IR 05000271/2006005

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NRC Integrated Inspection Report 05000271-06-005
ML070190286
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 01/19/2007
From: Racquel Powell
NRC/RGN-I/DRP/PB5
To: Ted Sullivan
Entergy Nuclear Operations
References
FOIA/PA-2015-0253 IR-06-005
Download: ML070190286 (34)


Text

ary 19, 2007

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000271/2006005

Dear Mr. Sullivan:

On December 31, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station. The enclosed report documents the inspection findings which were discussed on January 9, 2007 with you and members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

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,

/RA/

Raymond J. Powell, Chief Projects Branch 5 Division of Reactor Projects Docket No.: 50-271 License No.: DPR-28 Enclosure: Inspection Report 05000271/2006005 w/Attachment: 1: Supplemental Information w/ Attachment: 2: Mitigating System Performance Index verification cc w/encl:

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

G. J. Taylor, Chief Executive Officer, Entergy Operations J. T. Herron, Senior Vice President and Chief Operating Officer C. Schwarz, Vice-President, Operations Support O. Limpias, Vice President, Engineering J. M. DeVincentis, Manager, Licensing, Vermont Yankee Nuclear Power Station Operating Experience Coordinator, Vermont Yankee Nuclear Power Station W. Maguire, General Manager, Plant Operations, Entergy Nuclear Operations, Inc.

N. Rademacher, Director NSA, Vermont Yankee Nuclear Power Station J. F. McCann, Director, Licensing C. D. Faison, Manager, Licensing M. J. Colomb, Director of Oversight, Entergy Nuclear Operations, Inc.

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

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

D. O Dowd, Administrator, Radiological Health Section, DPHS, DHHS, State of New Hampshire Chief, Safety Unit, Office of the Attorney General, Commonwealth of Mass.

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

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

SUMMARY OF FINDINGS

IR 05000271/2006005; 10/01/06 - 12/31/06; Vermont Yankee Nuclear Power Station; Routine

Integrated Report.

This report covered a 13-week period of inspection by resident Inspectors and announced inspections by regional engineering, radiation protection, and nuclear materials inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Findings None.

iii

REPORT DETAILS

Summary of Plant Status

Vermont Yankee (VY) Nuclear Power Station began the inspection period at full power. With the exception of minor power reductions to support rod pattern adjustments and periodic alignment of the circulating water system to the cooling towers, VY remained at full power throughout the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Susceptibilities

a. Inspection Scope

(one sample)

The inspectors reviewed measures established by Entergy for ensuring cold weather availability and operability of the service water (SW) system. The inspectors reviewed Vermont Yankee Operating Procedure (OP) 2196, Seasonal Preparedness, and its Forms 1, Cold Weather Initiation Operations Checklist, and 3, Operations Cold Weather Protection Walkdown Checklist, and discussed the completion of items with operations personnel to confirm the items on the checklists were either completed or appropriately tracked for completion. The inspectors performed a walkdown of the SW system and compared the current system alignment and operation to those specified in OP 2196 and OP 3181, Service Water/Alternate Cooling Operating Procedure, to independently verify that selected actions to prepare for cold weather operations were completed appropriately and the system was maintained at temperatures to ensure operability. The inspectors also reviewed recent condition reports (CRs) related to cold weather protection to ensure proper actions were taken in response to identified issues.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial Equipment Alignment

a. Inspection Scope

(three samples)

The inspectors performed three partial system walkdowns of risk-significant systems to verify system alignment and to identify any discrepancies that could impact system operability. Observed plant conditions were compared to the applicable standby alignment of equipment specified in OP 2123, Core Spray; OP 2181, Service Water/Alternate Cooling Operation Procedure; and OP 2114, Operation of the Standby Liquid Control System. The inspectors also observed valve positions, the availability of power supplies, and the general condition of selected components to verify there were no obvious deficiencies. The inspectors verified the alignment of the following systems:

  • The 'A' train of the core spray (CS) system while the 'B' train was out of service for planned maintenance;
  • The accessible portions of the SW system while alternate cooling system (ACS)cooling tower cell 2-1 was out of service for planned maintenance; and

b. Findings

No findings of significance were identified.

.2 Complete Equipment Alignment

a. Inspection Scope

(one sample)

The inspectors performed a complete equipment alignment walkdown of the emergency diesel generators (EDGs). The walkdown was performed by comparing actual equipment alignment to approved piping and instrumentation diagrams; OP 2126, Diesel Generators, and OP 2181, Service Water/Alternate Cooling Operation Procedure, lineups; and the updated final safety analysis report (UFSAR) and design basis document descriptions of the system. The inspectors observed valve positions, the availability of power supplies, and the general condition of components to verify there were no unidentified deficiencies. The inspectors also reviewed OP 3126, Shutdown Using Alternate Methods, to confirm that operators could perform portions of the procedure applicable to the EDGs. Additionally, the inspectors reviewed open corrective maintenance and CRs related to the EDGs to confirm that open items did not impact system operability.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

(nine samples)

The inspectors identified fire areas important to plant risk based on a review of Entergys Vermont Yankee Safe Shutdown Capability Analysis, the Fire Hazards Analysis, and the Individual Plant Examination External Events (IPEEE). The inspectors toured plant areas important to safety in order to verify the suitability of Entergys control of transient combustibles and ignition sources, and the material condition and operational status of fire protection systems, equipment, and barriers. The following fire areas (FAs) and fire zones (FZs) were inspected:

  • Fuel oil storage tank and transfer pump house (FA 12);
  • Radwaste corridor (FA 13);
  • Control room (FZ 1);
  • RCIC corner room, reactor building 232 foot elevation (FZ RB1S);
  • Start-up transformers (no fire designation);
  • Main and auxiliary transformers (no fire designation); and
  • John Deere diesel generator enclosure (no fire designation).

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance (IP71111.07B)

a. Inspection Scope

(three samples)

The inspectors selected three heat exchanger (HX) samples for this review: the 'B' EDG lube oil HX, the 'B' EDG jacket water HX, and the ACS cooling tower cell 2-1. These samples were selected based on a review of plant-specific risk assessment information and the results of previous NRC inspections.

The inspectors reviewed Entergys methods for ensuring heat removal capabilities (e.g.,

inspection, cleaning, maintenance, and performance monitoring) for the selected HXs and compared them to commitments made in response to generic letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Equipment. The inspectors reviewed the results of various testing methods to verify that the number of plugged EDG HX tubes was bounded by assumptions in the engineering analyses.

The inspectors reviewed the design fouling factor assumptions for the EDG HXs and the engineering analyses of minimum calculated SW flowrate to the HXs. This review was performed to verify that the minimum calculated SW flowrate, in conjunction with the heat transfer capability of the EDG HXs, supported the minimum heat transfer rates assumed during accident and transient conditions. The inspectors reviewed EDG HX modeling analyses against the HX specification sheets to ensure the analysis was valid.

The inspector also reviewed SW and cooling tower basin silt survey results and Entergys associated trending data and action plans.

The inspectors compared surveillance test and inspection data to the established acceptance criteria to verify that the results were acceptable and that HX operation was consistent with design. The inspectors walked down the HXs, cooling tower and basin, accessible portions of the ACS, and the SW pumps and traveling water screens to assess the material condition and configuration control of these systems and components. The inspectors reviewed Federal Energy Regulatory Commission (FERC)inspection reports for the Vernon dam project.

The inspectors also reviewed a sample of corrective action notifications related to the selected HXs, the cooling tower, and the SW system to ensure that Entergy appropriately identified, characterized, and corrected problems related to these essential systems and components.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

(one sample)

The inspectors observed a simulator-based licensed operator requalification exam provided to operators. The inspectors evaluated crew performance in the areas of clarity and formality of communications; ability to take timely actions; prioritization, interpretation, and verification of alarms; procedure use; control board manipulations; oversight and direction from supervisors; and command and control. Crew performance in these areas was compared to Entergy management expectations and guidelines as presented in Vermont Yankee Administrative Procedure (AP) 0151, Responsibilities and Authorities of Operations Department Personnel; AP 0153, Operations Department Communication and Log Maintenance; and Vermont Yankee Department Procedure (DP) 0166, Operations Department Standards. The inspectors also compared simulator configurations with actual control board configurations. For any weaknesses identified, the inspectors observed Entergy evaluators to verify that they also noted the issues to be discussed with the crew.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

(two samples)

The inspectors performed one issue/problem-oriented inspection of actions taken by Entergy in response to an unexpected loss of power to motor control center (MCC) 89A when aligned to its maintenance (i.e., backup) power supply. The inspectors also performed one system/function performance history-oriented inspection of the station main (SM) portion of the 125 VDC electrical system, a subsystem currently designated as a(1). The inspectors reviewed work practices that may have contributed to degraded system performance, Entergys ability to identify and address common cause failures, the applicable maintenance rule scoping document for each system, the current classification of these systems in accordance with 10 CFR 50.65 (a)(1) or (a)(2), the applicable system a(1) performance evaluation, and the appropriateness of the performance criteria and goals established for each system. The inspectors also reviewed recent system health reports and/or discussed system performance with the responsible system engineer.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessment and Emergent Work Evaluation

a. Inspection Scope

(five samples)

The inspectors evaluated online risk management for four planned maintenance activities and one emergent repair activity. The inspectors reviewed maintenance risk evaluations, work schedules, recent corrective actions, and control room logs to verify that other concurrent or emergent maintenance activities did not significantly increase plant risk. The inspectors compared reviewed items and activities to requirements listed in AP 0125, "Plant Equipment" and AP 0172, "Work Schedule Risk Management - Online." The inspectors also walked down areas of the plant containing equipment that was determined to have higher risk significance during the following work activities:

  • Planned maintenance on the 'A' train of the CS system;
  • Planned maintenance on the 'B' train of the CS system;
  • Planned maintenance on the 345 KV offsite power line 381; and
  • Emergent repair of MCC 89A following the failure of its backup power supply breaker.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

(three samples)

The inspectors reviewed three operability determinations prepared by Entergy. The inspectors evaluated the operability determinations against the guidance contained in NRC Inspection Manual Part 9900, Technical Guidance, Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety, as well as Entergy procedure ENN-OP-104, Operability Determinations. The inspectors verified the adequacy of the following evaluations of degraded or non-conforming conditions:

  • Metallic wear products identified in the 'B' EDG lubricating oil during analysis;
  • The failure of standby gas treatment (SBGT) system valve SBGT-3B to close as expected during surveillance testing; and
  • 'A' ECCS corner room ventilation cooler (RRU-7) cooling coil differential pressure exceeded acceptance criteria during testing.

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

(six samples)

The inspectors reviewed six post-maintenance testing (PMT) activities on risk-significant systems. The inspectors either directly observed the testing or reviewed completed PMT documentation to verify that the test data met the required acceptance criteria contained in the applicable work order (WO), technical specifications (TS), UFSAR, and/or inservice testing program. Where testing was directly observed, the inspectors verified that installed test equipment was appropriate and controlled and the test was performed in accordance with applicable station procedures. The inspectors also verified that the test activities were adequate to ensure system operability and functional capability following maintenance, systems were properly restored following testing, and any discrepancies were appropriately documented in the corrective action program. The inspectors reviewed the following PMT activities:

  • Testing of the 'A' train of the CS system following the installation of Pomona jacks into the initiation logic circuitry, in accordance with WO 06-6249;
  • Testing of the 'B' train of the CS system following the installation of Pomona jacks into the initiation logic circuitry, in accordance with WO 06-6248;
  • Testing following the replacement of the 'B' EDG loss of field relay, in accordance with WO 05-5146;
  • Testing of ACS cooling tower CT 2-1 following the completion of fall mechanical preventive maintenance activities, in accordance with WO 06-5322;
  • Testing following the installation of the remote racking modification on the 'C' SW system pump breaker, in accordance with WO 51067805-32; and
  • Testing of the 'A' train of the SLC system following planned preventive maintenance activities, in accordance with OP 4114, Standby Liquid Control System Surveillance.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

(four samples)

The inspectors observed surveillance testing to verify that the test acceptance criteria specified for each test was consistent with TS and UFSAR requirements, the test was performed in accordance with the written procedure, the test data was complete and met procedural requirements, and the system was properly returned to service following testing. The inspectors observed selected pre-job briefs for the test activities. The inspectors also verified that discrepancies were appropriately documented in the corrective action program. The inspectors verified that the following surveillance testing activities met the above requirements:

  • Torus-to-reactor building vacuum breaker opening force test (in-service test), in accordance with OP 4202, Primary Containment Vacuum Breaker Inspection and Testing;

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety (OS)

2OS1 Access Control to Radiologically Significant Areas (71121.01)

a. Inspection Scope

(twenty-one samples)

Implementation of the access control program was reviewed against the criteria contained in 10 CFR 20, site technical specifications, and the licensees procedures.

The inspectors conducted the following activities to verify that the licensee was properly implementing physical, engineering, and administrative controls for access to high radiation areas, and other radiologically controlled areas, and that workers were adhering to these controls when working in these areas:

Planning

  • Reviewed occupational exposure cornerstone performance indicator incidents during the current assessment period.

Plant Walk Downs and Radiation Work Permit (RWP) Reviews

  • Conducted walk downs of exposure significant work areas of the plant and reviewed licensee controls and surveys to determine if licensee surveys, postings, and barricades were acceptable and in accordance with regulatory requirements;
  • Conducted independent radiation surveys to determine whether prescribed RWP and procedural controls were in place and whether licensee surveys and postings were complete and accurate;
  • Reviewed RWPs containing access control requirements to exposure-significant areas of the plant including high radiation areas. Reviewed electronic personal dosimeter alarm set points with respect to current radiological condition applicability, and interviewed radiation workers to verify their understanding of plant procedures governing alarm response and knowledge of radiological conditions in their work area;
  • Reviewed RWPs containing access controls requirements for airborne radioactivity areas with the potential for individual worker internal exposures of

>50 millirem (MREM) Committed Effective Dose Equivalent (CEDE);

  • Reviewed internal dose assessments where dose exceeded 50mrem in 2006; and;
  • Reviewed the licensees physical and programmatic controls for highly activated materials stored underwater in the spent fuel pool against the requirements of applicable access control procedures.

Problem Identification and Resolution

  • Reviewed licensee radiation protection program self-assessments and audits during 2006 to determine if identified problems were entered into the corrective action program for resolution;
  • Reviewed CRs associated with the radiation protection access control and as low as is reasonably achievable (ALARA) areas between January 2006 and September 2006. The inspectors also discussed CRs with licensee staff to determine if the follow-up activities were being conducted in an effective and timely manner commensurate with their safety significance;
  • Screened repetitive deficiencies to determine if the licensees self-assessment activities were identifying and addressing these deficiencies; and
  • Reviewed Occupational Exposure Performance Indicator incidents reported during the current assessment period.

Job-In-Progress Reviews

  • The following three radiologically significant jobs were reviewed with respect to the radiological work requirements: Leak investigation on the 4B feedwater heater during power operations, Turbine building roof replacement during power operations, and Radioactive shipment 06-73 preparations;
  • Reviewed the adequacy of surveys, job coverage and contamination controls employed during the above three radiologically significant jobs listed above; and
  • Reviewed significant dose gradients requiring relocation of dosimetry for the radiologically significant jobs listed above.

High Risk Significant, High Dose Rate High Radiation Area, and Very High Radiation Area Controls

  • Reviewed changes made to the high radiation area and very high radiation area procedures since the last inspection in this area. Also discussed the management of these changes with the Radiation Protection Manager;
  • Discussed controls established to support entry into the transverse in-core probe (TIP) room with the duty watch radiation protection technician; and

Radiation Worker Performance

  • Evaluated radiation worker performance during the three radiologically significant jobs listed in the Job-In-Progress section above. Reviewed performance against the specific radiation protection work requirements and worker knowledge of the radiological conditions in their work areas; and
  • Reviewed CRs to determined if radiological incidents occurred that were caused by radiation worker errors, to determine if there were any trends or patterns and, to determine if the licensees corrective actions adequately addressed these trends.

Radiation Protection Technician Proficiency

  • Evaluated radiation protection technician work performance during the three radiologically significant jobs listed in the Job-In-Progress section above.

Evaluated technician performance with respect to their knowledge of the radiological conditions, the specific radiation protection work requirements, and radiation protection procedures; and

  • Reviewed CRs to determine if radiological incidents occurred that were caused by radiation protection technician errors and to determine if there were any trends or patterns and if the licensees corrective actions adequately addressed these trends.

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02)

a. Inspection Scope

(six samples)

Implementation of the ALARA program was reviewed against the criteria contained in 10 CFR 20.1101(b) and the licensees procedures. The inspectors conducted the following activities to verify that the licensee was properly maintaining individual and collective radiation exposures as low as is reasonably achievable:

Planning

  • Reviewed the licensees collective exposure history to determine the plants current 3-year rolling average exposure for 2003-2005;
  • Reviewed site-specific source term trends to determine if there was any increasing trend reflecting higher than average boiling water reactor radiation levels or an increasing trend in collective exposures;
  • Reviewed source-term data from 2003 through 2006. Interviews were conducted with the ALARA supervisor and the Chemistry Superintendent relative to reactor water chemistry and source-term controls being implemented to reduce occupational exposure.

Problem Identification and Resolution

  • Reviewed licensee radiation protection program self-assessments and audits related to the ALARA program during 2006 to determine if the audit program scope met the requirements of 10 CFR 20.1101(c);
  • CRs associated with the radiation protection access control and ALARA areas were reviewed and discussed with licensee staff to determine if the follow-up activities were being conducted in an effective and timely manner commensurate with safety significance; and
  • Identified repetitive deficiencies were screened to determine if the licensees self-assessment activities were identifying and addressing these deficiencies.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety (PS)

2PS1 Gaseous and Liquid Effluents (71122.01)

a. Inspection Scope

(eleven samples)

The requirements for radioactive effluent controls are specified in the Technical Specifications and the Offsite Dose Calculation Manual (ODCM). The inspectors performed the following reviews and onsite inspections to evaluate the effectiveness of the licensees radioactive gaseous and liquid effluent control programs:

Planning

  • Reviewed the 2004 and 2005 Radiological Annual Effluent Release Reports.

The current ODCM (Revision 30) was reviewed including technical justifications for changes made since the previous revision. Sections 9.4 and 10.12 of the UFSAR were reviewed to gain an understanding of the gaseous radioactive waste system and station ventilation systems. The latest quality assurance audit (ODCM Audit Report, QA-6-2005-VY-1) was reviewed. Finally, Entergys program for identifying, controlling and assessing potential contaminated spills and leakage was also reviewed.

Onsite Inspection

  • Performed walkdowns of plant equipment and observed work activities to evaluate the effectiveness of the licensees radioactive gaseous and liquid effluent control programs. Equipment walkdowns were performed for the radioactive liquid/gaseous effluent radiation monitoring systems (RMS) and air cleaning systems. Observations were performed during radiological sampling and measurement activities and during a November 28, 2006, plant stack gaseous effluent sample;
  • Reviewed the radioactive annual effluent release reports through 2006 to determined if there had been any radioactive liquid waste releases. Two radioactive gaseous release permits were selected and reviewed with respect to ODCM and procedural requirements;
  • Performed reviews to determine if there had been instances of unplanned effluent RMS unavailability that would require compensatory sampling and analysis between November 2004 and October 2006. Also performed reviews to determine if there were any abnormal or unmonitored release, and no spills or leaks involving the spread of radioactive material on the grounds of the facility;
  • Reviewed the ground water monitoring program currently under development by the licensee. To date, the licensee has identified applicable systems containing radioactive liquid, has identified applicable underground piping and structures, and is developing a hydrology study;
  • Reviewed changes to the ODCM (Revision 30) since the last inspection of this program area;
  • Reviewed effluent release dose calculations for each month from November 2004 through October 2006 with respect to TS/ODCM calculation methodology, and 10 CFR 50, Appendix I public dose requirements;
  • Reviewed the most recent air cleaning system filter surveillance test results required by Technical Specifications (visual inspection, pressure differential, in-leakage tests, laboratory charcoal efficiency test, and air flow capacity tests, as appropriate) for the following systems: the SBGT system, the shutdown iodine system, the radwaste roof filtration system, and the augmented off-gas filtration system;
  • Reviewed the most recent calibration results for the gaseous and liquid effluent RMS radiation monitors and associated flow rate measurement devices, as required by the ODCM for the following: Liquid radwaste effluent (RM-17-350),

Service water effluent (RM-17-351); Cooling tower influent (RM-17-359), Steam jet air ejector (RM-17-150A/B), Augmented off-gas (RM-3127/3128), and Plant stack I & II primary and secondary calibrations. Effluent liquid and gas sample radiation measurement equipment calibrations were reviewed for in-use high purity germanium gamma spectrometers and liquid beta scintillation counter.

Selected counting equipment quality control charts were reviewed to ensure the continued operability of this equipment was appropriately documented; and

  • Reviewed the implementation of the measurement laboratory quality control program, including effluent intra-laboratory and inter-laboratory comparisons. In addition, the inspectors reviewed the 2005 quality assurance audit (ODCM Audit Report, QA-6-2005-VY-1) of the radioactive liquid and gaseous effluent control program and the ODCM.

Identification and Resolution of Problems

  • Reviewed CRs relative to the Vermont Yankee Effluents Program between January 2005 and November 2006.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

a. Inspection Scope

(three samples)

The inspectors reviewed Entergy submittals for the performance indicators (PIs) listed below. The PI definitions and guidance contained in Nuclear Energy Institute (NEI)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.

Mitigating Systems Cornerstone

  • Safety System Functional Failures The inspectors reviewed licensee event reports, portions of operator logs, maintenance rule out of service logs, and CRs to verify the accuracy and completeness of the PI data for the period from October 1, 2004, through September 30, 2006.

Occupational Radiation Safety Cornerstone

  • Occupational Exposure Control Effectiveness The inspectors reviewed implementation of Entergys Occupational Exposure Control Effectiveness PI Program. Specifically, the inspectors reviewed CRs and RCA dosimeter exit logs for the past four calendar quarters. These records were reviewed for occurrences involving locked high radiation areas, very high radiation areas, and unplanned exposures to verify that all occurrences that met the NEI criteria were identified and reported as performance indicators.

Public Radiation Safety Cornerstone

  • RETS/ODCM Radiological Effluent Occurrences The inspectors reviewed a listing of relevant effluent release reports for the past four (4)calendar quarters, for issues related to the public radiation safety performance indicator.

The inspectors reviewed the following documents to ensure Entergy met all requirements of the performance indicator: monthly projected dose assessment results due to radioactive liquid and gaseous effluent releases; quarterly projected dose assessment results due to radioactive liquid and gaseous effluent releases; and dose assessment procedures.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered into the Corrective Action Program

a. Inspection Scope

The inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into Entergys corrective action program at an appropriate threshold and that adequate attention was being given to timely corrective actions. Additionally, in order to identify repetitive equipment failures and/or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into Entergys corrective action program. This review was accomplished by reviewing the description of each new CR and/or by attending daily CR screening meetings. A listing of CRs reviewed is included in the attachment to this report.

b. Assessments and Observations No findings of significance were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual trend review to identify trends, either Entergy or NRC identified, that might indicate the existence of a more significant safety issue.

Included within the scope of this review were:

  • CRs generated from July through December 2006;
  • Corrective maintenance backlog listings from July through December 2006;
  • The corrective action program 2nd and 3rd Quarter 2006 trend reports; and
  • Daily review of main control room operating logs.

In NRC Inspection Report (IR) 2006-003, the inspectors discussed human performance-related trending CRs issued in the radiation protection department. During the current inspection, the inspectors also reviewed the CRs issued to identify any continuing trends in this area and discussed observations with the Plant Manager. The corrective actions completed and in progress to address the individual issues as well as to address human performance trends were reviewed for adequacy.

b. Assessment and Observations No findings of significance were identified.

However, the inspectors observed that two Level 'A' CRs were written this period potentially related to Radiation Protection (RP) Department human performance. CR 2006-2600 was written when a post-reactor water cleanup (RWCU) system resin transfer radiological survey was not completed prior to permitting personnel entry into the RWCU phase separator valve aisle, a locked high radiation area. This issue is currently under NRC review. CR 2006-2723 was written when a radioactive shipment sent from VY to another facility was found to have receipt dose rates above federal limits. This issue was determined to be a violation of low to moderate increased importance to safety as documented in IR 2006-011 and related correspondence.

The inspectors concluded that RP Department Management appropriately determined the significance of the issues in the corrective action program for evaluation and determination of corrective actions. Actions in the RP Department excellence plan, as discussed with the Plant Manager and RP Manager, and the specific CR root cause analyses appear appropriate to improve human performance in this area.

.3 Annual Sample Review - Loss of the Vermont Yankee Northfield 345 KiloVolt (kV) Line

a. Inspection Scope

(one sample)

The inspectors reviewed Entergy's response to the loss of the Northfield 345 kV line that occurred on August 3, 2006, to ensure that the full extent of the issues were identified, appropriate evaluations were performed, and appropriate corrective actions were specified and prioritized. The inspectors walked down affected areas of the plant and interviewed relevant station personnel. The inspectors evaluated the root cause analysis and corrective actions against the requirements of Entergys corrective action program.

b. Findings and Observations

No findings of significance were identified.

The inspectors found the root cause analysis to be thorough and the corrective actions to be appropriate. Entergy has initiated corrective actions commensurate with the significance of this issue and has acknowledged the organizational aspects as well as the design aspects of this loss of line. Upgrades to the Northfield lines protection strategy were given appropriate prioritization and coordination studies are planned.

Improvements to the Transmission Interface Agreements will be implemented that should give assurance that appropriate communications will be made for future protection system design changes.

.4 Annual Sample Review - History of Service Water System Leakage due to

Microbiologically Influenced Corrosion

a. Inspection Scope

(one sample)

The SW system at VY has historically been challenged by microbiologically influenced corrosion (MIC). MIC has been responsible for a number of deleterious effects including restricted system flows caused by tuberculation in piping and components as well as system through-wall leaks. The purpose of this inspection was to determine the current impact of MIC on the SW system, to evaluate the suitability of corrective actions taken by the licensee to address individual MIC-related SW system issues, and to assess the licensees long range plan for minimizing the effects of MIC on the SW system. The inspectors reviewed CRs and associated corrective actions addressing MIC-related SW system issues, reviewed available operating experience (OE) information pertaining to MIC, performed walk downs of the accessible portions of the SW system, and discussed long range SW system improvement plans with the SW system engineer.

b. Findings and Observations

No findings of significance were identified.

The inspectors found that the licensee had taken appropriate actions to address individual MIC-related SW system issues. Additionally, the licensee continues to effectively manage the deleterious effects of MIC on the SW system through a combination of visual inspections, ultrasonic testing (UT) inspections, enhanced chemistry control methods and sampling, and replacement of piping and components with MIC-resistant materials when possible.

4OA5 Other Activities

.1 (Closed) Unresolved Item (URI)05000271/2001003-01, Adequacy of Hemyc Cable

Wrap Fire Barrier Qualification Test and Evaluation.

Inspection Report 05000271/2001003 documented the potential inadequacy of Hemyc fire barrier wrap material used in 10 CFR 50, Appendix R, applications at VY. The issue was considered to be unresolved pending further NRC review to determine whether the qualification tests of the Hemyc fire wrap systems were acceptable. In subsequent NRC fire tests, results indicated that Hemyc fire wrap systems could not be routinely relied upon as one-hour fire barriers. The NRC staff informed the industry of the concerns associated with these materials by issuing information notice (IN) 2005-07, Results of Hemyc Electrical Raceway Fire Barrier System Full Scale Fire Testing, and GL 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations. As required by GL 2006-03, VY responded appropriately to the NRC concerns by implementing compensatory measures as appropriate and by initiating corrective actions to further evaluate Hemyc fire wrap systems used on-site. In 2005, VY replaced Hemyc fire wrap used in 10 CFR 50, Appendix R, applications with a different fire wrap material (i.e., 3M Interam). The NRC staff determined that there were no performance deficiencies associated with the licensees use or replacement of Hemyc fire wrap material. This URI is closed.

.2 Temporary Instruction (TI) - 2515/169, Mitigating System Performance Index

Verification

a. Inspection Scope

The objective of TI 2515/169 was to verify that the licensee had correctly implemented the Mitigating Systems Performance Index (MSPI) guidance for voluntarily reporting the unavailability and unreliability of the monitored safety systems. On a sampling basis, the inspectors validated the accuracy of the unavailability and unreliability input data used for both the 12-quarter period of baseline performance and for the first reported results (i.e., second calendar quarter, 2006). Specific attributes examined by the inspectors per this TI included surveillance activities which do not render the train unavailable for greater than 15 minutes, surveillance activities which do not render the train unavailable due to credit for prompt operator recovery actions, and independently confirming the accuracy of baseline planned unavailability, actual planned and unplanned unavailability, and the accuracy of failure data (i.e., demand, run, and load, as appropriate) for the monitored components. Per TI 2515/169-05 reporting requirements, additional information pertaining to the inspectors review is included in 2 to this report.

b. Findings

No findings of significance were identified.

.3 Independent Spent Fuel Storage Installation

a. Inspection Scope

(60853)

The inspectors reviewed engineering design documents and supporting calculations associated with the design and construction of the VY Independent Spent Fuel Storage Installation (ISFSI) pad. The inspectors discussed design specifications with cognizant personnel and the basis for various design parameters. The inspectors evaluated the design and construction details for the ISFSI pad against the design parameters for the dry cask storage system selected for use at VY (i.e., HOLTEC 100). Design aspects reviewed by the inspectors included seismic considerations, soil liquefaction potential, cask tip over analysis, and properties of construction materials.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 9, 2007, the resident inspectors presented the inspection results to Messrs.

Theodore Sullivan and William Maguire and members of the VY staff. The inspectors asked whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

A-1-1 ATTACHMENT 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy Personnel

M. Desilets, Training and Development Manager
J. Devincentis, Licensing Manager
J. Dreyfuss, Director of Nuclear Safety
M. Hamer, Licensing
E. Harms, Operations Manager
W. Maguire, General Manager of Plant Operations
D. Mannai, Licensing Manager
K. Pushee, Radiation Protection Manager
N. Rademacher, Director of Engineering
T. Sullivan, Site Vice President
C. Wamser, Work Planning and Outage Scheduling Manager
M. Wilson, Emergency Preparedness Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000271/2001003-01 URI Adequacy of Hemyc Cable Wrap Fire Barrier Qualification Test and Evaluation

LIST OF DOCUMENTS REVIEWED