-related cables that were submerged. These cab res were control cables for the EDGs,' and control and power cables for the EDG fuel oil transfer pumps. Neither of the manholes with submerged safety-related cables contained sump pumps or other de-watering devices. Entergy's staff entered this issue into the CAP as CR-VTY-2009 04142, generated a work order to dewater the manholes beginning April 5-8, 2010, and developed a preventive maintenance frequency for subsequent pump downs.

The inspectors reviewed the qualification data and determined that the underground power cables were only suitable to be used in wet or dry conditions. After discussions with additional NRC specialists, the inspectors determined that wet or dry conditions do not include continuously submerged conditions. The inspectors reviewed the specifications used to purchase these cables and noted that the purchase specifications did not include continuous submergence. Therefore, the inspectors concluded that Entergy failed to ensure that the cables were maintained in a design condition for the anticipated environmental conditions by not thoroughly evaluating the effect of continuous cable submergence.

\ In addition, the inspectors reviewed EN-DC-346, "Cable Reliability Program," issued on December 31,2009. and noted that it states, in part, " ... cables should be kept dry if possible to increase longevity of the insulation system" and "If manual inspections and pumping are used to maintain a cable system dry, the intervals must be sufficient to keep the cables dry." Therefore, the inspectors identified that Entergy's staff had not implemented timely corrective actions to address submerged cables in manholes and had deferred the implementation of corrective actions with an insuffiCient basis given an initial dewatering scheduled for April 5-8, 2010.

Entergy initiated CR-VTY-2009-04142 and CR-VTY-2010-01422 to address the issues.

commenced dewatering of the affected manholes, and initiated a preventive maintenance plan to ensure proper conditions.

Analysis:

The inspectors identified a performance deficiency because Entergy staff did not maintain safety-related cables .in an environment for which they were designed and qualified. The issue was within Entergy's ability to foresee and correct and should have been prevented. Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of IMe 0612. Appendix E, "Minor Examples," revealed that no minor examples were applicable to this finding. Using IMC 0612. "Power Reactor Inspection Reports,"

Appendix B. the inspectors determined the finding is more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, the inspectors noted that the insulation of continuously

"

submerged cables would degrade more than dry or periodically wetted cables which would lead to failures.

The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1

- Initial Screening pnd Characterization of Findings." The finding was determined to be of very low safety significance (Green) because it was a design or qualification deficliency which was confirmed to have not resulted in a loss of operability or functionality. Specifically, the continuously submerged cables were not designed or quali1ried for that environment but were still fully capable of performing their design functiions.

The inspectors determined this finding had a cross-cutting aspect in the area of problem identification and resolution within the CAP component because Entergy personnel did not thoroughly evaluate the problem when submerge~ cabling was identified. (P.1 (c))

Enforcement:

10 CFR Part 50, Appendix 6, Criterion III, "Design Control," requires, in part, that measures shall be established to ensure that applicable regulatory requilrements and the design basis are correctly translated into speCifications, drawings, procedures, and instructions. Measures shall also be established for the selection and review for suitability of application of materials, parts, and eqUipment that are essential to the, safety-related functions of the structures, systems and components. Contrary to the above, Entergy had not established measures to select and review for suitability of application of parts <lind materials that were essential to the safety-related functions of control and power cables for the EDGs. Specifically, the cables in manholes MH-32(SII)and MH 33(SII) were not selected for suitability of application for the submerged environment in which they were found on November 28, 2009. Corrective actions included generating a work order to dewater the manholes and developing a preventive maintenance frequency for subsequent pump downs.

Because this violation was of very low safety significance and was e'ntered into Enten~y's corrective action program (CR-VTY-2009-04142 and CR-VTY-2010-01422),this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000271/2010002-03, Inadequate Design Control for Continuously Submerged Underground Cables)40A6 Meetings, including Exit

Exit Meeting Summary

On April 20, 2010, the resident inspectors presented the inspection results to Mr. Michael Colomb, Site Vice President, and other members of the Vermont Yankee staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.

ATTACHMENlT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Vermont Yankee Personnel

M. Colomb, Site Vice President

C. Wamser, General Manager of Plant Operations

G. Lozier, Acting Director of Nuclear Safety

J. Devincentis, Licensing Manager

N. RademaGher, Director of Engineering

M. Philippon, Operations Manager

J. Rogers, Design Engineering

P. Rose, Operations/FIN Team

G. Von der Esch, Asst. Operations Manager

L. Doucette, System Engineering

R. Meister, Licensing

P. Corbett, Manager, Quality Assurance

P. Couture, Licensing Specialist

L. Derting, Supervisor, Radwaste

J. Geyster, Supervisor, Radiation Protection

M. Gosekarnp, Manager, Maintenance

J. Hardy, Superintendant, Chemistry

G. Lozier, Manager, CA&A

M. Morgan, Superintendent. Training

S. Skibniowski, Environmental Specialist

P. Stover, Supervisor, Radiation Protection

D. Tkatch, Manager, Radiation Protection

R. Wanczyk, Enexus Site Representative

K. Stupak, licensed Operator Requaltfication Program Lead

, '

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

105101010271/2011010102-01 NCV High Pressure Coolant Injection Inoperable Due to Spurious Suction Valve Swap and Technical Specification Actions Not Performed 1050100271/21011010102-102 NCV Emergency Diesel Generator Surveillance Testing Not Risk Assessed in Accordance with 10 CFR 50.65 (a)(4)

1051000271/21011010102-103 NCV Inadequate Design Control for Continuously Submerged Underground Cables Closed.

None

Discussed

None