IR 05000271/2013008
| ML13212A119 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/31/2013 |
| From: | Fred Bower NRC/RGN-I/DRP/PB5 |
| To: | Wamser C Entergy Nuclear Operations |
| Bower F | |
| References | |
| IR-13-008 | |
| Download: ML13212A119 (18) | |
Text
July 31, 2013
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000271/2013008
Dear Mr. Wamser:
On June 27, 2013, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed report documents the inspection results, which were discussed on June 27, 2013 with you and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems and entered them into the corrective action program at a low threshold. Entergy personnel prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.
This report documents one NRC-identified finding of very low safety significance (Green). The inspectors determined that this finding involved a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Vermont Yankee.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Fred L. Bower, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects
Docket No:
50-271 License No:
Enclosure:
Inspection Report 05000271/2013008
w/Attachment: Supplementary Information
REGION I==
Docket No:
50-271
License No:
Report No:
Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Vermont Yankee Nuclear Power Station
Location:
Vernon, VT
Dates:
June 10, 2013 through June 27, 2013
Team Leader:
Brice Bickett, Senior Project Engineer
Inspectors:
Sarah Rich, Resident Inspector
Aaron Dugandzic, Project Engineer
Briana Bollinger, Reactor Engineer
Approved by:
Fred Bower, Acting Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
SUMMARY
IR 05000271/2013008; 06/10/2013 - 06/27/2013; Vermont Yankee Nuclear Power Station (Vermont Yankee); Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified one finding in the area of prioritization and evaluation of issues.
This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified one finding of very low safety significance (Green) during this inspection and classified this finding as a non-cited violation (NCV). 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, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310,
Components Within Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
Problem Identification and Resolution
The inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, Entergy personnel appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Entergy typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified one violation of NRC requirements in the area of prioritization and evaluation of issues.
The inspectors concluded that, in general, Entergy adequately identified, reviewed, and applied relevant industry operating experience to Vermont Yankee operations. In addition, based on those items selected for review, the inspectors determined that Entergys self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a NCV of Title 10 Code of Federal Regulations (10 CFR)50.65(b)(2) because Entergy did not properly scope the reactor building heating, ventilation and air conditioning (HVAC) system within the stations maintenance rule program.
Specifically, the inspectors determined Entergy did not properly scope the reactor building HVAC system, specific to the systems function to run and assist in area temperature control, into the maintenance rule program as required. The system is directly used in the emergency operating procedure (EOP)-4, Secondary Containment Control, to assist in mitigating a high temperature condition.
The inspectors determined that this finding was 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 reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, reliably starting reactor building HVAC system could mitigate or lessen the severity of a high temperature condition in the reactor building during an event or system which requires EOP-4 entry. The performance deficiency was also determined to be similar to more than minor example 7.d per IMC 0612, Appendix E, Examples of Minor Issues. The inspectors completed a Phase screening of the finding per IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined the finding to be of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. The inspectors did not identify a cross-cutting aspect associated with the finding because the underlying performance aspects occurred in the late 1990s and no recent operating experience was identified that would reasonably have prompted Entergy to review their scoping adequacy. (Section 4OA2.1.c)
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described Entergys corrective action program at Vermont Yankee. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and Entergy procedure EN-LI-102, Corrective Action Process. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple operational focus and condition review group (CRG) meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (1) Effectiveness of Problem Identification
In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the high pressure coolant injection system and security defensive posts. Additionally, the inspectors reviewed a sample of condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Entergy personnel entered conditions adverse to quality into their corrective action program as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of Issues
The inspectors reviewed the evaluation and prioritization of a sample of condition reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in April 2011. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions
The inspectors reviewed Entergys completed corrective actions through documentation review, and in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Entergys timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected NCVs and findings to verify that Entergy personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Entergy actions related to service water pump oil issues and cable submergence challenges at the station.
b.
Assessment
- (1) Effectiveness of Problem Identification
Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Entergy staff identified problems and entered them into the corrective action program at a low threshold.
Entergy staff at Vermont Yankee initiated approximately 12,000 condition reports between April 2011 and May 2013. The inspectors observed supervisors at the daily operations focus meeting and CRG meetings, appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Entergy trended equipment and programmatic issues, and appropriately identified problems in condition reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution.
- (2) Effectiveness of Prioritization and Evaluation of Issues
The inspectors determined that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
Entergy screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by Entergy corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors identified one example of more than minor significance where Entergy personnel were not effective in evaluating maintenance rule applicability for the reactor building HVAC system. This finding is documented in Section 4OA2.1.c.
Additionally, two performance issues of minor significance were identified in which causal evaluations, contrary to EN-LI-119, Apparent Cause Evaluation Process, were not adequate or consistent to ensure the evaluations were supported by sufficient details and facts to adequately support and conclude the causes were well understood and corrective actions were adequate. Specifically:
Condition Report (CR)-2011-4672 (Clean Area Contamination issue): The inspectors determined that documentation and details associated with the adverse condition were not sufficient from a stand-alone quality perspective to determine whether the apparent cause appropriately identified potential causes and that corrective actions were adequate to address those causes. Ultimately, the inspectors were able to determine that necessary corrective action was taken at that time, addressed likely causes and appeared to be effective in the subsequent refueling outage. Entergy issued CR-2013-3925 to address the corrective action performance aspects.
CR-2012-4507 (D service water pump low oil level): The inspectors determined that corrective action program expectations as delineated in EN-LI-102, Corrective Action Program, and EN-LI-119, Apparent Cause Evaluation Process, with respect to depth of analysis and corrective action plan completeness were not met. The inspectors determined that the associated lower-tier apparent cause did not identify contributing and/or likely underlying causes. Specifically, Entergy staff did not fully investigate the repeat adverse condition to identify likely causes. Additionally, the inspectors determined that corrective actions did not fully address the cause or monitor the actions taken to ensure the condition was corrected. However, the inspectors were able to determine there were sufficient corrective actions, subsequent to closure of this condition report, implemented to ensure a degraded condition does not currently exist. The inspectors also acknowledge the stations corrective action and assessment group later identified that corrective actions for the identified issue in CR-2012-4507 had not been effectively addressed. Entergy issued CR-2013-04192 to address the corrective action performance aspects.
The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. As described above, the inspectors determined these condition reports were deficiencies of minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- (3) Effectiveness of Corrective Actions
The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Entergy identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. The inspectors did observe some minor weaknesses in Entergys resolution of degraded conditions and/or implementation of effective corrective actions. One example of this weakness was regarding Entergys corrective actions associated with CR-2013-02014.
Entergy did not take adequate corrective actions in accordance with EN-LI-102, Corrective Action Program, regarding an adverse condition associated with vendor workmanship issue on a feedwater valve. However, the inspectors were made aware of the fleet initiative to address this CR as part of a roll-up of similar issues in this regard.
The inspectors determined this corrective action would appear to capture the specific performance aspects of CR-2013-02014.
c.
Finding
Introduction:
The inspectors identified a Green NCV of 10 CFR 50.65(b)(2) because Entergy did not properly scope the reactor building HVAC system within the Vermont Yankee maintenance rule program. The system is directly used in EOP-4, Secondary Containment Control, to assist in mitigating a high temperature condition.
Description:
The inspectors identified that Entergy did not correctly scope the reactor building HVAC system into the Vermont Yankee maintenance rule program. 10 CFR 50.65 (b)(2)(i) requires that systems, structures and components (SSCs) used in plant EOPs be in scope of the maintenance rule program. Consistent with 10 CFR 50.65 and Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, the industry guidance document NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Rev. 4A, specifies that non safety-related SSCs that are explicitly used in the EOPs to provide a mitigating function be in the Maintenance Rule scope. The same document defines mitigating as actions or steps taken to lessen the severity or the adverse consequences of the event/symptom that necessitated entry into the EOPs. The plants EOP-4, Secondary Containment Control, Rev. 3, includes in the temperature leg a step that IF reactor building vent exhaust is below 14 mr/hr THEN operate available reactor building HVAC. A similar step is also included in the override section of the procedure. The entry criterion for EOP-4 related to temperature is an area temperature above the Maximum Normal Operating Temperature for that area. The inspectors determined that running reactor building HVAC would lessen the severity of a high temperature condition in the reactor building. Therefore, the system, specific to the start/run function, meets the criteria to be scoped into the Maintenance Rule. Entergy entered this into their corrective action program as CR-VTY-2013-4235.
The inspectors further determined that the reactor building HVAC system has not reliably started eleven times since December 2011. Review of the associated work orders showed that corrective maintenance had been performed on several occasions in response to the failures, and yet reliability of the system to start remains a challenge, with the most recent issue occurring on May 4, 2013. The failures have had only minor impact on plant operations.
Analysis:
The inspectors determined this finding was a performance deficiency because Entergy did not scope the reactor building HVAC system into the maintenance rule program. The inspectors determined that this finding was 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 reliability of systems that respond to initiating events to prevent undesirable consequences, in that the reactor building HVAC system does not start reliably, which could prevent it from being used to mitigate or lessen the severity of a high temperature condition in the reactor building.
The performance deficiency was verified to be more than minor per IMC 0612, Appendix E, Examples of Minor Issues, example 7.d.
The inspectors completed a Phase 1 screening of the finding per IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined the finding to be of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event.
The performance deficiency has no cross-cutting aspect associated with it because the improper scoping took place in 1997 and no recent events would reasonably have prompted Entergy to review their original scoping decision basis.
Enforcement:
10 CFR 50.65 (b)(2)(i), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, requires that the scope of the monitoring program specified in paragraph (a)(1) include non-safety related SSCs that are used in plant EOPs. The reactor building HVAC system is used in the temperature leg of EOP-4, Secondary Containment Control, to assist in temperature control. Contrary to the above, as of June 27, 2013, Entergy did not include the start/run function of reactor building HVAC system in the scope of the monitoring program specified in paragraph (a)(1). Because this violation was of very low safety significance (Green) and Entergy has entered this issue into their corrective action program as CR-VTY-2013-4235, this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000271/2013008-001, Improper Maintenance Rule Scoping of the Reactor Building HVAC System)
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of condition reports associated with review of industry operating experience to determine whether Entergy appropriately evaluated the operating experience information for applicability to Vermont Yankee and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Entergy adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b.
Assessment
The inspectors determined that Entergy staff appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of operational focus meetings.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Entergy entered problems identified through these assessments into the corrective action program, when appropriate, and whether Entergy initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
b.
Assessment
The inspectors concluded that self-assessments, audits, and other internal Entergy assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Entergy personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Entergy personnel completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Vermont Yankee. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Entergy entered issues into the corrective action program when appropriate.
b.
Assessment
During interviews, Vermont Yankee staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On June 27, 2013, the inspectors presented the inspection results to Mr. Wamser, Site Vice President and other members of the Vermont Yankee Staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
Chris Wamser, Site Vice President
Vincent Fallacara, General Manager Plant Operations
Jon Bengtson, CA&A Manager
Bob Wanczyk, Licensing Manager
Jim Rogers, Design Engineering Manager
Jeff Merkle, System Engineering Manager
Steve Naeck, Production Manager
Pat Ryan, Security Manager
Derek Jones, Operations Manager
Ed Harms, Assistant Operations Manager
Ken ONeil, Work Week Manager
Bill Penniman, CA&A Specialist
Ellen Cota, OE Coordinator
Paul Stover, RP Supervisor
Scott Dorval, RP Supervisor
Rob Power, P&C Engineer
Ronald Sherman, P&C Engineer
Mark Anderson, P&C Engineer
Jeff Clough, Systems Engineer
Donna Drolette, Systems Engineer
Gene Gibbs, Systems Engineer
Isaac Grossweiler, Systems Engineer
John Stasolla, Systems Engineer
Tom Silko, Maintenance Coordinator
Ben Egnew, Licensing Specialist
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
- 05000271/2013008-001 NCV Improper Maintenance Rule Scoping of the Reactor Building HVAC System