IR 05000271/2007007

IR 05000271-07-007; 10/22/2007 - 11/09/2007; Vermont Yankee Nuclear Power Station; Problem Identification and Resolution

ML073530018
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	12/19/2007
From:	Mel Gray Division Reactor Projects I
To:	Ted Sullivan Entergy Nuclear Operations
Gray M, RI/DRP/TSAB/610-337-5209
References
IR-07-007
Download: ML073530018 (18)

Text

ber 19, 2007

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO.

05000271/2007007

Dear Mr. Sullivan:

On November 9, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at your Vermont Yankee Nuclear Power Station. The enclosed report documents the inspection findings, which were discussed on November 9, 2007 with Mr. W. Maguire and other members of your staff.

The inspection examined activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commission=s rules and regulations and the conditions of your operating license. The inspectors reviewed selected procedures and representative records, observed activities, and interviewed personnel.

There were no findings of significance identified during this inspection. On the basis of the sample selected for review, the inspectors concluded that Entergy was effective in identifying, evaluating and resolving problems. Your staff generally identified problems and entered them into the corrective action program at a low threshold. The inspectors determined that personnel prioritized and evaluated issues commensurate with the safety significance of the problems and implemented timely, effective corrective actions. However, the inspectors noted several examples of minor material condition issues that had not been identified by your staff. These issues were subsequently properly documented, evaluated, and assessed within your corrective action program.

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 NRC's document system (ADAMS). ADAMS is accessible from the NRC Web-site at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mel Gray, Chief Technical Support & Assessment Branch Division of Reactor Projects Docket Nos. 50-271 License Nos. DPR-28 Enclosure: Inspection Report 05000271/2007007 w/ Attachment: Supplemental Information cc w/encl:

M. R. Kansler, Chief Nuclear Officer and President, Entergy Nuclear Operations, Inc.

G. J. Taylor, Group President, Utility Operations J. Wayne Leonard, Chairman and Chief Executive Officer, Entergy Operations J. T. Herron, Senior Vice President, Entergy Nuclear Operations M. A. Balduzzi, Senior Vice President and Chief Operating Officer J. DeRoy, Vice President, Operations Support O. Limpias, Vice President, Engineering D. J. Mannai, Manager, Licensing, Vermont Yankee Nuclear Power Station E. Cota, Operating Experience Coordinator, Vermont Yankee Nuclear Power Station W. F. Maguire, General Manager, Plant Operations, Entergy Nuclear Operations, Inc.

N. L. Rademacher, Director, Engineering, Vermont Yankee Nuclear Power Station J. F. McCann, Director, Nuclear Safety and Licensing E. Harkness, Director of Oversight, Entergy Nuclear Operations, Inc.

Assistant General Counsel, Entergy Nuclear Operations, Inc.

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

D. O Dowd, Administrator, Radiological Health Section, DPHS, State of New Hampshire W. Irwin, Chief, CHP, Radiological Health, Vermont Department of Health Chief, Safety Unit, Office of the Attorney General, Commonwealth of Mass.

D. Lewis, 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 J. Volz, Chairman, Public Service Board, State of Vermont Chairman, Board of Selectman, Town of Vernon

SUMMARY OF FINDINGS

IR 05000271/2007007; 10/22/2007 - 11/09/2007; Vermont Yankee Nuclear Power Station;

Problem Identification and Resolution.

This team inspection was performed by two regional inspectors and two resident inspectors. No findings of significance were identified during this inspection. 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.

Overall Assessment of Licensee=s Identification and Resolution of Problems The inspectors concluded that Entergy was effective in identifying, evaluating and resolving problems. Vermont Yankee personnel generally identified problems and entered them into the Corrective Action Program (CAP) at a low threshold, and had taken actions to address previous NRC findings. The inspectors determined that Entergy appropriately screened issues for operability and reportability, and prioritized issues commensurate with the safety significance of the problems. Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors determined that corrective actions addressed the identified causes and were typically implemented in a timely manner. However, the inspectors noted several examples of minor material condition issues that had not been identified by your staff. In addition, the inspectors noted that a corrective action was closed without being properly completed. These issues were determined to be minor and properly documented, evaluated, and assessed during the inspection.

The inspectors determined that operating experience information was appropriately considered for applicability, and corrective and preventive actions were taken as needed.

Self-assessments, Quality Assurance audits, and other assessments were critical, thorough, and effective in identifying issues. Based on interviews, observations of plant activities, and reviews of the CAP and the Employees Concerns Program (ECP), the inspectors determined that site personnel were willing to raise safety issues and to document them in the CAP.

NRC-Identified and Self-Revealing Findings

None.

Licensee-Identified Violations

None.

ii

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program

(1) Inspection Scope The inspectors reviewed the procedures that describe Entergys corrective action program (CAP) at Vermont Yankee. Entergy identified problems for evaluation and resolution by initiating condition reports (CRs) that were entered into the condition reporting system. The CRs were subsequently screened for operability, categorized by significance, and assigned for further evaluation, resolution and/or trending.

The inspectors evaluated the process for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspectors interviewed plant staff and management to determine their understanding of and involvement with the corrective action program.

The inspectors reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process (ROP) to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The inspectors selected items from functional areas that included chemistry, emergency preparedness, engineering, maintenance, operations, physical security, radiation safety, and oversight programs to ensure that Entergy appropriately addressed problems identified in these functional areas. The inspectors selected a risk-informed sample of CRs that had been issued since the last NRC Problem Identification and Resolution (PI&R) inspection conducted in September 2005. The inspectors considered risk insights from the stations risk analyses to focus the sample selection and plant tours on risk-significant systems and components. Inspector samples focused on these systems, but were not limited to them. The corrective action review was expanded to five years for evaluation of the emergency diesel generator and service water systems.

The inspectors selected items from other processes at Vermont Yankee to verify that they were appropriately considered for entry into the CAP. Specifically, the inspectors reviewed a sample of engineering requests, operator workaround conditions, operability determinations, work orders (WOs), and system health reports. The inspectors also reviewed completed work packages to determine if issues identified during the performance of preventive maintenance were entered into the corrective action program.

In addition, the inspectors reviewed operator logs to determine whether problems described in the logs were entered into the CAP.

The inspectors reviewed CRs to assess whether Entergy personnel adequately evaluated and prioritized identified problems. The issues reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. CRs that were assigned lower levels of significance which did not include formal cause evaluations were also reviewed by the inspectors to ensure they were appropriately classified. The inspectors observed daily CR screening meetings in which Entergy personnel reviewed new CRs for prioritization and assignment. 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 identified appropriate corrective actions to address the identified causes.

The inspectors also observed Corrective Action Review Board (CARB) meetings during which Entergy managers reviewed root cause evaluations, as well as selected apparent cause evaluations and corrective action assignments. 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 problems.

The inspectors reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The inspectors reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed the timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors further reviewed CRs associated with selected non-cited violations (NCVs) and findings to determine whether Entergy personnel properly evaluated and resolved the issues.

The CRs and other documents reviewed, as well as key personnel contacted, are listed in the Attachment to this report.

(2) Assessment

(a) Identification of Issues Based on the samples selected, the inspectors determined that Entergy staff were identifying problems and entering them into the CAP at a low threshold. In most cases, problems were identified appropriately in CRs. The inspectors observed managers at condition report group (CRG) meetings appropriately questioning and challenging CRs that did not contain sufficient information. The inspectors determined that Entergy appropriately trended equipment and programmatic issues. The inspectors concluded that personnel were identifying trends at low levels, and did not identify trends or repetitive issues that Entergy had not self-identified.

However, the inspectors noted several examples of minor material condition and housekeeping issues that had not been identified by Vermont Yankee personnel and entered into the CAP.

These included the following:

Four flexible hoses that connected the individual fire protection system high pressure CO2 tanks to the manifold assembly were kinked, potentially decreasing gas flow (CR 2007-4005);

An air start copper tube for emergency diesel generator 1-1A was outside its retaining clip and had missing chaffing protection, resulting in external rubbing during engine operation (CR 2007-4216);

A residual heat removal service water valve gland follower had metal delamination and corrosion (CR 2007-4008); and The 24 Vdc battery D-1 had cell separators with some chipped edges (CR 2007-4004).

The inspectors concluded these issues were minor because they did not impact the safety function of the equipment. Vermont Yankee personnel entered these issues into the CAP during the inspection.

(b) Prioritization and Evaluation of Issues The inspectors determined that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the problem. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The various CR screening and management review groups considered human performance issues, radiological safety concerns, repetitiveness, and adverse trends during the conduct of reviews.

Items were categorized for evaluation and resolution commensurate with the significance of the issues and guidance for categorization was sufficiently definitive for consistent implementation. Operability and reportability determinations were performed when conditions warranted and the evaluations supported the conclusions. Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. During this inspection, the inspectors noted that Entergys root cause analysiss (RCAs) were generally thorough, and additional corrective and preventive actions addressed the identified causes.

(c) Effectiveness of Corrective Actions The inspectors determined that corrective actions were generally appropriate to address identified issues and typically completed in a timely manner. Corrective actions were generally completed within the corrective action process guidelines described in EN-LI-102, Corrective Action Program, and controls were placed on long term corrective actions to ensure they were completed within a reasonable time frame.

Actions to prevent recurrence were identified and effectiveness reviews were conducted for more significant safety issues.

However, the inspectors determined that corrective actions identified by Vermont Yankee personnel to address the potential for air ingestion from a low level condition in the condensate storage tank (CST) by the high pressure coolant injection and reactor core isolation cooling pumps were not effectively implemented. Specifically, the inspectors identified that the corrective action to revise operating and surveillance procedures were not properly completed. However, the inspectors determined the changes had been effectively incorporated into the shift turnover procedure and described in an operations night order. The inspectors determined that the issue was minor because the shift turnover procedure and night order provided guidance to ensure operators maintained adequate level in the CST and level had been maintained as required. Vermont Yankee personnel documented and evaluated this issue in their CAP as CR 2007-4181.

(3) Findings No findings of significance were identified in the areas of problem identification, prioritization and evaluation of issues, and effectiveness of corrective action.

b. Assessment of the Use of Operating Experience

(1) Inspection Scope The inspectors selected a sample of industry operating experience issues to confirm that Entergy had evaluated the operating experience information for applicability to Vermont Yankee and had taken appropriate actions, when warranted. Operating experience (OE)documents were reviewed to ensure that underlying problems associated with the issues were appropriately considered for resolution via the corrective action process. The inspectors also observed plant activities to determine if industry operating experience was considered during the performance of routine and infrequently performed activities.

A list of the documents reviewed is included in the Attachment to this report.

NRC inspectors previously reviewed Vermont Yankee personnels use of operating experience information regarding the partial collapse of a non-safety related cooling tower on August 21, 2007. The results of this inspection are documented in NRC Inspection Report 05000271/2007004 dated November 7, 2007 (ADAMS accession number ML073110213).

(2) Assessment The inspectors determined that Entergy appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues. The inspectors assessed that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations.

The inspectors observed that industry operating experience was routinely considered during the performance of plant activities. For example, during shift briefing activities, relevant industry operating experienced was reviewed and discussed before the commencement of shift activities. An operating experience website with links to industry operating experience, pre-job brief information and program requirements was being maintained. Additionally, operating experience was reviewed during the routine operations focus meeting and was being considered for applicability to the site.

(3) Findings No findings of significance were identified in the area of operating experience.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspectors reviewed a sample of Quality Assurance (QA) audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments conducted by independent organizations. These reviews were performed to determine if problems identified through these assessments were entered into the CAP, when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

The inspectors also reviewed the most recent Nuclear Safety Culture Assessment report and discussed actions taken and planned with Entergy management in order to determine if appropriate action had been taken to address identified issues. A list of documents reviewed is included in the Attachment to this report.

(2) Assessment The inspectors concluded that self-assessments, QA audits, and other assessments were critical, thorough, and effective in identifying issues. The inspectors observed that these audits and self assessments were completed in a methodical manner by personnel knowledgeable in the subject. The audits and self-assessments were completed to a sufficient depth to identify issues that were entered into the CAP for evaluation. Corrective actions associated with the issues were implemented commensurate with their safety significance.

The inspectors determined that the Nuclear Safety Culture Assessment provided insights into the safety culture of the site workforce. Vermont Yankee managers evaluated the results and initiated appropriate actions to focus on areas identified for improvement.

(3) Findings No findings of significance were identified associated with assessments and audits.

d. Assessment of Safety-Conscious Work Environment (SCWE)

(1) Inspection Scope During interviews and discussions with station personnel, the inspectors assessed whether workers were willing to enter issues into the corrective action program and to raise safety concerns to their management and/or the NRC. The inspectors held discussions with staff and supervisors regarding use of the corrective action program, work processes, and other problem identification and resolution activities. The inspectors specifically interviewed the General Manager of Plant Operations; Director, Nuclear Safety Assurance; Quality Assurance Manager; Corrective Actions and Assessment Manager; and Employee Concerns Coordinator to assess their participation and roles in the corrective action program, work process, and alternative program for raising safety concerns.

The inspectors reviewed the Employee Concerns Program to assess whether employees were willing to use the program as an alternate path for raising concerns.

Several Employee Concerns Program issues and evaluations were reviewed with respect to maintaining and promoting a safety-conscious work environment and to verify that issues affecting nuclear safety were being appropriately addressed. The inspectors assessed Entergys management sensitivity to a safety-conscious work environment through inspection activities, discussions with management and Entergys personnel, and attendance at various meetings. A list of documents reviewed is included in the to this report.

(2) Assessment Based on interviews, observations of plant activities, and reviews of the CAP and Employee Concerns Program, the inspectors determined that site personnel were willing to raise safety issues and document them in the CAP. Individuals actively utilized the CAP as evidenced by the number and significance of issues entered into the program.

The inspectors noted that CRs were written by a variety of personnel, from workers to managers. Employee Concerns Program evaluations were thorough and appropriate actions were taken to address issues.

(3) Findings No findings of significance were identified related to the safety conscious work environment at Vermont Yankee.

4OA6 Meetings, Including Exit

On November 9, 2007, the team presented the inspection results to Mr. W. Maguire and other members of his staff, who acknowledged the observations. The inspectors confirmed that no proprietary information reviewed during inspection was retained by the team.

ATTACHMENT: Supplemental Information

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy

E. Harms Assistant Operations Manager

G. Losier Corrective Actions Manager

W. Penniman Technical Support Coordinator

J. Stasolla Maintenance Rule Coordinator

B. Vita Operations Department Performance Improvement Coordinator (DPIC)

G. Von der Esch Acting Operations Manager

W. Maguire General Manager, Plant Operations

P. Corbertt Quality Assurance Manager

S. Naeck Superintendent of Work Control

D. McElwee Employee Concerns Coordinator

R. Wanczyk Site Lead, Transition

J. Rogers Operating Experience Manager

H. Breite System Engineer

D. Mannai Licensing Manager

J. Dreyfuss Director, Nuclear Safety and Assurance

L. Kitchen Maintenance Manager

N. Rademacher Engineering Director

S. Jonash System Engineer

P. Rainey Design Engineer

B. Smith Sr. Maintenance Engineer

NRC and Other

R. Powell Branch Chief, DRP

R. Fernandes Senior Resident Inspector

M. Gray Branch Chief, DRP

U. Vanags Vermont Department of Public Service